Great Artesian Bain Springs Research Plan

Carmichael Coal Mine Project

Great Artesian Basin Springs Research Plan

Version 6c, 10 September 2019

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Document Control & Version Control

Document Title: Great Artesian Basin Springs Research Plan

Document No: CCMP-000000-PLN-HY-000100

Document Type: Plan

First Issue Date: 26 July 2018

Rev Issue Date Description of Revisions Made Author Code

1 26/6/18 Submission to the Adani Commonwealth Government Jacobs

2 6/12/18 Updates based on feedback from Adani the Commonwealth Government CDM Smith

3 22/3/19 Updates based on feedback from Adani the Commonwealth Government CDM Smith

4 27/6/19 Updates based on feedback from Adani the Commonwealth Government CDM Smith

5 7/8/19 Updates based on feedback from Adani the Commonwealth Government

6 22/8/19 Updates based on feedback from Adani the Commonwealth Government

6a 28/8/19 Minor correction Adani

6b 6/9/19 Minor correction Adani

6c 10/9/19 Minor correction Adani

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Contents

1 Introduction ...... 7 1.1 Project Description ...... 7 1.2 EBPC Act Approval 2010/5736, Condition 25 ...... 9 1.3 Document structure ...... 10 1.4 Objectives and scope ...... 10 1.5 Relationship with other research and management plans / adaptive management ...... 14 1.5.1 Relevant GAB Springs research programs and studies ...... 17 2 Baseline understanding...... 18 2.1 GAB Springs ...... 18 2.1.1 GAB spring wetlands ...... 18 2.1.2 GAB springs nomenclature ...... 18 2.1.3 GAB springs structure ...... 19 2.1.4 GAB springs wetland size ...... 21 2.1.5 GAB springs wetlands ecology ...... 21 2.1.6 OGIA 2016 Summary report on Surat CMA springs research and knowledge ...... 22 2.2 Hydrogeology ...... 23 2.2.1 Spring source aquifer ...... 26 2.3 Doongmabulla Springs Complex ...... 29 2.3.1 Overview ...... 29 2.3.2 Moses springs-group ...... 29 2.3.3 Little Moses springs-group ...... 30 2.3.4 Joshua spring-group ...... 31 2.3.5 Ecology ...... 31 2.3.6 Disturbance ...... 36 2.4 Fensham et.al. (2016) Overview of the Doongmabulla Spring Complex ...... 42 2.5 Hydrology ...... 44 2.6 Summary of baseline monitoring findings ...... 46 2.7 Predicted impacts ...... 47 2.7.1 Model development ...... 47 2.7.2 Peer review ...... 48 2.7.3 Predicted hydrological changes at Doongmabulla Springs Complex ...... 48

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2.7.4 Potential ecological impacts ...... 49 2.7.5 Specific project impacts ...... 50 3 Research program framework ...... 55 3.1 Framework ...... 55 3.2 Study and data requirements ...... 57 3.2.1 Q1. Predicted hydrological changes ...... 57 3.2.2 Q2. Ecological implications of any changes to wetland hydrology ...... 58 3.2.3 Q3. Development of methods for prevention and mitigation of ecological impacts to the GAB springs community...... 59 3.2.4 Q4. Development of methods for remediation and offset of ecological impacts to the GAB springs community ...... 59 3.3 Links to other research and management plans ...... 60 4 Program implementation ...... 62 4.1 Program governance ...... 62 4.2 Scope and objectives of research packages ...... 63 4.2.1 Overview ...... 63 4.2.2 RP1.1: Hydrogeology review and monitoring ...... 63 4.2.3 RP1.2: Geochemical survey ...... 65 4.2.4 RP1.3: Geological mapping ...... 66 4.2.5 RP1.4: Spring wetland hydro(geo)logical conceptualisation and water balance ...... 67 4.2.6 RP1.5: Rewan Formation connectivity investigations ...... 68 4.2.7 RP1.6: Regional hydrogeological conceptualisation review and updated groundwater modelling ...... 68 4.2.8 RP2.1: Ecological surveys and monitoring ...... 69 4.2.9 RP2.2: Hydro-ecological conceptualisation and assessment of key species ...... 70 4.2.10 RP3.1: Desktop prevention and mitigation scoping study ...... 71 4.2.11 RP3.2: Pilot testing of prevention and mitigation methods ...... 72 4.2.12 RP3.3: Prevention and mitigation strategy ...... 73 4.2.13 RP4.1: Desktop offset scoping study ...... 73 4.2.14 RP4.2: Targeted ecological surveys ...... 74 4.2.15 RP4.3: Targeted hydro-ecological studies ...... 74 4.2.16 RP4.4: Remediation assessment and trial ...... 75 4.2.17 RP4.5: Remediation and offset strategy ...... 75 4.3 Research proposal assessment criteria ...... 76

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4.4 Implementation schedule ...... 76 4.5 Priority actions for potential offsets to protect and manage the GAB Springs ...... 78 4.5.1 Offsets ...... 78 4.5.2 Ecological offsets ...... 78 4.5.3 Groundwater offsets ...... 79 5 Review, resourcing and reporting ...... 81 5.1 Independent review of this plan ...... 81 5.2 Personnel responsible for conducting research and qualifications ...... 81 5.3 Reporting and data provision ...... 83 References ...... 85 Appendix 1 - Compliance matrix ...... 90 Appendix 2 - Table of changes made in response to the peer review...... 94

List of tables

Table 1-1 Description of other management plans and linkages ...... 15

Table 2-1 Modelling predictions for aquifer springhead pressure reductions in springs-groups associated with the Doongmabulla Springs Complex – Operational Phase (GHD 2015) ...... 51

Table 2-2 Modelling predictions for aquifer springhead pressure reductions in springs-groups associated with the Doongmabulla Springs Complex – post-closure phase (GHD 2015) ...... 51

Table 3-1 GAB Springs Research Program framework ...... 56

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Abbreviations

Abbreviation Description Environment Protection and Biodiversity Conservation Act 1999 EPBC Act (Commonwealth) Approval granted by the Commonwealth under the EPBC Act, numbered EPBC Act 2010/5736 for the Carmichael Coal Mine and Rail Infrastructure Project, Approval Queensland GDE Groundwater dependent ecosystem GDEMP Groundwater Dependent Ecosystem Management Plan GMMP Groundwater Monitoring and Management Plan The Minister responsible for administering the Environment Protection and Minister Biodiversity Conservation Act 1999 (Commonwealth), or a delegate MNES Matters of National Environmental Significance, as defined under the EPBC Act NC Act Nature Conservation Act 1992 (Queensland) The Carmichael Coal Mine and Rail Infrastructure Project, as defined under Project EPBC Act approval number 2010/5736 Proponent Adani Mining Pty Ltd

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1 Introduction

1.1 Project Description

Adani Mining Pty Ltd (Adani) proposes to develop a 60 million tonne (product) per annum (Mtpa) thermal coal mine in the northern Galilee Basin, approximately 160 kilometres (km) north-west of Clermont (Figure 1-1). The Carmichael Coal Mine and Rail Project (the Project) has several components, being:

 The Carmichael Coal Mine over Mining Leases 70441, 70505 and 70506 and supporting off mine lease infrastructure  Rail line connecting the coal mine to port – the Carmichael Rail Network that includes the North Galilee Basin Rail (NGBR) Project  Abbot Point Coal Terminal for the exportation of coal The mine will cover a total area of approximately 41,500 ha, with an additional 1,850 ha required for offsite infrastructure. The operational mine life will be approximately 60 years, with a production rate peaking at 60 Mtpa. The open cut mine will have a capacity of 40 Mtpa and will be located along the eastern section of Mining Leases 70441, 70505 and 70506.

A total of 6 open cut pits will be progressively mined with a combined capacity of 40 mtpa coal, and five independent underground longwall mines with a combined capacity of 20 mtpa coal will operate concurrently with the open cut pits to provide coal for blending and ensure continuity of production. All offsite infrastructure which consists of an accommodation village and airport to support the operation of the mine will be located on the Moray Downs Cattle Station (Lot 662 on SP2282172) to the east of the mine. Offsite water supply infrastructure will enable the extraction, storage and delivery of water during the construction and operation phases of the mine.

The Project has been assessed by the State and Commonwealth Governments via the Environmental Impact Statement process (EIS). The Project was declared a 'significant project' under the State Development and Public Works Organisation Act 1971 requiring an EIS. The Project is also a 'controlled action' and requires assessment and approval under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). An EIS was prepared in accordance with the bilateral agreement between the Commonwealth of Australia and the State of Queensland.

The Project received conditional approval from the Queensland Coordinator General on 8 May 2014, and approval from the Commonwealth Minister for the Environment on 15 October 2015.

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Figure 1-1 Carmichael Coal Mine Location Plan

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1.2 EBPC Act Approval 2010/5736, Condition 25

The EPBC Act Approval 2010/5736 for the Project includes conditions requiring the development of a Great Artesian Basin (GAB) Springs Research Plan. Condition 25 states:

“At least three months prior to commencing excavation of the first box cut the approval holder must submit for the approval of the Minister a GAB Springs Research Plan that investigates, identifies and evaluates methods to prevent, mitigate and remediate ecological impacts on the EBPC listed community of native species dependent on natural discharge of groundwater from the Great Artesian Basin (GAB Springs community), including the Doongmabulla Springs Complex, in the Galilee Basin. The GAB Springs Research Plan must include but is not limited to the following:

a) Research aims and rationale with reference to existing scientific research on GAB spring hydrogeology and ecology b) Identify priority actions for potential offsets to protect and manage the GAB springs c) Personnel responsible for conducting research and their qualifications d) Timeframes for research and reporting e) Methods, including but not limited to, conceptualization of the hydrogeology of the springs, geological and geochemical surveys to inform the source aquifer/s for the Doongmabulla Springs Complex, ecological surveys to determine the composition of the GAB springs community, an assessment of transferability of approaches to present and mitigate hydrological impacts on springs in the Surat Basin, determination of water requirements (including ecological response thresholds) for the GAB springs community, and development and evaluation of methods to prevent, remediate ecological impacts f) An analysis of potential mitigation activities, such as but not limited to, re-injection to the groundwater source aquifer to maintain pressure head, flows and ecological habitat at the Doongmabulla Springs Complex g) An explanation of how research outcomes will directly inform the monitoring, management, prevention, mitigation and remediation of impacts on the Doongmabulla Springs Complex h) A peer review of the draft GAB Springs Research Plan, by a suitably qualified independent expert and a table of changes made in response to the peer review i) The GAB Springs Research Plan must be published on the proponent’s website for the life of the project. Research outputs must be submitted to the Minister within ten business days of completion and be made available for the Bioregional Assessment of the Galilee Basin sub- region and the Lake Eyre Basin and any subsequent iterations.”

Appendix 1 describes how condition 25 is met by this plan.

Condition 26 is also relevant to this plan, and states: “The approval holder must not commence excavation of the first box cut until the GAB Springs Research Plan has been approved by the Minister in writing. The approved GAB Springs Research Plan must be implemented.”

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1.3 Document structure

This plan is structured to demonstrate linkages between baseline information, research topics, approval conditions and other plans. The plan is structured in the following way:

 Chapter 1 describes the Project, the EIS process and approval condition on which this plan is based (see also Appendix 1) to outline the objectives and scope of the research plan  Chapter 2 - describes the: o current knowledge from which the research needs to build upon o threats from the Project, as identified through the EIS, to GAB Springs  Chapter 3 provides: o a framework that sets out the key research questions that need to be addressed in order to meet the objectives of the plan o an overview of the research program logic and linkages between existing plans  Chapter 4 details o the governance structure of the research program o the scope and objectives for each component of the research plan o research proposal assessment criteria o an implementation schedule for the research program  Chapter 5 includes: o details of the peer review including issues identified through the review and how they have been addressed (see also Appendix 2) o the requirements of personnel responsible for conducting the research reporting and data sharing arrangements

1.4 Objectives and scope

The requirement for this plan is an outcome of the environmental impact assessment and subsequent approval of the Carmichael Coal Mine and Rail Project and the findings of that assessment which predicted indirect impacts to the Doongmabulla Springs Complex, a GAB Springs community as per the EPBC listed community definition.

Accordingly, this plan has been prepared to meet EPBC Act Approval 2010/5736, condition 25. The specific objective of the condition is to investigate, identify and evaluate methods to prevent, mitigate and remediate ecological impacts on the EBPC listed community of native species dependent on natural discharge of groundwater from the Great Artesian Basin (GAB Springs community), including the Doongmabulla Springs Complex, in the Galilee Basin.

Several definitions are relevant to the scope of this plan:

 The EPBC Act defines the GAB Springs Community as “…the community of native species dependent on natural discharge of the groundwater from the Great Artesian Basin, listed as threatened ecological community under the EPBC Act”.

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 The “Doongmabulla Springs Complex” is defined as “the groundwater-fed springs located approximately 8 kilometres from the western edge of the mining lease boundary and consisting of springs within the spring groups identified on page 108 of the Coordinator- General’s Assessment Report”.  The GAB is defined by Habermehl and Lau (1997) as the Carpentaria, Eromanga and Surat geological basins and the contemporaneous (Triassic age) units towards the top of the Galilee Basin (the Clematis Sandstone and its overlying aquitard unit, the Moolayamber Formation). The deeper Permian age sedimentary units of the Galilee Basin are not part of the GAB.

Having regard to the above definitions and the wording of the approval condition, the scope of this research plan applies to GAB springs which intersect the Galilee Basin (see Figure 1-2). This includes the Doongmabulla Springs Complex (which occurs in an area where the Clematis Sandstone and Moolayamber Formations outcrop and subcrop) and other GAB Springs (which occur further to the west and overlie both the Eromanga and Galilee Basins). Springs that occur in the Galilee Basin but not in GAB (e.g. the Mellaluka Springs Complex) are not covered by the scope of this plan.

The Doongmabulla Springs Complex is the only GAB spring complex within the area of predicted groundwater drawdown extent presented in the SEIS (for reference, see Appendix K6 of the Supplementary EIS Report) and in subsequent groundwater studies undertaken in response to EPBC Act Approval conditions. The other GAB Springs included in the scope of this plan are well outside the area of predicted project influence. The research priorities adopted by this plan will focus on the Doongmabulla Springs Complex because “…methods to prevent, mitigate and remediate ecological impacts…” should necessarily apply to areas of predicted ecological impact. However, because remediation strategies include a consideration of offsets, some aspects of the research plan do apply to these other, more remote GAB Springs.

The research priorities identified in this plan are focused on those related to direct and indirect dewatering and depressurisation threats and impacts associated with the Project. There are other threatening processes associated with the Doongmabulla Springs Complex which are addressed in the Groundwater Dependent Ecosystem Management Plan (GDEMP) (ELA, 2018) and Groundwater Monitoring and Management Plan (GMMP) (AECOM, 2018) accordingly.

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DOONGMABULLA SPRINGS COMPLEX

")ARAMAC

") Figure 1-2 EPBC-listing G")AB springs which intersect Legend the Galilee Basin CAIRNS )" EPBC-listed GAB springs Major watercourse TOWNSVILLE (GAB springs community) 0 10 20 Kilometres )" Surface Elevation MOUNT ISA ° )" Great Artesian Basin High : 802.171 ROCKHAMPTON Scale @ A4 1:1,300,000 Carmichael Coal Mine )" Low : 164.97 Date: 22/03/19 Galilee Basin BRISBANE )" DATA SOURCE QLD Open Source Data, 2018

BRUGGEMANNGD \\brbsvr1\PRO\Project\1000322 - Adani GAB research plan review\7Work\3GIS\GIS\DATA\MXD\FINAL\1000322__r1 EPBC listed springs.mxd 3/22/2019

Great Artesian Bain Springs Research Plan

Figure 1-3 Doongmabulla springs-complex

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1.5 Relationship with other research and management plans / adaptive management

For the purposes of this plan, research is defined as:

A systematic investigation into the GAB springs and their connection to project activities in order to establish facts and reach robust conclusions and about whether the project will likely cause a material impact to GAB springs and how these impacts can be managed, if identified.

This definition of research is essentially the standard definition from a dictionary but written in terms of the approval condition 25. The term is not restricted to what may be construed as the development or application of ‘novel’ or ‘innovative’ methods but is simply a systematic assessment that is designed to meet the objectives, or partial objectives, of condition 25. In this regard, several of the research activities that are recommended may appear similar in nature to an initial project impact assessment task or monitoring obligation; but it is important that they are included because they are part of the overall systematic assessment to address the objectives of condition 25 and, as such, are regarded as a research task. Within the research plan, the areas of overlap with other relevant management and monitoring plans are highlighted. The areas where the research plan will extend these other plans are also highlighted.

In addition to condition 25, the following other EPBC Approval conditions are related to the GAB springs research:

 Groundwater Management and Monitoring Plan  Groundwater Dependent Ecosystems Management Plan  Biodiversity Offset Strategy  Groundwater flow model revisions  Rewan Formation Connectivity Research Plan. The GAB springs research described in this plan aims for consistency with other research, management and monitoring plans. There will be some interaction among the plans during various phases of the Project, with respect to key linkages across research program outcomes, modelling updates and management plan review, update and reporting.

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These are described in detail in Table 1-1 and in Section 3.

Table 1-1 Description of other management plans and linkages

Management Plan Description Link to Link with GAB Springs legislation or Research Plan approval Groundwater Identifies monitoring, EPBC Approval Monitoring results and data Management and management and Conditions 3-4 will be used to support Monitoring Plan mitigation with respect to research conducted under (GMMP) approved impacts to this plan. Research outcomes groundwater resources delivered under this plan will inform groundwater monitoring, management, prevention mitigation and remediation measures, and lead to adaptive management amendments to the GMMP. Groundwater Identifies monitoring, EPBC Approval Monitoring results and data Dependent management and Conditions 5 will be used to support Ecosystem mitigation with respect to and 6 research conducted under Management Plan approved impacts to this plan. Research outcomes (GDEMP) groundwater dependent delivered under this plan will ecosystems directly inform GDE monitoring, management, prevention mitigation and remediation measures, and lead to adaptive management amendments to the GDEMP. Rewan Formation Characterises the Rewan EPBC Approval Informs groundwater triggers, Connectivity Formation within the area Conditions 27- monitoring and management Research Plan impacted by the mine 28 through adaptive processes. (RFCRP) The RFCRP covers elements of the GABSRP that concern an understanding of potential impacts to the GAB Springs. The GDEMP will be amended due to RFCRP research related to connectivity that have a direct bearing on potential impact on springs. Biodiversity Offset Describes required offsets EPBC Approval The BOS outlines offset Strategy (BOS) for unavoidable residual Conditions 8- requirements for MNES impacts to MNES 13 including relevant GDEs

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Management Plan Description Link to Link with GAB Springs legislation or Research Plan approval Offset Area Describes specific EPBC Approval The OAMP includes Management Plans management actions for Conditions 8- management of GDE offset (OAMPs) properties to be used as 13 areas offsets under the BOS GAB Offset Describes required offsets EPBC Approval The GAB Offset Strategy Strategy for indirect impact to Conditions 8- addresses indirect impacts to Great Artesian Basin 13 GAB aquifers (GAB) aquifers

MNES Specific management EPBC Approval Ensure consistent monitoring, management plans plans for MNES listed in Conditions 5-7 mitigation and management (other than GDEs) the EPBC Approval measures for common threats and impacts

Key documents are the GMMP and GDEMP, as they define groundwater and related ecological trigger levels and management and mitigation measures.

The GMMP has been developed to characterise the baseline groundwater conditions (pre-mining) and to provide groundwater monitoring locations for all approved phases of mining operations, consistent with Project approval condition requirements to inform long term monitoring of groundwater resources. The GMMP also includes a groundwater monitoring network to evaluate potential impacts which may result from the Project on local groundwater resources, local landholder bores, aquifers of the Great Artesian Basin (GAB), groundwater dependent ecosystems (GDEs), overlying alluvium and Tertiary sediments groundwater resources, and surface water resources (Carmichael River baseflow, Doongmabulla Springs Complex, and Mellaluka Springs Complex).

The objectives of the GDEMP are as follows:

 Present the assessed and approved impacts and threats to groundwater and ecology for each of the relevant GDEs to the Project  Detail the environmental values that have been monitored during baseline phases of the Project  Identify goals and triggers for each GDE, which will be refined over time as further information becomes available during the pre-impact and impact Project phases  Detail the monitoring program for both pre-impact and impact phases of the project, including how this monitoring will inform relevant mitigation, management and offset measures

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 Describe mitigation and management measures with specific criteria, timing, performance objectives, goals and corrective measures  Achieve compliance with relevant Commonwealth and Queensland approval conditions to report results and corrective actions for each GDE over the full period of mining activities and for a period of five years post mining rehabilitation.

The GDEMP applies to the following groundwater dependent ecosystems:

 Waxy Cabbage Palm (Livistona lanuginosa)  Carmichael River (Carmichael River and its riparian zone between the Doongmabulla springs and the Belyando River)  The Mellaluka Springs Complex  Community of native species dependent on discharge from the Great Artesian Basin (Doongmabulla Springs Complex) including the Salt Pipewort (Eriocaulon carsonii); and the Blue Devil (Eryngium fontanum).

1.5.1 Relevant GAB Springs research programs and studies The research outlined in this plan will build on baseline understanding and is designed to complement other relevant GAB Springs research programs that include:

 The Galilee Basin bioregional assessment (2018) https://www.bioregionalassessments.gov.au/assessments/galilee-subregion  GAB springs research conducted as part of research to inform the assessment of ecohydrological responses to coal seam gas extraction and coal mining (Anderson et al. 2016)  Springs research in the Surat Cumulative Management Area (OGIA 2016)  The Lake Eyre Basin Springs Assessment (Fensham et al. 2016) which is being undertaken as part of the Australian Government Bioregional Assessment Program.

