Client Report Title Report Title Munglinup Graphite Project

Flora and Vegetation Impact Assessment Memo

PREPARED FOR: MRC GRAPHITE PTY LTD

MARCH 2021

TEL. (08) 9315 4688 [email protected] PO Box 50, Applecross WA 6953 www.woodmanenv.com.au MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo Prepared for: MRC Graphite Pty Ltd Job Number: MRC19-48 Report Number: MRC19-48-03

DOCUMENT REVISION AND STATUS Revision Status Originator Internal Internal Client Client Review Reviewer Review Date Reviewer Date A Draft Impact CG DW/GW 01/05/2020 MRC / ISPL 19/5/2020 Assessment 0 Final Impact CG CG / GW 5/6/2020 MRC / EPA / 8/9/2020 Assessment Other DMA 1 Final Impact CG CG / AS 30/10/2020 MRC 16/11/2020 Assessment with EPA requests 2 Final including CG CG/GW 19/11/2020 MRC/ISPL 19/11/2020 Disturbance Footprint 3 Final Impact CG GW/AS 5/3/2021 Assessment with updated Distrubance Footprint

DISCLAIMER This document is prepared in accordance with and subject to an agreement between Woodman Environmental Consulting Pty Ltd (“Woodman Environmental”) and the client for whom it has been prepared (“MRC Graphite Pty Ltd”) and is restricted to those issues that have been raised by the Client in its engagement of Woodman Environmental and prepared using the standard of skill and care ordinarily exercised by Environmental Scientists in the preparation of such Documents.

Any organisation or person that relies on or uses this document for purposes or reasons other than those agreed by Woodman Environmental and the Client without first obtaining the prior written consent of Woodman Environmental, does so entirely at their own risk and Woodman Environmental denies all liability in tort, contract or otherwise for any loss, damage or injury of any kind whatsoever (whether in negligence or otherwise) that may be suffered as a consequence of relying on this document for any purpose other than that agreed with the Client.

MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

TABLE OF CONTENTS DEFINITIONS ...... i EXECUTIVE SUMMARY ...... i 1. INTRODUCTION ...... 1 1.1 REGULATORY ASSESSMENT CONTEXT ...... 1 1.2 PURPOSE AND SCOPE OF THIS REPORT ...... 1 1.3 TERMINOLOGY AND DEFINITION ...... 2 1.4 BACKGROUND SUMMARY AND SOURCES OF INFORMATION ...... 4 1.4.1 Flora ...... 4 1.4.2 Vegetation ...... 7 2. METHODS ...... 11 2.1 THREATENING PROCESSES ...... 11 2.2 ASSESSMENT OF DIRECT IMPACTS ...... 11 2.2.1 Flora ...... 12 2.2.2 Vegetation ...... 13 2.3 ASSESSMENT OF INDIRECT IMPACTS ...... 15 3. RESULTS ...... 17 3.1 SIGNIFICANT FLORA TAXA AND LOCAL CONSERVATION SIGNIFICANCE RANKING ...... 17 3.2 VEGETATION AND CONSERVATION SIGNIFICANCE RANKING ...... 22 3.3 ASSESSMENT OF DIRECT IMPACT ...... 27 3.3.1 Direct Local and Regional Impact on Significant Flora Taxa ...... 27 3.3.2 Direct Local Impact and Significance of Local Impact on Vegetation Units ... 36 3.3.3 Regional Impact on Vegetation ...... 42 3.3.4 Cumulative Impacts ...... 47 3.3.5 Impacts on the Kwongkan TEC ...... 47 3.4 QUALITATIVE ASSESSMENT OF INDIRECT IMPACTS – FLORA AND VEGETATION ...... 52 3.4.1 Impacts to Groundwater Dependent Vegetation/Species ...... 52 3.4.2 Impacts from Surface Water Hydrology Changes ...... 52 3.4.3 Impacts from Increased Fragmentation ...... 53 3.4.4 Impacts from Dieback Disease and Introduced Weeds ...... 53 3.4.5 Impacts from Dust ...... 54 4. CONCLUSIONS ...... 56 4.1 FLORA ...... 56 4.2 VEGETATION ...... 56 5. REFERENCES ...... 58

MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

APPENDICES

Appendix A: Conservation Codes for Flora and Fauna of Western Australia

FIGURES

Figure 1.1: Tenements and Reserves Figure 1.2: Study Areas Figure 2: Potential Impact to Significant Flora Figure 3.1: Potential Impact to Vegetation Units Figure 3.2: Potential Impact to Vegetation Units (Legend) Figure 4: Potential Impact to ‘Proteaceae Dominated Kwonkgan Shrublands of the Southeast Coastal Floristic Province of Western Australia’ TEC

TABLES

Table 1: Development Envelope and Study Area Extents Table 2: Significant Flora Taxa Known in the Study Area Table 3: Vegetation System Associations Occurring in the Study Area Table 4: Vegetation Units of the Study Area (Woodman Environmental 2020) Table 5: Scale of Potential Local and Regional Impact on Significant flora taxa Table 6: Descriptions of Local Conservation Significance Rankings of Vegetation Units Table 7: Scale of Potential Local Impact on Vegetation Units Table 8: Significance of Potential Local Impact on Flora Taxa and Vegetation Units Table 9: Significant Flora Taxa considered in the Impact Assessment Table 10: Local Conservation Significance Assessment of Vegetation Units of the Development Envelope Table 11: Scale of Potential Local Impact to Locations and Individuals of Significant Flora Taxa Table 12: Scale of Potential Local Impact to Preferred Habitat of Significant Flora Taxa Table 13: Assessment of Regional Significance of Impact to Significant Flora Taxa Table 14: Local Direct Impact on Vegetation Units Table 15: Significance of Local Impact on Vegetation Units Table 16: Vegetation System Associations of the Development Envelope and predicted change to occurence Table 17: Potential for Significant Impact to Regional Extent of Vegetation Units Table 18: Local and Regional Extent of the Kwongkan TEC

MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Table19: Assessment of the Significant Impact Criteria for the Kwongkan TEC by the Project (DoEE 2013)

MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo DEFINITIONS Term Definition BC Act Biodiversity Protection Act 2016 (State) CSA Combined Study Area (Study Area and Extrapolated Study Area) (Woodman Environmental 2020) DBCA Department of Biodiversity, Conservation and Attractions DoEE Department of Environment and Energy (previously Department of Environment (DoE)) DMIRS Department of Mines, Industry Regulations and Safety En Endangered EPBC Act Environmental Protection and Biodiversity Conservation Act 1999 (Commonwealth) EPA Environmental Protection Authority EP Act Environmental Protection Act 1986 (WA) ESA Extrapolated Study Area (Woodman Environmental 2020) GDV Groundwater Dependent Vegetation ha Hectares km Kilometres MNES Matters of National Environmental Significance OEPA Office of the Environmental Protection Authority P Priority PEC Priority Ecological Community RoM Run of Mine TEC Threatened Ecological Community TSF Tailings Storage Facility VU Vegetation Unit Vu Vulnerable WRL Waste Rock Landform

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MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo EXECUTIVE SUMMARY MRC Graphite Pty Ltd are proposing to develop and operate the Munglinup Graphite Project, located north of Munglinup in the south coast region of Western Australia. Flora and vegetation baseline surveys have been conducted by Woodman Environmental Consulting Pty Ltd (2020). This report presents the potential local and regional impacts to flora and vegetation factors at the site, and their significance.

The impact assessment is based on rankings of significance of local populations in their regional context, and scale of local and regional impact. All local data for flora and vegetation is based on data presented in Woodman Environmental (2020), with regional data sourced from relevant government databases.

Nine significant flora taxa have individuals and/or habitat which are located within the project Development Envelope. Of these, individuals from four taxa will potentially be removed during the implementation of the project, and the potential local significance of impact to these taxa is ranked Moderate-Low. The potential regional significance of impact to three of these taxa is likewise ranked Low-Moderate or Moderate-High, with few regional populations known. The populations of Conostylis lepidospermoides (T), the only Threatened flora taxon known to occur in the Study Area, is not within the Development Envelope and thus will not be impacted by the project.

A total of 13 Vegetation Units (VUs) are within the Development Envelope; the local impact is ranked as Moderate for four of these VUs, and High for one further VU (VU 7) based on the extent of mapping of each VU within the Combined Study Area and Disturbance Footprint. At the regional scale, there will be potential for Low-Moderate significance of impact on VU 7, and Moderate significance of impact to VU 15.

A total of 10ha of the TEC ‘Proteaceae Dominated Kwongkan Shrublands of the Southeast Coastal Floristic Province of Western Australia’ (Kwongkan TEC) is proposed to be impacted, which equals 2.7% of the TEC community (VUs 16 and 17) mapped within the Combined Study Area. This potential impact fits within the significant impact criterion ‘Reduce the Extent of an Ecological Community’, specified in significant assessment guidelines 1.1 (DoEE 2013). Impacts to the TEC will be primarily through clearing in the service corridors; clearing of the TEC is likely to be less than the 10 ha stated, and final clearing boundaries can be modified to reduce the amount of clearing through this TEC as far as practicable.

i MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

1. INTRODUCTION MRC Graphite Pty Ltd (MRCG) is proposing to develop and operate the Munglinup Graphite Project (the Project), located in the south coast region of Western Australia approximately 85km east of Ravensthorpe and 4km north of the locality of Munglinup. The Project will mine graphite, with an expected 10-15 year mine life, through the development of a series of open pits will be established (Halberts Main; Halberts South; Harris; McCarthy East; McCarthy West; Whites). In support of open pit mining MRCG will also will also establish waste rock landforms (WRL), tailings storage facility (TSF), Processing Plant and Run-of-Mine (ROM) / low-grade stockpile, workshops and administration buildings, as well as haul roads and light- vehicle roads will be constructed. The proposed mining activities will occur within Mining Reserve R24714, on tenements M74/245, G74/9, L74/55 and L74/56.

Environmental baseline studies, including flora and vegetation, have been conducted for the Project. Flora and vegetation information for the area has been revised and updated to include survey data from 2018 – 2019 by Woodman Environmental (2020), including Detailed Vegetation and Targeted Flora surveys conducted to the requirements of Environmental Protection Authority (EPA 2016b).

The Project is located within the Esperance Plains bioregion, which is known to be one of the richest places in the world for botanical diversity (Beard 1990; Comer et al. 2001; Markey et al. 2012). The Project is also located within a highly cleared and fragmented landscape and this has been considered in the context of this impact assessment. 1.1 Regulatory Assessment Context The Project was referred to the Environmental Protection Authority (EPA) in November 2018. The level of assessment set was Referral of Information in May 2019, with additional information required under section 40(2)(a) of the Environmental Protection Act 1986 (EP Act).

The Department of Environment and Energy (DoEE) determined that the action was a controlled action; in July 2019 the DoEE determined that the project should be assessed by the EPA under the EP Act as an accredited assessment.

On the 12th July 2019 the EPA determined that further information was required for the assessment, to inform the impact assessment process.

The Project will be subject to various other approvals, including a Mining Proposal (under the Mining Act 1978) and EP Act Part V Works Approvals and Prescribed Premises Licences. 1.2 Purpose and Scope of this Report The EPA Objective for Flora and Vegetation is to protect flora and vegetation so that biological diversity and ecological integrity are maintained (EPA 2016a). This report provides an overall assessment of the potential impacts of the Project’s activities on the factor Flora and Vegetation, utilising the information collected during the 2018-2019 Detailed Flora and Vegetation Study and the Regional Vegetation Assessment. The extent of

1 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo the Development Envelope has been utilised to calculate potential impacts, and as such represents a worst-case scenario. There has been a small amount of historically cleared within the proposed Development Envelope. This clearing is limited to exploration activities and small-scale mining undertaking between 1900-1920s. As a result of the small amount of clearing, cumulative impacts to flora and vegetation in the Munglinup Study Area are not considered in this memo. 1.3 Terminology and Definition The impact assessment considers only the Development Envelope, and does not consider a proposed disturbance footprint.

The following definitions apply with reference to the Project: • Study Area: the area within which baseline Detailed and Targeted vegetation and flora surveys have been conducted for the Munglinup Project (Woodman Environmental 2020). The Study Area has a total area of approximately 1,673 ha. Limited survey for significant flora has also been undertaken outside of the Study Area, at areas where populations were found to extend outside of the Area, and in some cases where suitable habitat was identified. • Extrapolated Study Area: the area within which Vegetation Unit (VU) boundaries were interpreted using aerial photography from the Detailed vegetation mapping, extrapolating primarily on the western side of the Study Area. On-ground field survey inspection in this area to confirm the extrapolation was undertaken (March 2020), however Detailed vegetation survey has not been conducted; despite this, the confidence in this mapping is relatively high with the the aerial photograph extrapolation and field survey conducted by personnel who were very familiar with the vegetation the Study Area. Results of this extrapolated mapping are presented in Woodman Environmental (2020). The Extrapolated Study Area has a total area of approximately 337 ha. • Combined Study Area: refers to the combined Study Area and Extrapolated Study Area, with an approximate area of 2,009 ha. • Development Envelope: the total area within which the clearing will be contained. The Development Envelope is approximately 649.0 ha. • Disturbance Footprint: the area which is planned to be cleared. the Project has a maximum potential clearing of 350ha within the Development Envelope. The Disturbance Footprint as presented in this assessment is 320ha; the remaining 30ha of potential clearing will be limited to areas that are not environmentally sensitive (see Section 3 for more detail). Table 1 presents a summary of the extents of these components, and their relative percentages of the Combined Study Area (Study Area and Indicative Study Area). Figure 1.1 presents the tenement and reserves located in the Study Area, and Figure 1.2 presents the extent of the Development Envelope, Study Area and Extrapolated Study Area.

