Water –

There are many statements made in the ‘Summary of Assessment Outcomes - EIS and Amended Project’ in relation to water impacts which are incorrect.
The proposal to use water sources from within the Bowdens’ land holdings to supply the water for the proposed mine is fundamentally flawed. The extreme dry periods experienced by the landholders within the Lue region indicate that it is inconceivable that there is sufficient water to supply both mine and landholders. The surface water assessment has failed to properly consider the dry periods, such as experienced in 2018-2019. These years saw insufficient water for the existing industries, little only the vast volume required by a Lead & Silver mine.
The surface water assessment relies on invalid data, inappropriate modelling and contains misleading statements. With water being such a critical factor for both the community and viability of the project, it is important to have a rigorous assessment.
Groundwater is a valuable resource for lands within the Lawson Creek catchment. The loss of this resource due to the proposed mine is unacceptable.
Water is our most valuable and precious resource. This was clearly demonstrated in the 2019-2020 Black Summer Bushfires where our region suffered terrible losses with the 2018-2019 drought and the subsequent Black Summer Fires. The Amendment which proposes to greatly impact the water for the Lue region and all downstream, does not appear to consider the value of the Water to our region.
I refer you to the independent Report: Water –

There are many statements made in the ‘Summary of Assessment Outcomes - EIS and Amended Project’ in relation to water impacts which are incorrect.
The proposal to use water sources from within the Bowdens’ land holdings to supply the water for the proposed mine is fundamentally flawed. The extreme dry periods experienced by the landholders within the Lue region indicate that it is inconceivable that there is sufficient water to supply both mine and landholders. The surface water assessment has failed to properly consider the dry periods, such as experienced in 2018-2019. These years saw insufficient water for the existing industries, little only the vast volume required by a Lead & Silver mine.
The surface water assessment relies on invalid data, inappropriate modelling and contains misleading statements. With water being such a critical factor for both the community and viability of the project, it is important to have a rigorous assessment.
Groundwater is a valuable resource for lands within the Lawson Creek catchment. The loss of this resource due to the proposed mine is unacceptable.
Water is our most valuable and precious resource. This was clearly demonstrated in the 2019-2020 Black Summer Bushfires where our region suffered terrible losses with the 2018-2019 drought and the subsequent Black Summer Fires. The Amendment which proposes to greatly impact the water for the Lue region and all downstream, does not appear to consider the value of the Water to our region.
I refer you to the independent Report: Bowden’s Water Pipeline Amendment - analysis of updated surface water assessment, attached, which covers off comprehensively on the water issues of this amendment of the proposed project.
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The community health and well-being will be greatly negatively impacted with this proposal.
The lead and open min proposal impacts their health and the health of generations to come.
The tourism industry will be negatively impacted by the loss of productivity for the wineries in this community
And the world renound wool producers will be negatively impacted by the loss of water and environmental impact to the region
No to this proposal

This major project will take up all the ground water for all the surrounding areas and spread lead dust into the air around Lue

I object to the Bowden’s Silver Mine for the following reasons:

1. The site does not have sufficient water
The town of Lue, Mudgee, Rylstone, and surrounds cannot afford to sacrifice water from the Lawson Creek for this project.
Lawson Creek is already considered at the extreme rating of ‘highly stressed’ by the NSW Stressed Rivers Assessment.

2. Toxic dust
If water is taken from a tailings dam, there is a high chance of exposure to toxic dust as the water is extracted. If there is a wind event this toxic dust will be spread in the air and adversely affect human and animal health.

3. Dust mine
A mine that does not have enough water will not be able to mitigate or supress the movement of dust through actions such as, spraying the roads with water. During times of drought and wind, this will be deleterious for all of us in the Central West area and beyond.

4. Affect on Lawson Creek catchment
The mine’s massive daily usage of water will reduce the Lawson Creek catchment and thus negatively impact everyone who live downstream of the mine.

5. Acid mine drainage
According to Dr Haydn Washington, a former CSIRO Scientist, specialising in acid mine drainage and heavy metal pollution, 30 million tonnes of sulphide is ore is planned to be mined at the Lue Bowden Silver Mine. According to Dr. Washington, when sulphide is exposed to water and oxygen, acid mine drainage is created which is highly toxic with heavy metals. Even at low levels acid mine drainage is lethal to any aquatic life i.e. fish. This pollution will remain for hundreds of years detrimentally affecting human and animal health.

I whole heartedly disapprove of any project that has such devastating effects on the environment. I have a 10-year-old son and I therefore have a responsibility to protect his future. I am also a WIRES carer, and I am passionate about protecting native fauna that also rely on a healthy environment.

It is for the above reasons I do not approve of the Bowden’s Silver Mine Water Pipeline Amendment (SSD-10371-Mod-1).

Our water resources are precious . We live in a dry environment and the last thing we want is a mine requiring 1788 megalitres per year to operate.