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2 Baseline understanding

2.1 GAB Springs

2.1.1 GAB spring wetlands GAB spring wetlands occur on the northern, western, and southern margins of the Great Artesian Basin in Queensland, New South Wales, and South Australia (Fensham et al. 2010) (Figure 2-1). Discharged water from springs often forms a pool (Ponder 1986), with one or more overflow channels that carry flowing water from the head of the spring to the tail where a marshy wetland may form (Ponder 1986). Flows from individual spring vents can join to form a single wetland (Fensham & Fairfax 2003) and springs with a high rate of water discharge may support creeks that run for hundreds of metres, or less commonly, to several kilometres from the vent (Boyd 1990; Habermehl 1982; Ponder 1995).

The groundwater of the GAB springs wetlands is artesian water that originated from a Great Artesian Basin aquifer (Fensham et al. 2007). This groundwater comes to the surface at natural surface discharge points. These discharge points and their associated wetland areas are variously called springs, artesian springs, mound springs, mud springs, boggomoss springs, spring pools and groundwater seeps (Habermehl 1982; McLaren et al. 1986; Pickard 1992; TSSC 2001; Ziedler & Ponder 1989).

2.1.2 GAB springs nomenclature GAB discharge springs typically have one or more vents where the water discharges at the ground surface (Fensham & Fairfax 2003). Individual groundwater discharge points for GAB springs cluster at a variety of scales (Fensham et al. 2007):

 A spring group represents multiple spring discharge points where no adjacent pair of springs is more than about 1 km apart and all springs are in a similar geomorphic setting (Fensham and Fairfax 2003). A spring-group may extend for several kilometres or comprise a single spring where the nearest is more than 1 km away. Spring groups are often given the place name "Springs".  A spring complex is a group of springs or spring groups where no adjacent pair of springs or spring groups is more than about 6 km apart, and all springs within the spring complex are in a similar geomorphic setting (Fensham and Fairfax 2003). A spring complex may contain both active and inactive springs.  A Supergroup is a major regional cluster of spring complexes with some consistent hydrogeological characteristics and geographic proximity. Thirteen supergroups are now recognized (Fensham et al. 2007), refer Figure 2-1. The listed GAB springs wetland TEC ecological community comprises twelve supergroups, including the Barcaldine Supergroup, which is located in the general vicinity of the Project and includes the Doongmabulla Springs Complex (refer Figure 2-1). The Barcaldine Supergroup extends from the upper reaches of the Thompson River, in a north-south line from north of Aramac to east of Aramac, and then in a southerly direction to east of Barcaldine and Blackall (DoE, 2015). Most springs in the

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Barcaldine Supergroup are small, shallow, and marshy, and lack mounds (Unmack 1995; Fensham et al. 2007a).

2.1.3 GAB springs structure The water discharge rate within any one complex varies from spring to spring, according to spring head level, hydraulic conductivity, sub-surface fracture opening and closing, atmospheric pressure, sedimentation, and seasonal evaporation rates (Boyd 1990; Fensham & Fairfax 2003; Kinhill 1997; Mudd 2000; Read 1997).

Springs may occur at ground level or they may be associated with mounds (New South Wales Scientific Committee 2001; Pickard 1992; Ponder 1986, 1995). The springs range from dry or non- flowing mounds, to mounds with damp patches of soil or water seepages with or without distinct outlets, to mounds with pools at the top or water-filled craters, to non-mounded springs with open water and well-defined outflows, to non-mounded damp seepages (Boyd 1990; Fensham et al. 2007a; Habermehl 1982; Kinhill 1997; Ponder 1995; Unmack 1995).

The mounds associated with some springs may be up to 12 m high, and greater than 100 m in diameter (DoE, 2015). The mounds have shallow to steep slopes, and terraced mounds can occur (Habermehl 1998a, b). The overall morphology of the mounds vary according to groundwater discharge flow, climate variation, local expansion, solution, collapse, subsidence and structural displacement, secondary solution, deposition and cementation, and the interaction of hydrochemistry, discharge, evaporation and carbonate precipitation (Habermehl 1998b, 2002).

Dating of spring deposits only suggests that springs date from recent times (less than 100 years) to more than 700,000 years (Habermehl 2002; Habermehl & Prescott 2002). Fensham and colleagues (2007) note that at the scale of the spring complex, the concentration of endemic organisms provides evidence that some spring wetlands may date back to at least the mid-Tertiary, or 35 million years (based on Perez et al. 2005).

At least 40% of GAB spring complexes are estimated to have become inactive since European settlement, and at least one spring in another 14% of spring complexes has become inactive since European settlement (Fensham et al. 2007).

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Figure 2-1 Location of GAB Spring Supergroups

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2.1.4 GAB springs wetland size

The wetland area of GAB springs is directly proportional to the groundwater discharge rate (see Mudd 2000). The size of the GAB spring wetlands in Queensland varies from 100 cm2 to 3 ha, with most spring wetlands <0.05 ha in area (Fensham & Fairfax 2003). Where present, the diameter of ponds of pooled water may range from about 1 m (e.g. Pickard 1992) to 260 m (e.g. Bourke et al. 2007). The total area of the Barcaldine Supergroup is approximately 16.8 ha (calculated from Fensham et al. 2007). Water depth in spring wetlands is often only 2–3 cm, especially in outflow channels and spring tails, but can be up to 50 cm deep in pools around discharge vents (Fairfax et al. 2007; Fensham et al. 2007b, c; Ponder et al. 1989). Some spring wetlands increase in size after rainfall, and up to a four-fold seasonal variation in wetland surface area is known (e.g. Edgbaston Springs, Barcaldine Supergroup; Fairfax et al. 2007). The amount of surface water present is also affected by vegetation.

2.1.5 GAB springs wetlands ecology

Springs are highly dynamic biological systems on a time-scale of years to decades (Fatchen 2001; Kinhill 1997; Lange & Fatchen 1990). Vegetation varies within springs, in relation to moisture, as well within and between spring complexes and supergroups (DoE, 2015). The vegetation of the springs in the Barcaldine Supergroup is usually comprised of tussock grasses and mat-forming herbs, with sedges in shallower water (Fairfax et al. 2007; Fensham et al. 2007b, c).

The native plant and animal species that comprise the GAB springs community are associated with, and dependent on, the GAB springs and wetland areas for survival (DoE, 2015). This includes species that are endemic to one or more springs or wetlands, and species that occur more widely in the GAB area (TSSC 2001) or beyond it. GAB springs wetlands are known to support at least 13 endemic plant species, including Eragrostis fenshamii, Eriocaulon carsonii, Eryngium fontanum, Fimbristylis blakei, Hydrocotyle dipleura, Myriophyllum artesium and Sporobolus pamelae (Fensham et al. 2007).

At least 65 endemic fauna species are associated with the GAB spring wetland communities, including eight species of fish and 57 species of invertebrates (Fensham et al. 2007, Appendix 2). Fensham and colleagues (2007) note that many more endemic invertebrate species are likely to exist in GAB spring wetland communities, particularly in the Ostracoda and spider groups. Endemic invertebrates include 11 species of crustaceans, one dragonfly species, five spider species, 37 mollusc species, and three flatworm species (Sluys et al. 2007). The Barcaldine supergroup supports 19 known endemic invertebrate species (determined from Fensham et al. 2007), which is one of the highest number of endemic invertebrate species known for a GAB Springs supergroup; around double the number known from the Eulo and Dalhousie supergroups, and more than four times the number known from the Lake Frome and Springvale supergroups (DoE, 2015).

Birds, mammals, and occasionally reptiles use the wetlands or are associated with them (Fensham et al. 2007); however, they generally do not rely on the springs for survival (Harris 1992; Kinhill 1997).

The integrity of GAB springs wetland communities is significantly affected by changes in water discharge, and by physical disturbances to the spring’s wetlands, for example, through excavation and from grazing and feral animal impacts (DoE, 2015).

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2.1.6 OGIA 2016 Summary report on Surat CMA springs research and knowledge

In 2016 OGIA published the findings of the monitoring and research undertaken since the implementation of the 2012 UWIR in “Springs in the Surat Cumulative Management Area: A summary report on spring research and knowledge” (OGIA June 2016). The report summarises the completed activities and the new knowledge on springs in the CMA as well as presenting the technical basis which has informed the spring monitoring strategies set out in the UWIR 2016. The report sets out a new spring wetland typology summarised as follows:

 Type 1: Permanent fresh-to-brackish, palustrine wetlands with well-developed peat wetland soils, dense vegetation coverage, mainly connected to regional and local groundwater systems. There are two subtypes: o Type 1a: Wetlands located in off-stream environments, mainly along floodplains. o Type 1b: Wetlands located at the interface between floodplain and riverine environments and influenced by surface water flows.

 Type 2: Semi-permanent brackish, palustrine wetlands with minor wetland soils and minor vegetation cover, mainly connected to regional groundwater systems. Cockatoo Creek is an example.  Type 3: Permanent to semi-permanent riverine wetlands with minor wetland soils and moderate vegetation cover, sourced from local and regional groundwater systems and significantly influenced by surface water flows.  Type 4: Semi-permanent fresh riverine-to-palustrine wetlands with minor wetland soils and moderate vegetation cover, mainly connected to local groundwater systems. There are two subtypes: o Type 4a: Wetlands located within riverine environments with deep, sandy, alluvial deposits (non-GAB) o Type 4b: Wetlands located within riverine-to-palustrine environments with shallow-to- nil consolidated material. These wetlands can form in areas of significant topography (GAB) The 2012 the 2016 OGIA reports also describe:

 Spring dynamics and key influences  Monitoring techniques  Spring risk assessment combining the likelihood of impacts with typology, sensitivity and conservation ranking  Spring monitoring by typology and key indicators The typology developed by OGIA may or may not be directly applicable to the Doongmabulla Springs Complex. However, the methodology applied in using a typology to categorise and group individual spring wetlands within a complex and variable system is a technique that will be adopted by the GABSRP, as it provides a means to prioritise monitoring efforts and extrapolate results to describe the broader system.

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2.2 Hydrogeology

The following summary of the hydrogeological setting is specific to the Doongmabulla Springs Complex rather than the broader hydrogeological setting of the Mine Area and its surrounds.

Landscape

Topography across the Mine Area and its surrounds is dominated by a north-west to south-east trending ridge line, located west of the Mine Area boundary and running parallel to it. The topographic gradient typically flattens out in the vicinity of the Carmichael River and to the east of the ridgeline where it slopes gently towards the east and north-east. West of the ridgeline, topography is generally more elevated and is considered to form part of the Great Dividing Range. The topographic ridgeline is bisected by the Carmichael River, which flows west to east through the southern half of the Mine area. Several tributaries to the west of the Mine area feed into the Carmichael River, with the Carmichael River also receiving discharge from the Doongmabulla Springs Complex. The Doongmabulla Springs Complex itself is located immediately west of the topographic ridgeline.

Geology

Unconsolidated alluvium and colluvium typically form the uppermost hydrogeological unit within and in the vicinity of the Mine. Layered clay, sandstones and siltstones of Tertiary-age are mapped at outcrops and underlie the younger unconsolidated deposits over much of the Mine Area. Triassic- age GAB units comprising, from oldest to youngest, the Rewan Formation, Dunda Beds, Clematis Sandstone and Moolayember Formation lie within and to the west of the Mine Area. It should be noted that in some literature, the Dunda Beds and Clematis Sandstone are collectively termed the “Clematis Group”; however, this Research Plan continues with the concept of considering the two units separately, consistent with studies undertaken by Adani.

The Rewan Formation (comprising layers of sandstone, mudstone and conglomerate) underlies the Clematis Sandstone and is considered to be a major confining bed of the GAB, bounding the base of the GAB aquifers (GABCC, 1998). Within the Mine Area the Rewan Formation is indicated to be dominated by clays and mudstones and is considered to be an aquitard. It separates the Project coal resource within the underlying Permian-age strata from the stratigraphically younger Dunda Beds (predominantly sandstones) and Clematis Sandstone (a GAB aquifer) to the west. The coal resource of the proposed Project lies within the Late Permian-age Bandanna Formation and Colinlea Sandstone, which form part of the Galilee Basin. Towards the west of the Mine Area, the Triassic-age sandstones and mudstones of the Rewan Formation overlie the coals. Both the Triassic and Permian- age strata typically dip with a shallow gradient (2 to 4 degrees) towards the west and are unconformably overlain by Tertiary and Quaternary-age strata.

Groundwater flow

Mapping of groundwater levels indicate a varied and complex flow regime governed by topographic influences. The regional water table flow field forms a subdued replica of land surface elevations, with flow typically appearing to be related to the local land surface topography and surface drainage, particularly drainage towards the Carmichael River. Groundwater flow is typically towards 23 | P a g e

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the south-east across the northern and central parts of the Mine Area and towards the north across southern part of the Mine Area (i.e. towards the Carmichael River within the various monitored units). Maps of groundwater flow directions for the (non-GAB) aquifers in the Mine Area are shown in Figure 13 through Figure 19 of GHD 2013a.

Bores installed within the Clematis Sandstone (the GAB aquifer) west of the ridgeline indicate a strong correlation between ground elevation and groundwater level. The modelled flow conditions indicate flow from the elevated regions in the south, in a northerly direction shown in Figure 2-2, while flow to the south east is apparent in the north. These flow paths, based on available level data which is relatively sparse, suggest flow towards the Doongmabulla Springs Complex within the Clematis Sandstone. Westward groundwater flow on a regional scale (i.e. typical GAB groundwater flow) only appears to become established to the west of the Great Dividing Range, some 80km west of the Mine area’s western boundary.

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Figure 2-2 : Modelled and Observed Clematis Sandstone Groundwater Levels (GHD, 2013b)

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2.2.1 Spring source aquifer In 2012, Adani published its Environmental Impact Statement (EIS) for the Carmichael Coal Mine and Rail Project. The EIS included the following relevant studies about the source aquifer of the Doongmabulla Springs:

 Appendix N2 - Doongmabulla Springs Report  Appendix R - Mine Hydrogeology Report

In 2013, Adani published the Supplementary Environmental Impact Statement (SEIS) for the Carmichael Coal Mine and Rail Project. The SEIS included the following relevant studies about the source aquifer of the Doongmabulla Springs:

 Appendix H - Matters of National Environmental Significance Report  Appendix J3 - Doongmabulla & Mellaluka Springs Report  Appendix K1 - Mine Hydrogeology Report  Appendix K6 - Mine Hydrogeology Report Addendum  Appendix K7 - Numerical Groundwater Model Peer Review  Appendix K8 - Groundwater Model Peer Review Comments

Appendix K6 includes:

 the baseline data analysis and conceptual model  figure showing ta sketch cross section (west to east) through Doongmabulla Springs  a comparison of model results at Doongmabulla Spring for two model runs with different cumulative water balance errors  a figure showing the sensitivity analysis for Rewan Group and Doongmabulla Springs maximum impact  a sensitivity analysis for recharge at Doongmabulla Springs maximum impacts.

In 2014, Adani published additional Information for the EIS (AEIS) for the Carmichael Coal Mine and Rail Project. The AEIS included the following relevant studies about the source aquifer of the Doongmabulla Springs:

 Draft Groundwater Monitoring Program  IESC Response

Based on the above studies, Adani’s present conceptualisation of the Doongmabulla Springs Complex is that all the springs are likely fed by groundwater from the Clematis Sandstone aquifer, which (for most of the springs vents) discharges to the surface via the overlying Moolayember Formation and/or Quaternary alluvium. The degree of interaction with the surficial geological units differs between the spring groups. Samples collected from the Little Moses Spring and the Moses Spring group have similar major ion chemistry but with variable proportions of chloride. This suggests that the groundwater feeding these springs is likely to be from the same source and has been subject to similar conditions below the surface, but evaporative processes differ. The major ion chemistry of Joshua spring differs to the Moses spring group, which suggests either a different 26 | P a g e

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source of water (which given the geological setting is considered unlikely) or a different pathway and hence contact with surficial lithological units before discharging to surface. Anthropogenic modification to Joshua Spring may also play a part in the observed water chemistry differences.

Figure 2-3 and Figure 2-4 present the current geological and hydrogeological conceptualisation for the Doongmabulla Springs Complex.

The conceptualisation and alternative conceptualisations are to be tested by the research packages outlined in this research plan in Sections 3 and 4.

Figure 2-3 Conceptual 3D Geological Block Model (GHD, 2015)

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Figure 2-4 : Conceptual Hydrogeological E-W Cross Section Showing Detail Around the Springs (Bradley, 2014)

At Land Court (QLC 2015), an alternative conceptual model was presented in which the springs are sourced, at least in part, from the Colinlea Sandstone. The Carmichael mine will extract coal from the Bandanna Formation and the Colinlea Sandstone, below the Rewan Formation which is regarded as an aquitard. Adani’s current conceptualisation is that depressurisation of the Bandanna Formation and the Colinlea Sandstone is unlikely to have any significant effect on discharge to the Doongmabulla Springs Complex (sourced from the Clematis Sandstone) due to their separation by the substantial thickness of the low permeability Rewan Formation (aquitard).

Concerns were also raised in Land Court (QLC, 2015) that even if the springs are sourced primarily from the Clematis Sandstone, faulting within the Rewan Formation could result in a degree of groundwater connectivity to the Bandanna and the Colinlea sandstones such that depressurisation of these formations could propagate through the Rewan and result in a reduction of groundwater pressure in the Clematis Sandstone and therefore a reduction in spring discharge with resulting impacts on the associated ecology.

The Land Court concluded that while it accepted on balance the likelihood of a continuous pathway from the Colinlea Sandstone through the Rewan to the springs was low due to the thickness of the Rewan, its low permeability and the lack of evidence in relation to significant faulting, there was some evidence to the contrary and a lack of investigation and modelling of faulting. Land Court also concluded that there was some uncertainty as to the source aquifer of at least the Little Mosses Spring and that evidence in relation to groundwater flow directions in the Colinlea Sandstone had raised further uncertainty as to the source aquifer of the Doongmabulla Springs Complex.

The research packages outlined in Sections 3 and 4 (in combination with those outlined in the RCFCP), will test the plausibility of these alternative conceptualisations, by collecting additional data

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to verify the source aquifer and better understand the hydraulic connectivity of the Rewan Formation.

2.3 Doongmabulla Springs Complex

2.3.1 Overview

The Doongmabulla Springs Complex is located approximately 8 km from the western edge of the Carmichael Mine lease boundary. The Doongmabulla Springs Complex consists of a group of permanent artesian, fresh water springs and is part of the Barcaldine Spring Supergroup (regional clusters of springs associated with the Great Artesian Basin) (DSITI, 2016). The Doongmabulla Springs Complex is located on the extreme eastern margin of the Great Artesian Basin and within what is considered to be a recharge area to the Great Artesian Basin. The Doongmabulla Springs Complex is comprised of a cluster of springs (vents, seeps and mounds) adjacent the Carmichael River within 3 spring groups Figure 2-1):

 Moses spring group – a cluster of at least 65 mounding and non-mounding artesian springs and large wetland areas, spread over a 2.5 km radius, within close proximity (north and south) to Cattle Creek.  Little Moses spring group – a small number of incipient non-mounding springs, located approximately 2 km east of the Moses springs-group, which drain into a relict channel of Dyllingo Creek.  Joshua spring – a single large and very active spring, located 2 km north of the Moses springs-group, now modified into a turkey’s nest dam with associated overflow dams.

2.3.2 Moses springs-group

The Moses springs-group consists of at least 65 springs spread over an area 2.5 km long by 1.3 km wide, located in the Doongmabulla Mound Springs Nature Refuge, approximately 9 km west of the Project area (Figure 2-1 and Figure 2-1).

Most of the discharge areas in the Moses springs-group are mound springs ranging in height from 20 to 50 cm, and often supporting central pools (GHD 2014). The highest mound is 1.5 m tall, which suggests that the existing pressure head is up to 1.5 m above ground level (GHD 2014). Seepage springs are also present.

All the springs have a wetted area, with five springs supporting wetland areas larger than 0.5 ha. In four locations the mound springs have contributed water to broad shallow pools (often only a few centimetres deep), forming wetlands of approximately 3.5 ha in total area (GHD 2014). Elsewhere, mounds have occasionally formed localised shallow pools up to 20 m in diameter (GHD 2014) and aggregations of wetland vegetation <4 m in diameter.

The condition of the Moses springs-group is rated as 1a on a scale of 1-5 with 1 being the best condition, 4 being the poorest condition, and 5 being extinct (Fensham et al. 2010). However, Rod Fensham suggests that the Moses springs-group would be unlikely to achieve the highest overall

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score if the ranking exercise were to be undertaken again, due to degradation, and the discovery of a formerly endemic plant species at another springs complex nearby (GHD 2012).

Despite this, the Moses springs-group does have exceptional biological value, with two fauna species found only within this springs-group, seven GAB spring endemic flora species including one that is only known from two springs-groups and of which six are listed as threatened under the EPBC Act and / or the Nature Conservation Act 1992 (NC Act), including the Waxy Cabbage Palm.

The GAB endemic and threatened species associated with the wetland areas at Doongmabulla Springs Complex are all found in the Moses springs-group. These species were generally present on or immediately adjacent to mounds, seeps or pools, with the majority of species located within the wetland areas fed by seepage from the springs. Most mounds (and associated wetlands) are generally heavily vegetated with a characteristic suite of species that identify them from a distance, particularly the grass Sporobolus pamalae, which only occurs in association with GAB mound springs (GHD 2014).

Scalded, pale soils, and extensive grasslands and sedgelands at the Moses springs-group reflect altered soil chemistry, likely due to the high salinity content of GAB groundwater discharge, which has resulted in a specialised community of salt-tolerant and endemic flora (GHD 2012). These soil and vegetation characteristics indicate the Moses springs-group is mature and has probably been in place for a long time (GHD 2012).