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Table 1: Development Envelope and Study Area Extents

Combined Study Study Area (ha Extrapolated Study Development Disturbance Area (CSA) (ha) / % of CSA) Area (ha/% of CSA) Envelope (ha/%of Footprint (ha/%of CSA) CSA) 2009 1673 337ha 649 320 83.2 16.8 32.3 15.9

3 300000 302000 304000 306000 6278000 6278000

L 74/56 6276000 6276000 6274000 6274000

M 74/245

L 74/55

G 74/9 6272000 6272000 6270000 6270000

Legend Tenements Mining Reserve R24714 6268000 6268000 300000 302000 304000 306000

Author: Cathy Godden Figure Tenements and Reserves WEC Ref: MRC19-48-03 $ Filename: MRC19-48-03-f01-1 1.1

This map should only be used in conjunction with WEC report MRC19-48-03. Revision: 3 - 02 March 2021 Scale: 1:27,500 (A3) Projection: GDA 1994 MGA Zone 51 300000 302000 304000 306000 6278000 6278000 6276000 6276000 6274000 6274000 6272000 6272000 6270000 6270000

Legend Study Area Extrapolated Study Area Combined Study Area Development Envelope Disturbance Footprint 6268000 6268000 300000 302000 304000 306000

Author: Cathy Godden Figure The Project WEC Ref: MRC19-48-03 $ Filename: MRC19-48-03-f01-2 1.2

This map should only be used in conjunction with WEC report MRC19-48-03. Revision: 3 - 02 March 2021 Scale: 1:27,500 (A3) Projection: GDA 1994 MGA Zone 51 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

The following definitions apply with reference to flora and vegetation: • Significant flora – refers to flora taxa defined as significant by the Environmental Protection Authority (EPA) (EPA 2016a; b) which includes: • taxa identified as Threatened or Priority species (under either State (BC Act) or Commonwealth (EPBC Act; Matters of National Environmental Significance (MNES)) legislation or listings; • locally endemic or associated with a restricted habitat type (e.g. surface water or groundwater dependent ecosystems) • new species or anomalous features that indicate a potential new species • representative of the range of a species (particularly, at the extremes of range, recently discovered range extensions, or isolated outliers of the main range) • unusual species, including restricted subspecies, varieties or naturally occurring hybrids • relictual status, being representative of taxonomic groups that no longer occur widely in the broader landscape. • Significant vegetation – refers to vegetation that belongs to one of the following categories as defined by the EPA (EPA 2016a; b): • being identified as Threatened or Priority Ecological Communities • restricted distribution • degree of historical impact from threatening processes • a role as a refuge • providing an important function required to maintain ecological integrity of a Significant ecosystem. • Local – with regard to the distribution of significant flora taxa and significant vegetation, ‘local’ is defined as the known distribution within the Study Area, Extrapolated Study Area (‘Combined Study Area’) and locations otherwise known in the Munglinup River Macro Corridor (Wilkins et al. 2006) within 5km. • Regional – with regard to the distribution of significant flora taxa and significant vegetation, ‘regional’ is defined as the total known distribution within Western Australia. Therefore, regional impacts are defined as impacts to significant flora taxa or VUs across their total known distributions. • Population – Indicative regional populations of the flora taxa assessed have been provided after review of distribution of known locations as presented on NatureMap (DBCA 2007-). Within the Study Area, subpopulations have been defined as those locations (or groups of locations) which are separated by 500m or more.

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1.4 Background Summary and Sources of Information 1.4.1 Flora Several local flora surveys have been undertaken in the general region of the Study Area, as summarised in Woodman Environmental (2020). Ecologia (2015) and Woodman Environmental (2020) have undertaken flora studies directly within the Study Area. All data in relation to local distribution of significant flora taxa is taken from Woodman Environmental (2020). A total of one Threatened flora taxon (listed under the BC Act (Vulnerable) and EPBC Act (Endangered; MNES), seven Priority-listed flora taxa (DBCA 2018b), and four taxa that are considered significant because they either potentially represent undescribed taxa, are known from very few records, or are outliers of the main range of the taxon (as per EPA 2016b), are known to occur in the Study Area. The numbers of individuals, locations and populations in the Study Area are presented in Table 2.

The conservation codes used by the DBCA (2019a) for flora Western Australia are provided in Appendix A. One Threatened Flora taxon, listed under the BC Act (Vulnerable) and the EPBC Act (Endangered) is known to occur in the Study Area.

Lasiopetalum ?parvuliflorum (P3) as previously recorded in the Study area by Ecologia (2015) was not re-located in the Study Area despite targeted survey. Likewise, targeted survey for Rhizanthella johnstonii (T) identified no populations of this taxon in the Study Area; the potential habitat identified for this taxon also does not occur within the Disturbance Footprint. These two taxa are not considered further in this assessment memo. Likewise, a variety of taxa were recorded where the Study Area represents an extension to their known ranges (Table 10 of Woodman Environmental 2020); these are also not considered ‘significant taxa’ for the purposes of this memo as per the guidance presented in that report.

As per Table 11 of Woodman Environmental (2020), a further 15 flora taxa from the desktop study (as presented in that report) were determined as having the possibility of occurrence in the wider unsurveyed-portions of the Study Area; of these, only one was thought of having the possibility of occurrence in the Development Envelope itself (Eucalyptus dielsii x platypus (P1)). It is unclear why this hybrid has been listed as having Priority conservation status, with hybrids only considered of conservation significance if they are able to continue breeding (Kern 2010; Nicolle and French 2012) and therefore it is considered by Woodman Environmental that this taxon should not be listed as a taxon of conservation significance.

Targeted survey was undertaken in the Study Area, with most survey effort within the Development Envelope portion of the Study Area. Limited survey effort was undertaken immediately outside of the Study Area. The survey focusing on potential regional extents of VUs did not target significant flora taxa, however information was recorded where such taxa were opportunistically noted (Woodman Environmental 2020).

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Table 2: Significant Flora Taxa Known in the Study Area Number of Populations$ Number of Locations Recorded Number of Individuals Recorded Recorded Preferred Taxon Status Inside Outside Inside Outside Inside Outside Habitat Study Study Total Study Study Total Study Study Total Area Area Area Area% Area Area T (VU) (BC Act) Conostylis lepidospermoides T (EN) (EPBC 4 0 4 67 0 67 2 0 2 16 Act) Lepidosperma sp. Mt Chester (S. Kern et al. LCH P1 2 0 2 35 0 35 2 0 2 1, 2 16596) Lepidosperma ?sp. Mt Short P1 1 0 1 NR 0 NR 1 0 1 6 (S. Kern et al. LCH 17510) Leucopogon sp. Cascades P1 5 0 5 35 0 35 2 0 2 16 (M. Hislop (3693) Commersonia rotundifolia P3 2 0 2 35 0 35 2 0 2 14 Dampiera sp. Ravensthorpe P3 1 0 1 200 0 200 1 0 1 4 (G.F. Craig 8277) Pultenaea calycina subsp. P4 186 5 190 1372 34 1406 3 1^ 3 1, 15 proxena Stachystemon vinosus P4 50 3 53 292 4 296 5 1^ 5 1, 16

Unusual variant, Acacia spongolitica 1 0 1 NR 0 NR 1 0 1 4 range outlier

Leucopogon aff. Potential new 186 0 185 2009 0 2,009 6 0 6 1, 16 canaliculatus taxon Potential new Synaphea aff. drummondii 62 24 86 147 103 250 6 1^ 6 16 taxon# Synaphea sp. Jilakin Flat Potential new Rocks Rd (R. Butcher et. al 13 0 13 92 0 92 2 0 2 16 taxon RB200)

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$numbers of populations are based on the definition of a population provided in Section 1.3. *The previously recorded location of Pultenaea calycina subsp. proxena and the locations of Leucopogon aff. canaliculatus was revisited by the 2020 survey; therefore, associated data (Ecologia 2015) has been superseded by data recorded by that survey. ^Population comprises locations and individuals from both inside and outside Study Area. %Outside Study Area refers to locations, individuals and populations recorded by this survey and Ecologia (2015) only

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1.4.2 Vegetation Regional The Study Area is located in the Recherche subregion of the Esperance Plains Interim Biogeographic Regionalisation for Australia (IBRA) region (Commonwealth of Australia 2012). The vegetation of the Recherche subregion comprises heath, coastal dune scrub, mallee, mallee-heath and granite heath (Comer et al. 2001).

Four vegetation system associations (Beard et al. 2013) occur in the Study Area, as summarised in Table 3. Of these four vegetation system associations, two (Esperance 47 and Esperance 4048) have around 15% of their pre-European extent remaining, with the remaining two vegetation system associations being relatively well-represented compared to pre-European extent (about 40%). None of the vegetation system associations occurring in the Study Area are particularly well-represented in lands protected for conservation (all less than 15% of their current extents). Table 3: Vegetation System Associations Occurring in the Study Area Vegetation Description Current Percentage of Percentage of System Extent (ha) Pre-European Current Extent Association Extent Remaining Protected for Conservation Esperance 47 Shrublands; tallerack (Eucalyptus 61,386 14.9 11.2 pleurocarpa) mallee-heath Esperance 516 Shrublands; mallee scrub, black 46,651 40.7 9.7 marlock (Eucalyptus redunca and allies) Esperance 931 Medium woodland; yate 2,745 39.0 4.7 (Eucalyptus occidentalis) Esperance 4048 Shrublands; scrub-heath in the 2,927 15.9 12.9 Esperence Plains including Mt Ragged scrub-heath Vegetation Units and Significant Vegetation A total of 17 Vegetation Units (VUs) were mapped and described in the Study Area as presented in Table 4. Twelve of these were described as being ‘locally significant’ as they each represented less than 3% of the Study Area, and were mapped on landforms which are uncommon in the Study Area. Of these, VUs 7, 8, 9 and 10 were mapped as occurring in the Extrapolated Study Area, meaning their extent in the local area is more wide-spread than the data within the Study Area suggests. All VUs can be considered regionally significant, as all potentially have restricted distributions, and all have potentially been historically significantly impacted by threatening processes, in line with EPA guidance (EPA 2016b) (Woodman Environmenal 2020).

VU descriptions are presented in Figure 3.2 (Section 3.2). .

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Table 4: Vegetation Units of the Study Area (Woodman Environmental 2020)

Vegetation Study Area Extrapolated Study Area Combined Study Area Comments (Woodman Environmental Descriptor Unit 2020) Area (ha) Percentage Area (ha) Percentage Area (ha) Percentage 1 LWEsppMr 445.1 26.6 69.3 20.6 514.4 25.6 Not considered locally significant; relatively extensive in the SA and occurs on landforms which are not restricted

2 LWEsppMspp 183.4 11.0 1.8 0.5 185.2 9.2 Not considered locally significant; relatively extensive in the SA and occurs on landforms which are not restricted; mapped in Extrapolated Study Area and noted to occur in wider region

3 LWEdMpHp 1.9 0.1 0.0 0.0 1.9 0.1 Considered locally significant; not mapped in the Extrapolated Study Area and no further information available regarding its extent in the wider region 4 LWEdAhGp 7.2 0.4 0.0 0.0 7.2 0.4 Considered locally significant; not mapped in the Extrapolated Study Area and no further information available regarding its extent in the wider region 5 LMEsppMh 7.5 0.4 0.0 0.0 7.5 0.4 Considered locally significant; not mapped in the Extrapolated Study Area and no further information available regarding its extent in the wider region 6 LOWEeCvDs 4.6 0.3 0.0 0.0 4.6 0.2 Considered locally significant; not mapped in the Extrapolated Study Area and no further information available regarding its extent in the wider region

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Vegetation Study Area Extrapolated Study Area Combined Study Area Comments (Woodman Environmental Descriptor Unit 2020) Area (ha) Percentage Area (ha) Percentage Area (ha) Percentage 7 LWEdGpHp 19.9 1.2 7.8 2.3 27.7 1.4 Considered locally significant; mapped in the Extrapolated Study Area and potentially occurs in wider region 8 LWEoMhGa 42.6 2.6 90.6 26.9 133.2 6.6 Considered locally significant; mapped in the Extrapolated Study Area however potentially occurs in wider region

9 LWEoEqLs 32.0 1.9 3.7 1.1 35.7 1.8 Considered locally significant; mapped in the Extrapolated Study Area and potentially occurs in wider region 10 LOWEcMsppGa 7.1 0.4 41.6 12.4 48.7 2.4 Considered locally significant; mapped in the Extrapolated Study Area and potentially occurs in wider region 11 TSMuAs 26.4 1.6 0.0 0.0 26.4 1.3 Considered locally significant; not mapped in the Extrapolated Study Area however potentially occurs in wider region

12 LWOFEoAc 26.9 1.6 31.8 9.5 58.7 2.9 Considered locally significant; mapped in the Extrapolated Study Area however no further information available regarding its extent in the wider region 13 LWEoLlLf 41.6 2.5 0.0 0.0 41.6 2.1 Considered locally significant; not mapped in the Extrapolated Study Area and no further information available regarding its extent in the wider region 14 LFEpMtAg 465.3 27.8 30.1 9.0 495.4 24.7 Not considered locally significant; relatively extensive in the SA and occurs on landforms which are not restricted

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Vegetation Study Area Extrapolated Study Area Combined Study Area Comments (Woodman Environmental Descriptor Unit 2020) Area (ha) Percentage Area (ha) Percentage Area (ha) Percentage 15 LWEsppMpBi 40.2 2.4 0.0 0.0 40.2 2.0 Considered locally significant; not mapped in the Extrapolated Study Area and no further information avaialable regarding its extent in the wider region; unusual soil type therefore low likelihood of occurrence

16 LWEpBaMs 226.9 13.6 57.8 17.2 284.7 14.2 Forms part of the Kwonkgan TEC; locally and regionally significant 17 TSLiAcCd 89.3 5.3 0.0 0.0 89.3 4.4 Forms part of the Kwonkgan TEC; locally and regionally significant Cleared 4.8 0.3 1.8 0.5 6.6 0.3 Not assessed TOTAL 1672.7 100 336.3 100 2009 100

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The TEC ‘Proteaceae Dominated Kwongkan Shrublands of the Southeast Coastal Floristic Province of Western Australia’ (Kwongkan TEC) is known to occur in the Study Area. This TEC is listed as Endangered under the EPBC Act (and therefore is MNES) and listed as Priority 3(iii) by the DBCA. VUs 16 and 17 represent the TEC in the Study Area. A total area of 316.2 ha of this TEC was mapped in the Study Area, increasing to 374 ha throughout the Combined Study Area. 2. METHODS 2.1 Threatening Processes Impacts to flora and vegetation can be either Direct or Indirect. Direct impacts result in removal of vegetation and flora taxa through clearing and other ground disturbance activities. This results in both removal of known locations, death of individuals at these locations, and removal of habitat. Indirect impacts to flora and vegetation may occur as a result of processes such as: 1) Dust emissions: potential to smother individual plants causing decline in health or death, and potential to reduce the condition of vegetation 2) Degradation of vegetation through edge effects associated with clearing activities 3) Water and/or sediment run off (for example, erosion after significant rainfall from WRLs; spillage of saline water/tailings/hydrocarbons): potential to smother both individuals of significant flora taxa, and general vegetation resulting in decline in health or death 4) Altered hydrology and drainage shadow: potential for significant reduction or removal of seasonal surface water flow, causing either death or loss of condition to individual plants or vegetation 5) Introduction of weeds and pathogens, including Phytophthora cinnamomi: introduction of weed taxa can lead to competition for available resources with individual plants, and loss of condition of vegetation; introduction of P. cinnamomi will result in vegetaton loss and/or degradation and habitat alteration. 6) Changes to groundwater levels on groundwater dependent vegetation (GDV): can lead to death of phreatophytic taxa and change in composition of GDV; 7) Fragmentation to local populations of significant flora and vegetation: fragmentation of existing populations or patches of vegetation in an already fragmented landscape leading to decline in health and quality of populations/patches of vegetation, or loss of genetic diversity through isolation of segments of a population, leading to reduced genetic fitness of remaining population. 2.2 Assessment of Direct Impacts The assessment of direct impacts is provided by quantification of the project activities in a GIS environment on the known extent and range of significant environmental factors. Impacts have been calculated using the Development Envelope against both the extent of the Study Area and Extrapolated Study Area.

The project layout is expected to directly impact no more than 350 ha within a 650 ha Development Envelope. However this impact assessment considers the potential impacts to flora and vegetation for the whole Development Envelope as a worst case scenario. This approach was adopted as some aspects of the conceptual site layout are yet to be locked down.

