Union Reefs North Underground Project Environmental Impact Assessment

Ghost Bat Technical Report November 2019

Prepared for Kirkland Lake Gold

Final Report 22 November 2019

i Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

Project Union Reefs Exploration EIS Ghost Bat Technical Report November 2019 Report Author/s Paul Barden, Ecological Management Services Dr. Kyle Armstrong, Specialised Zoological

Client Kirkland Lake Gold

Client Contact Sally Horsnell

Disclaimer Ecological Management Services Pty Ltd/Specialised Zoological have prepared this report for the use of Kirkland Lake Gold. The report has been prepared in accordance with the scope of work based on discussions with Kirkland Lake Gold and the project Union Reefs project TOR (NT EPA 2019). Ecological Management Services Pty Ltd/Specialised Zoological do not warrant in any way whatsoever that the material contained in this report is fit for use for any other purpose or by any other party. This report should not be reproduced in whole or part for any use whatsoever without the express written permission of Ecological Management Services Pty Ltd. The methodology adopted, and sources of information used by Ecological Management Services Pty Ltd/Specialised Zoological are outlined in this report. Ecological Management Services Pty Ltd/Specialised Zoological have made no independent verification of this information beyond the agreed scope of works and Ecological Management Services Pty Ltd/Specialised Zoological accepts no responsibility for any inaccuracies, errors or omissions in any data or information that is in the public domain or that otherwise was obtained by or prepared for Ecological Management Services Pty Ltd/Specialised Zoological. This report is based on data reviewed and information compiled between September 2018 and November 2019. Ecological Management Services Pty Ltd/Specialised Zoological disclaim any responsibility for any changes that have occurred after this time. This report should be read in full. No responsibility is accepted for use of any part of this report in any other context or for any other purpose or by third parties. This report does not give legal advice.

Copyright © Ecological Management Services Pty Ltd 2019 ACN 084 304 110 PO Box 580 Coolum Beach QLD 4573 Australia © Specialised Zoological ABN 92 265 437 422 Copyright in some material in this report may vest in other persons. Cover Ghost bat (Macroderma gigas)

Document History

Version Date Author/s Reviewer P. Barden EMS Draft 29 October 2019 Dr. Bruce Thompson Dr. Kyle Armstrong SZ P. Barden EMS Final R2 3 November 2019 Nicole Conroy GHD Dr. Kyle Armstrong SZ P. Barden EMS Final R3 14 November 2019 Dr. Kyle Armstrong SZ P. Barden EMS Final R4 22 November 2019 Dr. Kyle Armstrong SZ

Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

Contents

1.0 INTRODUCTION ...... 1

1.1 PROJECT SCOPE ...... 1

2.0 BACKGROUND INFORMATION – GHOST BAT ECOLOGY AND STATUS ...... 3

2.1 GHOST BAT STATUS ...... 3

2.2 FOSSIL HISTORY AND TAXONOMY ...... 3

2.3 GHOST BAT ECOLOGY ...... 4

2.4 ROOSTING ECOLOGY AND USE OF ARTIFICIAL STRUCTURES ...... 5

2.5 VULNERABILITY OF GHOST BATS TO NOISE AND VIBRATION ...... 6

3.0 GHOST BAT ENVIRONMENTAL VALUES – SUPPORTING DATA ...... 7

3.1 LOCATION OF GHOST BATS USING THE PROPOSAL AREA ...... 7 3.1.1 Geographic Extent of the Regional Population ...... 7 3.1.2 Geographic Location and Size of Known or Predicted Ghost Bat Colonies ...... 9 3.1.3 Characteristics of Known and Likely Natural and Artificial Roosts in the Proposal Area ...... 15

3.2 SEASONAL USE OF THE UNION REEFS AREA BY GHOST BATS ...... 23 3.2.1 Occupation and Seasonal Use of Adits by Ghost Bats at Union Reefs ...... 23 3.2.2 Regional Use of Adits and Caves by Roosting Ghost Bats ...... 24

3.3 SIGNIFICANCE OF ADITS FOR GHOST BATS ...... 27 3.3.1 Significance of Proposal Area Adits for Ghost Bats ...... 27 3.3.2 Regional Significance of Union Reefs Adits for Ghost Bats ...... 27 3.3.3 Existing and Required Genetic Information ...... 28