2.3.3 Little Moses springs-group

The Little Moses springs-group is immediately adjacent to Dyllingo Creek, approximately 7 km from the western edge of the Project area boundary (Figure 2-10).The Little Moses springs-group is a series of seepages (no mounds) from the side of a slope and one large pool (GHD 2012). The spring is a tear-shaped sedgeland/wetland with an open pond in the centre. The spring is approximately 200 m long and 50 m wide.

Waxy Cabbage Palm has been recorded at the Little Moses springs-group (GHD 2012), although it occurs in non-wetland vegetation where the surface is not permanently wet. No GAB endemic flora or fauna species are known to occur at this spring.

Grasslands are absent from the Little Moses springs-group and the soil is dark brown to black and of a heavier nature. These observations, combined with a lack of surface water and GAB springs flora and fauna endemics, have led to the postulation that Little Moses may be a very young springs- group, in geological terms (GHD 2014).

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2.3.4 Joshua spring-group

The Joshua spring-group is located approximately 10 km directly west of the mine area boundary. The Joshua spring-group consists of one spring mound (‘Joshua Spring’) that has been modified into an artificial turkey’s nest dam (GHD 2012). It is a high flow spring with a strong pressure head, which rises at least 1 m above the surrounding plain (GHD 2014). The daily flow of Joshua Spring is approximately 4.32 to 8.64 ML (GHD 2014). The water flows out of the mound spring and into an adjacent shallow wetland of approximately 2 ha in area, and then drains to Dyllingo Creek, where it is believed to contribute a significant proportion of the Carmichael River’s base flow (GHD 2014).

The Joshua Spring is considered to be a high value habitat for aquatic fauna (GHD 2012). Given the depth and permanency of this spring, it is likely that fish, amphibian, turtle and aquatic invertebrate species use it, especially during the dry season (GHD 2012). The wetland contains two threatened flora species:

 Myriophyllum artesium (listed as Endangered under the NC Act)  Sporobolus partimpatens (listed as Near Threatened under the NC Act).

The Joshua Spring wetlands harbour a class 2 declared weed species Hymenachne amplexicaulis, with the outflow channel of the modified spring mound dam choked with this exotic grass.

2.3.5 Ecology

As well as being a GAB springs community, the Doongmabulla Springs Complex and associated wetlands are listed as being of national significance in the Directory of Important Wetlands because: 1) they are a good example of a wetland type occurring within a biogeographic region in Australia, and 2) the wetlands are important habitat for animal species at vulnerable stages in their life cycles, or provide a refuge when adverse conditions such as drought prevail (DoE 2015).

2.3.5.1 Vegetation Communities

The open vegetation areas of the Doongmabulla Springs Complex wetlands include (Figure 2-5):

 bare scalded clay pans with sparse grass and herb cover, including the Near Threatened grass Sporobolus partimpatens and low chenopod shrubs.  grasslands dominated by the Endangered Sporobolus pamelae, growing in or close to the saturated zone (within RE 10.3.31). This vegetation community is considered to be obligate groundwater dependent.  mixed-species sedgelands in the wetter areas, dominated by Cyperus laevigatus, C. polystachyos, C. difformis, Eleocharis cylindrostachys, and Fuirena umbellata. Some of these sedgelands contain a small population of the Vulnerable Livistona lanuginosa. These vegetation communities are all included in RE 10.3.31, which is an Of Concern RE that is part of the GAB springs community.

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Wooded vegetation communities within the Doongmabulla Springs Complex and wetland areas include Coolibah (Eucalyptus coolabah)/River Red Gum (E. camaldulensis) woodland and open woodland, Weeping Paperbark (Melaleuca leucadendra) forest, Peppermint Box (Eucalyptus persistens) open woodland, and Reid River Box (Eucalyptus brownii) woodland (GHD 2012).

Sporobolus pamelae grassland Mixed Sedglands

Weeping paperbark forest Peppermint box open woodland

Figure 2-5 Vegetation communities

2.3.5.2 Flora of the Doongmabulla Springs Complex

The wetland areas and mound springs of the Doongmabulla Springs Complex are known to contain six threatened flora species:

 Eryngium fontanum (Blue Devil) – Endangered under the EPBC Act and NC Act, and is only known from two springs-groups (Figure 2-7)  Eriocaulon carsonii subsp. orientale (Salt Pipewort)– Endangered under the EPBC Act NC Act (Figure 2-7)  Hydrocotyle dipleura – Vulnerable under the NC Act  Myriophyllum artesium - Endangered under the NC Act

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 Sporobolus pamelae – Endangered under the NC Act  Sporobolus partimpatens - Near Threatened under the NC Act  Waxy Cabbage Palm - Vulnerable under the NC Act and the EPBC Act,

Four other spring endemic flora species have been recorded at the complex:

 Isotoma sp. (R.J. Fensham 3883)  Peplidium sp. (R.J. Fensham 3880)  Chloris sp. (Edgbaston R.J. Fensham 5694)  Panicum sp. (Doongmabulla RJ Fensham 6555)

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Salt Pipewort Blue devil

Hydrocotyle dipleura Waxy Cabbage Palm

Myriophyllum artesium Sporobolus pamelae

Figure 2-6 Threatened flora

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2.3.5.3 Fauna of the Doongmabulla Springs Complex Baseline ecological studies (GHD 2012) identified that the Squatter Pigeon (Geophaps scripta scripta), which is listed as Vulnerable under the EPBC Act and NC Act, has been recorded in open woodlands associated with the Doongmabulla Springs Complex. The Ornamental Snake (Denisonia maculata), Yakka Skink (Egernia rugosa), Koala (Phascolarctos cinereus), Black-throated Finch (Poephila cincta cincta) and the Australian Painted Snipe (Rostratula australis) are threatened vertebrates that are considered likely to occur within the Doongmabulla Springs Complex (GHD 2012).

The Doongmabulla Springs Complex also contains two spring endemic fauna species:

 Gabbia rotunda (a mollusc)  Mamersella sp. AMS KS 85341 (an invertebrate)

2.3.5.4 Habitat Values The Doongmabulla Springs Complex and associated wetlands provide habitat for many non- threatened fauna, including nesting habitat for birds, permanent pools for fish and aquatic reptiles, sedgeland habitat for frogs, and aquatic habitat for invertebrates such as mussels, crayfish, freshwater crabs and insects. A total of 18 fish species are predicted to occur in the surface waters of the Doongmabulla Springs Complex, including rainbowfish and spangled perch (GHD 2012).

The Doongmabulla Springs Complex is also used for bird nesting. Mud nests are especially common, highlighting the importance of this site as a resource for nest building materials, particularly during dry periods when mud may be scarce. Stick nests have also been frequently observed within the Doongmabulla Springs Complex.

Hollows are plentiful on the periphery of the wetland and surrounds, so it is very likely that a number of arboreal species will be present at the wetland. Woody debris was typically abundant in forested areas but was (as would be expected) absent from the grasslands and wetlands. Leaf litter was dense in much of the forested parts of the wetland, particularly under the stands of weeping paperbark. Logs, lifted or fallen bark and fallen timber was common, and was confirmed to provide habitat for skinks, geckos and dragons. The Doongmabulla Springs Complex is fringed by rocky rises, some with short but abrupt escarpments, populated by a grassy open woodland of peppermint gum with porcupine grass and soft spinifex. The rock mosaic and spinifex provide ideal habitat for reptiles. It is likely that this diverse habitat within the Doongmabulla Springs Complex would support a diverse and abundant range of reptiles.

The Doongmabulla Springs Complex, and the Moses springs-group, provide abundant, suitable habitat for frogs in the region. The density of vegetation and abundance of perennial water makes the Doongmabulla Springs Complex and associated wetlands an important amphibian habitat in an otherwise arid environment.

While the springs themselves may provide a relatively small area of habitat for fish, the value of these springs is in providing surface flows which in some areas drained directly into the neighbouring

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waterways. Doongmabulla Springs Complex also provides a diverse range of habitat for aquatic invertebrates, including freshwater mussels, crayfish, freshwater crabs and various insects.

The diversity and abundance of aquatic invertebrates is largely determined by the habitat structure and type (for example clay substrates with root masses) and the availability of foraging material (for example leaf litter and other organic detritus). Suitable habitat was observed within the springs themselves, within the wetlands, and also in adjacent waterways. Substrates ranged from sand (suitable for freshwater mussels) to clays (preferred by many aquatic insects) and were mostly provided with abundant organic matter utilised by invertebrates for shelter and as a food source.

2.3.6 Disturbance In general, the habitats present within the Doongmabulla Springs Complex are intact and in good ecological condition. The wetland is exposed to introduced wildlife and stock, with cattle trampling observed particularly at the Moses springs-group (GHD 2012). The Doongmabulla Springs Complex is currently (and was historically) used for watering livestock, which directly impacts the springs through trampling, pugging, fouling of water and compaction (GHD 2012). The greatest damage to the wetlands was caused by feral pigs, with parts of some wetlands highly disturbed by pig wallowing and foraging (GHD 2012).

Outside of the wetland, the class two weed rubber vine (Cryptostegia grandiflora) is present along Cattle Creek. This weed was growing in very low densities, as scattered individuals. However, it is growing near mound springs within the Moses springs-group and is a potential future threat. The overflow channel for the Joshua spring is infested with the grass olive (Hymenachne amplexicaulis), which is classified as a ‘restricted invasive plant’ under the Biosecurity Act 2014.

The Joshua spring-group is the most impacted and is completely altered from its natural state. It now consists of an upper turkey’s nest dam and a more recently constructed lower turkeys nest dam. Given the depth of the turkey’s nest dam and the permanency and high flow rate of this spring, it is predicted that the Joshua Spring provides potential habitat for fish, amphibians, turtles and invertebrate species, especially during the dry season.

The degree of disturbance from existing anthropogenic drivers (and not related to the project) is an important background influence on the ecological condition of the springs and is to be assessed and monitored by the research packages outlined in Section 3 and 4 of this research plan.

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Figure 2-7 Eriocaulon carsonii and Eryngium fontanum records

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Figure 2-8 Moses springs-group wetland areas

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Figure 2-9 Moses springs-group mound springs

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Figure 2-10 Little Moses springs-group

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Figure 2-11 Joshua spring-group

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2.4 Fensham et.al. (2016) Overview of the Doongmabulla Spring Complex

Post EIS studies include that by Fensham et.al. (2016) which describes the complex as including relatively large spring wetlands and consisting of 187 vents forming 160 separate wetlands occurring near the confluence of the Carmichael River and Bimbah Creek, and downstream of this area.

Figure 2-12 : Doongmabulla Spring Complex layout (taken from Fensham et.al, 2016).

Figure 2-12 shows the Doongmabulla Springs Complex including the location of two monitoring bores (HD02 and HD03 installed in the Clematis Sandstone and Dunda Beds respectively) and the approximate location of the proposed Carmichael Mine (Source: GHD, 2013a, p. 19). The permanent (solid) and impermanent (dashed) sections of the streams (blue lines) and the areas of outcropping sandstone (yellow lines) are identified. The dotted black line distinguishes springs with an unambiguous discharge character, i.e. discrete mounded vents on flat scalded ground not associated with sandstone outcrop.

The House Springs comprise a cluster of small to medium-sized springs (64 to 6400 m2) just west of the Doongmabulla homestead. These are mounded vents in the middle of wetlands situated in flat topography. Adjacent to the House Springs is the Joshua Spring which has been modified into a turkey nest dam with a pipe discharging a large flow of water through the dam wall. The outflow from Joshua Spring and the House Springs converge to provide the main discharge feeding the Carmichael River for approximately 20 km. The vent of the massive Joshua Spring has not been located within the turkey nest where it occurs, and its precise character is difficult to determine. This spring excluded, the physical morphology of the vents and the topographic situation of the springs is variable and changes from the west to the east

On the scalded plain between the Carmichael River and Bimbah Creek are a cluster of numerous small springs poignantly known as the Mouldy Crumpet group. These springs are mounded and occur on flat scalded ground, features typical of discharge springs. Despite their small size (generally less than < 100 m2) these springs contain high concentrations of endemic species. The vents are mounded in the middle of the wetlands and are located on flat topography. South of these and amongst the channels of Bimbah Creek are the Stepping Stone Springs. The vents are mounded in the middle of the wetlands and are located on flat topography.

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South of the confluence of the streams are small and large springs on a scalded area extending over 1.4 km, from the most westerly Moses Springs, to Keelback Springs, Geschlichen Spring (on a shallow side gully to the south) and Camp Spring. The large wetlands at Moses and Keelback Springs flow into permanent open ponds and channels within the bed of Bimbah Creek, but when evaporation reduces moisture in the regolith during drought times these channels do not discharge into the Carmichael River. A vent at the large Moses Spring was accurately measured at 0.5m above the edge of the wetland using a dumpy level in November 2014. This situation strongly suggests groundwater fed by artesian pressure through a vertical conduit, and all these features are characteristic of discharge springs elsewhere.

To the north of Camp Springs amongst the channels of Bimbah Creek is Bush Pig Trap Spring, and to the south of Camp Spring on the edge of a belt of red-gums (Eucalyptus camaldulensis) is Camaldulensis Spring. On the side of a large water hole in Bimbah Creek are the Wobbly Springs, which contribute to the permanence of the water-hole.

On the bank of the Carmichael River south of Joshua Spring are the Bonanza Springs. Bonanza, Keelback, Geshlichen, Bush Pig Trap and Camaldulensis are not mounded but also occur in flat areas remote from outcrop and are also almost certainly discharge springs with vertical conduits. Camp Spring has two vents, both emerging from sandstone rock at the base of outcrop, but unlike other outcrop springs to the east, the vents are very discrete, indicative of discharge springs fed by pressurised artesian water.

North of the Carmichael River and 1 km downstream of the confluence of the streams is Little Moses Spring with its wetland at the base of a gentle slope but above the channels of the main stream Heading downstream on the northern side of the Carmichael River and east of the Labona boundary fence is the large Yukunna Kumoo Spring, and then a cluster of small springs known as the Dusk Springs.

On the edge of Surprise Creek, which enters the Carmichael from the southwest, is Surprise Spring, which has formed a short gully from its ill-defined source in colluvial material.

The eastern springs, Little Moses, Yukunna Kumoo, Dusk and Surprise Spring have vents on the edge of wetlands at the base of gently sloping topography suggesting lateral discharge, a feature typical of outcrop springs.

The flat topography, mounded vents and absence of outcrops at the western springs (House, Mouldy Crumpet, Stepping Stone) is strongly suggestive of a vertical conduit through a confining bed typical of discharge springs. Whereas, the position of the vents of the eastern springs on sloping topography, and their association with outcropping sandstone, suggests a potentially horizontal discharge conduit through an unconfined aquifer typical of outcrop springs.

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2.5 Hydrology

Studies undertaken during and post EIS indicate that the source aquifer of the Doongmabulla Springs Complex is discharge from the artesian Clematis Sandstone through weathered Moolayember Formation.

A conceptual groundwater model (Figure 2-13), which formed the basis of the numerical groundwater model, was developed based on existing information and field data collected for the Carmichael Coal Mine EIS process. This original conceptual model has been refined over time with new information since completion of the EIS. This model was independently peer reviewed through the EIS process by Adani and by the Queensland Government, reviewed by the Independent Expert Scientific Committee (IESC), further developed and subsequently approved through the Queensland Coordinator General’s Evaluation Report and the EPBC Approval. Subsequent work included the groundwater flow model review conducted as per conditions 22 and 23 of the EPBC Approval which was peer reviewed by an independent expert and the results of which further informed the conceptual groundwater model.

The current understanding of the site’s hydrogeological regime is presented in detail in the GMMP, with relevant material from the GMMP also provided in the GDEMP. This refined conceptual model has also been utilised to inform augmentation of the groundwater monitoring network and program and identify data gaps (through various mechanisms such as the GABSRP and the RFCRP) which will, in turn, be utilised to update the conceptual model. The research packages outlined in Sections 3 and 4 of this plan will support these activities. The research outlined includes updated hydrogeological understanding, geochemical surveys, geological mapping (for better information on geological controls of spring discharge and pathways, such as the thickness and hydraulic properties of the surficial deposits and Moolayember Formation), hydrological and ecological studies.

Figure 2-13 Conceptual groundwater model for the Doongmabulla Springs Complex GDE 44 | P a g e

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The regional groundwater conceptual model will also been refined to include the results of continued investigations. It is considered the key elements of the groundwater system in the area include:

 Geometry of each geological unit and their hydraulic properties  Groundwater levels and influences on these levels (e.g. artesian conditions south of Carmichael River)  Inter-aquifer connectivity  Groundwater flow directions  Recharge and discharge mechanisms.

The current understanding of these key elements has allowed for the development of pre- and post- mining conceptualisations presented in Figure 2-14 and

Figure 2-15. The groundwater contour impact mapping in Section 8.5.1 is presented on the basis of this hydrogeological conceptual model.

Figure 2-14 Hydrogeological conceptual model – pre-mining

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Figure 2-15 Hydrogeological conceptual model – post-mining

2.6 Summary of baseline monitoring findings

Baseline surveys of the Doongmabulla Springs Complex identified the following key features (GHD 2012, 2014), summarised below.

 The Moses springs-group is almost entirely intact, with the exception of impacts from cattle and pigs. It straddles Cattle Creek, and comprises approximately of 65 vents or springs, spread over 2.5 km, and forms a wetland of approximately 3.5 hectares (GHD, 2014).  The Little Moses springs-group is located to the east of the Moses springs-group. Little Moses differs from the main Moses springs-group in being much smaller (it has approximately two vents) and located within a woodland with different soils (GHD, 2014).  The Joshua spring-group was the most impacted and is completely altered from its natural state. It now consists of a single turkey’s nest dam and two associated scrapes. The overflow channel for the Joshua Spring (which carries a significant volume of water) is infested with the grass olive (GHD, 2014).

The greatest habitat values of the Doongmabulla Springs Complex is the permanency of water, and the connectivity of the wetland to the nearby waterways, and the surrounding region. The reliable water supply provides an important resource for both flora and fauna during dry periods, but it is the habitat connectivity that provides the means for fauna to access the springs. Generally, the

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Doongmabulla Springs Complex and adjacent areas consisted of a diverse range of habitats. All strata of terrestrial vegetation were present, from native grasses and herbs through to mature trees.

The Doongmabulla Springs Complex contains a comparatively high number of flora species of high conservation value, including:

 Salt pipewort – listed as endangered under both the NC Act and the EPBC Act, observed at Moses Spring during the 2012 and 2013 field surveys.  Blue devil – listed as endangered under the NC Act and the EPBC Act, observed at Moses Spring during the 2012 and 2013 field surveys.  Hydrocotyle dipleura – listed as vulnerable under the NC Act, observed confirmed at Moses Spring during the 2012 and 2013 field surveys.  Waxy cabbage palm – listed as vulnerable under the NC Act and the EPBC Act, observed at Moses and Little Moses springs during the 2012 and 2013 field surveys.  Myriophyllum artesium – listed as endangered under the NC Act, observed at Moses and Joshua springs during the 2012 and 2013 field surveys.  Sporobolus pamelae – listed as endangered under the NC Act, observed at Moses Spring during the 2012 and 2013 field surveys.  Sporobolus partimpatens – listed as near threatened under the NC Act, observed at Moses Spring during the 2012 and 2013 field surveys and Joshua Spring during the 2013 field survey. Several active searches for fauna were made during the 2012 and 2013 surveys in a variety of habitats during which only the squatter pigeon was observed.

2.7 Predicted impacts

2.7.1 Model development During the EIS process, a numerical groundwater model was constructed to assess potential impacts to groundwater resources and receptors arising from the Project, based on the available groundwater system information and conceptualisation at the time. Specifically, the objectives of the groundwater model were to assess the impacts on groundwater level and flow associated with the proposed mine development. This modelling was undertaken in accordance with Australian modelling guidelines, published by the National Water Commission (Barnett et all, 2012) and with reference to the Murray Darling Basin Commission (Middlemis et al, 2001) (GHD, 2015).

The groundwater model was further updated as part of the SEIS based upon revisions to the Project, incorporation of additional information gathered since the EIS, and to address comments to the EIS and provide further information to the State and Commonwealth. During the SEIS preparation, the mine hydrogeology report was updated to incorporate improvements in the understanding of the groundwater regime at and surrounding the proposed mine

At the conclusion of the SEIS process, conditions relating to the final State and Commonwealth Project approvals required further updates to the groundwater model, which are reported in GHD (2015). One of the underlying reasons for this revision of the groundwater model was to review its adequacy to characterise impacts on groundwater pertaining to GAB water resources as requested through the Commonwealth approvals process (Condition 23 of EPBC Approval 2010/5736). Fundamentally, the revisions entailed presenting an alternative conceptualisation of the western groundwater model boundary (i.e. within the GAB region) and assessing changes in predicted 47 | P a g e

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impacts from those predicted at earlier stages of the Project. Condition 23 also required specific model documentation and predictions related specifically to the Doongmabulla Springs Complex.

2.7.2 Peer review Condition 22 (EPBC 2010/5736) of the Commonwealth approvals process requires an independent peer review of the adequacy of the additional modelling information and the model re-runs specified under Condition 23. An independent peer review was undertaken by Hugh Middlemis (Middlemis, H. 2014).

The review was conducted in accordance with the principles of the Australian Groundwater Modelling Guidelines (Barnett et al., 2012), as well as the Murray Darling Basin Commission Groundwater Flow Modelling Guideline (Middlemis et al, 2001).

The independent peer review process did not identify any material weaknesses in the model design, boundary conditions, parameter values or calibration performance. The review found that the exploration of model uncertainty in conceptual and parameter value terms was commendable and the results indicated low sensitivity/uncertainty. The review concluded that the model revisions specified under Condition 23 had been undertaken competently, that the revised model design and performance was consistent with guidelines and suitable for impact assessment purposes, and that any future model refinements would be dependent on monitoring to obtain data for validation.