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The impact assessment scales (Tables 5 - 8) were prepared in consultation with the Species and Communities Branch of the DBCA during previous impact assessments. They are conservative taking into consideration a lack of detailed ecological information for the taxa and communities assessed. 2.2.1 Flora The significant flora dataset for the Project held by Woodman Environmental has been used to undertake this assessment. No cumulative impact assessment has been undertaken for the Combined Study Area, as historical impacts through factors such as mining and exploration have been minimal. The Development Envelope was overlaid on locations of significant flora in a GIS environment, to determine the potential extent of impact on these locations. The extent of proposed impact on preferred habitat VUs for each taxon has also been calculated, to determine the proportional extent to which habitat for each taxon will be impacted.

The methods for assessing the scale and significance of impact were developed by Woodman Environmental in consultation with the Environmental Protection Authority Services Unit (previously Office of the EPA) and DBCA (previously Department of Environment and Conservation) as part of previous impact assessment projects. A ranking of the scale of potential local impact on each taxon was determined and is presented in Table 5.

Impact on significant flora taxa in a regional context cannot be quantified as there is limited data available on the numbers of individuals of significant flora taxa known across their ranges within existing state or commonwealth datasets. Assessment of impacts at the regional scale utilises the significance of the local subpopulation(s) of a taxon to the maintenance of the taxon throughout its range and scales the proposed impact on local populations to determine the potential impact on the taxon in terms of conservation status across its entire range.

A qualitative assessment of the significance of the local populations of the significant flora which are at risk of impact to the regional conservation status of each taxon has been undertaken. This assessment reviews the number and distribution of populations, the size of these populations, the reservation status of the tenure of the lands upon which they are located, and the position of the Study Area within the known range of each taxon. The information for the regional populations is sourced from afore-mentioned government databases combined with Woodman Environmental company records. The significance of the potential impact at a regional scale is assessed based on the relative importance of the local populations of significant flora taxa to their conservation, as per Table 5.

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Table 5: Scale of Potential Local and Regional Impact on Significant flora taxa Scale of Level Description of Impact Potential Impact Low Impact Local <25 % of known local individuals or area of habitat may potentially be impacted Regional <25 % of known regional populations may potentially be impacted; Local subpopulations are not of particular significance in terms of maintaining the survival of the taxon: taxon has a wide distribution; >10 populations some of which are protected in conservation estate; and the local population is likely to have low significance in maintaining the extent of the taxon, for example being located within the known range and not representing a disjunct population, being located in relatively close proximity to other populations

Moderate Impact Local 25 - 50 % (inclusive) of known local individuals or area of habitat may potentially be impacted Regional 25 - 50 % of known regional populations may potentially be impacted; Local subpopulations are moderately significant in terms of maintaining the taxon through its range: generally <10 populations, which may include those on conservation estate; the taxon may have a wide distribution however the local population is located on the edge of the range or forms a significant disjunct population in comparison to the other populations; few if any nearby populations

High Impact Local >50 % of known local individuals or area of habitat may potentially be impacted Regional >50 % of known regional populations may potentially be impacted; Local subpopulations to be impacted are relatively significant in terms of maintaining the taxon through its range: there is limited distribution of the taxon (<40km); limited numbers of known populations (<5), with no populations being located on conservation estate; and the local population potentially contributes significantly to the maintenance of the taxon through being representative of the edge of the known range, forming a significant disjunct population or representing a significantly large population in comparison to other populations 2.2.2 Vegetation The local conservation significance of each VU mapped in the Development Envelope is defined utilising the scale presented in Table 6. This allows for the significance of potential local impacts to VUs to be ranked, as a function of the level of potential local impact and the local conservation significance of each VU. The extent within the Combined Study Area has been used in this definition.

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Table 6: Descriptions of Local Conservation Significance Rankings of Vegetation Units

Local Conservation Description Significance Ranking 1 • VU comprises >10 % of the combined study area; and • Landform/soil type where VU occurs is locally common and widespread 2 • VU comprises 1-10 % of the combined study area; and • Landform/soil type where VU occurs is locally common and widespread 3 • VU comprises 1-10 % of the combined study area; and • Landform/soil type where VU occurs is locally uncommon and/or restricted 4 • VU comprises < 1 % of the combined study area; and • Landform/soil type where VU occurs is potentially locally uncommon and/or restricted 5 • VU comprises < 1 % of the combined study area; and • Landform/soil type where VU occurs is locally uncommon and/or restricted

The Development Envelope and Disturbance Footprint were overlaid on VU polygons mapped in the Study Area and Combined Study Area in a GIS environment, to determine the area of each VU potentially to be impacted. A ranking of the level of potential local impact on VUs was determined using the scale presented in Table 7, using the scale of impact (Disturbance Footprint) within the Combined Study Area. The significance of the local impact is then calculated using the matrix presented in Table 8. Table 7: Scale of Potential Local Impact on Vegetation Units

Ranking of Potential Impact Description of Impact Low Impact <25 % of mapped VU in Combined Study Area may potentially be impacted Moderate Impact 25 - 50 % of mapped VU in Combined Study Area may potentially be impacted High Impact >50 % of mapped VU in Combined Study Area may potentially be impacted Table 8: Significance of Potential Local Impact on Flora Taxa and Vegetation Units

Scale of Potential Local Impact Low Moderate High Local Conservation Low Low Low Low Significance of Flora 1, 2 Taxon / VU Moderate Low Moderate Moderate-High

3 High Low Moderate-High High 4, 5

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Limited information regarding the regional distribution of VUs is available for the South Coast Region. Assessment of the similarity of the VUs of the Project Area with those of the Ravensthorpe Range (Markey et al. 2012) were presented by Woodman Environmental (2020) and where relevant have been included in this assessment. A regional field assessment was undertaken by Woodman Environmental, with areas chosen based on a desktop review of similar characteristics (IBRA subregion; soil and landform types, etc.) in an attempt to determine areas with similar vegetation to that of the Study Area. This data is referenced in the regional vegetation assessment. 2.3 Assessment of Indirect Impacts Some research has been undertaken at minesites in nearby regions in relation to impact of dust emissions on significant flora taxa. There is some evidence to suggest that dust from mining operations can impact flora taxa or vegetation, but the long-term impact is not clear. Turner (2013) reported that heavy dust loading created reduced stomatal conductance on two Acacia taxa; likewise it was evident in field observations that heavy dust loads did cause some death or stress to plants, including leaf shed. It was found that the leaf surface and dust interaction was more important to stress levels than the actual amount of dust; however metal-rich dust with low pH may have been the causal factor.

Sediment and water run off after significant rainfall events into surrounding native vegetation can occur and there is the possibility of impacts to vegetation. Likewise, introduction of weeds or other pathogens from activities such as clearing can degrade otherwise intact vegetation on a temporal basis. The introduction of P. cinnamomi to the Study Area would have the potential to increase on-going impact and death to vegetation in the local area. There is no GDV present in the Study Area (Woodman Environmental 2020), although groundwater layers are present in some areas within 10m of the surface, the salinity levels of this source are far higher than what can be utilised by vegetation. It is thought that the vegetation of the Study Area subsists entirely on soil-stored water which is replenished during rainfall events (mainly during winter).

The main drivers of indirect fragmentation effects include reduced patch (habitat) area, increased edge effects (introduction of weeds and other degradation), altered patch shape, increased patch isolation and altered matrix structure. Smaller patches, including smaller populations of significant flora, can result in reduction of reproductive success of individual species and reduce overall species composition (Didham 2010). The length of time of which a patch has been isolated is also important, with species richness decreasing over time. With respect to individual species, several traits may assist in predicting their sensitivity to fragmentation (Henle et al. (2004) as referenced by Didham 2010): • Population size: smaller populations are more prone to extinction; • Population variability: greater temporal variability in population size reduces the probability of population persistence; • Competitive ability and sensitivity to disturbance: competitively-dominant species in undisturbed habitats may reduce at the expense of disturbance-opportunists; • Degree of habitat specialisation: specialist species are more susceptible than generalists;

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• Rarity: rare, patchily distributed species are more susceptible than common species; and • Biogeographical location: tropical and Mediterranean biomes re more sensitive to fragmentation than temperate biomes.

The impact of fragmentation of populations of significant flora and vegetation is difficult to quantify at a site level. A qualitative assessment of the possible impacts of fragmentation by the Project is provided in Section 3.4.

16 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo 3. RESULTS 3.1 Significant Flora Taxa and Local Conservation Significance Ranking Six significant flora taxa have been recorded within the Development Envelope. A further two taxa, including the Threatened flora taxon Conostylis lepidospermoides, have been recorded in close proximity to the Development Envelope (within 100m). Suitable habitat occurs in the Development Envelope for a further two significant taxa, however these taxa were not recorded in the Development Envelope despite searching effort. The impact assessment therefore considers the significant flora taxa as detailed in Table 9, which were all either recorded as occurring, and/or have suitable habitat which occurs in the Development Envelope.

An assessment of the regional significance of the local populations in terms of their conservation status is also provided in Table 9. This assessment is based on factors such as the number of known populations, the range of the taxon and the position of the Study Area within this range, and location on lands managed for conservation.

The local populations of Conostylis lepidospermoides (T) have been ranked as being of Low- Moderate significance despite the taxon’s threatened status, due to the relatively large number of populations known, the presence of populations on conservation estate and the location of the Study Area being within the known range of the taxon.

The local populations of Leucopogon sp. Cascades (M. Hislop (3693) (P1) and Synaphea sp. Jilakin Flat Rocks Rd (R. Butcher et. al RB200) have been ranked as being of High regional significance as these taxa are known from few populations across a small or disjunct range, with the Study Area located on the edge of that range.

The local populations of the other listed significant taxa have been ranked either Low or Moderate significance as outlined in Table 9.

The knowledge of the ranges, numbers of populations and location in the conservation estate of the two potentially new taxa are limited, and the significance of the local populations to their potential regional conservation have been ranked as High Significance.

The 30ha of additional clearing (area yet to be defined) will be limited to within the Development Envelope, and will not impact known locations of significant flora taxa.

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Table 9: Significant Flora Taxa considered in the Impact Assessment Status Known / Potential Occurrence in the Development Significance of Local Populations in the Regional Context Taxon (Appendix Envelope and Disturbance Footprint (Table 5) A) Conostylis lepidospermoides T (VU) (BC • Suitable habitat present (VU 16) (noted to occur on Local populations are of Low-Moderate Significance Act) sandier sites within VU 16 only in Study Area) • Listed Threatened Taxon (BC Act; EPBC Act) T (EN) • Suitable habitat for this taxon within the Development • Known from 61 records representing approximately 25 EPBC Act Envelope has been surveyed populations, three of which are on DBCA-managed • Known locations in close proximity (within 100m) of tenure the Development Envelope, however not within 50m of • Range extends 240km from from Frank Hann National the Development Envelop Park, to Ravensthorpe, to near Cape Le Grand National • Possible that further locations occur in the Study Area Park north of the Development Envelope • The two populations recorded in the Study Area are • No plants observed within the Development Envelope located within the known range or Disturbance Footprint Lepidosperma sp. Mt P1 • Suitable habitat present (VUs 1, 2), although due to low Local populations are of Moderate Significance Chester (S. Kern et al. LCH numbers of records the habitat preference is • Known from 9 populations across 7 localities, none of 16596) considered unreliable which are on DBCA-managed tenure • Not known to occur in the Development Envelope • Range extends from south-west of Lake King, to north of • Suitable habitat in the Development Envelope was the Fitzgerald National Park to north of Jerdacuttup surveyed (DBCA Naturemap; Barret et al. 2015) • Considered likely that further populations occur in the • The two populations recorded in the Study Area Study Area outside of the Development Envelope represent new populations and are also a range • No plants observed within the Development Envelope extension of approximately 40km to the east of the or Disturbance Footprint known range, however this taxon is poorly collected therefore the extension in the known range is not unusual Leucopogon sp. Cascades P1 • Suitable habitat present (VU 16) Local populations are of High Significance (M. Hislop 3693) • All suitable habitat in the Development Envelope • Known from four locations representing four surveyed populations, none of which are on DBCA-managed • Not known to occur in the Development Envelope tenure; • Likely to be further populations in V 16 in the Study • Range extends from the Study Area to approx. 26km east Area to the north of the Development Envelope of the Study Area • No plants observed within the Development Envelope • The two populations within the Study Area are on the or Disturbance Footprint edge of the known range

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Status Known / Potential Occurrence in the Development Significance of Local Populations in the Regional Context Taxon (Appendix Envelope and Disturbance Footprint (Table 5) A) Commersonia rotundifolia P3 • Known to occur in the Development Envelope Local population is of Low Significance • Suitable habitat present in the Development Envelope • Known from 16 records representing approximately 12 (VU 14), however survey limited as the taxon is most populations, five of which are on DBCA-managed tenure likely a fire-responder and there was a lack of recent (Fitzgerald River NP; Lake Magenta NR; Warperup East burnt areas precluding more intense survey for this NR) taxon • Potentially two populations in the Study Area; the Study • It is likely that more populations would occur in VU 14 Area is located with the known range of this taxon, which in the Study Area however survey post-fire would be extends 310km from Ongerup to north-west of required to confirm this Esperance • One population recorded by Woodman Environmental (2020); the other recorded population (Ecologia 2015) was investigated and no plants were recorded in 2020, however this is attributed to the time since fire. • 30 plants observed within the Development Envelope, no plants observed within Disturbance Footprint Pultenaea calycina subsp. P4 • Known to occur in the Development Envelope Local populations are of Low Significance proxena • Suitable habitat in the Development Envelope (VU 15) • Known from 41 records representing approximately 20 • All suitable habitat in Development Envelope surveyed populations, none of which are on DBCA-managed • Field observations indicate this taxon is not likely to tenure extend further in the Study Area • Has a known range of approximately 75km, with the • 1372 plants observed of which 1321 are within the majority of known populations on the western side of the Development Envelope and 744 plants observed within range (in the vicinity of Ravensthorpe); the Study Area Disturbance Footprint and a population south in the Munglinup River Macro Corridor forming part of the eastern extent of the range, with a further population recorded by Woodman Environmental (2020) a further 15km to the north-east of the Study Area, therefore the Study Area is located within the known range of this taxon. Stachystemon vinosus P4 • Known to occur in the Development Envelope Local populations are of Low Significance • Suitable habitat present in the Development Envelope • Known from 51 records representing approximately 17 (VUs 1, 16) populations, three of which are on DBCA-managed • All suitable habitat in the Development Envelope was tenure surveyed