I object to the Bowdens Silver project (SSD-5765) (“the project”, “the proposed mine”, “the mine”) on the basis that the proposed mine will create multiple negative externalities to current land holders and the environment with no net benefit to the state or the community.
Bowdens Silver’s (“the company”) assessment for strategic importance of the project is greatly exaggerated, silver is not a scarce resource and recent prices increases are the result of speculation rather than substantial increases industrial demand (2021 Silver Survey). The global silver markets have been in supply surplus for five consecutive years with LBMA, Comex, SGE and SHFE holding a cumulative 1702.3 million ounces of silver (more than one year’s demand) as price control for oversupply. Lower cost producers particularly in Mexico and Peru currently have established projects in care and maintenance mode and any sustained increase in the price of silver would bring these mines back online creating supply in the market. The company points to the assumption of a US$20 per ounce silver price during the feasibility study as testament to the strength of the project but failed adequately explain the effects of current inflation levels in particular substantial increases to the costs of inputs (diesel, energy, mining equipment) all of which fall well outside the models commissioned by the company. The models also failed to account for the current increase in corporate debt rates which have risen significantly since the original studies meaning funding options the company outlined are no longer adequate. Anyone of these factors would be cause for concern for a project highly dependent on elevated commodity price levels. Obviously, this brings into question why a company would proceed with their application despite a clear uncertainty on the project being a going concern? A cynic would point to the levels of executive compensation specifically the release of options based on the mine’s approval, not earnings.
In the latest amendment to application SSD-5765 - Water Supply Amendment Report, the use ground water to supply continued operations borders on farcical. The company has not shown in amendment that they will be able to meet ongoing water requirements from harvestable water particularly in times of drought when dam evaporation is high. In an extended drought when harvestable water is depleted the projects only source of water then becomes ground water. The basic land holder rights established in the Water Management Act 2000 made domestic and stock water a public good (albeit a somewhat impure one) for landowners overlaying an aquifer. The company and the department will state that usage is monitored and that usage in of excess entitlement will be subject to a fine. For an entity where recourse is limited a fine becomes a business expense. There are many examples of this practice in the mining industry, Rio Tinto’s destruction of Juukan Gorge caves is the well-known recent example. This creates where excessive usage of groundwater is achievable by paying a fee (fine). The public good available to land holders then becomes excludible and rivalrous or in other words a private good. Should approval be granted based on this amendment, the department will have granted an implied privatisation of the aquifer creating a negative externality for stock and domestic users of the aquifer.
Mining has provided significant benefits in NSW whereby the marginal social benefit has far exceeded the marginal social benefit in most situations. This project will create enormous social cost for little social benefit. If approval is granted and the mine commences operation the margins of the project are so slim that jobs in the community will be dependent on commodity already oversupplied and reliant on speculation in commodity markets. In the unlikely situation where the global economic conditions allow for ongoing operation throughout the life of the mine the negative externalities on land holders and the community far outweigh any perceived benefit. Enterprise is under no obligation to create solutions for these costs and then the responsibility for rectification will fall on the government.

I believe it to be outrageous and disgusting that as a member of the outlying community of Olinda that I wasn’t notified of the huge amendments being put forward. To discover that the full EIS was submitted in May 2020 during the pandemic crisis where the whole community and country was stressed and anxious about their survival. Giving everyone no time digest a 746 page EIS that would require specialist people to help with analysis of the report.
Having a quick look at EIS – Project Objectives point 2. To undertake all activities in an environmentally and socially responsible manner to demonstrate compliance with relevant criteria and satisfy reasonable community expectations
As we have experienced so far that the environmental consideration have not been met in relation to potential huge water losses to areas , impacts to native flora and fauna due to drying up of the
Local environment and loss of income to farmers downstream due reduction in water runoff and subsurface movement from onsite storage of surface water and drilling to access underground water.
Social responsibility dealing with mental and physical health impacts haven’t been considered. Eg impact from a 24/7 processing and maintenance, potentially 24/7 mining subject to noise based on what they say is acceptable not what people say in tolerable for their families. Blasting, trucking of concentrate, building the embankment is Monday to Saturday 10am -4pm all within 2.6km from school for 23yr. How is this right?
Trucks going passed school all day carrying toxic mining concentrate. How will they guarantee the trucks staying 100%sealed from releasing toxic chemicals/particulates into school yard potentially killing innocent children for the life of the mine? They can’t. Millions of tonnes per year. Can the DPIE guarantee the immediate community and myself as a commuter passing through town to go shopping or a tourist going between towns by push bike that for our immediate and or long term health is not compromised ?
Another health concern is the removal of water from tailings dam to compliment their water needs that lack of moisture in dam means potential dust into air affecting human health. Dust entering the domestic water supply via roof water. Can this be guaranteed not to happen No it can’t
Given all the risks associated with this project from catastrophic downstream contamination , poisoning of the local community, loss of drought Resilence due to water loss, potential catastrophic fire risk due environmental changes, mental health issues caused by noise, toxins and the constant haulage by road of mining concentrate across the country causing risk to life and damage to infrastructure. It should be allowed to proceed. It should be shut down. It’s corporate greed
Point number 7. Achieve the above objectives in a cost effective manner to ensure the Bowdens silver project is economically viable. Which means spend the least amount of money possible and get away with whatever we can. Because we know that for corporations paying the fine is cheaper than doing the right thing.
Once the mine has ceased to be viable how are they going to deal with decontamination of the tailings dam and toxic stockpile? History has shown us that they don’t care, they will just walk away or do as little as possible or have no money left to complete rehabilitation of the site .
As per the EIS
The nature of the project dictates, however, that the disturbed areas associated with the main open cut pit, processing area and tailings storage facility would remain active throughout the mine life and, as a consequence, the opportunity to undertake progressive rehabilitation of these components would be minimal.
The issue of rehabilitation to these areas after the mining has ceased need to be addressed now and to think that there will be no chance of leakage and or water contamination is impossible
Based on the impacts to water loss and environmental contamination and health impacts this project needs to be shut down. Please help us
please find attached mid Western councils in the main disapproval of the mine with emphasis on the need to protect water

See attached document