Cultural heritage threats. No silver lining yet for Bowdens mine

Bowdens’ proposed mine in central NSW is under increasing pressure to ensure the area’s heritage, cultural significance and water supply are protected. Michael Sainsbury reports.

Silver Mines Ltd. has so far failed to properly investigate Aboriginal cultural heritage as it proposes to build the Bowdens’ lead, zinc and silver mine near Lue in central NSW. This puts it squarely in the regulatory danger zone that sees the McPhillamy’s Gold Project near Blayney. Suspended for 30 years.

Following the destruction of the Juukan Pass in May 2020, Aboriginal heritage surrounding mining projects came to the fore and discussions continued. About Woodside’s operations throughout northern Australia. The Federal Environment Minister can refuse approvals granted by state and Federal governments under the Aboriginal and Torres Strait Islander Heritage Protection Act or the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act), as amended late last year.

In the post-Juukan regulatory environment, projects that fail to demonstrate sustained consultation, defensible research scope and a reliable understanding of cultural significance are increasingly stalled or left to unravel in court.

That’s the risk Bowdens now faces, where both the local Wiradjuri body and an independent archaeologist say the project’s Aboriginal heritage assessment is inherently flawed and inadequate to support the approval contained in documents submitted to and submitted to the NSW government. MWM.

Cultural significance ignored

Beyond the procedural failings, Wiradjuri experts say the project’s footprint lies within a culturally significant landscape that has never been properly assessed as a whole. With abundant water, high ground, caves, crushed burrows, scarred trees and extensive surface artefacts, Aboriginal groups describe the Bowdens area and surrounding areas, including Bingman Hill, as a culturally significant landscape.

Numerous Aboriginal artefacts have been identified on many properties around the mine site, and there are rock paintings on properties adjacent to the site.

Aboriginal groups say the cultural landscape context was never properly integrated into Bowdens’ assessment and the area was not properly surveyed. Map of works obtained by MWM It shows the numerous artifacts in the land surrounding the mining site.

In an official letter to the Wellington Valley Wiradjuri Aboriginal Corporation, the NSW planning minister said (WVWAC) called for a “complete redo” of Bowdens’ Aboriginal cultural heritage research, saying it was based on “sporadic research between 2011 and 2019”.

Traditional Owners were never properly reported, investigated or consulted.

WVWAC also points out that the Environmental Impact Statement acknowledges that the Landscape 2020 Aboriginal Cultural Heritage Assessment “does not have separate reporting for each of the individual survey periods.”

The company says this approach meant Aboriginal people “did not have the opportunity to discuss a report and make any recommendations from 2011 to 2019”, a failure it described as “contrary to the code of practice and consultation rules”.

Most importantly, WVWAC says the EIS “does not include a detailed transect map, which is a requirement of the state government,” meaning there is no way to verify what ground has been surveyed or overlooked.

Insufficient surveys

These concerns were independently reinforced by a June 2025 peer review by archaeologist Doug Williams, who concluded that the Landskape report was “deficient in a number of respects that compromise its ability to appropriately support a high-impact development such as the Bowdens mine.”

Williams describes the survey work as “piecemeal” and was conducted “at very short intervals over 9 years, with no documentation”, calling it “an ineffective and unfair way of engaging Aboriginal stakeholders”. He finds “numerous breakdowns in Aboriginal consultation lasting longer than normally permitted”, including multi-year gaps with no documented engagement.

Regarding the news, Williams is blunt: “The survey methodology does not provide evidence of survey shifts (a requirement of the Code of Practice),” adding:

There is no evidence that survey coverage was as comprehensive as claimed.

The archaeological documents themselves were also found to be incomplete. Although the report claims that approximately 500 artefacts were identified, Williams notes that there was “no record of individual artefacts”, no measurements were taken and “photographs of stone artefact samples were not provided” to Aboriginal stakeholders; this failure, he says, “prevents a meaningful appreciation of the significance of the place.”

Threats to water supply

According to First Nations heritage experts, the region contains at least 29 springs, as well as seeps and swamps, providing a permanent water source that supported continued Aboriginal occupation. Threatened Mountain Marshes and Peatlands also exist and need protection.

Multiple reports prepared for Bowdens, including reports from Landskape, Cardno, Jacobs and WRM Water and Environment, identified springs, swamps and seeps throughout the mine area. Elders say no evidence has been produced to support the claim that water is not permanent.

Williams’s peer review reinforces this concern, criticizing the report for underestimating water reliability and incorrectly limiting important archaeological assumptions to areas near major waterways; Williams says this approach is “absolutely not valid” in the region

WVWAC also raises alarm about the “supplementary” heritage works on which Bowdens later relied. A “visual inspection” in November 2024 reported no new sites – but WVWAC says this was carried out “without any Aboriginal Cultural Heritage Site Officer present” and again no cross-mapping or coverage was provided

Williams warned that postponing unresolved inheritance issues until after confirmation was fundamentally flawed.

Asking for approval and only then carrying out further evaluation is extremely poor heritage management practice,

“It is contrary to the principles of ‘free, informed and prior consent,'” he writes.

This warning echoes the reasoning currently being tested in the Federal Court in McPhillamy’s, where the federal environment minister concluded that uncertainty about the impacts of Aboriginal heritage posed an unacceptable risk and triggered a protection order.

Bowdens said he would not respond to questions directed to the company. MWM “Right now”.

A spokesperson for the Department of Planning, Housing and Infrastructure said: MWM: “The Ministry is currently awaiting additional information from the applicant regarding the proposal. The Independent Planning Commission will be the approval authority for this proposal and will be referred to it for decision once the Ministry has completed its assessment.”

“The Department cannot speculate about any future Federal heritage preservation actions that may be taken under Federal legislation.”

After previously promising shareholders that it had submitted all relevant paperwork to advance its project to the NSW Independent Planning Commission for consideration, Silver Mines told the ASX on December 23 that it would conduct new biodiversity surveys in early 2026 for a new report.

MWM He recognizes that the IPC’s determination process will provide the community with greater opportunity to have a say.

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