2.7.3 Predicted hydrological changes at Doongmabulla Springs Complex GHD (2015) presents a discussion of the most recent predictive results of the revised groundwater model that was developed in response to Condition 23 of EPBC Approval 2010/5736. This most recent model considered two alternate conceptualisations of the western model boundary, consistent with Condition 23, such that two model predictions are presented. Consistent with the hydrogeological conceptualisation (refer Section 2.5), the modelled pre-mining groundwater contours within the Clematis Sandstone result in topographically controlled flow for both versions of the latest model, with discharge of groundwater to the east of the GAB at the Doongmabulla Springs Complex and the Carmichael River. However, towards the western boundary of the model, the models also show groundwater flow components to the west within the Clematis Sandstone consistent with the broader GAB, and are topographically driven. The extent of topographically driven flow towards the Carmichael River and Doongmabulla Springs Complex for all options is noted to be particularly significant, supporting the conceptualisation of the Clematis Sandstone as the primary source aquifer for the Doongmabulla Springs Complex.

The operational and post-closure phase model predictions show relatively small drawdowns in the Clematis Sandstone aquifer of between <0.05 and 0.19 m at the Doongmabulla Springs Complex, peaking between approximately 2100 and 2129 i.e. during the post-closure phase. The predictions suggest that potential drawdown impacts will not occur until around 60 years into the operational phase of the Project. The relatively small predicted drawdowns in the spring source aquifer are a result of the intervening low-permeability strata between the mined coal seams and the shallower Clematis Sandstone, primarily the Rewan Formation, mitigating against pressure reductions in the Clematis Sandstone.

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Figure 2-16 : Predicted impacts – Doongmabulla Springs Complex– operational phase (GHD, 2015)

2.7.4 Potential ecological impacts Threats and potential direct / indirect project impacts were outlined in the EIS (GHD 2012; Adani 2012) Carmichael Coal Mine and Rail Project – Groundwater Dependent Ecosystems Management Plan (11 February 2014).

It should be noted that the Doongmabulla Springs Complex is located a minimum of approximately 8 km from the Project’s western boundary and will therefore not be subject to direct impacts.

It should be noted that the Doongmabulla Springs Complex is on land not owned by Adani, and therefore potentially subject to impacts beyond Adani’s control (e.g. grazing, clearing). Indirect impacts described in the following sections primarily relate to threats unrelated to Project activities. These potential third party impacts will be addressed by other Federal and state legislation managed between the landholder and the relevant government departments.

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The key threats and potential direct / indirect project impacts identified for Doongmabulla Springs Complex that are relevant to the Project were identified as follows

# Potential Threat or Impact Project Phase/s Earliest predicted potential impact

1 Groundwater drawdown from mine dewatering Operations Year 20 Rehabilitation

2 Changes to hydrology including: Operations Year 1  stream diversion and flood levees  other alterations to surface water regime  degradation of surface water quality 3 Weeds and pests through direct competition or habitat Construction Year 1 degradation Operations

2.7.5 Specific project impacts

2.7.5.1 Groundwater drawdown from mine dewatering Aquifer drawdown is listed as a key threat in the Recovery plan for the community of native species dependent on natural discharge of groundwater from the Great Artesian Basin (Fensham et al., 2010). Drilling of bores for the pastoral industry since the nineteenth century has created thousands of free-flowing artesian bores throughout the GAB. This has resulted in pressure head declines of up to 120 m, and spring flows in the discharge areas of the GAB have declined dramatically as a result of aquifer pressure decline from artificial extraction (Fensham et al., 2010).

Groundwater modelling results indicate mine dewatering will influence groundwater pressure within the Doongmabulla Springs Complex during the operational and post-operational phases (GHD 2015). The maximum predicted reduction in pressure for each spring during these phases is presented in Table 2-1 and Table 2-2.

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Table 2-1 Modelling predictions for aquifer springhead pressure reductions in springs-groups associated with the Doongmabulla Springs Complex – Operational Phase (GHD 2015)

Peak predicted drawdown in Clematis Spring number and name Spring system Sub-system Sandstone (m)

SEIS model 1031_Moses4* Doongmabulla Moses <0.05 1032_Moses3* Doongmabulla Moses <0.05 1033_Moses2* Doongmabulla Moses 0.08 1034_Littmose* Doongmabulla Little <0.05 Moses 1035_Moses1* Doongmabulla Moses 0.06 1036_75E* Doongmabulla Moses 0.09 1037_75A* Doongmabulla Moses 0.08 1038_75D* Doongmabulla Moses 0.07 1039_75B* Doongmabulla Moses 0.12 1040_75C* Doongmabulla Moses 0.12 1041_Doongma* Doongmabulla Joshua 0.19

* predicted drawdown in the Clematis Sandstone

Table 2-2 Modelling predictions for aquifer springhead pressure reductions in springs-groups associated with the Doongmabulla Springs Complex – post-closure phase (GHD 2015)

Peak predicted drawdown in Spring number and Spring system Sub-system Clematis Sandstone name (m)

SEIS model

1031_Moses4* Doongmabulla Moses <0.05

1032_Moses3* Doongmabulla Moses 0.05

1033_Moses2* Doongmabulla Moses 0.08

1034_Littmose* Doongmabulla Little Moses <0.05

1035_Moses1* Doongmabulla Moses 0.06

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Peak predicted drawdown in Spring number and Spring system Sub-system Clematis Sandstone name (m)

SEIS model

1036_75E* Doongmabulla Moses 0.09

1037_75A* Doongmabulla Moses 0.07

1038_75D* Doongmabulla Moses 0.07

1039_75B* Doongmabulla Moses 0.11

1040_75C* Doongmabulla Moses 0.11

1041_Doongma* Doongmabulla Joshua 0.16

* predicted drawdown in the Clematis Sandstone

Twelve mounds at Moses Springs are less than 20 cm high, 24 mounds are 20 to 50 cm high, and 20 mounds are >50 cm high. The tallest mounds are approximately 1 to 1.5 m high (GHD 2014). The reduction in pressure at the Moses springs-group is predicted to be between <0.05 and 0.11 m (Table 2-1 and Table 2-2), with the predicted reduction in pressure for the majority of the Moses spring heads being <0.08 m (GHD 2014). This predicted pressure declines fall within the observed range of seasonal fluctuations in spring flow to which the Moses springs-group wetland communities are already adapted. Therefore, it is thought that the reduction in flow will be within a tolerable range (GHD 2014). The threatened species associated with the Moses springs-group are generally present on or immediately adjacent to the mounds, seeps or pools. Most mounds are separated from other mounds by bare sections of plain. The majority of the population of endemic and/or threatened species at Moses springs-group are located within wetland areas fed by seepage from the springs. These wetlands generally form sedgeland or grassland, rarely with trees (weeping paperbark clumps or individual waxy cabbage palms).

The predicted reduction in pressure at the Little Moses springs-group will be <0.05 m, which is predicted to result in a negligible impact on the spring wetland communities (GHD 2014).

Joshua Spring is a high flow spring that rises at least 1 m above the surrounding plain (GHD 2014). The predicted reduction in pressure of up to 0.19 m at Joshua Spring is expected be a minor impact, with no major impact on associated threatened flora (GHD 2014). The threatened species found at the Joshua Spring wetland, M. artesium and S. partimpatens, are unlikely to be impacted, as the water supply to the wetland in which they occur is not likely to be reduced to an extent that will affect these species.

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The reduction in pressure of the aquifers expected after approximately 20 years from the commencement of mining operations (GHD 2014).

The levels of reductions (generally less than 5 percent at Moses Springs and within the range of natural seasonal fluctuations) are likely to have negligible adverse impacts at Moses Springs and, at most, negligible adverse impacts to Joshua and Little Moses Springs.

In summary, no significant impacts to the GAB springs community are predicted to occur, as the Project (Mine) is not predicted to:

 Reduce the extent of, fragment, or increase fragmentation of the ecological community  Adversely affect habitat critical to the survival of the ecological community, or destroy or modify factors necessary for the survival of the community  Cause substantial changes or reductions in species compositions, quality or integrity. The research activities in Sections 3 and 4 of this plan provide an ongoing research effort aimed at regularly reviewing these impact assessment findings as more data and knowledge become available. The research will prepare revised estimates of drawdown predictions and review their implications based on a refined understanding of background trends and influences (e.g. natural fluctuations in the Clematis Sandstone and the impact of pastoral extractions), and the hydrology of the spring wetlands and and how it affects ecological conditions.

2.7.5.2 Changes to hydrology The Doongmabulla Springs Complex is situated near the confluence of three third order creek systems (Cattle Creek, Dyllingo Creek and Carmichael Creek). These creeks join downstream to form the Carmichael River within the upper reaches of the Burdekin River catchment. The Springs Complex is located upstream of the Project area. There is no predicted significant impact to flooding conditions associated with the construction of levees on either side of the Carmichael River.Figure 2-17 shows no increase to flooding at the western edge of the mining lease, noting that the Doongmabulla Springs Complex is upstream from this location. The focus for this threat is therefore to maintain existing surface water quality of the Doongmabulla Springs Complex.

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Figure 2-17 Predicted flood impacts on Carmichael River: 100-year ARI event (SEIS, Appendix K5)

2.7.5.3 Weeds and pests through direct competition or habitat degradation Exotic plant incursion (e.g. ponded pasture species such as Hymenachne), and introduction of exotic animals (e.g. Mosquito Fish and Cane Toads) are listed as threats in the Recovery plan for the community of native species dependent on natural discharge of groundwater from the Great Artesian Basin (Fensham et al., 2010).

Project-related impacts on the Doongmabulla Springs Complex through drawdown may exacerbate existing impacts from weeds and pests, by reducing the resilience of the wetland communities and impacting sensitive native flora species. However, drawdown impacts have been modelled to be negligible and no exacerbation of impacts from weeds and pests are predicted as a result of drawdown. The Doongmabulla Springs Complex currently experiences impacts in the form of pugging from cattle and pigs. Impacts from cattle grazing are not under the direct control of Adani, as the Doongmabulla Springs Complex is located on land not owned by Adani.

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3 Research program framework

3.1 Framework

A framework is presented in Table 3-1 to guide the research activities undertaken for the GABSRP. The framework takes an objective-driven approach by outlining a series of questions that need to be addressed to meet Condition 25 of the EPBC approval. Four primary questions are outlined which relate to whether project activities will likely impact the ecology of the springs and what needs to be done to manage, prevent, mitigate or offset any impacts (if identified). Due to the complexity of addressing these primary questions, they have been subdivided into a series of secondary questions to formulate a logical sequence of enquiry. These secondary questions are used to frame the scope and objectives of individual studies and assessments and the data and monitoring requirements of the GABSRP.

While the research is focussed on the development of methods to prevent, mitigate and remediate ecological impacts, the initial investigations seek to better understand the nature of the impacts themselves (in terms of hydrological and ecological changes) because this knowledge is necessary for the development of appropriate and effective management measures.

The program logic inherent in the framework is that by addressing the secondary questions through a series of studies or assessments (which are informed by monitoring and data gathering activities), the primary questions are addressed, and the research objectives of Condition 25 are met. Links to related research programs and management plans are also listed.

The following sections provide a broad overview of how the framework should be interpreted with respect to the questions outlined and their assessment and data requirements. The relationship between the GABSRP, individual assessments, monitoring activities, and related management plans for the project are also described.

The implementation of framework is described in Section 4.

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Table 3-1 GAB Springs Research Program framework

GABSRP Objective: to investigate, identify and evaluate methods to prevent, mitigate and remediate ecological impacts on the EPBC listed community of native species dependent on natural discharge of groundwater from the GAB (the GAB Springs Community) in the Galilee Basin, and by doing so meet EBPC Act Approval 2010/5736, Condition 25 Primary Questions Secondary Questions Study/Assessment needs Data/Monitoring requirements Links to other management plans

Q1. What are the predicted What are the source aquifers to the springs and what are their flow paths and - Geochemical survey - Geochemical characterisation of relevant aquifers and spring wetlands GMMP hydrological changes (due to project relative contributions, based on an evaluation of multiple, alternative - Hydrogeology review - Groundwater head (potentiometric surfaces and vertical gradients) activities) at GAB springs in the Galilee conceptualisations? - Geological mapping - Geophysics Basin, in terms of magnitude and What are the background trends and influences on the source aquifers? - Geological mapping - Groundwater head monitoring GMMP timing, relative to background trends - Hydrogeology review - Third party groundwater usage and influences? - Hydrogeological properties (K and S) What are the other background trends and influences on spring wetland - Spring wetland hydro(geo)logical - Weather monitoring (rainfall, temperature) GDEMP hydrology; e.g. climate, surface water, geomorphology? conceptualisation and water balance - Digital elevation model, bathymetry survey - Streamflow and stage height monitoring (wetland inflows and discharge) - Wetland area monitoring What is the relationship between groundwater pressure change in source - Groundwater head monitoring GDEMP aquifers and wetland hydrology? - Streamflow and stage height monitoring Is the Rewan Formation an effective hydraulic barrier to groundwater pressure - Rewan Formation connectivity - Groundwater head data (vertical gradients) in response to pumping RCRP To be investigated by reduction in the Permian sandstone units of the Galilee Basin? investigations - Hydrogeological properties of Rewan Formation studies conducted under Based on the above, does the regional hydrogeological conceptualisation - Hydrogeological conceptualisation - All above RCRP, GMMP RCRP & GMMP require revision? review What are the predicted hydrological changes and their uncertainty? - Updated groundwater modelling - All above GMMP Q2. Will the predicted hydrological What is the ecological composition of the communities that depend on the - Ecological survey and development - Flora and fauna presence/absence and abundance/cover (incl. aquatic invertebrates) GDEMP changes likely impact the GAB Springs spring discharge? of spring typology Community in the Galilee Basin? If so, What are the environmental water requirements and ecological response - Hydro-ecological conceptualisation - Measurement and monitoring of abundance/cover and condition/stress of key species GDEMP what are the nature of these ecological thresholds of the communities that depend on spring discharge? and assessment of key species - Wetland hydrology data as above impacts relative to background trends and influences? Will the ecological water requirements be compromised by the predicted - Predicted hydrological changes from above GDEMP, GMMP hydrological changes and, if so, what is the nature of ecological impacts? What are the other (non-hydrological) background trends and influences on the - Ecological survey and development - Ecological condition GDEMP ecological condition of the spring communities; e.g. land use, weeds and pests? of spring typology - Land use data Q3. How can ecological impacts to the Can the approaches developed, tested and implemented in the Surat Basin be - Desktop mitigation scoping study - Outputs from hydrogeological and hydro-ecological conceptualisation & Surat Basin studies GAB Springs Community in the Galilee applied to prevent or mitigate ecological impacts, and should other options be Basin be effectively prevented or considered? mitigated? How effective and feasible are each of the prevention and mitigation options - Desktop mitigation scoping study - Outputs from hydrogeological and hydro-ecological conceptualisation GMMP identified (including groundwater injection)? - Pilot testing - Hydrogeological and geochemical data of target aquifer(s) and injection water source - Hydrogeological properties of target aquifer(s) What actions can be deployed to prevent or mitigate impacts? - Prevention and mitigation strategy - Outputs from desktop scoping study, pilot testing GDEMP, GMMP

Q4. How can ecological impacts to the Can impacts be remediated though improvements to other factors that affect - Remediation assessment and trial - Ecological condition GDEMP GAB Springs Community in the Galilee spring hydrology and ecology at affected springs? - Third party groundwater usage Basin be effectively remediated or Do other GAB Springs in the Galilee Basin (outside of those affected) provide - Desktop offset scoping study - Ecological condition GDEMP offset? opportunities for remediation or species relocation to offset ecological impacts? - Targeted ecological surveys - Third party groundwater usage - Targeted hydro-ecological studies - Digital elevation model, bathymetry survey - Remediation assessment and trial What actions can be feasibly deployed to remediate or offset impacts? - Remediation and offset strategy - Remediation assessment and trial GDEMP

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3.2 Study and data requirements

3.2.1 Q1. Predicted hydrological changes

Question 1 is framed around estimating the timing and magnitude of any hydrological changes at the Doongmabulla Springs Complex caused by project activities and contextualising these changes in relation to background trends and influences. While these changes have been modelled as part of the EIS, the objective of the work undertaken in the GABSRP is to reduce uncertainty in the updated groundwater drawdown predictions and to provide a clearer understanding of how these changes are likely to manifest in the hydrology of the spring wetlands.

The work to be undertaken for Question 1 is at multiple scales, as follows:

 Spatially, a regional focus is required for much of the hydrogeological investigations given the scale of the groundwater flow systems in the GAB and Galilee Basins. However, a local focus is required to examine the nature of groundwater discharge at Doongmabulla Springs Complex, the role of local groundwater flow systems, and the hydrological processes (water balance dynamics) within Doongmabulla Springs Complex.  Temporally, the influence of mine dewatering on the regional aquifers will stretch into the long term (over decades to centuries), while the hydrology of the wetland will be dynamic and respond to seasonality and climate trends (months to years).

The initial investigations for Question 1 focus on collecting data to inform the understanding of the source aquifers to Doongmabulla Springs Complex and their relative contributions. Geological mapping (including geophysical surveys), geochemical sampling and groundwater head measurements from an augmented groundwater monitoring network (as outlined in the GDEMP and GMMP) will provide this understanding.

Background trends and influences of the source aquifers will be examined using groundwater head monitoring data, reviews of third-party groundwater usage and pumping tests to determine hydrogeological properties. Understanding the background trends and influences of the source aquifers provides context to predictions of any drawdown related to the project activities.

Investigations of wetland hydrology will focus on the wetland water balance and its dynamics. Several datasets will be required, including meteorological data (rainfall, temperature, relative humidity), digital terrain data (including bathymetry), surface water gauging (wetland levels, stage height, flow), and measurements of wetland area. When combined with groundwater head measurements the data is to be used to develop a relationship between groundwater head in the source aquifers and spring wetland hydrology. The background trends and influences on wetland hydrology will also be quantified including an assessment of the influence local topographically controlled groundwater systems have on the wetland hydrology.

The hydraulic connectivity of the Rewan Formation is a key factor regarding the risk of project activities impacting the Doongmabulla Springs Complex. Geological mapping and geophysical mapping will be carried out as part of a suite investigations described in the RCRP.

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Based on the above investigations the conceptualisation of the regional and local hydrogeology will be reviewed and refined. The conceptualisation will be represented in updated groundwater modelling studies and a revised set of model predictions will be produced regarding groundwater drawdown over time due to project activities. The drawdown predictions will be linked to wetland hydrology to produce a revised set of predictions of changes to wetland hydrology due to the project. The modelling is to include uncertainty analysis, such that a range of plausible outcomes to wetland hydrology are produced.

3.2.2 Q2. Ecological implications of any changes to wetland hydrology

Question 2 is framed around considering the ecological implications for the predicted changes to wetland hydrology determined by the investigations carried out to address Question 1.

An ecological survey and monitoring program will be carried out to characterise the ecological composition of the Doongmabulla Springs Complex, building on previous studies (e.g. Fensham et al. 2016 and GHD 2012). The survey will measure the presence/absence and abundance/cover of the flora and fauna (including aquatic invertebrates) and will focus on the key species which make up the environmental values to be maintained (those which are endemic, and those which comprise the EPBC listing1) and their relationship to spring hydrology and chemistry. An outcome of the survey will be the development of a typology specific to the Doongmabulla Springs Complex using approaches developed by OGIA (2015). The survey will measure the ecological condition of Doongmabulla Springs Complex and will design an ecological monitoring program that will include the regular monitoring of key species at designated monitoring points, using the typology to guide the selection of these monitoring locations. An assessment of land use pressures to Doongmabulla Springs Complex will also be conducted.

The ecological survey and wetland hydrology studies will be used to develop hydro-ecological conceptualisations for the variety of wetlands and ecological communities that occur at Doongmabulla Springs Complex. Control-stressor diagrams, as outlined byIESC (2015), will be used to describe the relationship between hydrology of the spring wetlands and the ecology of key species and how these are influenced by natural drivers (climate, landform and geology, hydrology and hydrogeology), anthropogenic drivers (agriculture, land use, third party groundwater and surface water use/modification), and project-related stressors (any predicted drawdown in the source aquifer). In addition, the hydro-ecological conceptualisations will be required to propose critical ecological endpoints (OGIA 2015). The ecological endpoints represent components of the wetlands that have been determined to be directly influenced by changes in groundwater, and therefore if monitored provide a measure of the impact changes in groundwater may have on the wetland ecology, relative to background trends and influences (e.g. climate, landholder management practices etc.). The ecological endpoints will include the GAB spring endemic species observed in Moses Spring in the 2012 and 2013 baseline surveys (Eriocaulon carsonii, Eryngium pinnatifidum, Hydrocotyle dipleura, Myriophyllum artesium, Sporobolus pamalae, Sporobolus partimpatens) as listed in the GDEMP.

1 http://www.environment.gov.au/cgi-bin/sprat/public/publicshowcommunity.pl?id=26

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The conceptualisations will form the basis of defining the environmental water requirements of the key species and, as a corollary, ecological response thresholds. When combined with the predicted changes in wetland hydrology from Question 1, the nature of any potential ecological impacts can be described and quantified, in the context of other background trends and influences.

3.2.3 Q3. Development of methods for prevention and mitigation of ecological impacts to the GAB springs community

Question 3 is framed around identifying and evaluating methods to prevent and mitigate ecological impacts to the GAB springs community.

In this context, prevention methods are those which aim to prevent any groundwater drawdown to source aquifers (i.e. those which prevent impacts) and mitigation methods are those which aim to lessen the magnitude of groundwater drawdown in source aquifers and/or hydrological changes in spring wetlands to acceptable levels (i.e. those which mitigate impacts).