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Status Known / Potential Occurrence in the Development Significance of Local Populations in the Regional Context Taxon (Appendix Envelope and Disturbance Footprint (Table 5) A) • Likely that there are further locations of this taxon • Range of the taxon is approximately 312km (north of within suitable habitat in the Study Area Ravensthorpe to north of Esperance), the populations in • 296 plants observed, of which 148 are within the the Study Area being located within the known range Development Envelope and 74 plants observed within Disturbance Footprint Leucopogon aff. Potential • Known to occur in the Development Envelope Local populations are of High Significance canaliculatus new taxon • Suitable habitat in the Development Envelope (VUs 1, • Known from another two specimens, all of which are 16) anomalous to Leucopogon canaliculatus and therefore • All suitable habitat in the Development Envelope was potentially represents a new taxon surveyed • Range of the anomalous specimens is 70km, with the • Likely to occur more widely in the Study Area, with Study Area located on the western extent and increasing most survey effort in the Development Envelope the range by 25km • 2009 plants observed, of which 1886 are within the • Relatively large numbers were recorded in the Development Envelope and 175 plants observed within Development Envelope, with the populations noted as Disturbance Footprint extending outside of the Development Envelope and into the Study Area. The numbers of individuals in the Study Area were not fully investigated, so the extent of this taxon in the area is not well known • There is up to 621.1 ha (365.1 ha for VU 1 and 256 ha for VU 16 excluding the area of these VUs within the Development Envelope) of potential suitable habitat within the Combined Study Area for this taxon Synaphea aff. drummondii Potential • Known to occur in the Development Envelope Local populations are of High Significance new taxon • Suitable habitat in the Development Envelope (VU 16) • Synaphea drummndii is accepted as occurring only in the • All suitable habitat in the Development Envelope was Wheatbelt; several collections lodged at the WAHerb surveyed from Cranbrook to the Study Area are referenced as • Appears to be a fire-responder or disturbance Synaphea aff. drummondii or Synaphea ?drummondii. opportunist One of these collections (collected 4km south of the • Likely to occur more widely in the Study Area, with Study Area) is considered analogous and both collections most survey effort in the Development Envelope may represent a new taxon • Further survey would be best timed for post-fire events • Range and extent of the potential new taxon is unknown, if required however they also form the eastern-most collections of material resembling Synaphea drummondiii

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Status Known / Potential Occurrence in the Development Significance of Local Populations in the Regional Context Taxon (Appendix Envelope and Disturbance Footprint (Table 5) A) • 250 plants observed, of which 113 are within the • Further survey required to determine extent through Development Envelope and 13 plants observed within Study Area, however would need to be timed with Disturbance Footprint respect to future fire events • There is up to 256 ha (mapped extent of VU 16 excluding the area of this VU within the Development Envelope) of potential suitable habitat within the Combined Study Area for this taxon Synaphea sp. Jilakin Flat Potential • Known to occur in the Development Envelope Local populations are of Moderate-High Significance Rocks Rd (R. Butcher et. al new taxon • Suitable habitat in the Development Envelope (VU 16) • This is a recently named taxon, with three other locations RB200) • All suitable habitat in the Development Envelope was known (from specimens at the Western Australian surveyed Herbarium (W.A. Herbarium 2020). The extent and • Potentiallly a fire-responder population size of other populations is poorly • Likely to occur more widely in the Study Area, with understood, and all three other known locations are most survey effort placed in the Development Envelope approximately 180km west of the Study AreaOf the three • Further survey would be best timed for post-fire events other known locations, one is located in conservation if required estate (Lake Magenta Nature Reserve); the other two are • 92 plants observed, of which 91 are within the located on road reserves. Development Envelope and no plants observed within • Further survey required to determine extent through Disturbance Footprint Study Area, however would need to be timed with respect to future fire events • There is up to 256 ha (mapped extent of VU 16 excluding the area of this VU within the Development Envelope) of potential suitable habitat within the Combined Study Area for this taxon

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3.2 Vegetation and Conservation Significance Ranking A total of 13 VUs have been mapped in the Development Envelope, and therefore are at risk of impact by the Project. The four VUs which are not mapped in the Development Envelope (VUs 3, 4, 6 and 13) are all located to the east of the Development Envelope. Although extents of VUs 6 and 13 occur in relatively close proximity to the Development Envelope (within 300m) it is not considered likey that they will be impacted by project activities. These four VUs are not considered further in this impact assessment.

An assessment of the local conservation significance of each VU is presented in Table 10. The local conservation significance of the majority of the VUs were ranked ‘1’ or ‘2’, with a ranking of ‘3’ allocated to VUs 7, 11 and 15, and a ranking of ‘5’ allocated to VU 5.

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Table 10: Local Conservation Significance Assessment of Vegetation Units of the Development Envelope

Vegetation Descriptor % of Study Area / Local Area Characteristics Preferred Habitat Local Conservation Unit % of Combined for Significant Flora Significance Ranking Study Area (Table 6) 1 LWEsppMr 26.6 / 25.6 Red-brown, orange-brown or grey-brown clay loam, usually with Lepidosperma sp. 1 ironstone, sandstone or mixed colluvial gravel, on upper to mid Mt Chester (S. Kern slopes of valleys and low hills et al. LCH 16596) Relatively extensive in the Study Area and occurs on landforms (P1) which are not restricted Leucopogon aff. Mapped also in the Extrapolated Study Area canaliculatus Not considered as locally significant (Woodman Environmental Stachystemon 2020). vinosus (P4) 2 LWEsppMspp 11 / 9.2 Red-brown to brown clay loam, usually with ironstone, sandstone Lepidosperma sp. 2 or mixed colluvial gravel, on slopes valleys and low hills Mt Chester (S. Kern Relatively extensive in the Study Area and occurs on landforms et al. LCH 16596) which are not restricted; (P1) Mapped also in Extrapolated Study Area Not considered as locally significant (Woodman Environmental 2020) 5 LMEsppMh 0.4 / 0.4 Dark brown to brown clay loam with dolerite gravel and dolerite Nil 5 outcropping on upper and mid slopes of valleys Relatively rare in the Study Area Not mapped in the Extrapolated Study Area Considered locally significant (Woodman Environmental 2020) 7 LWEdGpHp 1.2 / 1.4 Red-brown or light brown sandy loam with sandstone gravel and Nil 3 sandstone outcropping on breakaways and ridge Not extensive the Study Area and occurs on a landform which is relatively restricted Mapped also in the Extrapolated Study Area Considered locally significant (Woodman Environmental 2020)

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Vegetation Descriptor % of Study Area / Local Area Characteristics Preferred Habitat Local Conservation Unit % of Combined for Significant Flora Significance Ranking Study Area (Table 6) 8 LWEoMhGa 2.6 / 6.6 Orange-brown clay or sandy loam on river flats Nil 2 Although landform is restricted is it not uncommon Mapped more extensively in the Extrapolated Study Area Considered locally significant (Woodman Environmental 2020) 9 LWEoEqLs 1.9 / 1.8 Brown clay loam with quartz gravel on valley slopes Nil 2 Although landform is restricted is it not uncommon Mapped also in the Extrapolated Study Area Considered locally significant (Woodman Environmental 2020) 10 LOWEcMsppG 0.4 / 2.4 Red-brown or brown clay loam with dolerite and occasionally Nil 2 a quartz stones on valley flats and slopes Landform is not considered relatively restricted Mapped more extensively in the Extrapolated Study Area Considered locally significant (Woodman Environmental 2020) 11 TSMuAs 1.6 / 1.3 Brown clayey sand or clay loam with granite and quartz stones and Nil 3 often granite outcropping on low rises and slopes Relatively restricted landform in the local area Not mapped in the Extrapolated Study Area Considered to be locally significant (Woodman Environmental 2020) 12 LWOFEoAc 1.6 / 2.9 Grey-brown to clay or clay loam in narrow drainage line channels Nil 2 Although landform is restricted it is not uncommon Mapped more extensively in the Extrapolated Study Area Considered to be locally significant (Woodman Environmental 2020)

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Vegetation Descriptor % of Study Area / Local Area Characteristics Preferred Habitat Local Conservation Unit % of Combined for Significant Flora Significance Ranking Study Area (Table 6) 14 LFEpMtAg 27.8 / 24.7 Grey, light brown or brown clay, clay loam or sandy clay with Commersonia 1 colluvial stones (frequently sandstone, quartz, irostone and rotundifolia (P3) laterite) on valley slopes and flats and undulating plains Not a restricted landform type, Not mapped in the Extrapolation Study Area Not considered as locally significant (Woodman Environmental 2020) 15 LWEsppMpBi 2.4 / 2.0 Grey or grey-brown clay loam with calcareous stones on low rises Pultenaea calycina 3 on undulating plains subsp. proxena (P4) Restricted soil and landform type Not mapped in the Extrapolation Study Area Considered to be locally significant (Woodman Environmental 2020) 16 LWEpBaMs 13.6 / 14.2 Grey-yellow, yellow-brown or grey-brown sandy or clay loam with Conostylis 1 lateritic gravel on undulating plains lepidopsermoides Relatively extensive in the Study Area and occurs on landforms (T) which are not restricted Leucopogon aff. Mapped also in the Extrapolated Study Area canaliculatus Not considered to be locally significant (Woodman Environmental Leucopogon sp. 2020) Casacades (M. Hislop 3693) (P1) Stachystemon vinosus (P4) Synaphea aff. drummondii Synaphea sp. Jilakin Flat Rocks Rd (R. Butcher et. al RB200)

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Vegetation Descriptor % of Study Area / Local Area Characteristics Preferred Habitat Local Conservation Unit % of Combined for Significant Flora Significance Ranking Study Area (Table 6) 17 TSLiAcCd 5.3 / 5.3 Grey-brown sand, occasionally with laterite gravel, on undulating Nil 2 plains Not uncommon in the Study Area and occurs on landforms which are not restricted Not mapped in the Extrapolated Study Area Not considered to be locally significant (Woodman Environmental 2020)

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3.3 Assessment of Direct Impact 3.3.1 Direct Local and Regional Impact on Significant Flora Taxa Six significant flora taxa are known to occur in the Development Envelope, three of which are Priority flora taxa and three are significant for other reasons. Preferred habitat for another three significant taxa (including Conostylis lepidospermoides (T)) has been mapped in the Development Envelope however no individuals were located during searches. Figure 2 presents the locations of significant flora taxa within the Study Area and Development Envelope.

No locations of Conostylis lepidospermoides (T) are known to occur within 50m of the Development Envelope. The preferred habitat for this taxon (VU 16) contiguous with these locations was surveyed and no other individuals were recorded. Therefore no vegetation within the Development Envelope is considered to represent an Environmentally Sensitive Area (ESA) as declared under Section 51B of the EP Act.

Table 11 presents the scale of potential local impact to significant flora taxa which are known to occur in the Disturbance Footprint, based on assessment of percentages of individuals which are at risk of impact (as presented in Table 5). This assessment uses the total number of individuals of significant flora taxa which have also been recorded immediately outside of the Study Area by Woodman Environmental (2020) and Ecologia (2015), as presented on Figure 2. The scale of local potential impact of the Disturbance Footprint to one of the four significant taxa has been ranked as Moderate.

Table 12 presents the scale of potential local impact to significant flora taxa where preferred habitat occurs within the Disturbance Footprint. This includes all significant flora taxa irrespective if known locations are present in the Disturbance Footprint (for example, Conostylis lepidospermoides (T)).

Table 13 presents the significance of potential impact at the regional scale by the Project on significant flora taxa (as per Table 8). Additional contextural information with regards to the knowledge of the extent of population in the Development Envelope and Study Area, and in the wider region is provided.

As per Tables 12 and 13, there will be no direct impact to Conostylis lepidospermoides (T) at the local or regional scales. Therefore, assessment of the significance of impact under the EPBC Act (DoEE 2013) has not been undertaken.

27 300000 302000 304000 306000

Legend Study Area Development Envelope Extrapolated Study Area Combined Study Area Disturbance Footprint

Sad ! !! !! Sad ! ! Sad !

!! 6276000 Sad 6276000 ! Sad ! ! Sad ! !! Sad Sad !! !! Sad Ssp Lac Svi Sad !! !!!! !!!!!!!!!!! ! Pcap ! ! Sad Lac ! Pcap Ssp Sad ! !! ! Lac Sad !#*!!Lac !! ! ! LspC ! Lac !! ! ! Lac ! Lac !!!!! Svi ! Sad Svi !!!! Cle Lac !!!!!!! Svi !! ! Lac !!!!! Sad Lac LspC LspMC Lac ! Cle ! #* ! !! LspC! ! LspC ! ! !Lac ! Lac Sad Pcap!!!!!!! Sad ! Pcap !!!!! Pcap ! !! !!!! !! !!!!!!! !!!! Pcap ! !! ! !!!!! !! ! ! Pcap !!!!!! !!!!!!!!!! !! Sad ! Sad !!! !!! !!!!!!! ! ! Pcap ! !! !!!!! !!!!!!!!!! !!!!! !!! !!! Pcap Lac Pcap Pcap !! Svi ! !!!! Pcap ! Pcap 6274000 !! !! ! 6274000 Pcap ! Pcap ! !! !!!! ! !!! Svi Pcap !!!!!!!!!!!!!!!!! Pcap Svi !! !!!!!!!!!!!!! !!!!! Svi Pcap !!! Pcap Pcap ! LspMC Pcap ! Pcap Lac Lac !!! ! ! ! ! !!! Pcap !! L?spMS Lac ! ! ! ! Lac !!!!!!!!! Lac !!!!! !!! Lac !!! !!!!!! Lac !!!!!!!!!!! Lac !! !!! !! Lac !!!!!!!! !!!! !!!!!!!!!!!!!! ! Lac Lac !!!!!!!!!!! !! Lac !!!!!!!! Lac ! !!!!!! Lac Svi Lac ! !!!!! Lac ! ! !!!!!!!!!!!! ! Lac Lac !!Lac ! ! Aspo !! ! !! Lac DspR Lac !

Crot Svi #* ! !! Sad ! Svi 6272000 6272000

Svi !

Svi! Sad ! ! ! Svi Sad !! !!!!!! Sad !!!!!!!!!!!! !!!!!!!! Ssp Sad Ssp !! Crot Sad !

Significant Flora (Woodman Environmental 2018-2019) ! Aspo Acacia spongolitica ! Cle Conostylis lepidospermoides (T) 6270000 6270000 ! Crot Commersonia rotundifolia (P3) ! DspR Dampiera sp. Ravensthorpe (G.F. Craig 8277) (P3) ! Lac Leucopogon aff.canaliculatus ! LspC Leucopogon sp. Cascades (M. Hislop 3693) ! LspMC Lepidosperma sp. Mt Chester (S. Kern et al. LCH 16596) (P1) ! L?spMS Lepidosperma ?sp. Mt Short (S. Kern et al. LCH 17510) (P1) ! Pcap Pultenaea calycina subsp. proxena (P4) ! Sad Synaphea aff.drummondii ! Ssp Synaphea sp. Jilakin Flat Rocks Rd (R. Butcher et. al RB200) ! Svi Stachystemon vinosus (P4) Significant Flora (Ecologia 2015) #* Lac Leucopogon aff.canaliculatus #* Crot Commersonia rotundifolia (P3) 6268000 6268000

300000 302000 304000 306000

Author: Cathy Godden Figure Potential Impact to WEC Ref: MRC19-48-03 Significant Flora $ Filename: MRC19-48-03-f02 2

This map should only be used in conjunction with WEC report MRC19-48-03. Revision: 3 - 02 March 2021 Scale: 1:27,500 (A3) Projection: GDA 1994 MGA Zone 51 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Table 11: Scale of Potential Local Impact to Locations and Individuals of Significant Flora Taxa

Significant Flora Taxa Status Study Area Development Envelope Disturbance Footprint Scale of Potential Local Impact # # # % Locations # % Individuals of # Individuals % Individuals Locations Individuals Locations of Study Area Individuals Study Area of Study Area (Numbers of Individuals) Conostylis T 4 67 0 0 0 0 0 0 Nil lepidospermoides Lepidosperma sp. Mt P1 2 35 0 0 0 0 0 0 Nil Chester (S. Kern et al. LCH 16596) Leucopogon sp. P1 5 35 0 0 0 0 0 0 Nil Cascades (M. Hislop 3693) Commersonia P3 2 35 1 50 30 85.7 0 0 Nil rotundifolia Pultenaea calycina P4 190 1406 183 96.3 1321 94.0 577 41.0 Moderate subsp. proxena Stachystemon P4 53 296 49 92.5 148 50.0 70 23.6 Low vinosus Leucopogon aff. Potential 185 2009 172 93.0 1886 93.9 175 8.7 Low canaliculatus new taxon Synaphea aff. Potential 86 250 50 58.1 113 45.2 13 5.2 Low drummondii new taxon Synaphea sp. Jilakin Potential 14 92 12 85.7 91 98.9 0 0 Nil Flat Rocks Rd (R. new Butcher et. al RB200) taxon

Note: those taxa shaded in light green are known to occur in the Disturbance Footprint.