4.0 POTENTIAL IMPACTS AND RISKS ...... 29

4.1 NOISE AND VIBRATION ...... 29 4.1.1 Susceptibility of Ghost Bats to Low Level Vibration and Noise ...... 29 4.1.2 Damage to Roost Sites – Internal Blockages and Collapse ...... 30 4.1.3 Relocation to Sub‐optimal Roosts ...... 31

4.2 IMPACTS OF A TEMPORARY EXCLUSION FROM THE OK ADIT ...... 32 4.2.1 Exclusion Impacts at Various Scales ...... 34

4.3 CAPACITY OF OTHER SITES TO ACCOMMODATE EXCLUDED BATS ...... 35 4.3.1 Union North Adit ...... 35 4.3.2 Lady Alice Adit ...... 35 4.3.3 Kohinoor Adit Pine Creek ...... 36 4.3.4 Spring Hill ...... 36

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4.4 CONSEQUENCES OF A TOTAL LOSS OF GHOST BAT ROOSTING HABITAT AT PINE CREEK ...... 37 4.4.1 Significance of Residual Impacts Following Avoidance Measures ...... 37 4.4.2 Likelihood of Unknown, Unpredictable or Irreversible Events or Impacts ...... 38 4.4.3 Short Term and Long‐Term Impact Pathways, and Their Consequences ...... 38

4.5 LIKELY IMPACTS AT LOCAL, NATIONAL AND REGIONAL SCALE ...... 42

5.0 MITIGATION AND MINIMISATION ...... 42

5.1 MITIGATION MEASURES ...... 42 5.1.1 Summary of Proposed Actions ...... 43 5.1.2 Action Plan Sequence ...... 44

5.2 EFFECTIVENESS AND STATUTORY OR POLICY BASIS FOR MITIGATION MEASURES ...... 44

5.3 DISCUSSION OF ACTIONS IN THE CONTEXT OF A MITIGATION HIERARCHY ...... 60

5.4 CONSIDERATION OF PROJECT ALTERNATIVES...... 60 5.4.1 Closure is Temporary ...... 62 5.4.2 Population Augmentation ...... 62 5.4.3 Sub‐optimal Actions ...... 63

6.0 MONITORING AND REPORTING ...... 64

6.1 FUTURE MONITORING TIMEFRAMES ...... 64 6.1.1 Continuous Monitoring ...... 64 6.1.2 Sustained and Expanded Regional Focus ...... 65 6.1.3 Regularity of Monitoring ...... 65 6.1.4 Triggers ...... 66 6.1.5 Contingencies ...... 67

6.2 RESIDUAL IMPACT ...... 67

7.0 EPBC SIGNIFICANT IMPACT CRITERIA ‐ MNES ...... 68

7.1 ACTIONS THAT MAY LEAD TO A LONG‐TERM DECREASE IN THE SIZE OF AN IMPORTANT POPULATION

OF A SPECIES ...... 70

7.2 ACTIONS THAT MAY REDUCE THE AREA OF OCCUPANCY (AOO) OF AN IMPORTANT POPULATION ..... 70

7.3 ACTIONS THAT MAY FRAGMENT AN EXISTING POPULATION INTO TWO OR MORE POPULATIONS ...... 71

7.4 ACTIONS THAT MAY ADVERSELY AFFECT HABITAT CRITICAL TO THE SURVIVAL OF A SPECIES ...... 71

7.5 ACTIONS THAT MAY DISRUPT THE BREEDING CYCLE OF AN IMPORTANT POPULATION ...... 71

7.6 ACTIONS THAT MAY MODIFY, DESTROY, REMOVE OR ISOLATE OR DECREASE THE AVAILABILITY OR

QUALITY OF HABITAT TO THE EXTENT THAT THE SPECIES IS LIKELY TO DECLINE ...... 72

7.7 ACTIONS THAT MAY RESULT IN INVASIVE SPECIES THAT ARE HARMFUL TO A VULNERABLE SPECIES

BECOMING ESTABLISHED IN THE VULNERABLE SPECIES’ HABITAT ...... 72

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7.8 ACTIONS THAT MAY INTRODUCE DISEASE THAT MAY CAUSE THE SPECIES TO DECLINE ...... 72