A desktop mitigation scoping study will review available prevention and mitigation methods (including those being trialled and implemented in the Surat Basin) to assess their feasibility for application to Doongmabulla Springs Complex. The methods considered will include:

 Managed aquifer recharge via alteration of surface recharge processes  Managed aquifer recharge via groundwater injection  Offsetting existing groundwater extraction by third-parties  Alteration of surface hydrology (environmental watering)

Based on the outcomes of scoping study, pilot testing of feasible prevention and mitigation methods will take place to evaluate their effectiveness. This may include a groundwater injection trial and/or testing of an environmental watering method.

3.2.4 Q4. Development of methods for remediation and offset of ecological impacts to the GAB springs community

Question 4 is framed around identifying and evaluating methods to remediate and offset ecological impacts to the GAB springs community.

In this context, remediation methods concern actions which are aimed at reducing existing pressures (such as land use pressures from grazing, weeds and pests) to remediate the habitat of the impacted communities such that they are more resilient to any hydrological changes brought about by project activities. Offset methods are related to remediation methods and concern actions at other GAB springs in the Galilee Basin (not impacted by project activities) where the habitat of the GAB springs community may be remediated to offset any impacts at Doongmabulla Springs Complex. The relocation of impacted species is one offset methods that will be considered.

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A desktop scoping study will review all GAB spring communities in the Galilee Basin to assess their potential for remediation methods to be applied as an offset action. The desktop study will prioritise these sites from which targeted ecological and hydro-ecological studies will take place to understand the ecological condition of the GAB springs community at these sites and the nature of groundwater dependence.

Based on the scoping study and the targeted investigations a remediation assessment and trial(s) will be undertaken to evaluate the effectiveness of proposed remediation methods at Doongmabulla Springs Complex and the proposed offset methods at other GAB springs in the Galilee Basin.

3.3 Links to other research and management plans

Figure 3-1 illustrates the relationship between the GABSRP and other relevant management plans for the project. The GABSRP and RFCRP are foundational documents and set guidance for the specific monitoring and investigation requirements for their respective approval conditions. The monitoring and assessment requirements outlined by the research plans sit within a broader, project-wide requirements of the GDEMP and the GMMP.

Whereas the research plans are foundation documents that are used for an initial defined period of the project, the GDEMP and the GMMP will be updated regularly as more information becomes available. For example, both the GDEMP and the GMMP will be updated as the research undertaken for the GABSRP reveals more information about whether project activities will likely impact the ecology of the springs and what needs to be done (if anything) to manage, prevent, mitigate or offset any impacts (if identified). The GDEMP and the GMMP will be revised to include the trigger response framework developed for Doongmabulla Springs Complex and will outline the management required in accordance with the monitoring data collected. In this way, potential impacts to the Doongmabulla Springs Complex will be managed adaptively.

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Great Artesian Basin OUTPUTS DEFINE MANAGEMENT ACTIONS Springs Research Plan9

Groundwater Management and Monitoring Plan1 Groundwater Dependent Ecosystem • Groundwater monitoring program Management Plan8 • Groundwater level and quality thresholds • Ecological monitoring & survey – • Early warning trigger levels Doongmabulla Springs • Groundwater model re-runs • Early warning trigger levels • Annual Reporting • Ecological triggers • Annual Reporting

Great Artesian Basin Offsets Strategy2 Rewan Formation Connectivity Research • Groundwater monitoring and management Plan7 • Groundwater model re-run • Research programs and deliverables • Annual reporting • On ground studies and activities to characterise the Rewan Formation Matters of National Environmental Biodiversity Offset Strategy3 Significance Management Plans - Species 5 • Offset requirements for groundwater Management Plan Environmental Management Plan and Sub- dependent ecosystems • Listed threatened species and Plans6 communities • Management and monitoring • Manages direct and indirect impacts • specific aspects Offset Area Management Plan4 MNES specific impact monitoring • Management actions for specific offset • Habitat management goals areas • Assesses success of management

Key Linkage to Great Artesian Basin Springs Research Plan Relevant EPBC Act Approval Conditions KEY 1. Conditions 3 & 4 1. Monitoring results and data from the GMMP to inform and support research RESEARCH FINDINGS, REPORTS, METHODS 2. Conditions 11(k) to 11(p) under this plan 3. Conditions 8 to 12 2. Key input from GABSRP to GAB Offset Program will be research on existing DATA, REPORTING, INVESTIGATION OUTCOMES 4. Conditions 13 & 14 pressures and how this could inform offsets 5. Conditions 5 & 6 FINDINGS INFORM ADAPTATION 7. Findings are to inform research programs under the GABSRP 6. Queensland Government required plans 8. Monitoring results and data from the GDEMP to inform research under the 7. Conditions 27 & 28 GABSRP 8. Queensland Government required plans 9. Condition 25

Figure 3-1 Relationship between GAB Springs Research Plan and other management plans

Great Artesian Basin Springs Research Plan

4 Program implementation

4.1 Program governance

The governance structure of the GABSRP is presented in Figure 4-1.

Adani will appoint a GABSRP Coordinator whose role is to:

 oversee the implementation of the GABSRP;  procure and manage research studies according to the timetable outlined in Section 4.4;  facilitate technical review of the study packages via an independent technical review panel;  liaise with the co-ordinators of the RCFRP, GDEMP and GMMP; and  prepare reports in accordance with the requirements outlined in Section 4.4.

Figure 4-1 Governance structure of GABSRP

An independent technical review panel will be appointed to provide technical review of the research packages. Given the breadth of the research covered by the GABSRP it will be necessary to appoint specialists from multiple fields: spring ecology, geology, hydrogeology and hydrology. The panel members will be appointed for set periods (initially 3 years), rather than for individual studies, to provide continuity to the research program. Its members will be required to advise the GABSRP coordinator on the fulfilment of individual study objectives, and the implications for the broader GABSRP objectives as outlined in the framework presented in Table 3-1.

Individual research packages will be managed by study managers who will report directly to the GABSRP coordinator.

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4.2 Scope and objectives of research packages

4.2.1 Overview The following sections outline the scope and objectives of the research packages required for the GABSRP. While some guidance is provided on methodologies, it is recognised that there may be multiple ways to achieve the objectives of each study. Thus, while the scope and objectives are set, there is flexibility inherent in the methodologies that may be used. The research packages (RP) are coded according the primary questions of the research framework that they seek to address; i.e. research packages prefixed RP1 collectively seek to address Q1, those prefixed RP2 collectively seek to address Q2, etc. The sequence, timing and dependencies of the research packages are shown in Figure 4-2. Some of these research packages will occur in parallel while others depend on the completion of preceding research packages. This detail is listed in Figure 4-2.

4.2.2 RP1.1: Hydrogeology review and monitoring The objectives of the hydrogeology review are:

 To contribute to an improved understanding of the source aquifers to the springs of the Doongmabulla Springs Complex and their relative contributions by augmenting the groundwater monitoring network and summarising the data obtained; and  To describe background trends and influences in the potential source aquifers, including natural fluctuations and third-party use.

The tasks undertaken will include:  An expansion of the groundwater monitoring network (in consultation with GMMP implementation) via drilling, installation of new wells and piezometers, and conducting pumping tests.  Preparation of updated potentiometric surfaces of the potential source aquifers to better understand vertical and lateral hydraulic gradients in relation to spring discharge elevations.  A survey of third-party groundwater use in potential source aquifers;  Analysis of temporal trends (including historical trends) in the aquifers surveyed; and  Ongoing monitoring in accordance with the GMMP.

The hydrogeology review will assist in answering the research questions that concern: the source aquifers and their relative contribution to the springs; and the background trends and influences in the source aquifers. The investigation of source aquifers requires a local focus, while the investigation of background trends and influences requires a regional focus given the scale of the groundwater flow systems that are likely to contribute to the groundwater discharge at the Doongmabulla Springs Complex. Current groundwater monitoring commitments for the Doongmabulla Springs Complex are outlined in the GDEMP and GMMP, and feature a network of monitoring wells installed as spear-points in selected spring mounds and as designated monitoring bores in the Moolayember Formation and

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Clematis Sandstone. The hydrogeology review conducted for the GABSRP will review the coverage of this network in relation to source aquifer considerations and augment the network where appropriate. For instance, there is limited potentiometric data in hydrostratigraphic units below the Clematis Sandstone (Dunda Beds, Rewan Formation) and targeted groundwater monitoring installations in these units, and in the overlying Moolayember Formation and alluvium would provide a clearer picture of groundwater potentiometry. To address this knowledge gap, Adani commits to installing additional monitoring bores into the Dunda Beds and the Rewan Formation to the west of Mining lease in between the Mining lease and the Doongmabulla Springs Complex. If feasible, these additional bores will be co-located with the existing bores, HD02, HD03A, and C14011SP, as nested monitoring bores in consultation with DNRME of Queensland. These bores, to be installed within the first year of commencement, will be added to the operational groundwater monitoring program and will allow for the collection of additional spatially comparable groundwater level and quality data.. These bores, once installed, will be added to the operational groundwater monitoring program and will enable to collect spatially comparable groundwater level and quality data in between the mining lease and the Doongmabulla Springs-Complex for the purpose of additional data collection prior to the occurrence of predicted impacts associated with project activities. These bores will be further used to assign with groundwater level thresholds and groundwater quality triggers after completing 12 sampling events and will be included in GMMP once established. Consideration will also be given during GMMP review and groundwater model re-run to review effect of revised groundwater drawdown to relevant GDEs. The additional monitoring points will assist in further evaluation of the predicted groundwater impacts associated with the mining activities and will also assist in validating the predicted timing of impacts. Existing bores in the Alluvial (HD03B) and Moolayember (C14020SP, C18003SP) formations will be used to monitor water level, pressure and quality data, and stratigraphic and hydraulic parameter information in the near surface aquifers in the vicinity of the Doongmabulla Springs-Complex. As described in the GDEMP (Version 12A), as part of the new nested bore installation, Adani will install one hole below the Rewan Formation in the vicinity of the Doongmabulla Springs-Complex within the Permian Betts Creek Beds (which includes the Bandanna and Colinlea). These bores will gather water level, pressure and quality data and stratigraphic and hydraulic parameter information in deeper Permian units. The monitoring data collected will be used to develop updated potentiometric surfaces of potential source aquifers to contribute to an improved understanding of source aquifers and the relative contributions, feeding into a synthesis of source aquifer information that will be undertaken as part of the development of spring wetland hydro(geo)logical conceptualisations (RP1.4). The assessment of background trends and influences will take a more regional focus and will collect data on background trends and existing (third-party) use in potential source aquifers.

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4.2.3 RP1.2: Geochemical survey The objective of the geochemical survey is:

 To contribute to an improved understanding of the source aquifers to the springs and their flow paths and relative contributions.

For the most robust chemical classification of a spring source aquifer, sampling and analysis of spring discharge water at a number of vents within a spring complex will be combined with sampling and analysis using dedicated bores in all potential source aquifers of a spring complex. The sampling and analysis will provide data to allow an assessment of geochemical types, evolution along the flow path, and the identification of potential mixing of aquifer sources in the spring discharge water.

The survey will cover the variety of vents and wetlands that occur within the complex, with multiple sampling points in all spring groups (Moses, Little Moses and Joshua) and in all designated groundwater monitoring points for the Doongmabulla Spring Complex (see GDEMP and GMMP) and bores in all potential source aquifers, including Permian bores to the west of the mining lease. The geochemical sampling for RP1.2 will occur at quarterly intervals over a period of one year, with ongoing water quality monitoring as specified in the GDEMP, to be determined on the basis that the geochemical sampling will continue until a robust dataset is established.

Groundwater and surface water sampling will be conducted in accordance with respective guidelines (DES 2018, Sundaram et al. 2009, AS/NZS 5667.11:1998 (R2016)). Geochemical characterisation will include total dissolved solids, pH, major cations and anions, bromide, sodium adsorption ratios, forms of nitrogen, total phosphorus and selected radioisotopes (deuterium, oxygen-18, carbon-13, carbon-14, strontium-86, strontium-87 and radon-222). This approach is consistent with that adopted by OGIA for the Surat Basin springs investigations (KCB 2012, Lyons et al. 2015, Flook et al. in prep), being the best known approach available (as at August 2019). Before geochemical survey commences, the researcher/s will conduct an additional review of the latest water quality sampling parameters and analysis methods. The researcher/s will provide analysis in any report about the geochemical survey justifying the proposed monitoring locations, analytical suite and investigation methods, including isotopes, to inform the source aquifer/s for the Doongmabulla Springs Complex.

The data obtained from the geochemical survey will be combined with the results of the hydrogeology review (RP1.1), geological mapping (RP1.3) to feed into the development of spring wetland hydro(geo)logical conceptualisations (RP1.4).

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4.2.4 RP1.3: Geological mapping The objective of the geological mapping is:

 To contribute to an improved understanding of the source aquifers to the springs, their pathways and relative contributions by developing more detailed maps of the surface geology and by preparing refined geological cross-sections in proximity to the springs to the depth of the available and augmented boreholes.

Geological mapping is considered important in the context of the Doongmabulla Springs Complex for a number of reasons. Principally, on-ground geological surveys can provide evidence in support of source aquifer characterisation by visually confirming the presence of an outcrop of a particular confining strata, or identification of the outcrop of the source aquifer itself. Furthermore, geological mapping may delineate structural features or geological contacts that may have a role in spring discharge mechanisms.

Although broad-scale surface mapping is available in the vicinity of the Doongmabulla Springs Complex and via the Galilee 1:250,000 geological map sheet (DND, 1972), this mapping does not capture the exact outcrop extents in the vicinity of the Doongmabulla Springs Complex nor any local scale structural features.

The geological mapping undertaken in this research will prepare surface geology maps at a scale of 1:25,000 or finer over an area of approximately 30 km2 to focus on the Doongmabulla Springs Complex. The mapping will be complemented by the collected of detailed topographic data (e.g. LIDAR) to a vertical accuracy of at least +/- 15 cm for RP1.4, which can be used to provide detail on the geomorphology of the survey area.

In addition to on-ground surveys, the geological mapping will include an examination of lithological logs from the hydrogeology review (RP1.1) and applying geophysical methods (via new surveys using seismic, TEM and/or resistivity techniques) to generate a refined understanding of formation surfaces, lithology and hydraulic properties. Ground geophysics proved useful in identifying geological structures, such as faults, to inform an understanding of source aquifers in the Surat Basin spring studies (Flook et al. in prep.) and the geophysical survey carried out for RP1.3 will employ the same techniques. As an output of this task, refined geological cross-sections will be prepared to the depth of the available and augmented boreholes in the vicinity of the Doongmabulla Springs Complex.

The data obtained from the geological mapping will be combined with the results of the hydrogeology review (RP1.1), geochemical survey (RP1.2) to develop refined spring wetland hydro(geo)logical conceptualisations (RP1.4).

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4.2.5 RP1.4: Spring wetland hydro(geo)logical conceptualisation and water balance The objective of the wetland hydro(geo)logical conceptualisation and water balance is to develop a refined understanding of:

 background trends and influences in spring wetland hydrology;  source aquifer contributions; and  relationships between groundwater pressure and spring hydrology.

This work will involve several scope elements:

 installation of weather monitoring (rainfall, temperature and relative humidity);  completing detailed topographic surveys (e.g. LIDAR) to a vertical accuracy of at least +/- 15 cm to develop a digital elevation model of the landscape and measure the bathymetry of key wetland storages and flow channels;  installation of surface water gauging (level and/or flow) at key sites to measure surface inflows and outflows;  initiation of wetland area monitoring, which will be a combination of both field-based (e.g. GPS tracking surveys of a wetland area based on vegetation type and soil saturation, Fensham and Fairfax 2009) and remote sensing-based techniques (e.g. use of a range of high resolution and multispectral imagery to generate metrics such as the normalised difference vegetation index);  development of a spring wetland typology to group spring wetland types based on similar hydrological and ecological characteristics (see RP2.1);  synthesis of source aquifer investigations, using inputs from RP1.1, RP1.2, RP1.3 and the hydrological data collected to test multiple hypotheses and rule out (where possible) implausible hypotheses, for each spring wetland type;  develop hydro(geo)logical conceptualisations for each spring wetland type which describes inputs from source aquifer(s), and water balance dynamics, including the development of the relationship between groundwater pressure and wetland hydrology.

The work will cover the variety of wetlands within the Doongmabulla Springs Complex and identify key sites for ongoing monitoring. A spring wetland typology, similar to that developed for Surat Springs (OGIA 2015) but tailored to Doongmabulla Springs Complex, will be developed as a means to target key sites and assist with the conceptualisation. The typology will be developed in tandem with RP2.1 so the wetland types are defined by their ecological and hydrological characteristics.

The initial tasks for RP1.4 focus on the collection of topographic and hydrological data. This data, along with data collected in the preceding research packages, will be synthesised to make a series of interpretations which lead to a refined understanding of the hydro(geo)logy of the spring wetlands within Doongmabulla Springs Complex. Firstly, a spring wetland typology will be developed to group spring wetlands into types based on similar hydrological and ecological characteristics (e.g. outcrop vs discharge springs, permanent vs semi-permanent). Secondly, the source aquifer synthesis will follow a logic similar to Flook et al. (in prep.) in which multiple lines of evidence from geology and geophysics (RP1.3), hydrogeology (RP1.1), geochemistry (RP1.2) and surface hydrology (RP1.4) are combined to test multiple hypotheses relating to the source aquifers supporting each spring wetland

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Great Artesian Basin Springs Research Plan type; i.e. alternative conceptualisations will be identified and evaluated. Thirdly, conceptual hydro(geo)logical models will be developed for each spring wetland type. These models will detail the water balance dynamics of the wetland and will describe the relationship between groundwater pressure change in the source aquifer(s) and wetland hydrology; i.e. they will define the implications to a spring wetland’s hydrology for a given reduction in groundwater pressure.

The scale of the hydro(geo)logical spring wetland conceptualisations is local and they are separate to the regional hydrogeological conceptualisations carried out under RP1.6. However, the spring wetland conceptualisations will be linked to updated groundwater modelling studies as they can be used to define the hydrological changes associated with predicted groundwater pressure change.

Additionally, the monitoring undertaken by this work package will be used to quantify the background trends and influences regarding the dynamics of spring wetland hydrology, to contextualise predicted hydrological changes from project activities.

4.2.6 RP1.5: Rewan Formation connectivity investigations In relation to the GABSRP, the objective of the Rewan Formation connectivity investigations is:

 To provide an improved understanding of the hydraulic connectivity of the Rewan Formation and its ability to provide an effective barrier to groundwater pressure reductions in the Permian sandstone units of the Galilee Basin caused by mine dewatering. This work encompasses a series of investigations being carried out under the RFCRP, which details their scope and objectives.

4.2.7 RP1.6: Regional hydrogeological conceptualisation review and updated groundwater modelling This research package will be undertaken as part of the GMMP and GDEMP but is closely linked to the GABSRP. It will require inputs from the GABSRP, and its outputs will be used by the GABSRP.

The hydrogeological conceptualisation review and updated groundwater modelling is to occur after the above GABSRP work packages are completed. Its objectives (in addition to those outlined in the GMMP and GDEMP) are:

 To review and refine the hydrogeological conceptualisation of the Doongmabulla Springs Complex (based on the preceding research packages) by describing the source aquifers, their relative contribution to spring discharge, the background trends and influences which also affect spring discharge and the nature of the hydraulic connectivity to the Permian sandstone aquifers of the Galilee Basin;  Undertake updated groundwater modelling that represents the reviewed conceptualisation and prepares a set of revised drawdown predictions for the source aquifer due to project activities; and  Produce a revised set of predictions of changes to wetland hydrology due to project activities by linking the model outputs to the wetland water balance developed in RP1.4.

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The study is to include uncertainty analysis, such that a range of plausible outcomes to wetland hydrology are produced.

4.2.8 RP2.1: Ecological surveys and monitoring Ecological surveys with ongoing monitoring at the Doongmabulla Springs Complex has the following objectives:

 In addition to research undertaken to date, to further describe and quantify the ecological composition of the communities that depend on spring discharge;  To assess the abundance/cover and condition/stress of key species and invasive species and identify other (non-hydrological) background influences and trends on these metrics, such as land use;  To examine the relationship between ecological composition/abundance and wetland hydrology and chemistry;  To develop a typology that groups similar types spring wetlands based on their ecological and hydrological characteristics;  To initiate ongoing monitoring of the abundance/cover and condition/stress of key species at designated monitoring points;

The ecological surveys will align with the pre-impact (initial) surveys and ecological monitoring tasks specified in GDEMP. Initial surveys will be undertaken at all four main wetland areas in the Moses Springs-group, the main wetland area in the Little Moses Springs-group, Joshua Spring and at least 10 mound springs in the Moses Springs-group. Initial surveys will be repeated at quarterly intervals over the first two years of the research program.

For the purposes of the GABSRP, the surveys will focus on the key species which contribute to the environmental values at Doongmabulla Springs Complex; i.e. those which are endemic, those which are covered under the EPBC listing and the Waxy Cabbage Palm. However, it will also be important to survey and monitor invasive species that can adversely affect habitat condition; particularly for Hymenachne which is listed as a Weed of National Significance.

The typology developed will occur in concert RP1.4 because the spring wetland types should be defined in terms of their hydrology and ecology. Additionally, the ranking of springs in terms of their ecological condition and degree of endemicity might be a useful means of prioritizing springs to target more effectively in the ongoing monitoring program.

The surveys and the ongoing monitoring program will be designed to provide a robust framework for monitoring of temporal changes to spring ecological condition. The parameters and methods selected must be repeatable and replicated sufficiently across the complex to allow for replication by a third party if required.

The results of the survey will feed directly into the Hydro-ecological conceptualisation undertaken in RP2.2.