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Table 12: Scale of Potential Local Impact to Preferred Habitat of Significant Flora Taxa Significant Flora Taxa Status Preferred Total Area in Study Area Combined Study Area Scale of Potential Habitat (Vus) Disturbance Local Impact Footprint Area Pecentage Area Percentage (Habitat Area) Impact Impact Conostylis T 16 5.8 226.9 2.6 284.7 2.0 Low lepidospermoides Lepidosperma sp. Mt P1 1, 2 113.3 628.5 18.0 699.6 16.2 Low Chester (S. Kern et al. LCH 16596) Leucopogon sp. Cascades P1 16 5.9 226.9 2.6 284.7 2.1 Low (M. Hislop 3693) Commersonia rotundifolia P3 14 139.6 465.3 30.0 495.4 28.2 Moderate Pultenaea calycina subsp. P4 1, 15 61.9 485.3 12.8 554.6 11.2 Low proxena Stachystemon vinosus P4 1, 16 48.2 672.0 7.2 799.1 6.0 Low Leucopogon aff. Potential 1, 6 42.4 449.7 9.4 519.0 8.2 Low canaliculatus new taxon Synaphea aff. drummondii Potential 16 5.9 226.9 2.6 284.7 2.1 Low new taxon Synaphea sp. Jilakin Flat Potential 16 5.9 226.9 2.6 284.7 2.1 Low Rocks Rd (R. Butcher et. al new taxon RB200)

Note: those taxa shaded in light green are known to occur in the Disturbance Footrpint (Table 11).

30 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Table 13: Assessment of Regional Significance of Impact to Significant Flora Taxa Significant Flora Status Significance Scale of Scale of Scale of Significance of Comments Taxa of Local Potential Potential Potential Potential Populations Local Impact Local Regional Regional (Table 9) (Numbers of Impact Impact Impact (Table Individuals; (Habitat (Table 5) 5) Table 11) Area;Table 12) Conostylis T Low- Nil Low Nil Nil All preferred habitat for C. lepidospermoides (T) in the lepidospermoides Moderate Development Envelope was searched for this taxon and no locations were recorded. Known locations are 91m, 123m, 512m and 961m north of the Development Envelope (Figure 2). Areas of VU 16 (habitat) adjacent and within the Development Envelope were surveyed and no other individuals were recorded. Impacts of the Development Envelope to this taxon will be Nil. There will be no regional impact to this taxon. Lepidosperma sp. P1 Moderate Nil Low Nil Nil Preferred habitat for L. sp. Mt Chester (S. Kern et al. LCH Mt Chester (S. 16596) (P1) in the Development Envelope was surveyed and Kern et al. LCH no individuals were recorded. 16596) Preferred habitat (VUs 1 and 2) are common within both the Study Area and the Development Envelope and it was noted that this taxon is possibly more extensive in the unsurveyed portions of the Study Area (Woodman Environmental 2020). Impacts of the Development Envelope to this taxon will be Nil. There will be no regional impact to this taxon. Leucopogon sp. P1 High Nil Low Nil Nil All preferred habitat for L. sp. Cascades (M. Hislop 3693) (P1) Cascades (M. in the Development Envelope was searched for this taxon Hislop 3693) and no locations were recorded. Three locations were recorded in close proximity to the northern extent of the Development Envelope (38m, 56m; 71m; 123m) (Figure 2). No other individuals were recorded during the survey of the preferred habitat in this area.

31 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Significant Flora Status Significance Scale of Scale of Scale of Significance of Comments Taxa of Local Potential Potential Potential Potential Populations Local Impact Local Regional Regional (Table 9) (Numbers of Impact Impact Impact (Table Individuals; (Habitat (Table 5) 5) Table 11) Area;Table 12) Impacts of the Development Envelope to this taxon will be Nil. There will be no regional impact to this taxon. Commersonia P3 Low Nil Moderate Nil Low The relative scarcity of known locations within the Study Area rotundifolia as a whole is representative of the limited area of appropriate time since fire as the taxon is a fire responder. The one known population in the Development Envelope (Ecologia 2015) was not re-located in 2019, most likely due to senescence since the last burn (Woodman Environmental 2020). The other known population in the Study Area is not at risk of impact (Figure 2). The regional significance of impact is ranked Low due to a combination of the Low significance of the local populations of this taxon and the moderate scale of potential local impact to preferred habitat for this taxon. Pultenaea calycina P4 Low Moderate Low Low Low All three of the populations recorded in the Study Area will subsp. proxena be impacted to some extent; the largest population is entirely located within the Development Envelope, whilst two of the smaller populations extend outside of the Development Envelope. The scale of local potential impact is Low - Moderate due to the proportion of both numbers of known individuals and habitat occurring within the Disturbance Footprint (41.0% of individuals; 11.2% of the preferred habitat of the Study Area). The regional significance of impact is ranked Low, due to the relatively large number of known populations and the location of the Study Area being within the known range of this taxon.

32 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Significant Flora Status Significance Scale of Scale of Scale of Significance of Comments Taxa of Local Potential Potential Potential Potential Populations Local Impact Local Regional Regional (Table 9) (Numbers of Impact Impact Impact (Table Individuals; (Habitat (Table 5) 5) Table 11) Area;Table 12) Stachystemon P4 Low Low Low Low Low Two of the five populations of this taxon in the Study Area vinosus are located entirely within the Development Envelope; the other three are not at risk of impact by the Development Envelope or the Disturbance Footprint (Figure 2). The two populations in the Development Envelope are located in the service corridors associated with the Disturbance Footprint, and these populations may extend further into the Study Area. The scale of potential Local impact is ranked Low, with the regional significance of potential impact also ranked as Low due to the relative Low significance of the local populations to the overall conservation status of the taxon. Leucopogon aff. Potential High Low Low Moderate Moderate Four of the six populations known in the Study Area are at canaliculatus new risk of impact by the Disturbance Footprint. The scale of taxon impact at the local level has been reduced to Low by modifications to the Disturbance Footprint, avoiding the majority of the known plants of the largest population (Figure 2). The regional significance of potential impact is ranked Moderate; although the significance of the local populations to the conservation status of a potential new taxon (using the precautionary principle) is ranked High, there is low scale of impact at the local scale (17.4% of known individuals in the Study Area), and the local Moderate scale of potential impact to the preferred habitat of this taxon. Synaphea aff. Potential High Low Low High Moderate Six populations of S. aff. drummondii were recorded in the drummondii new Study Area, mainly in the northern and western extents taxon (Figure 2).

33 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Significant Flora Status Significance Scale of Scale of Scale of Significance of Comments Taxa of Local Potential Potential Potential Potential Populations Local Impact Local Regional Regional (Table 9) (Numbers of Impact Impact Impact (Table Individuals; (Habitat (Table 5) 5) Table 11) Area;Table 12) Not all populations were fully censused in the Study Area, and not all suitable habitat in the Study Area was surveyed (or able to be surveyed, due to length of time since fire). Four of the known populations are at risk of impact by the Disturbance Footprint. The majority of locations at risk of impact are located within service corridor routes, with the populations at all these areas extending outside of the Disturbance Footprint into the wider Study Area. The regional significance of potential impact has been ranked Moderate. Although the local populations are of High significance (with only one other analogous population known, the extent of which is data deficient), the local scale of impact to the local population, which is the largest knonw, is Moderate to Low (attributed to numbers of individuals and habitat respectively). This taxon grouping is generally data deficient and requires further study. Synaphea sp. Potential Moderate- Nil Low Moderate Moderate- Neither of the two populations of Synaphea Synaphea sp. Jilakin Flat Rocks new High High Jilakin Flat Rocks Rd (R. Butcher et. al RB200). in the Study Rd (R. Butcher et. taxon Area are located in the Disturbance Footprint; these al RB200) populations are located on a Service Corridor area and it is likely that the populations extend further into bushland either side of the Disturbance Footprint.. There has been a lack of survey for this taxon within the greater Study Area and therefore this is considered an over- estimate of the actual impact. There is also three other populations of this taxon known, one of which occurs in conservation estate.

34 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Significant Flora Status Significance Scale of Scale of Scale of Significance of Comments Taxa of Local Potential Potential Potential Potential Populations Local Impact Local Regional Regional (Table 9) (Numbers of Impact Impact Impact (Table Individuals; (Habitat (Table 5) 5) Table 11) Area;Table 12) The regional Moderate-High significance of potential impact acknowledges the lower scale of impact to preferred habitat of this taxon.

Note: those taxa shaded in light green are known to occur in the Disturbance Footprint (Table 11).

35 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

3.3.2 Direct Local Impact and Significance of Local Impact on Vegetation Units Thirteen VUs have been mapped within the Development Envelope. Figures 3.1 and 3.2 presents the Study Area, Combined Study Area and Development Envelope with respect to mapped VUs.

Table 14 presents the scale of potential local impact of the Disturbance Footprint on VUs, with regards to both the mapped extent in the Study Area and the inferred extent in the Combined Study Area. Please note the total area to be cleared will not exceed 350ha; any extra clearing areas above the 320ha calculated will be located in VUs which are not significant..

The potential scale of impact to VUs in the Study Area are ranked:

• Nil impact to four VUs (VUs 3, 4, 6 and 13); • Low Impact to seven VUs (VUs 1, 5, 8, 11, 12, 16, 17); • Moderate Impact to four VUs (VUs 9, 10, 14, 15); and • High Impact to two VUs (VUs 2, 7)

The potential scale of impact to VUs in the Combined Study Area are ranked:

• Nil impact to four VUs (VUs 3, 4, 6 and 13); • Low Impact to eight VUs (VUs 1, 5, 8, 10, 11, 12, 16, 17); • Moderate Impact to four VUs (VUs 2, 9, 14, 15); and • High Impact to oneVU (VU 7).

36 300000 302000 304000 306000 6278000 6278000

10

10

8 16 10 10

10 16 7 10 7 6276000 10 6276000 14 14 16

10 16 8

1 1 1 1 17 16 2 16 C 7 7 5 14 12 16 17 1 7 17 16 14 5 2 16 16 16 7 14 12 1 1 17 8 16 1 14 14 14 1 2 17 12 16 16 14 15 16 1 5 2 7 7 14 14 1 6274000 5 6274000 14 5 5 9 5 15 1 9 14 9 7 2 14 15 2 12 1 2 5 6 15 15 8 9 10 15 1 16 14 1 5 1 6 10 9 14 2 8 15 1 14 14 16 12 15 2 1 4 11 2 2 7

16 1 14 14 8 8 1 2 14

2 6272000 13 6272000 14 11 2 4 8 1 2 8 2 11 1 11 2

16 14 1 1 14 C 2 3 8 2 1 14

8

1 6270000 6270000

1

8 8

8 6268000 6268000 300000 302000 304000 306000

Author: Cathy Godden Figure Potential Impact to Vegetation Units WEC Ref: MRC19-48-03 $ Filename: MRC19-48-03-f03-1 3.1

