I originally objected to the project and am making another object in addition to my original submission. The second submission was precipitated by the amendments proposed by Bowdens.
My areas of concern are:-
1. Insufficient groundwater available for the mine to proceed without creating shortages to primary production in the local area.
2. Depletion of all waters downstream of the mine
3. Ongoing acid mine drainage during and after the life of the mine. Key risk is that Bowdens has totally ignored the problem of AMD and heavy metal pollution. The EIS fails even to mention it.
4. The use of cyanide in the extraction of metals from the base ores
5. Hazards of lead dust to local residents, especially children
6. Proximity to Lue village
7. The fact that it is being marketed as a silver mine when in fact lead is the primary metal being mined and processed.
8. Lawson Creek is listed in the NSW Stressed Rivers Assessment in the most stressed category (S1) – with both
high environmental stress and a high extraction rate
9. The amount of electricity used in this project will place more demand on fossil fuel fired power station and will have a cumulative impact of global warming.
10. The removal of the original water source, ie piped in from local coal mines, is further proof that the original proposal recognized that there is insufficient local water available for the project. Why should the amendment be approved without a source of water being utilised other than the stressed local groundwater reserves.
11. November 2019 Impact Assessment Outcomes "In order to maintain a regular water supply, it is also proposed to source water for the project from Ulan/ Moolarben Coals mines. As a result, the Project would place no additional demand on local and regional water resources" This is now not the case and as such the mine should not be permitted to proceed in any circumstance. Water is life and the lifeblood of the existing communities around Lue.
12. Noise and dust pollution. Due to the low average rainfall at Lue dust will become a major issue. The sources include the mine itself, denuded country side, dam sites, dam walls, dry creek beds (that will proliferate), access roads and the increased vehicular traffic.

I object to this project because it poses a critical, long term threat to our region.
The potential risks of this project significantly outweigh the benefits.
It will leave a toxic legacy in our region forever.
Please see attached.

The proponent has not provided adequate information to support their claims sufficient water supply has been secured to support mining during extended dry periods, or will be able to effectively manage water runoff during extreme rainfall events necessary to avoid the pollution of streams and groundwater system during operations and post mining.

The reliance on advance groundwater dewatering when storage dams are likely to fail during extended dry periods provides a false sense of security. During these critical times of regional water shortage any further lowering of groundwater levels and associated loss of baseflow to local streams imposes an unacceptable risk to the environment and other water users.

The proponent’s assessment of climate change scenarios and implications for the final void pit rely on average monthly and annual datasets. This does not adequately consider for example the risk of extreme daily rainfall events on a wet catchment. WRM s claim that it is ‘unlikely” receiving waters will be impacted by “seepage, leachate and runoff’ … from the PAF material either during operations or after closure and decommissioning “ (WRM_ 6-131) does little to reassure downstream water users.

The reality of a changing climate increases the frequency of extreme events of < 1 percentile probability. This requires greater analysis and testing of the proposed response management plan; the identification of appropriate trigger values to detect trends and initiate effective and timely response actions when impacts are identified, backed up with substantial bonds to cover post mining pollution events and rehabilitation.

The history of silver-lead mining tells us there is a serious long term risk of groundwater pollution by toxic metals and acid mine drainage (AMD). This likelihood has not been fully scrutinised or adequately investigated in the EIS.

Bowdens Silver states their decision is to “defer the option to use a pipeline to supply water to the Mine Site” sourced from the Ulan coal mines. “Defer” indicates they may revisit this option in the future – any approval must not depend on this as a back-door solution if provision of adequate water supply predictions prove inadequate.

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.