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4.2.9 RP2.2: Hydro-ecological conceptualisation and assessment of key species This research package will follow the ecological survey (RP2.1), the wetland hydrology studies (RP1.1) and the updated groundwater modelling (RP1.6). Its objectives are:

 To conceptualise the relationships between the hydrology of the wetlands, the ecology of the key species and how these are influenced by natural drivers, anthropogenic drivers and project- related stressors;  Define the ecological water requirements of key species and ecological response thresholds that can be linked to hydrological indicators;  Determine if the predicted hydrological changes will result in ecological impacts; and  Describe the nature of these impacts, relative to background trends and influences.

This research package is the culmination of the preceding research activities to present an updated prediction of potential impacts to the GAB Springs Community at Doongmabulla Springs Complex from project activities, in the context of other background trends and influences. It is recommended that control-stressor diagrams, as outlined by IESC (2015), be used to describe the relationship between hydrology of the spring wetlands and the ecology of key species. The GDE Toolbox (Richardson et al. 2011) outlines methods that can be used to define ecological water requirements.

The exact methodology used to determine ecological water requirements will be determined as part of the assessment and be specific to the ecological endpoint being studied; but essentially the process will include a description of the lifecycle of the ecological endpoint, its use of water throughout this lifecycle and the ecological implications associated with a change in hydrology. For example, certain vegetation species may require perennial saturation to outcompete other species and the introduction of wetting and drying cycles may adversely impact the abundance of the species. In other cases, species may be able to withstand dry periods if they are not too prolonged. Such relationships will be described by the ecological water requirements and be underpinned by the ecological and hydrological data collected in the preceding work packages.

Ecological water requirements will be defined using a measurable hydrological metric (e.g. groundwater levels at designated bores) for each ecological endpoint, and this metric will be used to define the degree of hydrological change from project activities that is tolerable (i.e. an ecological threshold will be established). The assessment of background hydrological trends and influences (which cause natural fluctuations) will be part of this determination. The research outcomes under this package about ecological water requirements and response thresholds defined will directly inform both monitoring and management of impacts to the Doongmabulla Springs Complex, as managed under an updated GDEMP. The sections of the GDEMP that describe how the results of the GABSRP will inform an updated GDEMP are:

 Section 4.3.1 about the hydrogeological conceptual model;

 Section 5.9 about additional studies, research and the model re-run, including section 5.9.2 that describes the relationship between the GDEMP and this document;

 Section 8.3.1 about the conceptual groundwater model and Doongmabulla Springs Complex;

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 Table 8-12 describing management actions for the Doongmabulla Springs Complex, whereby actions will incorporate research outcomes from this GABSRP to inform GDEMP implementation; and

 Table 10-1 about reporting requirements of other management plans with linkages to the GDEMP – the third row describes that this GABSRP informs ecological triggers, monitoring and management through adaptive processes in the GDEMP.

4.2.10 RP3.1: Desktop prevention and mitigation scoping study This research package has the following objectives:

 To review potential prevention and mitigation options and their feasibility for application to Doongmabulla Springs Complex.

In this context, prevention methods are those which aim to prevent any groundwater drawdown to source aquifers (i.e. those which prevent impacts) and mitigation methods are those which aim to lessen the magnitude of groundwater drawdown in source aquifers and/or hydrological changes in spring wetlands to acceptable levels (i.e. those which mitigate impacts).

The desktop mitigation scoping study will identify and review available prevention and mitigation methods (including those being trialled and implemented in the Surat Basin) to assess their feasibility for application to Doongmabulla Springs Complex.

The prevention and mitigation methods reviewed by the scoping study will include:

1. Managed aquifer recharge via alteration of surface recharge processes 2. Managed aquifer recharge via groundwater injection 3. Offsetting existing groundwater extraction by third-parties 4. Alteration of surface hydrology (environmental watering)

Method 1 involves the techniques aimed at artificially recharging unconfined aquifers though the harvesting and impoundment of surface water at designated, enhanced recharge points in the landscape. The technique may be suitable where the source aquifer lies at or very close to the ground surface and sufficient surface water can be harvested upgradient of the impacted spring wetland. Potential limitations and disadvantages of this method concern the availability of surface water in sufficient volumes, the suitability of the local hydrogeology and impacts associated with any engineering works required.

Method 2 involves the injection of water (from a defined surface water or groundwater source) to source aquifers via designated injection wells. This technique aims to prevent or mitigate impacts either by augmenting any reduction in groundwater storage in the source aquifer or by creating a pressure barrier to locally prevent or minimise groundwater pressure reductions. Potential limitations and disadvantages of this method include: the availability of water sources for injection; water quality considerations with respect to ecological endpoints; issues associated with well and aquifer clogging due to physical, chemical and microbial processes; and impacts associated with any engineering works required.

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Method 3 involves offsetting of any groundwater pressure reduction by the capture of equivalent groundwater volumes in the source aquifer through the purchase of existing groundwater entitlements and/or the capping of uncapped artesian bores. Offsetting groundwater extraction is a well-established technique to restore aquifer pressure and spring flows in the GAB. The offsetting could occur via the relocation of existing water bores, via the purchasing of entitlements that are not needed, via strategies aimed at reducing current third-party usage through water use efficiency gains (e.g. capping bores or reducing evaporation losses from pumped water). Potential limitations and disadvantages of this method include: the availability of existing third-party use within the zone of hydrogeological influence for the source aquifer; and socio-economic costs to third-parties.

Method 4 involves altering surface water flows to artificially inundate or irrigate impacted springs or to minimise surface water losses from spring wetlands. Examples include: alterations to spring wetland outlets to encourage a more prolonged or deeper impoundment of surface water; the creation of a weir or regulating structure across a watercourse and the redirection of this water via pumping or gravity to the spring wetland; the construction of contour banks to direct runoff to spring wetlands. The changes to surface hydrology could be major or minor depending on the technique employed and will likely vary between different spring wetlands according to the existing hydrological environment. Potential limitations and disadvantages include: the ability of surface hydrological changes to offset groundwater pressure and flow reductions; and impacts associated with any engineering works required, including downstream impacts.

The scoping study will develop multiple conceptual designs for application of each of the above methods to Doongmabulla Springs Complex and undertake a high-level cost benefit analysis as a first-pass feasibility assessment by considering: a) their likely effectiveness; b) practicality of implementation; and c) risks of implementation to environmental, social and cultural values of the Doongmabulla Springs Complex or other receptors related to the option being considered (e.g. third- party users in the aquifer from which additional water is sourced). The scoping study will also design pilot testing trials in which feasible methods can be tested.

4.2.11 RP3.2: Pilot testing of prevention and mitigation methods This research package will involve pilot testing of feasible methods (as identified and scoped by RP3.1). For example, a pilot test for well injection may involve the drilling and construction of an injection well, several monitoring wells, the development of a temporary water supply for injected water, and an injection trial. However, it is possible that an injection trial may not be deemed as being feasible, and other forms of pilot testing will take place. These details will be scoped as part of RP3.1

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4.2.12 RP3.3: Prevention and mitigation strategy The objective of this research package is to develop a prevention and mitigation strategy for the Doongmabulla Springs Complex.

The research package will undertake the following tasks:

 Synthesise the findings of RP3.1 and 3.2 to identify feasible and effective prevention and mitigation methods;  Develop detailed designs for their implementation

The outcome will be a prevention and mitigation strategy, which is then linked to the trigger- response framework in the GDEMP and implemented. The prevention and mitigation strategy will provide a summary of any feasible and proven prevention and mitigation measures, and these will be listed or referred to in the GDEMP, and implemented should any monitoring triggers be exceeded.

4.2.13 RP4.1: Desktop offset scoping study The objective of this research package is to undertake a desktop review all GAB spring communities in the Galilee Basin to identify which of these sites may be most suitable for remediation methods to be applied as an offset action. The desktop review will consider:

 Available records of the ecology present, in terms of the EPBC-listed species which may be impacted by project activities at Doongmabulla Springs Complex;  The condition of the ecology present;  The hydrogeology of the source aquifers contributing to these springs;  Existing pressures on the GAB springs community at these springs (e.g. land use, grazing, weeds and pests, third party groundwater use); and  The suitability of these sites for species relocation/repopulation from Doongmabulla Springs Complex.

The above information will be reviewed to identify and prioritise sites where remediation activities can potentially be deployed, and a short-list of target sites will be developed for targeted field investigations aimed at better understanding the potential for remediation activities to offset impacts at Doongmabulla Springs Complex.

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4.2.14 RP4.2: Targeted ecological surveys In this research package, ecological surveys will occur at the target sites identified by RP4.1. The targeted ecological surveys will build on ecological surveys and monitoring at the Doongmabulla Springs Complex under RP2.1

The surveys will:

 Record the presence/absence, abundance/cover and condition/stress of key species (EPBC-listed species in the GAB Springs Community);  Record the presence of invasive species;  Record the condition of the wetland and identify identify other (non-hydrological) background influences and trends on these metrics, such as grazing pressures;  Map the spring wetland extents.

The above information will be used, along with the findings of research package 2.1 and 4.3 to determine the:

 Composition of GAB springs communities;  Ecological water requirements for the GAB Springs Community at these sites; and  Habitat suitability for relocated species from Doongmabulla Springs Complex.

4.2.15 RP4.3: Targeted hydro-ecological studies In this research package, hydro-ecological studies will occur at the target sites identified by RP4.1. The studies will:

 Obtain detailed topographic data via remote sensing (e.g. LIDAR);  Collect and collate potentiometric data from existing monitoring infrastructure;  Assess relationship between groundwater pressure and spring wetland hydrology; and  Develop hydro-ecological conceptualisations of the GAB Springs Community.

The above information will be used, along with the findings of RP4.2, to:

 Determine ecological water requirements and ecological response thresholds for the GAB Springs Community; and  Identify opportunities for remediation and offset actions in RP4.4.

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4.2.16 RP4.4: Remediation assessment and trial In this research package, potential remediation and offset actions will be scoped and trialed to evaluate their effectiveness. The research package will:

 Review the findings of RP4.1, RP4.2 and RP4.3 to outline feasible remediation and offset options;  Develop the scope of trials to be undertaken to the effectiveness of the options identified;  Undertake trials to evaluate the effectiveness of the options to remediate and offset impacts.

The remediation methods will consider actions that are aimed at reducing existing pressures (such as land use pressures from grazing, weeds and pests) to remediate the habitat of the impacted communities such that they are more resilient to any hydrological changes brought about by project activities. Examples of remediation methods may include the installation of fencing to control pests or the establishment of weeding and planting programs.

The offsets considered under this research package concern actions at other GAB springs in the Galilee Basin (not impacted by project activities) where the habitat of the GAB springs community may be remediated to offset any impacts at Doongmabulla Springs Complex. The relocation of impacted species is one offset method that will be considered, in addition to the application of remediation methods (e.g. fencing, weeding, planting) at these other sites.

This research package will draw on the findings of RP4.1, RP4.2 and RP4.3 to identify possible remediation and offset options and evaluate their feasibility by undertaking a high-level, desktop, cost-benefit analysis as a first-pass feasibility assessment by considering: a) their likely effectiveness; b) practicality of implementation; and c) risks of implementation to environmental, social and cultural values of GAB springs or other receptors related to the option being considered (e.g. third- party users in the aquifer from which additional water is sourced).

Based on the outcomes of the desktop review, pilot trials will be undertaken to test the effectiveness of the methods selected. The trials undertaken in this research package will occur at Doongmabulla Springs Complex and potentially at the sites investigated by RP4.2 and RP4.3, depending on the feasibility of the options identified.

4.2.17 RP4.5: Remediation and offset strategy In this research package, the findings of remediation assessment and trial will be synthesised to form a remediation and offset strategy, which is then linked to the trigger-response framework in the GDEMP and implemented. The remediation and offset strategy will provide a summary of any feasible and proven remediation and offset measures, and these will be listed or referred to in the GDEMP, and implemented should any monitoring triggers be exceeded.

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4.3 Research proposal assessment criteria

Proposals will be sought to complete the research packages listed in Section 4.2. Successful proposals are to be selected according to the following criteria:

 Presentation of an appropriate methodology to meet the scope and objectives of the research package in a robust, reliable and repeatable manner that allows for ongoing temporal assessment.  The potential application or usability of research outcomes beyond the scope of the Carmichael Coal Project.  Capability and experience in undertaking similar research.  Ability to leverage value from other research programs.  Ability to meet the GABSRP timelines.

4.4 Implementation schedule

The implementation schedule for the research packages is presented in Figure 4-2.

The research program will commence on the excavation of the first box cut with an initial, 5-year research effort anticipated. The need for ongoing research will be evaluated after the initial 5-year period, on the basis of whether the research undertaken has met the objectives of the plan as specified, or whether some knowledge gaps remain and require further investigation. The program will cease when it is determined that the research undertaken has satisfactorily met the objectives of the plan.

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Research effort Ongoing activities during mining Research Package (RP) RP Dependencies Year 1 2 3 4 5 undertaken as part of GDEMP and GMMP

RP1.1: Hydrogeology review and monitoring Ongoing monitoring as outlined in GMMP RP1.2: Geochemical survey Repeat surveys every 5 years

RP1.3: Geological mapping

RP1.4: Spring wetland hydro(geo)logical conceptualisations and water balance 1.1, 1.2, 1.3, 1.4

RP1.5: Rewan Formation connectivity investigations Refer to RFCP for timing RP1.6: Hydrogeological conceptualisation review and updated groundwater modelling 1.1, 1.2, 1.3, 1.4, 1.5 Ongoing modelling as part of the GMMP

RP2.1: Ecological surveys and monitoring Ongoing monitoring as part of GDEMP RP2.2: Hydro-ecological conceptualisation and assessment of key species 1.4, 2.1

RP3.1: Desktop prevention and mitigation scoping study All above

RP3.2: Pilot testing of prevention and mitigation methods 3.1

RP3.3: Prevention and mitigation strategy 3.1, 3.2

RP4.1: Desktop offset scoping study As per 3.1

RP4.2: Targeted ecological surveys 2.1 4.1, 4.3 RP4.3: Targeted hydro-ecological studies 4.1, 4.2

RP4.4: Remediation assessment and trial 4.1, 4.2, 4.3

RP4.5: Remediation and offset strategy 4.4

Figure 4-2 Implementation timeline and dependencies of GABSRP research packages

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4.5 Priority actions for potential offsets to protect and manage the GAB Springs

4.5.1 Offsets An Environmental Impact Statement (EIS) was prepared in accordance with the bilateral agreement between the Commonwealth and Queensland Governments, with the objective of avoiding or mitigating potentially adverse impacts on environmental, social and economic values and enhancing positive impacts. Where there were unavoidable residual impacts, offsets were proposed in accordance with Commonwealth and Queensland Government policies. Adani worked closely with stakeholders and undertook a range of technical, environmental, social and cultural investigations to develop the EIS, which described the current environment, the Project's environmental impacts and ways of avoiding, mitigating or offsetting these impacts.

A Biodiversity Offset Strategy (BOS) was approved in October 2016, describing the required offsets for unavoidable residual impacts to Matters of National Environmental Significance. In addition, Offset Area Management Plans have been developed to describe the management and monitoring of offset delivery.

The Groundwater Dependent Ecosystem Management Plan (GDEMP) also describes management of relevant GAB Springs. The purpose of the GDEMP is to minimise and manage the environmental impacts of the project on listed groundwater dependent species and ecosystems, through the development of mitigation and monitoring measures for implementation prior to construction, during construction, during operations, during offsetting and post operations.

These documents include requirements for ecological and groundwater offsets, relevant to GAB Springs. The below sections outline these requirements, as well as priority offset actions under this plan.

4.5.2 Ecological offsets The GDEMP describes priority actions for offsets to protect and manage GAB Springs for the following ecological matters:

 Livistona lanuginosa (Waxy Cabbage Palm)  Carmichael River, and its riparian zone between the Doongmabulla springs and the Belyando River  The community of native species dependent on discharge from the Great Artesian Basin (Doongmabulla Springs Complex).

Under the GDEMP, an investigation must occur if a trigger is reached. If a trigger is exceeded, an investigation will be conducted to determine whether the detected result has been caused by mining activities. The investigation will include consideration of groundwater monitoring data, surface water flow and quality data and ecological data collected. The investigation will focus on determining whether an observed decline in the matter is caused by the project, and will involve:

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 A review of groundwater monitoring data to determine the potential for drawdown to be impacting the matter  Site-specific investigations involving the collection and interpretation of additional data  A review of relevant data related to potential non-mining causes of variability in environmental variables (e.g. climatic data)  Developing a detailed model of relevant environmental variables  Expert opinion on the potential for environmental harm.

If the investigation assessment finds disturbance to the differs from that approved in the BOS, the priority actions for offsets are:

 Amending the BOS within 30 days from when triggered; and  The amended offset delivered within 12 months from the amended BOS date.

4.5.3 Groundwater offsets The GDEMP is consistent with the project Groundwater Management and Monitoring Plan (GMMP), and describes priority offset actions for groundwater at the Doongmabulla Springs Complex. The GDEMP and GMMP outline groundwater triggers for investigations. If an investigation indicates that there is a risk of impacting the Doongmabulla Springs Complex beyond the current project approval, the BOS will be reviewed, and a report prepared within 3 months to identify the actual impact to the Doongmabulla Springs Complex from the mining activities. If the assessment finds that unapproved impacts to the Doongmabulla Springs Complex will occur, the BOS will be amended within 30 days and the amended offset delivered within 12 months.

Priority offset actions, if required, will include:

 Rehabilitation of GAB springs wetland communities, in re-activated springs complexes within the Barcaldine Supergroup, to the same quality as baseline measures for the Doongmabulla Springs Complex wetland communities that become degraded due to groundwater drawdown  Translocation of threatened and Doongmabulla Springs Complex endemic flora and fauna species to rehabilitated and / or alternative spring habitats within the Barcaldine Supergroup  Incorporate information from the GAB Springs Research Plan into translocation and rehabilitation measures for offsetting the Doongmabulla Springs Complex wetland communities  Directing research priorities under this plan in relation to mitigation strategies and offset requirements.

In the event that groundwater drawdown thresholds for the Doongmabulla Springs Complex are exceeded, an investigation into the cause will be undertaken and the administering authority notified within 28 days of the detection. During this time mining activities will be limited to current activities (no expansion or mining of new areas), until the investigation determines the cause of the trigger level exceedance and also to ensure the drawdown impact interim threshold to 0.2m as per EPBC Act condition 3 (d) is not breached.

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If the investigation identifies mining activities as the cause, an assessment into the known or likely impacts will be undertaken and mitigation measures identified. Adaptive management measures to be implemented include, but are not limited to:

 Limit mining activities to current activities, until monitoring indicates the trigger level(s) are no longer being exceeded, or at further risk of exceedance.  Recharge springs using suitable quality groundwater in compliance with the EA.  Implementation of prepared and approved BOS and Offset Management Plan.

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5 Review, resourcing and reporting

5.1 Independent review of this plan

Condition 25 states this plan must include “a peer review of the draft GAB Springs Research Plan, by a suitably qualified independent expert and a table of changes made in response to the peer review”.

“Suitably qualified independent expert” means “a person who has professional qualifications, training, skills or experiences related to the nominated subject matter and can give authoritative assessment, advice and analysis on performance relative to the subject matter using the relative protocols, standards, methods or literature”.

This version of the plan has been independently reviewed by:

 Ned Hamer, BSc Hons, Principal Hydrogeologist with Earth Search with 24 years of experience; and  David Stanton, BSc Hons, Principal Landscape Ecologist with 3D Environmental with 24 years of experience Comments and issues raised by the independent reviewers are included in Appendix 2 alongside a response on what changes were made to this plan in response to those comments.

5.2 Personnel responsible for conducting research and qualifications

Condition 25 states this plan must include “(c) Personnel responsible for conducting research and their qualifications”.

Person/s implementing research activities described in this plan will have appropriate skills and qualifications as relevant to that line of research or monitoring.

Research leaders will have greater than 5 years of experience in the design, implementation and reporting of similar research projects including relevant academic qualifications and attributable publications. In addition to this broad experience, it is expected that research leaders will have expertise relevant to the specific research activity being supervised.

Research team members will have at least 2 years relevant experience in participating in research programs post obtaining relevant qualifications for the field of research in which they are participating under this plan. In particular, ecologists/botanists participating in research activities will be familiar with the threatened flora species associated with the Doongmabulla Springs Complex. Likewise, it is expected that research undertaken on hydrogeological matters is done so by qualified and experienced hydrogeologists. It is also recommended that research leaders have published material within peer review journals regarding their selected disciplines.

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In addition to project staff minimum experience it is envisaged that the internal management and technical review of these studies within the responsible consulting / contractor organisation will completed by staff with significantly greater relevant experience.

There exist 5 specific scientific disciplines that cut across the work packages, the expected expertise and experience for each discipline is described in the table below.