This map should only be used in conjunction with WEC report MRC19-48-03. Revision: 3 - 02 March 2021 Scale: 1:27,500 (A3) Projection: GDA 1994 MGA Zone 51 Legend Study Area Extrapolated Study Area Combined Study Area Development Envelope Disturbance Footprint Vegetation Mapping 1 Low mallee woodland to open woodland of mixed species including Eucalyptus leptocalyx subsp. leptocalyx, Eucalyptus flocktoniae subsp. flocktoniae, Eucalyptus uncinata, Eucalyptus suggrandis subsp. suggrandis and Eucalyptus phaenophylla subsp. interjacens over tall to mid shrubland of mixed species usually dominated by Melaleuca rigidifolia and occasionally Melaleuca subfalcata, Melaleuca calycina and Melaleuca lateriflora over low open to sparse shrubland of mixed species including Grevillea oligantha, Daviesia articulata, Daviesia lancifolia, Hibbertia pungens and Grevillea pectinata over low sparse sedgeland of mixed species dominated by Gahnia ancistrophylla, Gahnia aristata and Tetraria sp. Mt Madden (C.D. Turley 40 BP/897) on red-brown, orange-brown or grey-brown clay loam, usually with ironstone, sandstone or mixed colluvial gravel, on upper to mid slopes of valleys and low hills. 2 Low mallee woodland to open woodland of mixed species including Eucalyptus flocktoniae subsp. flocktoniae, Eucalyptus leptocalyx subsp. leptocalyx, Eucalyptus suggrandis subsp. suggrandis, Eucalyptus conglobata subsp. conglobata and Eucalyptus phaenophylla subsp. interjacens over tall to mid shrubland to open shrubland of mixed species dominated by Melaleuca hamata, Melaleuca sapientes, Melaleuca lateriflora, Daviesia aphylla and Melaleuca undulata over low open to sparse shrubland of mixed species including Acacia ingrata, Grevillea pectinata, Aotus sp. Southern Wheatbelt (C.A. Gardner & W.E. Blackall 1412), Hibbertia psilocarpa and Chorizema nervosum over low open sedgeland of mixed species dominated by Gahnia ancistrophylla, Tetraria sp. Mt Madden (C.D. Turley 40 BP/897), Gahnia aristata and Lepidosperma gahnioides on red-brown to brown clay loam, usually with ironstone, sandstone or mixed colluvial gravel, on slopes valleys and low hills. 3 Low mallee woodland dominated by Eucalyptus densa subsp. densa over tall shrubland dominated by Melaleuca pentagona var. pentagona and Banksia media over low sparse shrubland dominated by Hibbertia pungens on skeletal light brown clay loam with sandstone stones over sandstone outcropping on breakaways and ridges. 4 Low mallee woodland of Eucalyptus densa subsp. densa over tall sparse shrubland dominated by Acacia harveyi and Hakea laurina over mid shrubland dominated by Gastrolobium parviflorum and Melaleuca thapsina over low shrubland dominated by Dampiera sp. Ravensthorpe (G.F. Craig 8277) (P3) on skeletal brown sandy loam with sandstone stones over sandstone outcropping on breakaways and ridges. 5 Low isolated mallees of mixed species including Eucalyptus conglobata subsp. conglobata and Eucalyptus phaenophylla subsp. interjacens over tall shrubland dominated by Melaleuca hamata, Calothamnus quadrifidus subsp. quadrifidus, Melaleuca elliptica and occasionally Allocasuarina campestris over mid to low open shrubland of mixed species dominated by Astus tetragonus, Leucopogon cuneifolius, Philotheca gardneri subsp. gardneri and occasionally Hybanthus floribundus subsp. adpressus and Grevillea anethifolia over low open sedgeland of mixed species dominated by Tetraria sp. Mt Madden (C.D. Turley 40 BP/897), Lepidosperma sanguinolentum, Lepidosperma sp. Ravensthorpe (G.F. Craig 5188), Lepidosperma sp. Jerdacuttup (R.L. Barrett RLB 2770) and Gahnia aristata on dark brown to brown clay loam with dolerite gravel and dolerite outcropping on upper and mid slopes of valleys. 6 Low open mallee woodland of mixed species dominated by Eucalyptus ecostata and Eucalyptus pleurocarpa over tall to mid shrubland of mixed species dominated by Calothamnus villosus, Melaleuca hamata, Kunzea affinis, Acacia sulcata var. platyphylla and Melaleuca rigidifolia over low sparse shrubland of mixed species dominated by Darwinia sp. Lake Cobham (K. Newbey 3262), Leucopogon sp. Newdegate (M. Hislop 3585), Hemigenia teretiuscula, Philotheca gardneri subsp. gardneri and Calytrix leschenaultii over low open sedgeland of mixed species dominated by Lepidosperma sanguinolentum, Lepidosperma ?sp. Mt Short (S. Kern et al. LCH 17510) (P1), Lepidosperma rigidulum and Lepidosperma sp. Jerdacuttup (R.L. Barrett RLB 2770) on brown sandy loam with sandstone gravel and stones and occasional sandstone outcropping on breakaways and ridges. 7 Low mallee woodland to open forest dominated by Eucalyptus densa subsp. densa and occasionally Eucalyptus flocktoniae subsp. flocktoniae and Eucalyptus phaenophylla subsp. interjacens over tall to mid open shrubland of mixed species dominated by Gastrolobium parviflorum, Calothamnus quadrifidus subsp. quadrifidus, Hakea lissocarpha and occasionally Melaleuca hamata over low sparse shrubland of mixed species including Hibbertia pungens, Hibbertia gracilipes and Lasiopetalum rosmarinifolium over low sedgeland and forbland of mixed species including Tetraria sp. Mt Madden (C.D. Turley 40 BP/897), Lepidosperma sp. Ravensthorpe (G.F. Craig 5188), Lepidosperma sp. Bandalup Scabrid (N. Evelegh 10798), Lepidosperma sp. Jerdacuttup (R.L. Barrett RLB 2770) and Stylidium albomontis on red-brown or light brown sandy loam with laterite or sandstone gravel and laterite or sandstone outcropping on breakaways and ridges. 8 Low woodland of Eucalyptus occidentalis over tall open to sparse shrubland dominated by Melaleuca hamata and Acacia cyclops over mid open to sparse shrubland of mixed species including Hakea lissocarpha, Melaleuca glaberrima and Hakea nitida over low sparse shrubland of mixed species including Lasiopetalum rosmarinifolium, Hibbertia gracilipes, Dodonaea caespitosa and Thomasia angustifolia over low open to sparse sedgeland and rushland of mixed species dominated by Gahnia ancistrophylla, Lepidosperma sp. Bandalup Scabrid (N. Evelegh 10798), Lepidobolus preissianus, Lomandra micrantha subsp. teretifolia and Lepidosperma sanguinolentum over low sparse forbland and grassland of mixed species including Neurachne alopecuroidea, Chamaescilla corymbosa var. corymbosa, Goodenia affinis, Oxalis exilis and Lagenophora huegelii on orange- brown clay loam or sandy loam on river flats. 9 Low woodland of Eucalyptus occidentalis over low open mallee woodland of Eucalyptus quadrans over tall to mid open to sparse shrubland of mixed species including Acacia glaucoptera, Hakea lissocarpha, Acacia cyclops, Melaleuca acuminata subsp. acuminata and Acacia verriculum over low sparse shrubland of mixed species including Thomasia foliosa, Dodonaea caespitosa and Phyllanthus calycinus over low open to sparse sedgeland of mixed species dominated by Lepidosperma sp. Ravensthorpe (G.F. Craig 5188), Tetraria sp. Mt Madden (C.D. Turley 40 BP/897) and Lomandra effusa over low sparse forbland of mixed species including Lysimachia arvensis, Chamaescilla corymbosa var. corymbosa, Goodenia affinis, Oxalis exilis and Plantago hispida on brown clay loam with quartz gravel on valley slopes. 10 Low open mallee woodland dominated by Eucalyptus conglobata subsp. conglobata and occasionally Eucalyptus phaenophylla subsp. interjacens over tall to mid shrubland to open shrubland of mixed species dominated by Melaleuca hamata and Melaleuca lateriflora, and occasionally Melaleuca glaberrima, Santalum acuminatum and Acacia cyclops, over low sparse shrubland of mixed species including Lasiopetalum rosmarinifolium, Dodonaea caespitosa and Hakea lissocarpha over low open to sparse sedgeland, forbland and rushland of mixed species dominated by Gahnia ancistrophylla, Tetraria sp. Mt Madden (C.D. Turley 40 BP/897), Lepidosperma sp. Carracarrup Creek (S. Kern, R. Jasper, D. Brassington LCH 16738), Lepidobolus preissianus and Opercularia vaginata on red-brown or brown clay loam with dolerite and occasionally quartz stones on valley flats and slopes. 11 Tall to mid open to sparse shrubland dominated by Melaleuca uncinata over mid to low shrubland to open shrubland of mixed species dominated by Acacia sulcata var. platyphylla, Melaleuca elliptica and Astus tetragonus over low sparse shrubland of mixed species including Leptospermum oligandrum and Styphelia sp. Cascades (R. Davis 11037) on brown clayey sand or clay loam with granite and quartz stones and often granite outcropping on low rises and slopes. 12 Low woodland to open forest dominated by Eucalyptus occidentalis and Melaleuca cuticularis over tall open shrubland of mixed species dominated by Acacia cyclops, Acacia saligna subsp. lindleyi ms and Labichea lanceolata subsp. brevifolia over low open to sparse sedgeland of mixed species including Chorizandra enodis, Gahnia trifida and Juncus pallidus over occasional low sparse chenopod shrubland dominated by Salicornia quinqueflora subsp. quinqueflora, Suaeda australis and Disphyma crassifolium subsp. clavellatum over low sparse forbland of mixed species including Cotula australis and *Cotula coronopifolia on grey-brown to clay or clay loam in narrow drainage line channels. 13 Low woodland dominated by Eucalyptus occidentalis over tall to mid shrubland to closed shrubland of mixed species dominated by Labichea lanceolata subsp. brevifolia, Acacia cyclops, Acacia sulcata var. platyphylla and Grevillea anethifolia over low sparse shrubland of mixed species including Thomasia angustifolia and Thomasia foliosa over low sparse sedgeland dominated by Lepidosperma fimbriatum and Lepidosperma sp. Bandalup Scabrid (N. Evelegh 10798) over low sparse forbland of mixed species including Dichondra repens, Cotula australis and Oxalis exilis on yellow-brown to light brown sand or sandy clay in broad drainage lines and adjacent flats. 14 Low open mallee forest dominated by Eucalyptus platypus subsp. platypus and occasionally Eucalyptus dielsii and Eucalyptus extensa over tall sparse shrubland of mixed species dominated by Melaleuca torquata, Melaleuca cucullata, Melaleuca acuminata subsp. acuminata, Acacia cyclops and Exocarpos sparteus over low sparse shrubland of mixed species dominated by Acacia glaucoptera and Exocarpos aphyllus over low sparse grassland dominated by Rytidosperma setaceum on grey, light brown or brown clay, clay loam or sandy clay with colluvial stones (frequently sandstone, quartz, ironstone and laterite) on valley slopes and flats and undulating plains. 15 Low mallee woodland dominated by Eucalyptus flocktoniae subsp. flocktoniae, Eucalyptus conglobata subsp. conglobata and Eucalyptus indurata over tall to mid shrubland dominated by Melaleuca pauperiflora subsp. pauperiflora and occasionally Choretrum glomeratum, Dodonaea stenozyga and Pultenaea calycina subsp. proxena (P4) over low shrubland dominated by Boronia inornata subsp. inornata on grey or grey-brown clay loam with calcareous stones on low rises on undulating plains. 16 Low mallee woodland dominated by Eucalyptus pleurocarpa and occasionally Eucalyptus uncinata over mid to low shrubland of mixed species dominated by Banksia armata var. ignicida, Banksia alliacea, Banksia obovata, Beaufortia micrantha and Leucopogon sp. Newdegate (M. Hislop 3585) over low open to sparse sedgeland of mixed species dominated by Mesomelaena stygia subsp. stygia, Lepidosperma sp. Clathrate (R.L. Barrett & G.F. Craig RLB 3570), Caustis dioica, Lepidosperma carphoides and Lepidobolus chaetocephalus on grey-yellow, yellow-brown or grey-brown sandy or clay loam with lateritic gravel on undulating plains. 17 Tall open to sparse shrubland dominated by Lambertia inermis var. inermis and occasionally Nuytsia floribunda over mid shrubland to open shrubland of mixed species dominated by Adenanthos cuneatus, Allocasuarina humilis, Banksia baueri, Taxandria spathulata and Chamelaucium megalopetalum over low shrubland of mixed species including Conothamnus aureus, Petrophile teretifolia, Eutaxia inuncta, Jacksonia viscosa and Hibbertia gracilipes over low sedgeland and rushland of mixed species dominated by Caustis dioica, Chordifex sphacelatus, Hypolaena fastigiata, Lepidobolus chaetocephalus and Lyginia imberbis on grey-brown sand, occasionally with laterite gravel, on undulating plains. C Cleared land (roads and permanent tracks)

Author: Cathy Godden Figure Potential Impact to Vegetation Units WEC Ref: MRC19-48-03 $ Filename: MRC19-48-03-f03-2 3.2

This map should only be used in conjunction with WEC report MRC19-48-03. Revision: 3 - 02 March 2021 Scale: 1:27,500 (A3) Projection: GDA 1994 MGA Zone 51 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Table 14: Local Direct Impact on Vegetation Units Vegetation Descriptor Development Disturbance Study Area Combined Study Area Unit Envelope Footprint Area (ha) % within % within Scale of Local Area (ha) % within % of Scale of Local (ha) (ha) Development Disturbance Impact (Table Development Disturbance Impact (Table 7) Envelope Footprint 7) Envelope Footprint

1 LWEsppMr 149.3 42.4 445.1 33.5 9.5 Low 514.4 29.0 8.2 Low

2 LWEsppMspp 112.1 71.2 183.4 61.1 38.7 High 185.2 60.5 38.4 Moderate

3 LWEdMpHp 0 0 1.9 0.0 0 Nil 1.9 0.0 0.0 Nil

4 LWEdAhGp 0 0 7.2 0.0 0 Nil 7.2 0.0 0.0 Nil

5 LMEsppMh 3.6 1.7 7.5 48.0 22.7 Low 7.5 48.0 22.7 Low

6 LOWEeCvDs 0 0 4.6 0.0 0 Nil 4.6 0.0 0.0 Nil

7 LWEdGpHp 19.4 17.5 19.9 97.5 87.8 High 27.7 70.0 63.2 High

8 LWEoMhGa 30.3 0.3 42.76 70.9 0.7 High 133.2 22.7 0.2 Moderate

9 LWEoEqLs 31.3 10.0 32 97.8 31.4 High 35.7 87.7 28 High

10 LOWEcMsppGa 6.4 2.7 7.1 90.1 37.3 High 48.7 13.1 5.5 Low

11 TSMuAs 14.1 5.7 26.4 53.4 21.4 High 26.4 53.4 21.6 Low

12 LWOFEoAc 3.2 0.2 26.9 11.9 0.8 Low 58.7 5.5 0.3 Low

39 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Vegetation Descriptor Development Disturbance Study Area Combined Study Area Unit Envelope Footprint Area (ha) % within % within Scale of Local Area (ha) % within % of Scale of Local (ha) (ha) Development Disturbance Impact (Table Development Disturbance Impact (Table 7) Envelope Footprint 7) Envelope Footprint

13 LWEoLlLf 0 0 41.6 0.0 0 Nil 41.6 0.0 0 Nil

14 LFEpMtAg 205.5 139.6 465.3 44.2 30.0 Moderate 495.4 41.5 28.2 Moderate

15 LWEsppMpBi 36.3 19.5 40.2 90.3 48.6 Moderate 40.2 90.3 48.5 Moderate

16 LWEpBaMs 28.7 5.9 226.9 12.6 2.5 Low 284.7 10.1 2.1 Low

17 TSLiAcCd 4.3 0.7 89.3 4.8 0.8 Low 89.3 4.8 0.8 Low

Cleared 4.5 2.6 4.8 93.8 61.3 - 6.6 - 44.6 - TOTAL 649.0 320.0 1672.86 38.8 19.1 - 2009.0 32.4 -

VUs shaded yellow have Moderate or High local impact with reference to the Combined Study Area

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Table 15 presents the local significance of impact to the 13 VUs in the Development EnvelopeDisturbance Footprint. The local significance of impact is based on the matrix presented in Table 8. The outcome is based on the Local Conservation Significance (the detailed results of this are presented in Table 10) which is a function of the area mapped and the landform/soil type upon which the VU occurs (the method for this is presented in Table 6), with the scale of local impact (the detailed results of this are presented in Table 14) which is based on the percentage of the VU to be impacted.