7.9 ACTIONS THAT MAY INTERFERE SUBSTANTIALLY WITH THE RECOVERY OF THE SPECIES ...... 72

7.10 EPBC CONCLUSION ...... 73

8.0 REFERENCES ...... 74

Table 3.1 Summary of Recent and Historical Ghost Bat Count Estimates for the Northern Territory Table 3.2 Structure of Adits at the Union Reefs Project Area Table 4.1 Potential Impacts and Risks: Ghost Bats at the Union Reefs Project Site Table 5.1 Ghost Bat Action Plan, Union Reefs: Effectiveness and Rationale Table 5.2 Summary of the environmental consequences, viability, risk, cost and benefits of each alternative Action Table 6.1 Planned ghost bat monitoring and reporting frequency Table 6.2 Risk of the significant impact criteria

Figure 1 Union Reefs Project Area Figure 2.1 NT Ghost Bat Records – Combined Regional Areas Figure 2.2 Pine Creek Region Ghost Bat Records Figure 3 Union North adit internal structure Figure 4 OK adit internal structure Figure 5 Prospect adit internal structure Figure 6 Lady Alice adit internal structure Figure 7 Seasonal Use of Adits in the UR Project Area 2018 – 2019 based on Acoustic Monitoring Data

Appendix 1 Kirkland Lake Gold EIS Blasting noise and vibration modelling ‐ ghost bats (GHD 2019) Appendix 2 Ghost Bat Action Plan (Armstrong and Barden 2019) Appendix 3 Project Personnel and Consultation Appendix 4 Correspondence from independent peer review (Dr Bruce Thompson)

Acronyms

AOO Area of Occupancy DENR Department of Environment and Natural Resources EA Act Environmental Assessment Act EIA Environmental Impact Assessment EIS Environmental Impact Statement EMP Environmental Management Plan

iii Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

EMS Ecological Management Services EPA Environmental Protection Authority EPBC Act Environment Protection and Biodiversity Conservation Act 1999 GW Groundwater KLG Kirkland Lake Gold MLN Mineral Lease Number MNES Matter of National Environmental Significance MM Act Mining Management Act MMP Mining Management Plan NT Northern Territory NTMO NT Mining Operations Pty Ltd PCPA Pine Creek Project Area TPWC Act Territory Parks and Wildlife Conservation Act TSF Tailings Storage Facility SZ Specialised Zoological URCP Union Reefs Crosscourse Pit URPA Union Reefs Project Area WRD Waste Rock Dump

Glossary

Certain words have specific meaning in this document, and the attached Action Plan (Armstrong and Barden 2019b).

Adit—a horizontal tunnel extending underground from an entrance portal in a near‐vertical or sloped rock face. The adit may link to other horizontal cross‐cuts on either side, and to vertical shafts that extend below or above the horizontal tunnels.

Alternative diurnal roost; contingency roost—any underground structure, including underground mine workings, natural caves, or other equivalent structures, which can provide the conditions required for diurnal roosting by the Ghost Bat. These are predicted to occur outside the project area, and within the nightly flight range of a Ghost Bat, but remain to be found. They may also constitute any artificial structures constructed specifically as replacement roost habitat as part of the Project. Suboptimal alternative roosts are those structures that may be used temporarily by Ghost Bats following a disturbance, but they do not provide suitable conditions for longer term roosting.

Bat population—an interconnected set of colonies of Ghost Bats, in this case inferred to occupy an unknown number of roosts within the Daly Basin and Pine Creek IBRA bioregions. Gene flow occurs amongst members of the same population, but may not occur with other population/s (it is not known if gene flow occurs with colonies further north and in other parts of the Northern Territory).

iv Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

Breeding site—a diurnal roost where some part of the breeding cycle occurs, including where bats congregate to mate, where pregnant females congregate, where females give birth (parturition), and where young are raised until they become independent.

Colony—a set of individual Ghost Bats that occur in an underground diurnal roost at any one time. Members of one colony may move to another colony, and most or all individuals of a particular colony might move from one roost site to another. Based on previous genetic studies (Worthington Wilmer et al. 1994, 1999; K.N. Armstrong unpublished study in prep.), females do not move away or far from their natal roost, and males also show high fidelity to roosts but are more likely to disperse greater distances.