Table 5-1 Expected expertise and experience for discipline research leaders

Discipline Required expertise and experience Geology / Work packages require geologists that have specific experience field mapping and analyses of geomorphology data sets that can specifically; and soils 1) Identify sub surface features (e.g. faults and contacts) that are physically related to surface features 2) Map and identify geological, geomorphologic and soil units of the Galilee and GAB basins 3) Conduct surface and sub surface geophysical surveys and surface and sub surface soil surveys (in regard to soil, by a suitable qualified soil scientist) 4) Interpretation of outcropping strata and drill core to identify geological, lithological, geomorphological and soil units 5) Develop 3D representation of the surface and sub surface geology and structures within suitable software 6) Interpretation of the changes in soil units associated with the immediate spring wetland and adjoining soils within Galilee and GAB basins Hydrogeology Work packages require hydrogeologists that have specific experience in; 1) Investigating the source aquifer for groundwater discharge zones (spring wetlands), ideally within the Galilee and GAB basins. 2) Installation of groundwater monitoring wells into multi aquifer and artesian settings, adhering to all required specifications. 3) Interpretation of groundwater data related to pressure, groundwater flow direction and groundwater flow volumes. In order to distinguish likely groundwater flow paths associated with different aquifers and to surface discharge zones 4) Conduct and interpret groundwater re injection trials Hydro- Work packages require hydro-geochemists that have specific experience in geochemistry 1) Identifying the source aquifer / aquifers of water within groundwater bores through geochemical sampling and analyses within the Galilee and GAB basins 2) Interpreting the source aquifers for discharge water sampled within spring wetlands within the Galilee and GAB basins 3) Conducting field sampling programs to required specifications Ecology Work packages require ecologists that have specific experience in; 1) The identification and mapping of flora and fauna species associated with spring wetlands of the Galilee and GAB basins and what are the drivers to the composition and abundance within spring wetlands. 2) The analyses of these data to assess the condition and hydrology of the spring wetland 3) Interpreting changes in the ecology of spring wetlands through remote data sets such as aerial photography and remote sensing

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Discipline Required expertise and experience Hydrogeological / Work packages require hydrogeologists / ecologists that have specific experience in ecological 1) Interpreting multi-disciplinary data sets to establish hypothesis regarding the specialist relationship between groundwater flow and the ecology of the spring wetlands, and how the ecology may be affected if groundwater regimes were to change within the Galilee and GAB basins 2) The development of water balances of spring wetlands that considers the uncertainty of data (e.g. probabilistic outputs) and assess the likely water requirements of specific ecological communities and or species within the spring wetland. 3) The development of monitoring programs that link changes in the groundwater regime associated with a spring wetland to changes in either the hydrology, soil and ecology of the wetland 4) The development of management programs that are directly related to adaptive decision processes associated with determining and or implementing mitigation and or off set measures

5.3 Reporting and data provision

Adani will prepare an annual summary report on the implementation of this plan. The annual report will:

 summarise the activities implemented under the plan, including the personnel responsible for conducting any research and their qualifications;  discuss the effectiveness of research outcomes in addressing the uncertainties outlined in this plan;  assess the activities and research outcomes against the objectives in section 1.4; and  describe any further research requirements to meet the objectives.

When the research effort outlined in the plan has concluded (after the initial 5-year research effort), the annual report will also evaluate the need for ongoing research based on whether the research undertaken has met the objectives of the plan as specified, or whether some knowledge gaps remain and require further investigation.

The GDEMP and the GMMP will be revised based on the annual GABSRP reports and the reporting outputs of the research packages.

Adani will conduct periodic audits to monitor compliance with Research Plan commitments, in accordance with the Adani quality system. Adani will integrate the plan commitments with other relevant research and management plans, to avoid actions being overlooked.

The plan will be published on Adani’s website for the life of the project. Research outputs will be submitted to the Minister within ten business days of completion and be made available for the Bioregional Assessment of the Galilee Basin sub-region and the Lake Eyre Basin and any subsequent iterations.

Adani anticipates receiving requests for the use of data generated through research activities under this plan. Data sharing agreements will be implemented to facilitate the beneficial use of this data

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across similar research programs. Similarly, Adani commits to using data from other, relevant research activities to inform the research undertaken as part of this plan.

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Fensham, R.J., Silcock, J.L., Laffineur, B., MacDermott, H.J. 2016, Lake Eyre Basin Springs Assessment Project: Hydrogeology, cultural history and biological values of springs in the Barcaldine, Springvale and Flinders River supergroups, Galilee Basin springs and Tertiary springs of western Queensland. Report to Office of Water Science, Department of Science, Information Technology and Innovation, Brisbane.

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Appendix 1 - Compliance matrix

Description of EPBC 2010/5736 Condition How Addressed Section of GAB 25 Springs Research Plan

At least three months prior to commencing This GAB Springs Research Plan was first lodged to the Commonwealth Department of the Environment and Energy on 26 July 2018. Three months from the Entire plan excavation of the first box cut the approval submission date is 26 October 2018 meaning the condition has been met. holder must submit for the approval of the Excavation of the first box cut has not commenced, as at August 2019, in accordance with the approval condition. Minister a GAB Springs Research Plan …

… that investigates, identifies and evaluates The plan includes a research framework (presented in Section 3) to addressing the objectives of the condition; i.e. it presents a systematic assessment Section 3 methods to prevent, mitigate and remediate approach to identifying the nature of impacts the hydrology of the springs; what these changes might mean for spring ecology, the identifying, investigating Table 3-1 ecological impacts on the EBPC listed and evaluating how these ecological impacts can be prevented or mitigated; or remediated or offset.. community of native species dependent on Section 4 The research packages to meet these objectives are listed and described in Section 4. natural discharge of groundwater from the Great Artesian Basin (GAB Springs community), …

… including the Doongmabulla Springs Section 1.4 explains the scope of this research plan applies to GAB Springs Communities which intersect the Galilee Basin. The EPBC Act defines the GAB Section 1.4 Complex, in the Galilee Basin Springs Community as “…the community of native species dependent on natural discharge of the groundwater from the Great Artesian Basin, listed as Figure 1-2 threatened ecological community under the EPBC Act”. The “Doongmabulla Springs Complex” is defined as “the groundwater-fed springs located approximately 8 kilometres from the western edge of the mining lease boundary and consisting of springs within the spring groups identified on page 108 of the Coordinator-General’s Assessment Report. Therefore, the scope of this research plan applies to GAB spring communities which intersect the Galilee Basin (shown in Figure 1 2).

The GAB Springs Research Plan must include Section 1.51 explains that the research outlined in this plan aims to builds on existing research, and is designed to complement other relevant GAB Springs Section 1.5.1 but is not limited to the following: research programs. Section 2 provides a description of existing scientific research on GAB spring hydrogeology and ecology is provided. How this research is Section 2 to be used is described in Section 4. a) Research aims and rationale with Section 4 reference to existing scientific research on GAB spring hydrogeology and ecology

b) Identify priority actions for potential Section 4.5 describes the offset framework for the Carmichael Coal Mine Project, under Commonwealth and Queensland Government approvals, for ecological Section 4.2.13 offsets to protect and manage the and groundwater offsets, relevant to GAB Springs. Section 4.5 also describes how approved management plans operate if a trigger is exceeded and an Section 4.2.14 GAB springs investigation finds disturbance differs from that approved (eg. deliver amended offsets within 12 months). In the event that groundwater drawdown thresholds for the Doongmabulla Springs Complex are exceeded, an investigation into the cause will be undertaken and the administering authority notified Section 4.2.15 within 28 days of the detection. During this time mining activities will be limited to current activities (no expansion or mining of new areas), until the investigation determines the cause and ensure the drawdown impact interim threshold does not breach the approved 0.2m. Section 4.2.16 Sections 4.2.13 to 4.2.16 describe research packages under this GABSRP, being a desktop scoping study, targeted ecological and hydro-ecological surveys of Section 4.5 identified potential offsets for the Doongmabulla Springs Complex, remediation assessments and trials.

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c) Personnel responsible for Section 5.2 describes that personnel responsible for conducting research will have appropriate skills and qualifications as relevant to that line of research or Section 5.2 conducting research and their monitoring. Specifically that research leaders will have greater than 5 years of experience in the design, implementation and reporting of similar research Table 5-1 qualifications projects including relevant academic qualifications and attributable publications, among other requirements. Research team members will have at least 2 years relevant experience in participating in research programs post obtaining relevant qualifications for the field of research in which they are participating under this plan. In particular, ecologists/botanists participating in research activities will be familiar with the threatened flora species associated with the Doongmabulla Springs Complex. Also research undertaken on hydrogeological matters will be carried out by qualified and experienced hydrogeologists. The expertise and experience for each discipline for the research packages are described Table 5-1. Section 5.3 states that the annual report will include a summary of activities implemented under the plan, including the personnel responsible for conducting research and their qualifications.

d) Timeframes for research and Section 4.4 (Implementation schedule) includes Figure 4-2 that shows a schedule for all research packages. Broadly, timing is based on approval of this Section 4.4 reporting program and commencement of the excavation of the first box cut for the Carmichael Coal Mine. An initial, 5-year research effort anticipated, however, the Figure 4-2 overall timeframe will be dictated by whether the research has met the objectives of this plan and conditions of approvals. Section 5.3 Section 5.3 describes the timeframes for reporting, being an annual summary report and submission of research outputs to the Commonwealth Government within ten business days of completion. Section 5.3 also describes that what the annual summary report on the implementation of this plan will include, such as a summary of activities carried out under this plan, the effectiveness of research outcomes and an assessment of activities and research outcomes against the objectives in section 1.4.

e) Methods, including but not limited Methods are outlined in detail in this plan. The methods include all those listed in paragraph (e). Section 4 to,

conceptualisation of the Objectives of research package 1.1 include improving the understanding of the source aquifers to the springs and describe background trends and influences Section 4.2.2 hydrogeology of the springs, including the natural fluctuations. The hydrology will be conceptualised by research package 1.4, that being to understand the relationship between Section 4.2.5 groundwater pressure and spring hydrology. The hydrogeology of will be conceptualised by research package 1.6, by undertaking updated groundwater modelling that represents the reviewed conceptualization and prepares a set of revised drawdown predictions. The eco-hydrology of the springs will be Section 4.2.7 conceptualised by research package 2.2 to define ecological water requirements of key species and ecological response thresholds that can be linked to hydrological factors.

geological and geochemical surveys Geological surveys will be used to further inform the source aquifer/s for the Doongmabulla Springs Complex under research package 1.3. Section 4.2.4 to inform the source aquifer/s for Geochemical surveys will also be used to further inform the source aquifer/s for the Doongmabulla Springs Complex under research package 1.2. Section 4.2.3 the Doongmabulla Springs Complex,

ecological surveys to determine the Ecological surveys to determine the composition of the GAB springs community will be conducted under research package 2.1. Research package 2.1 describes Section 4.2.8 composition of the GAB springs that ecological surveys and ongoing monitoring at the Doongmabulla Springs Complex. Research package 4.2 includes ecological surveys at sites identified as a Section 4.2.14 community, result of the desktop offsets scoping study under research package 4.1.

an assessment of transferability of Section 2.1.6 describes reports published by the Queensland Government (2016) with findings of monitoring and research undertaken about springs in the Section 2.1.6 approaches to present and mitigate Surat Basin, including mitigation of hydrological impacts on Springs. An assessment of transferability of approaches to present and mitigate hydrological Section 4.2.10 hydrological impacts on springs in impacts on springs in the Surat Basin will be conducted under research package 3.1 the Surat Basin,

determination of water The determination of water requirements (including ecological response thresholds) for the GAB springs community will be conducted under research package Section 4.2.9 requirements (including ecological 2.2. Research package 4.3 includes targeted hydro-ecological studies for the GAB springs community. Section 4.2.15 response thresholds) for the GAB springs community, and

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Description of EPBC 2010/5736 Condition How Addressed Section of GAB 25 Springs Research Plan

development and evaluation of The development and evaluation of methods to prevent, remediate ecological impacts will be conducted under research packages 3.1, 3.2, 3.3, 4.1, 4.2, 4.3 Section 4.2.10 methods to prevent, remediate and 4.4. Research package 3.1 will review potential prevent and mitigation options and feasibility for application to the Doongmabulla Springs Complex. Section 4.2.11 ecological impacts Research package 3.2 will pilot test prevention and mitigation methods. Research package 3.3 will synthesise these finding to identify feasibility and effective prevention and mitigation methods. Research package 4.1 will conduct a desktop offset scoping study, and then research package 4.2 will conduct targeted Section 4.3.12 ecological surveys at those target sites. Research package 4.4 will also cover hydro-ecological studies. All of these studies lead to the evaluation of methods to prevent and remediate ecological impacts. Section 4.3.13 Section 4.3.14 Section 4.3.15 Section 4.2.16

f) An analysis of potential mitigation An analysis of potential mitigation activities, such as but not limited to, re-injection to the groundwater source aquifer to maintain pressure head, flows and Section 4.2.10 activities, such as but not limited to, ecological habitat at the Doongmabulla Springs Complex will occur under research packages RP3.1, 3.2 and 3.3. Section 4.2.11 re-injection to the groundwater Research package 3.1 includes a desktop scoping study of managed aquifer recharge via groundwater injection specifically, but also includes other water source aquifer to maintain pressure Section 4.3.12 modification techniques applicable to maintaining pressure head and flows at the Doongmabulla Springs Complex. Research package 3.2 then pilot tests those head, flows and ecological habitat at feasible methods and research package 3.3 provides detailed design for implementation. the Doongmabulla Springs Complex

g) An explanation of how research An explanation of how research outcomes will directly inform the monitoring, management, prevention, mitigation and remediation of impacts on the Section 1.5 outcomes will directly inform the Doongmabulla Springs Complex will occur under research packages 3.3 and 4.5. Section 1.5 states that research outcomes delivered under this plan will Section 4.2.9 monitoring, management, directly inform groundwater and groundwater dependent ecological monitoring, management, prevention mitigation and remediation measures, and may prevention, mitigation and lead to adaptive management amendments to the GMMP and GDEMP. Section 4.2.12 remediation of impacts on the The following research packages describe linkages to the GMMP and GDEMP, which directly inform the monitoring management, prevention, mitigation and Doongmabulla Springs Complex Section 4.2.17 remediation of impacts on Doongmabulla Springs Complex: Section 5.3 • research package 2.2 – Hydro-ecological conceptualisation and assessment of key species (section 4.2.9) • research package 3.3 – Prevention and mitigation strategy (section 4.2.12); • research package 4.5 – Remediation and offset strategy (section 4.2.17); and • reporting and data provision (section 5.3).

h) A peer review of the draft GAB “Suitably qualified independent expert” means “a person who has professional qualifications, training, skills or experiences related to the nominated subject Section 5.1 Springs Research Plan, by a suitably matter and can give authoritative assessment, advice and analysis on performance relative to the subject matter using the relative protocols, standards, Appendix 2 qualified independent expert and a methods or literature”. This definition has been included in section 5.1 and the review itself has been included in Appendix 2. table of changes made in response to the peer review

The GAB Springs Research Plan must Once approved, the GAB Springs Research Plan will be published on Adani’s website, for the life of the project, as described in section 5.3. Section 5.3 be published on the proponent’s

website for the life of the project.

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Description of EPBC 2010/5736 Condition How Addressed Section of GAB 25 Springs Research Plan

Research outputs must be submitted “Bioregional Assessment of the Galilee Basin sub-region and the Lake Eyre Basin and any subsequent iterations” is defined in the approval as mining that “will Section 5.3 to the Minister within ten business be conducted in conjunction with the relevant state and territory government agencies and natural resource management bodies and entails a scientific days of completion, and be made analysis of the ecology, hydrology and geology for the purpose of assessing the potential risks to water resources in the area as a result of the direct and indirect impacts of coal seam gas development and large coal mining development”. Section 5.3 describes that the outputs will be smiteed ot the Minister available for the Bioregional iwthin 10 business days of completion, and be made available for the Bioregional Assessement of the Galilee Basin sub-region and the Lake Eyre Basin and and Assessment of the Galilee Basin sub- subsetquent iterations. region and the Lake Eyre Basin and any subsequent iterations.

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Appendix 2 - Table of changes made in response to the peer review

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Page Independent Comment scope Independent review comment Response (REVC) reviewer The “Doongmabulla Springs Complex” is defined as “the groundwater‐fed springs located approximately 8 kilometers from the western edge of the mining lease boundary and The definition of a GAB Spring in Section 1.4.1 has been clarified to explain consisting of springs within the spring groups identified on page 108 of the Coordinator‐ It may be worth stating the excluded systems and the rationale for the what exactly is meant by GAB Spring and an explanation is provided in Section 15 General’s Assessment Report”. Ned Hamer exclusion so that regulatory and proponent expectations are clearly aligned 1.4 as to why the focus is the GABSRP is solely on the Doongmabulla Springs The definition of a Great Artesian Basin spring for the purposes of this plan, and as prior to research efforts are commenced. Complex; i.e. the systems that make‐up EPBC listing occur more than 70km confirmed with the Department, is a natural discharge of the groundwater from the Great from the project boundary and are outside the predicted drawdown extent. Artesian Basin, where community of native species are dependent on that discharge.

The “Doongmabulla Springs Complex” is defined as “the groundwater‐fed springs located approximately 8 kilometers from the western edge of the mining lease boundary and consisting of springs within the spring groups identified on page 108 of the Coordinator‐ If this is a meeting with a regulator and if so can the agreement be formally 15 General’s Assessment Report”. Ned Hamer Clarification of agreement with department included documented and referenced here? The definition of a Great Artesian Basin spring for the purposes of this plan, and as confirmed with the Department, is a natural discharge of the groundwater from the Great Artesian Basin, where community of native species are dependent on that discharge. Can we list all excluded listed springs and other documented significant GDEs (Mellaluka Springs Group, river baseflows, Doongmabulla Springs Complex The definition of a GAB Spring in Section 1.4.1 has been clarified to explain does not apply to areas where the Great Artesian Basin does not occur (e.g. the Melaleuca 15 Ned Hamer discharge direct flows to river, etc) in the defined study area so the what exactly is meant by GAB Spring and why it does not apply to the the Springs Complex). understanding of scope and scope exclusions captured in the plan is absolutely Melaleuca Springs Group and GDEs related to non‐GAB systems. clear? Can the Doongmabulla be labeled here? Are all listed and excluded springs Label included. Non‐GAB Springs are not shown because they are not the 16 Figure 1‐2: EPBC‐listed Springs Complexes in the vicinity of the Project Ned Hamer shown, even if outside the GAB? May want to include in a different colour for within the scope of the research plan. clariry? To avoid confusion and blurring of boundaries, can we define what is meant by “Research” here in order to differentiate between core assessment, monitoring 18 Relationship with other research and management plans / adaptive management Ned Hamer and other compliance activities which would be covered in the GMMP and the Definition of the term 'research' has been included management plans, acknowledging that the two are strongly linked and complementary. As well as the listed related Adani docs, can all existing relevant springs References to the springs research being undertaken in the Surat CMA and the 18 Relationship with other research and management plans / adaptive management Ned Hamer research programmes be listed here, especially any other Lake Eyre Basin Springs assessment provided in Section 1.5.1 academic/Govt/industry ongoing research on the Doongmabulla. The GMMP is a monitoring and management plan, and research is not Are the outcomes of this plan applied to research simply monitoring data? proposed in the plan. Research work for groundwater will be located in the 18 Monitoring Ned Hamer What about outcomes of other assessment work that will have a bearing on Rewan Research Connectivity Plan. However, it is understood there may be springs understanding and potential impacts? outcomes from this GABSRP that could apply to the GMMP, so amendments have been made to clarify this. Are the outcomes of this plan applied to research simply monitoring data? Amendments have been made to Table 1‐1 to clarify the relationship between 19 Monitoring Ned Hamer What about outcomes of other assessment work directed at refining the plans. project area CSM? What about refinements to the CSM related to connectivity that may have a Amendments have been made to Table 1‐1 to clarify the relationship between 19 Informs groundwater triggers, monitoring and management through adaptive processes Ned Hamer direct bearing on potential impact on springs? plans. It has been clarified that the Doongmabulla Springs Complex sits within the 22 The Barcaldine Supergroup Ned Hamer Clarify that the Doongmabulla complex sits within this supergroup. Barcaldine Supergroup 29 direction Ned Hamer ? Should this refer to Fig 2.2? cross‐reference fixed Figure 2‑22.2 : Modelled and Observed Clematis Sandstone Groundwater Levels (GHD, 31 Ned Hamer Please provide a figure where the text is legible. clearer image has been inserted 2013b) Figure 2‑22.2 : Modelled and Observed Clematis Sandstone Groundwater Levels (GHD, Note added to text where fig is referenced regarding distribution of monitoring 31 Ned Hamer The number of monitoring bores appears very limited given the project area. 2013b) bores Figure 2‑22.2 : Modelled and Observed Clematis Sandstone Groundwater Levels (GHD, Formation extent refers to areal extent of formation that was modelled, which 31 Ned Hamer Is “Formation extent” accurate? Maybe formation outcrop area? 2013b) is not just the area of outcrop or subcrop. No amendment required. Please reference relevant studies/documents which support this Adani’s present conceptualisation of the Doongmabulla Springs Complex is that all of the conceptualization. Please list the primary lines of evidence for this assumption. A list of all studies informing this conceptualisation has been inserted at the 32 Ned Hamer springs are likely fed by groundwater from the Clematis Sandstone aquifer Please list any key areas of uncertainty which present critical research start of Section 2.2.1. Areas of uncertainty have also been described. opportunities? Page Independent Comment scope Independent review comment Response (REVC) reviewer major ion chemistry of Joshua spring differs to the Moses spring group, which suggests either a different source of water (which given the geological setting is considered unlikely) The items discussed (major ion chemistry, discharge pathways, anthropogenic 33 or a different pathway and hence contact with surficial lithological units before discharging Ned Hamer This appears to be a major uncertainty and potential area for research? modification) are included in scope of research program outlined in Sections 3 to surface. Anthropogenic modification to Joshua Spring may also play a part in the and 4. observed water chemistry differences. 33 Error! Reference source not found. Figure 2‑3 and Error! Reference source not found. Ned Hamer ? cross‐reference fixed Edited to clarify connectivity as related to Permian sandstones to Clematis 35 Bandanna and the Colinlea Ned Hamer Connectivity with Clematis? sandstone via the Rewan Formation This appears to be another key area of uncertainty and opportunity for 35 a lack of investigation and modelling of faulting Ned Hamer It is covered by the research plan research? source aquifer of at least the Little Mosses Spring and that evidence in relation to 35 groundwater flow directions in the Colinlea Sandstone had raised further uncertainty as to Ned Hamer Another key area of uncertainty. It is covered by the research plan the source aquifer of the Doongmabulla Springs Complex Any credible alternative models and their CSMs should be presented at this stage. Key uncertainties and data gaps related to each should be summarized 36 Ned Hamer Note included that alternative CSMs are to be tested by the research plan and opportunities for research which would provide lines of evidence to support or reject each alternative model should be presented.