The significance of potential local impact to each VUs is ranked: • Low for eleven VUs (VUs 1, 2, 5, 8, 9, 10, 11, 12, 14, 16, 17); and • Moderate or Moderate-High for two VUs (VUs 7, 15). Table 15: Significance of Local Impact on Vegetation Units based on the proposed Disturbance Footprint Vegetation Descriptor Local Scale of Local Scale of Local Significance Unit Conservation Impact Impact Ranking of Local Significance (Study (Combined Study Impact (Table 8) (Table 10) Area) Area) (Table 14) (Table 14)

1 LWEsppMr 1 Low Low Low

2 LWEsppMspp 1 Moderate Moderate Low

5 LMEsppMh 5 Low Low Low

7 LWEdGpHp 3 High High Moderate-High

8 LWEoMhGa 2 Low Low Low

9 LWEoEqLs 2 Moderate Moderate Low

10 LOWEcMsppGa 2 Moderate Low Low

11 TSMuAs 3 Low Low Low

12 LWOFEoAc 2 Low Low Low

14 LFEpMtAg 1 Moderate Moderate Low

15 LWEsppMpBi 3 Moderate Moderate Moderate

16 LWEpBaMs 1 Low Low Low

17 TSLiAcCd 2 Low Low Low

Note: VUs shaded yellow have Moderate or High significance of local impact

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3.3.3 Regional Impact on Vegetation All of the vegetation system associations of the Study Area are present within the Development Envelope. The percentage of the pre-european extent of these vegetation system associations (VSAs) within the Recherche IBRA subregion with the implementation of the Project are presented in Table 16. The implementation of the Project will not result in these VSAs going below 30% of their pre-european extent threshold (EPA 2008) (excluding Esperance_47 which is already at below 30%). Table 16: Vegetation System Associations of the Development Envelope and predicted change to occurence Vegetation System Pre- Current Current Development Disturbance Percentage Association European Extent (ha)* Percentage Envelope Footprint Remaining Extent Remaining * (ha) (ha) after (ha)* Disturbance Footprint has been removed Esperance_47 408122.8 60660.6 14.86 174.7 37.1 14.9

Esperance_516 84604.6 26861.1 31.75 474.2 282.9 31.4

Esperance_931 6037.3 2426.3 40.19 0.3 - 40.18

*Note: data from Government of Western Australia (2019) Although there is no published regional vegetation dataset which covers the South Coast region of Western Australia, the DBCA undertook statistical analysis of vegetation datasets collected at the Ravensthorpe Range, which is located approximately 70 km west of the Study Area (Markey et al. 2012). An analysis of a combination of the datasets from that study and that collected in the Study Area was undertaken and presented by Woodman Environmental (2020). It was concluded that there was a general strong dissimilarity between the VUs mapped and described in the Study Area in comparison to those of Markey et al. (2012). This result was expected, given the distance between the Study Area and the Ravensthorpe Range, and the rapid species turnover known to occur across the Esperance Plains IBRA region, and in particular the Ravensthorpe Range (Markey et al. 2012).

However, there was some similarity between VU 15 (the Study Area) and Community 11 as described by Markey et al. (2012), with evidence to suggest that at a local scale the two communities are not analogous, however on a regional scale they are analogous (Woodman Environmental 2020). These two communities may form the same regional vegetation type, which is supported by the similarity in soil type, both being located on areas of magnesite. A key difference between the communities was a number of short-range endemic taxa at the Ravensthorpe Range that did not occur in VU 15 mapped in the Study Area.

In addition, VUs 8 and 9 of the Study Area (Eucalyptus occidentalis woodlands) also present a similar case to that described above; the limited sampling of these VUs to date indicates that they are distinct within the Study Area, however, should be considered as localised forms of a single regional vegetation type.

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Of the 13 VUs which are present in the Development Envelope, seven were identified as potentially occurring on lands managed either by the DBCA or other government departments (including local shires) in the region (Woodman Environmental 2020). The reconnaissance assessment undertaken was designed to identify areas suitable for further investigation only and as such no quadrat data or mapping of extent of these areas is available. Table 17 presents a qualitative assessment of the potential for significant regional impact on VUs within the Study Area based on available data. There is a low potential of significant regional impact on the majority of VUs; the potential increases to Low-Moderate for VU 7 and Moderate-High for VUs 5 and 15.

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Table 17: Potential for Significant Impact to Regional Extent of Vegetation Units Vegetation Descriptor Local Scale of Significance Details of Known Extent (Woodman Environmental Potential for Significant Unit Conservation Local Impact Ranking of 2020) impact to Regional Extent Significance (Combined Local Impact (Table 10) Study Area) (Table 15) (Table 14) 1 LWEsppMr 1 Low Low Relatively widespread VU in Study Area; mapped in Low Extrapolated Study Area; not characterised by restricted landform type; not targeted for further regional survey 2 LWEsppMspp 2 Moderate Low Relatively widespread VU in Study Area; mapped in Low Extrapolated Study Area; not characterised by restricted landform type; noted to potentially occur at four regional locations, some potentially extensive, noted as being likey to be representative of VU 2 in a local and regional context 5 LMEsppMh 5 Low Low Restricted in the Study Area; not mapped in the Low Extrapolated Study Area; characterised by a restricted landform type; not noted to potentially occur on further investigated regional areas

7 LWEdGpHp 3 High Moderate- Relatively restricted in the Study Area; mapped in the Low to Moderate High Extrapolated Study Area; characterised by a restricted landform type; one suitable area for further investigation noted during the reconnaissance survey with vegetation noted as likely being representative of VU 7 in a local and regional context 8 LWEoMhGa 2 Low Low Relatively restricted in the Study Area; more Low commonly mapped in the Extrapolated Study Area; not on a restricted landform type; not noted to potentially occur on further investigated regional areas

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Vegetation Descriptor Local Scale of Significance Details of Known Extent (Woodman Environmental Potential for Significant Unit Conservation Local Impact Ranking of 2020) impact to Regional Extent Significance (Combined Local Impact (Table 10) Study Area) (Table 15) (Table 14) 9 LWEoEqLs 2 Moderate Low Relatively restricted in the Study Area; mapped in the Low Extrapolated Study Area; not on a restricted landform type; one suitable area (possibly extensive) for further investigation noted during the reconnaissance survey with vegetation noted as possibly being representative in a local context and likely being representative of VU 9 in a regional context 10 LOWEcMsppGa 2 Low Low Restricted in the Study Area; mapped in the Low Extrapolated Study Area; characterised by a relatively restricted landform type (dolerite influence); one suitable area (possibly extensive) for further investigation noted during the reconnaissance survey with vegetation noted as likely being representative of VU 10 in a local and regional context 11 TSMuAs 3 Low Low Restricted in the Study Area; not mapped in the Low Extrapolated Study Area; not characterised by a restricted landform type (granite); noted to potentially occur on six regional locations (extensive), likey to be representative of VU 11 at a local and regional context 12 LWOFEoAc 2 Low Low Relatively restricted in the Study Area; mapped in the Low Extrapolated Study Area; not considered to be characterised by restricted landform type (narrow drainage channels); not targeted for further regional survey and regional extent unknown 14 LFEpMtAg 1 Moderate Low Relatively widespread VU in the Study Area; mapped Low in Extrapolated Study Area; not characterised by restricted landform type; not targeted for further regional survey

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Vegetation Descriptor Local Scale of Significance Details of Known Extent (Woodman Environmental Potential for Significant Unit Conservation Local Impact Ranking of 2020) impact to Regional Extent Significance (Combined Local Impact (Table 10) Study Area) (Table 15) (Table 14) 15 LWEsppMpBi 3 Moderate Moderate Restricted in the Study Area; not mapped in the Moderate Extrapolated Study Area; characterised by a restricted landform type (calcareous rises); noted to potentially occur in one area (not extensive) and in that area the vegetation is only likely to be representative in a regional rather than a local context 16 LWEpBaMs 1 Low Low Relatively widespread VU in the Study Area; mapped Low in the Extrapolated Study Area; not characterised by restricted landform type; not targeted for further regional survey 17 TSLiAcCd 2 Low Low Relatively widespread VU in the Study Area; not Low mapped in the Extrapolated Study Area; not characterised by restricted landform type; not targeted for further regional survey VUs shaded yellow the potential for Moderateor higher significant regional impact

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3.3.4 Cumulative Impacts The Study Area is located in a highly cleared and fragmented landscape due to wide scale clearing in the region, primarily for agriculture. As such, VUs which have been assessed as having the potential for moderate or highersignificance of local direct impact (Table 15) have been further assessed for cumulative impacts. These cumulative impacts are based on the combined impact of historical human activities in the region together with the proposed Project impacts. It is based on a qualitative assessment as it is not possible to quantify impacts to these VTs with the level of existing data avaiable.

VU 7 has been mapped over a total of 27.7 ha over the Combined Study Area of which 70 % occurs within the Development Envelope and 63.1% (17.5 ha) of the known mapped extent of VU 7 directly due to clearing is considered to have a low to moderate potential for significant impact impact when considering the regional context / historical cumulative impacts of the Project on this VU.

VU 15 has been mapped over a total of 40.2 ha over the Combined Study Area of which 90.3 % occurs within the Development Envelope and 48.6% of the proposed Disturbance Footprint. The landform/soil type where VU occurs (grey or grey-brown clay loam with calcareous stones on low rises on undulating plains) is a restricted soil and landform type and is considered to be locally uncommon and restricted. This VU was not mapped in the Extrapolated Study Area, however one location of this VU was identified regionally during the reconnaissance assessment. This regional occurrence is not considered to represent this VU in a local context, although it may possibly represent VU 15 in regional context. The occurrence occurs as part of a mosaic of vegetation types and the extent of the occurrence appears limited. It is therefore possible that this VU either does not occur outside of the Study Area or potentially occurs in limited extents only (in the absence of additional survey). Removal of 48.6 % (19.5 ha) of the mapped extent of VU 15 directly due to clearing is considered to have a moderate potential for significant impact when considering the regional context / historical cumulative impacts of the Project on this VU.

3.3.5 Impacts on the Kwongkan TEC The Kwongkan TEC is represented by VUs 16 and 17 within the Study Area. As per Woodman Environmental (2020), patch sizes and condition thresholds (as per DoEE 2014) were considered when defining the occurrence of the TEC in the Study Area, including considering vegetation outside the Study Area and also other factors. All areas of VU 16 and VU 17 in both the Study Area and Combined Study Area met the condition thresholds as outlined by DoEE (2014). Figure 4 presents the extent of the Kwongkan TEC within the Combined Study Area in relation to the Development Envelope.

The extent of the Kwongkan TEC in the Development Envelope is primarily within the service corridors extending to the north-east and north-west of the main body of the Development Envelope; it is confined entirely to these service corridors in terms of the extent of the Disturbance Footprint. Table 18 presents the extent of the Kwongkan TEC in the Study Area, Combined Study Area, Development Envelope and Disturbance Footprint A total of 6.5 ha of

47 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo the Kwongkan TEC (2.1% of the mapped extent in the Study Area, and 1.7% of the mapped extent in the Combined Study Area), is at risk of impact within the Disturbance Footprint.

There will be a maximum potential impact to the Kwongkan TEC of 10 ha due to direct clearing activities, of which 3.5 ha is currently not allocated in the Disturbance Footprint. Any clearing of the Kwongkan TEC will be confined to the Development Envelope. This impact is equivalent to 3.2% of the mapped extent in the Study Area, and 2.7% of the mapped extent in the Combined Study Area. Table 18: Local and Regional Extent of the Kwongkan TEC

Area Total Area (ha) Kwongkan TEC extent (ha)

Disturbance Footprint 320 6.5 (max 10)

Development Envelope 649 33

Study Area 1672.7 316.2

Combined Study Area 2009 374

Kwongkan TEC Regional Extent 1 185 188 1 185 188

Note that the ‘Regional Extent’ of the Kwongkan TEC is extracted from an assessment provided by DoEE (2014), which was based on best available mapping covering the regional extent of the geographic range of the TEC (Hopkins et al. 2001). The presumed mapped extent of the TEC incorporated likely occurrences of the TEC using units identified as having ‘high’ and ‘medium’ susceptibility to Phytophthora cinnamomi, which was based on their high proportion of Proteaceous species (Massenbauer pers. comm., (2013) in DoEE (2014)). It is noted by DoEE (2014) that both the Pre‐European and current calculated extents of the TEC community should be considered indicative of the extent of clearing, and that ground truthing is necessary to further define the extent of this TEC.

Approximately 52% of the regional range of the Kwongkan TEC occurs in conservation estate, including some large and significant reserves within its range (e.g. Stirling Range National Park (NP), Fitzgerald River NP, Cape le Grand NP and Cape Arid NP). The distribution both outside of reserves and between-reserves is severely fragmented due to historical clearing for agriculture, resulting in these reserves being largely fragmented from one another; fragmentation of the remnants on other lands; and many patches of the TEC being relatively small (<10ha) (DoEE 2014).

An assessment of the potential impacts against the significant impact criteria (for endangered ecological communities listed under the EPBC Act) in relation to the Kwongkan TEC by the Project (DoEE 2013) is provided in Table 19.

48 300000 302000 304000 306000 6278000 6278000 6276000 6276000 6274000 6274000 6272000 6272000 6270000 6270000

Legend StudyArea Extra polatedStudy Area Com binStudy ed Area Developm entEnvelope Pro teaceaeDo m in a tedKwo n gkan Shrublanthe dsSoutheastof Co a staFloristic l Pro vinWesternof ce Austra TEC lia (Endan gered–EPBC Act) DisturbanFoo ce tprin t 6268000 6268000 300000 302000 304000 306000

Potential Impact to Author:Cathy Go dden Figure 'Proteaceae Dominated Kwonkgan WECMRC19-48-03 Ref: Shrublands of the Southeast Coastal Floristic $ Province of Western Australia' TEC Filena mMRC19-48-03-f04 e: 4

Thisma should p on usedbe ly incon jun ctio nwith WEC report MRC19-48-03. RevisioMa02 - 3 rch2021 n : (A3) 1:27,500 Scale: Pro jectioGDA n : 1994MGA Zon 51 e MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

Table19: Assessment of Potential Impacts Against the Significant Impact Criteria for the Kwongkan TEC by the Project (DoEE 2013)

Significant Impact Criteria Expected Project Impact Description Likelihood of Significant Impact An action is likely to have a significant impact on a critically endangered or endangered ecological community if there is a real chance or possibility that it will: Reduce the extent of an There will be direct impact to the Kwongkan TEC within the Yes ecological community Development Envelope (max 10 ha), within the two service corridor areas (Figure 4). The design of the Disturbance Footprint has been modified to reduce the extent of potential impact to this TEC. The project is expected to reduce the extent of the Kwongkan TEC. Fragment or increase Clearing for the Project within the Kwongkan TEC will No fragmentation of an ecological predominantly involve road construction. The clearing in the community, for example by north-west service corridor (see Figure 4) will occur on the clearing vegetation for roads or boundary with cleared paddock, and therefore not transmission lines exacerbate fragmentation in this area. There will be minor fragmentation of mapped polygons of this TEC in the north- eastern service corridor, and in the north-western corridor. Adversely affect habitat critical A maximum of 10 ha of the Kwongkan TEC, and therefore No to the survival of an ecological habitat for this TEC, has the potential to be cleared. To be managed community However, clearing of this portion of the TEC will not by an approved adversely affect the survival of the TEC, due to the small Environmental extent of proposed clearing and the location of the Management Disturbance Footprint within the TEC’s range. The Plan Disturbance Footprint (and Study Area) are located in the centre of the range of this TEC and therefore the vegetation does not comprise an important outlier of the TEC; it is not located in conservation estate within the range of the TEC; and clearing will impact 0.003% of the estimated range of this TEC (Table 18). Unauthorised clearing, or introduction of pathogens such as Phytophthora cinnamomi will be managed through an Environmental Management Plan. Modify or destroy abiotic (non- Abiotic factors associated with the Kwongkan TEC at the No living) factors (such as water, local level will be modified by Project design (road nutrients, or soil) necessary for construction). However, these modifications will not an ecological community’s adversely affect the TECs survival. The vegetation associated survival, including reduction of with the TEC is not reliant upon groundwater (Woodman groundwater levels, or Environmental 2020), and alterations to surface water substantial alteration of surface hydrology is not expected to adversely affect the TEC water drainage patterns outside of the Development Envelope. Cause a substantial change in There will be no substantial change in the species No the species composition of an composition of the TEC in areas outside of the Development To be managed occurrence of an ecological Envelope. All aspects of project activities will be managed in by an approved community, including causing a accordance with an Environmental Management Plan, Environmental decline or loss of functionally which will ensure that factors which could temporarily or Management important species, for example permanently alter the species composition in adjacent Plan through regular burning or flora Kwongkan TEC patches (e.g. change in natural burning or fauna harvesting regime; unauthorised clearing; introduction and spread of Phytophthora cinnamomi) will not occur.