Feeding site—see ‘Nocturnal refuge’

Further afield—the wider region that is occupied by the Ghost Bat population.

Local persistence; occurrence—presence within the Union Reefs project area.

Nocturnal refuge—a site where bats may hang to rest during the night, and where they may consume captured prey. They will not be present during the day.

Persist—present and detectable at one or more roost sites within the project area during the time of the defined activity (the closure of the OK adit and Prospect adit to bats) and for at least 6 months after the OK adit is re‐opened.

Project area—all the area within tenements held by Kirkland Lake Gold Ltd and referred to as the Union Reefs project area.

Region—the Daly Basin and Pine Creek IBRA bioregions.

Roost; diurnal roost; daytime roost—an area within an underground structure where Ghost Bats remain during daylight hours, and sometimes during the night.

Stronghold colonies—the large colonies at Spring Hill c. 15 km to the north of Union Reefs project area, and the large colony c. 15 km south in the Kohinoor mine adit adjacent to the town of Pine Creek. These colonies have been known for many years, and are also known to be subject to a range of threats.

Temporary closure—the period in which the OK adit is closed to bats while underground tunnels are excavated and used nearby (accessed from a portal within the Prospect pit), estimated at around two years.

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Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

1.0 Introduction

Northern Territory Mining Operations (NTMO), owned by Kirkland Lake Gold (KLG), is planning to develop and advance the Union Reefs North Underground Mine (the project) to target the Prospect Claim gold deposit mineralisation. The site is located 13 km north of Pine Creek and 170 km south‐east of Darwin (Figure 1). Underground mining is proposed for two years, with the possibility of an extension of operations. Mine development will be completed along the Union Line and extend into the Lady Alice Line. The underground development will also be used as an exploration point to test mineralisation deeper in the Union trend, as well as new mineralisation on the Lady Alice trend. Both of these mineralised trends have been mined previously via the Union North, Prospect, Lady Alice, Crosscourse and Millars open pits.

The underground mine will be accessed via a portal and decline developed from within the existing Prospect North open pit (Figure 1). The Prospect north and south open pits will be completely dewatered prior to facilitate portal construction. The Prospect south open pit will be used to store waste rock, prior to this material being returned underground and used as backfill during mining operations. This is the same model for waste rock management is used at the Cosmo Deeps mine by KLG.

1.1 PROJECT SCOPE

Kirkland Lake Gold have committed to minimising and/or avoiding the potential effects of their various mining‐related activities on the ghost bat (Macroderma gigas) within the Union Reefs (UR) project area (Exploration Mining Management Plan; Kirkland Lake Gold 2018). The ghost bat is currently listed as Vulnerable under the Commonwealth EPBC Act 1999. The species was first identified at the Union North project area in the late 1987 (CCNT 1993). Baseline surveys in 2018 established the continued presence of the species in the UR project area (URPA), with two remnant portions of historical adits in the sidewalls of mine pits (‘Union North adit’, ‘OK adit’) initially identified as diurnal roost habitat for ghost bats (Armstrong and Barden 2018). This work prompted the development of a long‐term monitoring strategy to collect further baseline information about roost size and usage and to develop measures to prevent potential impacts on the species from an exploration drilling program (Armstrong and Barden 2019).

This report summarises baseline data on the presence, activity levels and colony sizes of ghost bats in the UR project area in 2018 and 2019 and provides an assessment of potential impacts of the current NTMO/KLG underground mining proposal for the URPA, with reference to the terms of reference (TOR) provided by the Northern Territory EPA (NT EPA 2019). The TOR provided a series of information requests specifically related to the distribution and ecology of the ghost bat at the Union Reefs project area and in the wider region (NT EPA 2019).

