The proposed mine will have an unreliable water supply

The mine will have to shut down during droughts

I am concerned that the proposed mine will put severe stress on Lawsons Creeks and the families and farms that currently rely on Lawsons Creek as a water source.

Lawson Creek is identified in the NSW Stressed River Assessments to be in the most seriously stressed category with a high level of environmental stress as well as a high extraction rate.  

Bowdens Mine proposes to transfer water licences from further down the Macquarie catchment as well from the Sydney basin catchment,  further depleting Lawson Creek

Lead is poisonous for Lue

I object to now taking all of the water out of Lawson Creek. It has a history of drying up which means that if there is no water to spray and undertake dust mitigation, they will be unable to reuse water and the environment and human and wildlife population will be put at risk.
In addition, the roads around Lue are not suitable for heavy vehicles.

The proposed mine will have an unreliable water supply. The mine will have to shut down during droughts. Lawson Creek is identified in the NSW Stressed River Assessments to be in the most seriously stressed category with a high level of environmental stress as well as a high extraction rate. Bowdens Mine proposes to transfer water licenses from further down the Macquarie catchment as well from the Sydney basin catchment, further depleting Lawson Creek. Lead is poisonous for Lue!

I OBJECT to the proposed SVL Bowdens Project
(1)The proposal must be rejected, due to the huge impacts its proposed water useage will have on agriculture in the surrounding area, residents in the village, those dependent on reliable bore water and downstream users. My major personal concern as a landholder engaged in an agricultural business is the potential impacts on critical underground water sources on our property, most particularly our farm 50 megalitre irrigation licence. Our ability to use our land to raise cattle and sheep is entirely dependent on underground water in times of drought and I have no confidence that any make good provisions will overcome that potential loss.
The fact that this proponent has never undertaken any monitoring of our registered 50 megalitre bore only heightens my concerns.
Using modelling projections, the proponents assert that sufficient water will be sourced from within Bowdens holdings and the mine site. Actual rainfall records, meticulously kept by property owners adjacent to the proposed mine site show that the water available to the proponent from rainfall is far less and far less reliable than claimed in the proponents modelling.
When the project inevitably falls seriously short of the water it needs, where will the replacement water come from? Even a brief analysis of the rainfall figures scrupulously recorded at our property over 35 years will show that not enough reliable water can be accessed through rainfall and the modelling is not supported by historical records.
Once again the proponents have failed to make a believable case that they can source anything like an adequate volume of water from the area or anywhere else that would justify the project’s approval.
The rainfall data below clearly shows that the annual Summer recorded rainfall falls well short of the modelled 75mm per month (450mm over Summer) on 21 of the past 32 Summers.
That is, only 33% of Summer rainfalls in the past 30 years has exceeded 450mms. Also, in only 84 of 204 summer months (41.1%) has the monthly total exceeded 45 mms.
Rainfall data from Mudgee Airport Weather Station (1994-2022) also indicates that the modelled projected Summer rainfall of 75 mm per month is incorrect. The mean rainfall figures are October (50.3), November (76.1),December (77.3), January (66.1), February (64.7), March (65.4).
Total = 399.9 mm. Monthly average = 66.6 mm.
The proponent will not be able to find the necessary water to conduct its operations without catastrophically depleting groundwater in the area of Hawkins Creek and Lawson Creek.
(2)I am also very concerned that the proponent consistently refuses to address very real community concerns about potential health impacts by at least establishing comprehensive baseline data for severe health risks such as lead. The proponent SVL advertises the project as a Silver mine. When the volume of Lead derived from this project is AT LEAST 50 times that of Silver, the glossing over of the volume of lead to be extracted and the sidestepping of any health impacts is dishonest. If, as the proponent asserts, there is NO risk to health from lead at the project, then to show good faith to the community the proponent must be compelled to carry out comprehensive baseline testing before approval is granted or any work commences. Community concerns about Lead were not adequately addressed in the EIS and the data used was historic (from 2012 and 2013 in the time of KCN ownership of the project) and discredited, derided and dismissed as out of date by the proponent SVL.
(3)Another very serious aspect of this process has been that the EIS which was put on display for community comment in 2020 is markedly different to what is being put forward as a simple amendment in 2022. The community did not have access to the current model and the far more serious effects it will certainly have on surface and groundwater in this area.
The 2020 proposal included a water pipeline from the coalfields which was to supply a significant volume of water to supplement water collected on site. Community members were assured that this would relieve pressure on local ground and surface water supplies. Some community members believed, rightly or wrongly, that this water pipeline would include a reticulated water supply system to the village of Lue. This community benefit was widely reported as being a strong reason for some Lue residents to support the project.
In the interests of giving the local community a fair opportunity to assess the real impacts of this project on the Lue community and its surrounding agricultural enterprises, an amended EIS must now be submitted by the proponent.
RESPONSE TO BOWDENS PIPELINE AMENDMENT
• Users of Surface and Groundwater: (Page x) states “this strategy would not be likely to increase the projects impacts on users of surface water and groundwater resources”.
(1) The term “not be likely” engenders no confidence in the people of Lue and surrounds who rely on surface and groundwater for stock and domestic purposes that they will continue to enjoy safe and reliable water supplies. During 2018 and 2019 drought surface water supplies were severely depleted, with many dams and water storages drying up completely. Groundwater was critical for keeping stock alive. The huge volumes of water to be used annually in this proposed project, coupled with the next severe drought, will make conventional farming and grazing extremely difficult if not impossible. The projected rainfall figures used in the modelling are wildly optimistic.