This seems unusual given most springs have experienced declining pressure, and/or have ceased to flow. Why is this a relatively new spring? Can this be The term 'young' is in relation to geological terms, which has been included for 38 young springs‐group, in geological terms (GHD 2014). Ned Hamer explained through a valid hydrogeological hypothesis, does this make it more or clarification less vulnerable to minor depressurization, and if these questions cant currently be answered is this an important area for research? 39 (Error! Reference source not found.Figure 2‑5): Ned Hamer ? cross‐reference fixed If these disturbances are significant and there is a desire to rectify, is the The wetland is exposed to introduced wildlife and stock, with cattle trampling observed rehabilitation of these springs a potential topic for research (eg effective rehab Note added in Section 2.3.6 for clarification: The degree of disturbance from particularly at the Moses springs‐group (GHD 2012). The Doongmabulla springs‐complex is methods and means of monitoring rehab success?), or at least fencing to existing anthropogenic drivers (and not related to the project) is an important currently (and was historically) used for watering livestock, which directly impacts the 43 Ned Hamer exclude other sources of disturbance so that they can be effectively monitored background influence on the ecological condition of the springs and is to be springs through trampling, pugging, fouling of water and compaction (GHD 2012). The for potential changes due to depressurization? Given these springs are being assessed and monitored by the research packages outlined in Section 3 and 4 of greatest damage to the wetlands was caused by feral pigs, with parts of some wetlands utilized directly as a resource (stock watering) is there a useful research angle this research plan. highly disturbed by pig wallowing and foraging (GHD 2012). here for Adani, even if unrelated to potential mining impacts? This is from the defunct LP Act. Under the new Biosecurity Act 2014, 43 a class two declared weed. David Stanton Text amended to list hymenachne as a 'resticted invasive plant' hymenachne is classified is a ‘restricted invasive plant’. The Joshua spring‐group is the most impacted and is completely altered from its natural Note added about how disturbance from other anthropogenic drivers will be 43 state. It now consists of an upper turkey’s nest dam and a more recently constructed lower Ned Hamer Same as previous comment. dealt with by research plan turkeys nest dam. 44 Figure 2‑72‑7 Eriocaulon carsonii and Eryngium fontanum records Ned Hamer Is there reference in the text to these figures? reference included Are these relevant to spring studies, if so what aquifer are they targeting, who is monitoring, and how are they being used to study the springs? Is this an two monitoring bores (HD02 and, HD03 installed in the Clematis Sandstone and Dunda Beds 49 Ned Hamer existing monitoring/research project that could be expanded upon, Target aquifers for these bores has been listed respectively) collaboration opportunity. Refer to existing literature. Were there any key uncertainties/priority areas for further research identified?

50 Eucalyptus camaldulensis David Stanton Italics edited

Note added: The research packages outlined in Sections 3 and 4 of this plan will support these activities. The research outlined includes updated Is there sufficient data available on thicknesses and hydraulic properties of the hydrogeological understanding, geochemical surveys, geological mapping (for 51 Ned Hamer surficial deposits and Moolayember Formations at each Spring? If not these better information on geological controls of spring discharge and pathways, appear to be key areas for research? such as the thickness and hydraulic properties of the surficial deposits and Moolayember Formation), hydrological and ecological studies. Page Independent Comment scope Independent review comment Response (REVC) reviewer The specific flow pathways to the vent from the Clematis appears vague and Additional text added to link to research packages which describe how 51 Ned Hamer likely an area for research? discharge pathways will be investigated. To assist providing context and stimulate possibilities for research, it would be useful to briefly summarise the key project groundwater activities and metrics This detail can all be found in the referenced reports. Not within the scope of 54 Predicted impacts Ned Hamer (such as water pumping forecast over the life of the mine (maybe a graph) this document to reproduce all of that detail. Important that it remains focused including the maximum daily discharge, and where is the water proposed to be on the research discharged to.) 55 (refer Section Error! Reference source not found.Section 2.5), Ned Hamer ? cross‐reference fixed 56 and 0.19 Ned Hamer This is not consistent with the graph below? It relates to table 2‐1 Yes these are conservative estimates undertaken through the EIS modelling Figure 2‑162.16 : Predicted impacts – Doongmabulla Springs ComplexDoongmabulla Springs Is this a conservative case, best estimate, etc? What is the range of potential 56 Ned Hamer process. Impacts ranges were presented through those studies, this impact Complex– operational phase (GHD, 2015) impacts within the range of modelling uncertainty? scenario determined and accepted through EIS process and approval. Assumed source aquifer? Or maybe just state drawdown in Clematis 59 source aquifClematis Sandstoneer Ned Hamer Referred to as the Clematis Sandstone Sandstone? 59 post‐closure phase Ned Hamer What year/s does this correspond to? It is a peak drawdown, so timing may vary 59 source aquifer (m) Ned Hamer Assumed source aquifer? Referred to as the Clematis Sandstone To put in context how does this compare to historical declines in pressure due to exploitation of groundwater for pastoral and other activities? If this is not Research plan includes tasks specifically aimed at quantifying background 66 between <0.05 and 0.11 m Ned Hamer understood is it a key area for research along with evidence for corresponding trends (natural fluctuations or changes due to other anthropogenic influences) responses to depressurization at the springs? Likely another key area of uncertainty requiring research? What will the Therefore, it is thought that the reduction in flow will be within a tolerable range (GHD 66 Ned Hamer modelled depressurization state look like at the springs and how will the These questions are covered by the research plan 2014). ecology respond/adapt? To put in context how does this compare to historical declines in pressure due to exploitation of groundwater for pastoral and other activities? See comment Research plan includes tasks specifically aimed at quantifying background 66 0.19 m Ned Hamer above. Is there evidence that allows a quantitative assessment of the decline in trends (natural fluctuations or changes due to other anthropogenic influences) spring extent related to head decline in the Clematis aquifer in the study area (if any?) 67 Hymenachne David Stanton Remove Italics removed 70 Research Ned Hamer Missing “Springs” edited Please check the identified potential critical areas of uncertainty/opportunities for research identified in comments noted throughout the previous chapters 70 Secondary Questions Ned Hamer Reviewed and all are covered under the research plan related to the existing body of knowledge collated by Adani through the EIS/SEIS and other studies, and incorporate here if not already addressed.

Existing (?) and potentially new seismic and other geophysical campaigns (more sensitive methods available) may be useful for refining the structural setting (key component of the CSM) and determing the presence or absence of significant cross‐formational sub‐vertical faults or fracture zones which may either be transmissive flow pathways (eg spring flow pathways) or hydraulic 70 Study/Assessment needs Ned Hamer boundaries. Sensitively planned low impact geological/geophysical Scope of geological mapping broadened to include this programmes could also be combined with both Rewan research plan objectives and commercial exploration opportunities along the western flank of the tenements? Seismic/geophysical campaigns could be complemented by a coring programme with core holes converted to monitoring bores for groundwater monitoring in various formations of interest (aquifers/aquitards).

Would it be possible to split out activities already incorporated in other plans and highlight remaining true research activities that would be the focus of the 70 Links to other management plans Ned Hamer Figure 3‐1 included to clarify relationship with other plans Springs Plan? These specific tangible research tasks could then be described in Section 4.2. Page Independent Comment scope Independent review comment Response (REVC) reviewer Suggest that there is a question around what are the flow paths from the source aquifer to the springs and what are the hydrogeological controls for the What are the source aquifers to the springs and what are their flow paths and relative 70 Ned Hamer spring discharge locations? Tasks and tools designed to improve the shallow First secondary question revised to accommodate this contributions? structural geological setting may be useful for research – seismic, shallow geophysical, shallow drilling and coring campaign, etc). A desktop review of historical declines in Clematis aquifer/bores in the area 70 What is the relationship between groundwater pressure change and wetland hydrology? Ned Hamer and evidence for historical responses in the springs extent and ecological Part of scope of hydrogeology review composition may be useful?

Good points here. There is little consideration of cumulative impacts. Research activities may need to be undertaken in cumulative impact context. This The work to be undertaken for Question 1 is at multiple scales, as follows: includes depressurization of aquifers from agricultural and other water supply Spatially, a regional focus is required for much of the hydrogeological investigations given purposes, as well as existing or potential depressurization from other projects the scale of the groundwater flow systems in the GAB and Galilee Basins. However, a local at a sufficiently advanced project approval stage (if any?). If other focus is required to examine the nature of groundwater discharge at DSCDoongmabulla projects/groundwater impacts are approved or are likely to occur, modelling, Springs Complex, the role of local groundwater flow systems, and the hydrological processes monitoring, management and research directions should adapt accordingly and Cumulative impacts are included as part of the consideration of background 71 Ned Hamer (water balance dynamics) within DSCDoongmabulla Springs Complex. consider the cumulative impacts. This may become a reality once the rail trends and influences. This is featured throughout the research plan. Temporally, the influence of mine dewatering on the regional aquifers will stretch into the corridor is constructed and other projects become commercially viable. long term (over decades to centuries), while the hydrology of the wetland will be dynamic Collaborative research with other proponents and stakeholders would be and respond to seasonality and climate trends (months to years). encouraged. Unless the project is truly isolated with sufficient distance from other groundwater extractive activities and projects, then project‐only impact assessment will not provide accurate or useful outcomes. This is a learning from the Surat CSG industry.

Geological mapping, geochemical sampling and groundwater head measurements from an See comments above related to the need for significant improvements in the 71 augmented groundwater monitoring network (as outlined in the GDEMP and GMMP) will Ned Hamer structural geological setting (currently a very coarse resolution with limited Scope of geological mapping broadened to include this provide this understanding. heterogeneity) and relationships with groundwater flow paths. The definition of research provided in Section 1 clarifies what is meant by Background trends and influences of the source aquifers will be examined using Rather than focusing on the monitoring itself (core impact assessment research: i.e. it is a systematic evaluation to address the objectives of the groundwater head monitoring data, reviews of third‐party groundwater usage and pumping requirement) I would have thought research could focus on improvements to condition. The work may be similar in nature to an impact assessment task, but 71 tests to determine hydrogeological properties. Understanding the background trends and Ned Hamer critical monitoring and assessment methods, including tailored novel this work is necessary to meet the objectives of the condition. The influences of the source aquifers provides context to predictions of any drawdown related approaches specific to answering critical spring impact questions? Or possibly investigations do not have to be 'innovative' or 'novel' to be classified as to the project activities. improved data management and interpretation? research. RH (Relative humidity) will be important as a means to measure evaporation / 71 temperature David Stanton Relative humidity included as a metric to measure evapotranspiration rates. Background trends and influences of the source aquifers will be examined using groundwater head monitoring data, reviews of third‐party groundwater usage and pumping tests to determine hydrogeological properties. Understanding the background trends and influences of the source aquifers provides context to predictions of any drawdown related to the project activities. Most of this appears to be core impact assessment activities that would The definition of research provided in Section 1 clarifies what is meant by normally be expected to be incorporated in management plans rather than research: i.e. it is a systematic evaluation to address the objectives of the Investigations of wetland hydrology will focus on the wetland water balance and its research plans. Generally research activities tend to be more targeted, and condition. The work may be similar in nature to an impact assessment task, but 71 dynamics. Several datasets will be required, including meteorological data (rainfall, Ned Hamer may fill in critical gaps within the broader management programmes. See this work is necessary to meet the objectives of the condition. The temperature, relative humidity), digital terrain data (including bathymetry), surface water previous comments (Including in section 1.5) regarding defining research vs investigations do not have to be 'innovative' or 'novel' to be classified as gauging (wetland levels, stage height, flow), and measurements of wetland area. When core assessment, monitoring and management activities. research. combined with groundwater head measurements the data is to be used to develop a relationship between groundwater head in the source aquifers and spring wetland hydrology. The background trends and influences on wetland hydrology will also be quantified including an assessment of the influence local topographically controlled groundwater systems have on the wetland hydrology. Page Independent Comment scope Independent review comment Response (REVC) reviewer These activities would be informing research rather than form the research itself. Can the modelers identify key research priorities relating to improving No action ‐ Modelling and uncertainty analysis is research and there is a the accuracy of modelled outputs around the Springs (eg increased refinement preceding data gathering and research effort to inform it (which focuses on the The modelling is to include uncertainty analysis, such that a range of plausible outcomes to of grid around/beneath the springs that will have maximum benefit in terms of 72 Ned Hamer issues raised by the reviewer). Additionally, the modelling and wetland hydrology are produced. reducing model uncertainties? Given likely significant implications to modelled conceptualisation are subject to regular reviews throughout the program drawdowns, could research focus on recharge locations and volumes, as well as providing feedback opportunities as suggested. localized intra‐aquifer flow paths especially within the recharge areas close to the springs.

Fensham describes the links between ecology and wetland chemistry as a 72 . Fensham Ned Hamer Could Fensham identify any key research priorities? research priority. This has been included in the scope of the ecology survey. Use of control sites (i.e control and impact) is a desirable and standard Given scale of groundwater flow system, drawdown effects not predicted for component most ecological monitoring programs. Some justification should be 72 2012 David Stanton decades, therefore initial monitoring will constitute a control and a measure of provided as to why control sites aren’t being applied (e.g. distance to springs, background trends and influences variability of disturbance regims A brief description be provided to identify how designated monitoring points will / or should be chosen and their allocation to various components of the Doongmabulla Springs Complex would be useful. It should cover off on the 72 conducted David Stanton range of spring ecological and morphological variations. The monitoring Provided in Section 4 program also consider those springs that do not meet species / composition thresholds for the EPBC community (if there are any?) These may be relevant for comparative purposes.

Examples of ecological endpoints have been included.

In the context of this project, the outcome would be no impacts to the DSC over and above those that are approved wrt groundwater, and the expression Based on current knowledge, is it possible to give an example of an ecological 72 ecological endpoints David Stanton of that ecologically is the purpose of this research plan. endpoint that is applicable to the Doongmabulla Springs Complex There are other factors that will influence the DSC ecology including landholder management practices, climate etc. and these will be examined by the research program.

Is this the document to flesh out a little further to include high level options for sources of water for injection, logistical feasibility of getting mine water to the Yes, the desktop mitigation scoping study as outlined in Section 4 will address 73 injection options will be considered Ned Hamer closest point in the Clematis, injection location option review, treatment and these scope items chemical compatibility research, modelling, etc?

Suggest clarify that these would need to be close enough to the springs and of sufficient volume to provide a material benefit (off‐set) at the spring complexes. This differentiates licenses/bores for springs off‐sets (required to Text clarified to explain that if the purchase of licences are close enough to the 73 in the source aquifer Ned Hamer be identified in the Fed Condition ‐ Identify priority actions for potential offsets springs this could be a potential mitigation measure to protect and manage the GAB springs) from other GAB resource impact off‐ sets which could be remote from the mine. I would have thought they would require updating as the importance of certain Where the research plans are foundation documents that will not be updated during the research directions becomes apparent and may not yet be foreseen? Where do Review and update of key research packages included as part of research plan 73 Ned Hamer project the specific detailed research packages sit? Are they not within the Plan? Will implementation schedule outlined in Section 4.4 they be added as an addendum? Page Independent Comment scope Independent review comment Response (REVC) reviewer This doc covers the key objectives quite well. But is there a risk that the regulator may not be satisfied that there is enough detail within the scopes of each research package here to approve? High level but specific and tangible research programmes/activities may need to be provided. The objectives are 77 Scope and objectives of research packages Ned Hamer More detail added to the scope of each research package good, but the scopes are very broad and include predominantly core impact assessment activities rather than research. Without any regulatory engagement I don’t have a feel for regulatory expectations on the scope details for this document, and its not clear in the wording of the condition.

I find this flow chart / diagram a little unclear. Can some further clarification of 80 Sequence and dependencies of research packages David Stanton Research plan IDs included for clarification what the various colour bars and columns represent be provided?

Some indication of the geochemical suite to be sampled would be beneficial, or 81 complex David Stanton Details of geochemical suite included where the geochemical suite for sampling will be drawn from?

This seems a little shallow. Maybe the research could go a little deeper for much greater benefit? Maybe geological appraisal may be a better term? Agree that the refinement of surface geology by desk top and field surveys is important. But should not just include surface geology mapping, but also include subsurface geological correlations, refinement of formation surfaces, lthology and hydraulic properties, correlations. Seismic, coring, geophysical 82 Geological mapping Ned Hamer Scope of geological mapping broadened to include deeper analysis logging and other subsurface appraisal methods would be most useful for improving critical subsurface aspects of the CSM which are currently simplistic and possible don’t recognize some critical complexities, particularly around the springs. Both the Rewan interconnectivity and Springs research would be directed at aiming to have a pretty clear picture of the intervening geology between the Clematis and the ground surface at the springs.

In relation to the GABSRP, the objective of the Rewan Formation connectivity investigations is:

To provide an improved understanding of the hydraulic connectivity of the Rewan Given this is covered by another plan, may just want to focus on the most Research Plan 1.4 is provided simply as a reference to the work that will be 83 Formation and its ability to provide an effective barrier to groundwater pressure reductions Ned Hamer critical overlaps for answering spring impact questions? undertaken under the Rewan Connectivity Research Plan in the Permian sandstone units of the Galilee Basin caused by mine dewatering.

This work encompasses a series of investigations being carried out under the RFCRP, which details their scope and objectives.

See Arrow GDE Assessment methods which incorporate a number of methods which may be useful for water balancing and understanding moisture distribution through the spring complexes including: shallow geological coring Method development is included as part of the scope of RP2.1 (including the 83 RP1.5: Wetland hydrological monitoring, conceptualisation and water balance Ned Hamer to assess shallow geology, tree rooting depths, soil and leaf moisture potential development of ecological indices) measurements, soil/gw/leaf moisture isotope fingerprinting. Consider what combination of methods may be most useful to this specific setting noting the variety of springs expressions in the Doongmabulla Springs Complex.

83 temperature David Stanton RH?? Relative humidity included as a metric to measure A description of what field‐based and remote sensing techniques might be applied to to wetland area monitoring would be useful. Otherwise some indication of where these methods should be adapted or drawn from should be 83 techniques David Stanton Suggestions of field‐based and remote sensing techniques have been included considered (e.g from Fensham et al 2004 which I have pasted in the references section, plus Fensham and Fairfax 2009, Petus et al 2013 included in references). Page Independent Comment scope Independent review comment Response (REVC) reviewer A review of the monitoring plan be undertaken at a set time interval to assess 83 conceptualisation David Stanton This is covered under the implementation schedule provided in Section 4.4 its effectiveness and identify areas where improvements can be made?

It’s a key element of the research package in that it brings together the findings Not sure that this is research, but rather a core impact assessment activity that of the previous research packages to answer the primary question. Without this 84 Hydrogeological conceptualisation review and updated groundwater modelling Ned Hamer should be revisited regularly probably covered in GMMP? Some components of element included it is not made clear how the findings of the previous research this review should be strongly informed by research activities. packages will be used. Furthermore, conceptualisation, groundwater modelling and uncertainty analysis do constitute a research activity. While monitoring in isolation may not necessarily be research, it is listed here specifically to address several research questions. It is important that the data 84 RP2.1: Ecological survey and monitoring Ned Hamer Same comment as for 4.2.7. and monitoring requirements of each research element is identified within the plan. As a general comment, there is very little information in literature concerning ecological characterisation of the Doongmabulla Springs Complex. Additional ecological characterisation ranking springs in terms of species composition and 84 monitoring David Stanton endemicity might be a useful means of prioritizing springs to more effectively Addition detail on scope of ecological survey included. target the ongoing ecological monitoring program. Additional details from Fensham and Price (2004) in regard to spring ranking should be considered (reference pasted in reference section)

Provide a robust framework for monitoring of temporal changes to spring ecological / vegetation condition should be a priority. Parameters and methods 84 objectives David Stanton Discussion of typology included to address this should be repeatable and methods documented in enough detail to allow for replication by a third party if required.

Monitoring of invasive species extent cover and composition is also highly 84 points David Stanton relevant as is will provide a key indicator of habitat condition. Particularly for This comment has been included Hymenachne which is listed as a Weed of National Significance.

I guess that it is an project objective that these wont be required. However I guess the regulator wants some assurance that if impacts are greater than expected and unacceptable, that a mitigation method has been proven up and is ready to implement. They would not want a programme of R&D to begin after a significant impact has been realised. In lieu of a full blown mitigation 85 Desktop mitigation scoping study Ned Hamer A staged investigation is what has been recommended research project that may never be required I suggest you may want to consider presenting trigger levels that would be sufficiently in advance of unacceptable impacts such that the detailed research and trialing would occur in an acceptable timeframe to mitigate. So maybe only a high level feasibility study and possibly any long lead items required in the plan now?

To assist context and stimulate research possibilities, it is suggested that there 86 RP3.2: Injection pilot trial (if necessary) Ned Hamer is a statement regarding the current proposed discharge location for mine This is part of the scope of the desktop assessment RP3.1 water and what other options are available for injection water supply. 86 RP3.2: Injection pilot trial (if necessary) Ned Hamer See comments above re staging mitigation research. Yes, a staged investigation is what has been recommended Text clarified to explain that if the purchase of licences are close enough to the 86 source aquifer Ned Hamer Near enough to the springs to present a material benefit springs this could be a potential mitigation measure Potential for improvements to ecologically degraded springs through property 86 DSC David Stanton Included as a potential offset to be considered purchases or covenant agreements? 86 RP3.4: Management options assessment Ned Hamer See comments above re staging mitigation research. A staged investigation is what has been recommended Maybe this is not research and should be covered in the GMMP. Would be It is listed because this is focus that all of the individual research elements are 86 RP3.5: Refinement of monitoring and management triggers Ned Hamer partially informed by research outcomes. working towards. Important context for the research plan. Page Independent Comment scope Independent review comment Response (REVC) reviewer 87 manner David Stanton That allows for ongoing temporal assessment. text amended to include this comment

87 years David Stanton Note this addresses previous comment relating to a specified review period. No action required.

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