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Significant Impact Criteria Expected Project Impact Description Likelihood of Significant Impact Cause a substantial reduction in There is a risk of impact by Project activities which may No the quality or integrity of an adversely affect the Kwongkan TEC outside of the To be managed occurrence of an ecological Disturbance Footprint, including introduction of invasive by an approved community, including, but not species (weed taxa), Phytophthora cinnamomi (Dieback), Environmental limited to potential impacts of dust, pollutants such as hydrocarbons, Management overspray or spillage of hyper-saline water (used in dust- Plan -- assisting invasive species, that supression, etc.), and less likely impacts through sediment are harmful to the listed run-off from WRLs and spillage from the TSF. These aspects ecological community, to will be managed by the application of an approved become established, or Construction and Operations Environmental Management -- causing regular mobilisation Plan, and it is therefore considered that there will be no of fertilisers, herbicides or substantial reduction in the quality or integrity of the TEC other chemicals or pollutants outside of the Development Envelope. into the ecological community which kill or inhibit the growth of species in the ecological communit Interfere with the recovery of The condition of the vegetation associated with the No an ecological community Kwongkan TEC within the Combined Study Area is predominantly in Pristine condition, with some areas (11.7ha; 3.9% of the mapped extent) mapped in Good condition. It is not considered that any of the extent of the TEC in the Study Area is being managed for recovery.

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3.4 Qualitative Assessment of Indirect Impacts – Flora and Vegetation 3.4.1 Impacts to Groundwater Dependent Vegetation/Species No phreatophytic flora taxa or GDV have been identified as occurring naturally within the Study Area (Woodman Environmental 2020). Although groundwater sources are present within 10m of the topographical surface, the water is too saline for use by vegetation. Assessment of impacts to groundwater dependent flora or vegetation is not discussed further. 3.4.2 Impacts from Surface Water Hydrology Changes Munglinup River and several tributaries of the Munglinup River flow across or close to planned mine infrastructure. There are also two other minor ephemeral drainage lines (Clayhold Creek and a minor tributary to Clayhole Creek) which may be impacted within the Disturbance Footprint. Both of these are located on the service corridors and therefore it is expected that surface water flow in these areas can be adequately managed.

The south-western edge of the Disturbance Footprint is located adjacent to the course of the Munglinup River. There is the potential for surface water drainage shadow impacts downstream through reduction in available surface water entering the Munglinup River during and after periods of rainfall. This scenario was investigated by Rockwater (2020), who stated that the most significant change in hydrological processes related to the proposed mining infrastructure is the removal of catchment areas contributing to downstream receptors (in this case, the Munglinup River which feeds into the Oldfield River).

Of the six catchment areas which contribute to the Munglinup River in proximity to the project (Table 8 and Figure 5 of Rockwater 2020), Rockwater (2020) identified one in particular (M3) where the catchment area will be reduced by the project design. The M3 catchment is comprised of seven subcatchments (four of which are associated with minor tributaries to the Munglinup River (Figure 6 of Rockwater 2020)), all of which will be impacted to some level. It is expected that 31% of the M3 catchment area will be impacted by the project design, which is likely to reduce the flow into the Munglinup River. However, Rockwater (2020) also noted that the impacted sub-catchments comprise 3.6% of the total Munglinup River catchment area, and 1.4% of the total catchment area of the Munglinup River to the junction with the Oldfield River; therefore this loss of surface catchment area is unlikely to have a significant impact on downstream Munglinup River flows.

There is the potential of impact to the vegetation downslope of the areas of impact towards the Munglinup River in each of these sub-catchments due to loss of surface water and subsequent creation of drainage shadows. The vegetation at risk of impact includes both terrestrial vegetation that is reliant on sub-surface soil-water flow, and riparian vegetation that is at least partially reliant on water sources provided by the creeklines and drainage areas. The loss of area of each sub-catchment due to project activities is presented in Table 20 (as calculated and presented by Rockwater 2020; total 31% of the M3 catchment area proposed to be impacted). Three of the four minor creelines who’s sub-catchments will be impacted (Creeks A, C and D) will be impacted by project components such as pits and waste rock dumps.

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Table 20: Tributary Catchment Characteristics, during and post-mining (sourced from Table 13 of Rockwater 2020) Catchment Area (km2) Length (km) Reduction in catchment area (in comparison to pre-mining) (%) M3 (A) 0.4 1.5 -22% M3 (B) 0.5 1.2 -33 M3 (C ) 0.6 1.7 -37 M3 (D) 0.4 0.7 -65 M3 (E ) 0.4 0.6 -8 M3 (F) 0.1 0.2 -45 M3 (G) 0.3 0.8 -58 M3 Total 4.5 3.3 -31

As the vegetation of the Study Area is reliant upon surface water inputs, the vegetation downslope of the Disturbance Footprint, between the Disturbance Footprint and the Munglinup River is potentially at risk of impact through reduced availability of of this water source. The extent of potential impact in terms of inducing dought stress to vegtation as a result of a reduction catchment area (Table 20) is unknown, monitoring of vegetation health is recommend. 3.4.3 Impacts from Increased Fragmentation The impacts of fragmentation, habitat loss and degradation, in combination with the introduction of invasive species and pathogens are recognised issues which may impact flora and vegetation factors (EPA 2016b). The Disturbance Footprint currently does not appear to significantly isolate populations of significant flora from other local populations and therefore this issue is not relevant for this factor. Impacts of fragmentation to the vegetation may be significant at the local level if the Project increases the occurrence of weed invasion, or introduction of significant pathogens (e.g. Phytophthora cinnamomi) into this highly fragmented landscape (these impacts are discussed further in section 3.4.4). These impacts can be managed through the implementation of a project environmental management plan.

The Munglinup River Macro Corridor can be considered a significant corridor as much of the vegetation of the region has been cleared, leaving remnant vegetation occurring on river corridors being the remaining examples of vegetation extending from near the coastline to the interior regions. The Munglinup River Corridor is approximately 47km in length, however does not connect directly to the Cheadanup Nature Reserve and the extensive UCL located to the north of the reserve. The Development Envelope occurs on a large portion of the vegetation in this area of the Corridor, however (excluding the clearing associated with roads) will not result in a cut-off across the corridor, with vegetation remaining in a north-south unbroken band on the western side of the Munglinup River. Notwithstanding this, planning of suitable rehabilitation and revegetation works post-mining will be necessary to ensure that additional fragmentation of the Munglinup River Macro Corridor does not impact the long-term viability of the vegetation of the corridor, in terms of decreasing genetic diversity or increasing edge effects. 3.4.4 Impacts from Dieback Disease and Introduced Weeds The condition of the majority of the vegetation in the Study Area was rated Pristine. There was little evidence of unnatural disturbance, with weeds generally absent or at very low levels

53 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo across the Study Area (with the exception of several mapped areas as discussed in Woodman Environmental 2020), and no evidence of Phytophthora cinnamomi (Dieback) impact. If not managed properly, the project activities could result in the introduction and spread of weeds and Dieback in a largely Pristine area of vegetation.

There is limited information on the susceptibility of the significant taxa recorded in the Study Area to Phytophthora Dieback. However, many species within the genera Conostylis, Leucopogon and Synaphea are known to be affected by Dieback (Dieback Working Group 2008) and therefore it is likely that Dieback could impact the following significant taxa known from the Study Area: • Conostylis lepidospermoides (T) • Leucopogon sp. Cascades (M. Hislop 3693) (P1) • Leucopogon aff. canaliculatus (Potential new taxon) • Synaphea aff. drummondii (Potential new taxon) • Synaphea sp. Jilakin Flat Rocks Rd (R. Butcher et. al RB200) (Potential new taxon)

It is unclear if the remaining significant taxa (including Lepidosperma sp. Mt Chester (S. Kern et al. LCH 16596) (P1), Commersonia rotundifolia (P3), Pultenaea calycina subsp. proxena (P4) and Stachystemon vinosus (P4)) are susceptible to Phytophthora Dieback. However, these taxa could be impacted indirectly if the surrounding habitat was infected with Phytophthora Dieback and the general condition of the vegetation was reduced.

The Kwongkan TEC has been identified as having ‘high’ and ‘medium’ susceptibility to Phytophthora cinnamomi based on the high proportion of Proteaceous species known from the TEC (Massenbauer pers. comm., (2013) in DoEE (2014)) (as discussed previously). If Phytopthora Dieback is introduced or otherwise spread to the Study Area, it is likely it would have a significant impact on the Kwongan TEC Likewise, given the high proportion of Proteaceous species recorded in the Study Area, it is likely that the introduction of Dieback would have a significant impact on the vegetation of the Study Area in general.

The introduction of invasive weeds coud also have a significant impact on the vegetation of the Study Area including the Kwongkan TEC given the fact that the vegetation is largely in Pristine condition. Significant flora taxa could also potentially be indirectly impacted by the introduction of weeds through degradation of habitat and competition.

Impacts associated with Dieback and introduced weeds should be addressed by the implementation of an approved weed and hygiene management plan. The plan should consider the potential for Dieback / weed introduction and edge effects on a long term basis.

3.4.5 Impacts from Dust There is potential for dust generated during construction and operation to be deposited on flora and vegetation in close proximity to the project areas. Dust can impact photosynthesis or other physiological processes of plants, including by blocking stomata which can impact the health of vegetation. Dust has been identified as a potential impact on plant and vegetation health at several mine sites in Western Australia, with a number of studies undertaken to investigate the impact of dust on native vegetation in the Pilbara and southwest of WA (Butler

54 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

2009; Matsuki et al. 2013). While some temporary impacts have been recorded in terms of reduced photosynthesis, no long-term effects such as increased plant deaths have been established. Impacts from dust could have an impact on significant flora and Kwongkan TEC within the Development Envelope.

Dust suppression using saline water (if undertaken) may result in run-off of saline water into vegetation, or overspray of water directly into vegetation, resulting in a decline in plant and vegetation health.

It is recommended that monitoring is undertaken identify any potential impacts to the vegetation within potential impact areas.

55 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo 4. CONCLUSIONS 4.1 Flora Of the 12 significant flora taxa which are known to occur in the Study Area, six have locations within the Development Envelope, and a further three taxa have preferred habitat mapped within the Development Envelope. In summary:

There will be no impact to Conostylis lepidospermoides (T), Lepidosperma sp. Mt Chester (S. Kern et al. LCH 16596 (P1) or Leucopogon sp. Cascades (M. Hislop 3693 (P1). No known individuals are located within the Development Envelope, and although there is habitat for each taxon in the Development Envelope survey of this habitat did not locate any individuals. Likewise, there will be no significant regional impact to these taxa.

There will be Moderate scale of local impact to individuals and/or habitat of Pultenaea calycina subsp. proxena (P4), and Low impact to Stachystemon vinosus (P4) and Synaphea aff. drummondii within the Disturbance Footprint. Pultenaea calycina subsp. proxena (P3) was mainly recorded in the body of the Development Envelope, and therefore the likelihood of further altering project design to reduce the local impact on this taxon is low. In contrast, Stachystemon vinosus (P4) was recorded in the service corridor sections of the Development, and project design may be able to reduce the local impact to this taxon. The significance of the regional impact to these two taxa was ranked Low, due to the relatively low significance of the local populations to their overall regional conservation status.

Both the significance of the impact at the regional scales will be greater for the potential new taxa Leucopogon aff. canaliculatus, Synaphea aff. drummondii and the recently described taxon Synaphea sp. Jilakin Flat Rocks Rd (R. Butcher et. al RB200). It is likely that there are further individuals of all three taxa in the Study Area outside of the Development Envelope and further searching is recommended to locate additional occurrences and populations. The scale of potential local impact to Leucopogon aff. canaliculatus has been reduced due to changes in the project design, which in turn reduces the potential for significant regional impact on the taxon. Synaphea aff. drummondii is located located in the service corridors of the Disturbance Footprint and modifications to the project design could not avoid this taxon. Synaphea sp. Jilakin Flat Rocks Rd (R. Butcher et. al RB200) was previously located in the service corridors of the Disturbance Footprint, however, further project design reviews were undertaken to reduce the potential impact to this taxon. Although the regional significance of the local populations of these two taxa are considered High, the significance of potential regional impact to these taxa is considered Moderate to Moderate-High due to either the reduced local impact on these taxa, or level of impact to the number of regional populations known. 4.2 Vegetation Of the 17 VUs mapped in the Study Area, 13 occur within the Development Envelope. Of these 13 VUs, the local conservation significance of the majority were ranked ‘Low’ (rankings 1 or 2), with higher local significance ranking of ‘3’ given to VUs 7, 11 and 15, and ‘5’ (highest ranking) to VU 5.

The scale of potential impact to VUs in the Combined Study Area were ranked:

56 MRC Graphite Pty Ltd Munglinup Graphite Project Flora and Vegetation Impact Assessment Memo

• Nil impact to four VUs (VUs 3, 4, 6 and 13); • Low Impact to eightVUs (VUs 1, 5, 8, 10, 11, 12, 16, 17); • Moderate Impact to four VUs (VUs 2, 9, 14 and 15); and • High Impact to one VU (VU 7). The significance of the potential local impact was ranked Moderate for VU 15 and Moderate- High for VU 7. . This was due to a combination of higher levels of potential local impact combined with higher significance rankings applied to these VUs, as a result of limited distribution mapped in the Combined Study Area and relative rarity of the landforms upon which they occur. To reduce this impact it is recommended that additional field work be undertaken to identify these communities outside the current study area (using methods as per EPA 2016a); reduce as far as practicable the impact to these communities during project design; and consideration be given to incorporating these communities into the Project rehabilitation plans.

On a regional scale, the potential significance for regional impacts to VU 7 is considered to be Low-Moderate and Moderate for VU 15, being a combination of higher local significance, higher scale of impact and limited to no known regional extents. Further efforts should be made to locate appropriate regional representations of VU 7 and 15 outside the current survey areas, as well as to assess and map the extents of regional extents of VUs 7 and 15 as identified by Woodman Environmental (2020). Consideration should be given to establishing an offset that looks to re-establishing these communities within suitable soil types in areas that can be protected in the future.

The Kwongkan TEC has mapped occurrence within the Development Envelope (33 ha; VUs 16 and 17) and therefore is at risk of impact. The potential impact to this TEC by the project (10 ha total) is equivalent to 2.7% of the mapped extent of the TEC occurrence in the Combined Study Area, and represents 0.0028 ha of the presumed regional extent of this TEC. This potential impact is consistent with the significant impact criterion ‘Reduce the Extent of an Ecological Community’, as per the significant assessment guidelines presented by DoEE (2013).

It is unlikely that further indirect impacts will occur on either flora or vegetation, however impacts through issues such as dust, use of hyper-saline water for dust suppression/other uses, introduction of pathogens such as Phytophthora and weed taxa, and surface water hydrology factors will need to be managed and taken into consideration during construction and operations.

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