In particular, the projected Summer rainfall average of 75mm per month in a 34 year period was exceeded on only 41% of the Summer months recorded since 1987. (See detailed rainfall data below)

• Impacts on other Registered Groundwater Users: (Page xiv concedes there will be “potential impacts associated with the availability of groundwater for other registered groundwater users”. The proponent concedes in (x) and (xiv) that other users will “potentially” be impacted. There are 106 bores located within 10 kms of the project. They are used for stock and domestic purposes. How severe are the “potential” impacts likely to be in times of severe drought?
Enough to make a bore unusable? All the make good promises will be as nothing when the project concludes and a bore no longer produces water.
Has the proponent promised to “make good” in perpetuity?

• Drawdown: (Page xvi): Whilst groundwater drawdown greater than 2m is predicted at only one privately-owned registered groundwater bore Jacobs (2022) considers this prediction is the result of model conservatism”. Words to strike fear into the hearts of groundwater users –
Predicted- and if the modelling is erroneous and the prediction is in error, the groundwater users of Lue and surrounds will be bearing the burden
Considers – the opinion of a consultant which may prove to be in error

• Environmental Outcomes. (Page xxi): “The residual environmental outcomes are not predicted to impose an unacceptable cost to future generations”. Once again, a consultant is making predictions about what might happen in the future. The prediction may prove to be incorrect.
How did SVL come to the conclusion that a future cost is not “unacceptable”?
The residents of LUE and surrounds are expected to submit to what the proponent suggests is acceptable. Loss of amenity, visual impacts, noise impacts, light, possible depletion of surface and groundwater, increased traffic and the parting gift of a massive void partially filled with what was once precious water in our underground aquifers will be their legacy. Agricultural land (currently growing a very impressive dryland sorghum crop) (See photograph below) which has sustained life for countless generations of First Nations people will be rendered agriculturally useless forever. This is absolutely unacceptable.


Dryland Sorghum crop on Price’s Gully, Bowdens – 7th February 2022.

• Downstream water Users: Water Supply Amendment Report (Page 4):-potential impacts – the loss of baseflow on the availability of water for downstream users in the Lawson Creek water source. (Page 41) “there would be negligible change in availability of surface water for downstream users adjacent to Lawson Creek.
Again, in times of severe drought such as in 2018 and 2019, downstream users were reliant on permanent pools fed by underground aquifers as there was no flow in Lawson Creek. Upstream diversion of underground water to the proposed mine site may well have very significant effects on downstream users. If the project were to proceed, those effects would be irreversible.

• Registered Groundwater Users. There are 106 of these within 10 kilometres of the proposed mine site. Only 24 are part of a monitoring program. My family property contains a registered bore (WAL 27907/Associated Groundwater work/Stock, Domestic/Irrigation. Sydney Basin, Murray Darling Basin). This bore has an associated 50 megalitre irrigation licence. The previous proponent KCN undertook some intermittent monitoring of this bore around 2011 -2015 and provided me with the results of that monitoring program.

Since taking over the project in 2016, the current proponent SVL, has never approached any member of my family to request access to this bore for monitoring purposes.

All 106 bores should be part of a monitoring program so there can be no dispute about the degree of loss of access to water once the proponent commences the dewatering and collection process. (Page 59. Referring to bores likely to be adversely effected by drawdown- “Monitoring for potential drawdown impacts at these bores would be an objective of the groundwater monitoring program for the project”.
Clearly, monitoring of all 106 bores to clearly indicate if drawdown impacts have occurred must be required of the proponent. The proponent has stated that “Make (No room for rest of submission) (Unable to upload attachments)

Project will provide long term employment while providing materials necessary to support green energy.
Removal of pipeline will help minimise long term impact of project post mine life.

i believe the Bowdens silver project will help boost the small community of Lue through providing jobs for the locals living in and around Lue and surrounding towns, as well as provide support for other businesses and facilities around the region.

I frequent this area of the proposed mine on a very regular basis and i am very concerned about the ongoing environmental effects this project will have on the local Lue area. I also have grave concerns about the mine directly accessing the natural water ways that also use the water for there farms and domestic use.

The development of a new metals mine will provide valuable jobs and is part of the post-coal transition required for the primary resources industry in NSW. The proposal by Bowdens Silver is well thoughtout and will undoubtedly provide innumerable benefits for this region, NSW and Australia.

the Bowdens Silver project is part of a resurgence of silver-base metals mines. New projects and world-class assets come along so infrequently. For NSW to have a primary resources sector, the regulators and committees must say yes to this project. Otherwise, exploration is dead in NSW.