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Figure 1. Union Reefs 1 0000.0 1520�1..5J•00.000 154000.000 155000.0 156000.000 Project Area Mapping data source: GEOScience 8485 00.000 Australia/ALA/NT Fauna Atlas 2019 Datum: Map Grid of Australia 94 Zone 52/GDA94 UTM Original mapping layer data Copyright EMS Pty Ltd 2019 [email protected] Client: KLG • • Project: UR Ghost Bat EIS 84840 0.000 • Date: 20 Sept 2019 Author: PB ·\ I ·'

•

8482000.000 Legend

o Ghost Bat Records NT Fauna Atlas

• Adit (Historical) �- 8481000.000 8481000.000 0 Proposed Porta I • Heritage Mining Sites (Checked) _) roads ' f--+-+ railways _/ 8480000.000 0 Mineral Titles Granted ---- 0� D Union Reefs Operations N 0 �- 500 1000 1500 m \ t 8479000.000 I 8479000.000 ECOLOGICAL MANAGEMENT SERVTCES EMS ENVlRONMENTAL CONSULTANTS 1 0000.000 151000.000 152000.000 153000.000 154000.000 • 155000.000 156000.000 157000.000

Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

2.0 Background Information – Ghost Bat Ecology and Status

The ghost bat is one of the more iconic bats of Australia because of its large size, predatory habitat and remarkable appearance. A summary of the most relevant aspects of its biology and management are provided below.

2.1 GHOST BAT STATUS

The ghost bat has a history of decline across its broad Australian distribution. There is subfossil evidence in southern Australia that suggests a decline during the Holocene (Molnar et al. 1984) and evidence of further range reductions since the arrival of Europeans, especially in parts of central Australia (Churchill and Helman 1990; Churchill 2008; review in Armstrong and Anstee 2000). In the past 50 years there has also been evidence of declines in natural roost caves and the loss of several roost sites from mining interests in Queensland (Augusteyn et al. 2018), the Pilbara region (K.N. Armstrong unpublished observations) and within the Northern Territory, including within the Pine Creek region (NSR 1993a). The most recent documented loss of a roost site involved a colony of 50 ghost bats Frances Creek, when mining activity resulted in destruction of a roost site in an old conveyor tunnel (MBS Environmental 2006). Losses of roost sites in the past decade were an important consideration in the listing of the ghost bat as Vulnerable under the EPBC Act 1999 (Threatened Species Scientific Committee 2016; listed 5 May 2016).

2.2 FOSSIL HISTORY AND TAXONOMY

The ghost bat Macroderma gigas (family Megadermatidae) is endemic to Australia (Churchill 2008; Richards et al. 2008). Other members of the family are found in Asia and Africa (Simmons 2005; Soisook et al. 2015). The ghost bat is the last relict of a diverse radiation in the Tertiary wet forests of northern Australia (Hand 1996). Seven megadermatids, including other extinct Macroderma, have been described so far from Tertiary deposits at the Riversleigh fossil sites in north‐western Queensland and elsewhere, with the oldest record of Macroderma gigas from deposits that are of early to mid‐Pliocene in age (Hand et al. 1988; Hand 1996).

A comparison of morphology across both its current and former range did not reveal a significant pattern of difference amongst regions, but there was a clinal pattern in body size, with northern individuals being slightly smaller (Hand and York 1990). Genetic differences among geographically isolated populations have not been used as a basis to suggest the presence of distinct subspecies (Worthington Wilmer et al. 1994; 1999). Each of the regional populations is a distinct evolutionary unit worthy of independent consideration in management and conservation planning.

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2.3 GHOST BAT ECOLOGY

The ghost bat is the third‐largest echolocating species of bat in the world (after Vampyrum spectrum and Cheiromeles torquatus), and the largest in Australia, weighing up to 170 g (Hudson and Wilson 1986; Churchill 2008). Females are larger than males, averaging 125 g and 110 g, respectively (Douglas 1967).

Ghost bats are one of the few carnivorous species of bat, and locate their prey using their large eyes, large ears and echolocation system. They have excellent sight, with a visual acuity equivalent to some murid rodents (Pettigrew et al. 1988). Their hearing is aided by the large pinna and has sensitivity peaks at 10–20 kHz and 35–43 kHz that correspond to the higher energy portions of each component of their multi‐harmonic echolocation calls (Guppy and Coles 1988).

Echolocation calls are short and multi‐harmonic, as is typical of the family (Kulzer et al 1984; Guppy et al. 1985). Ghost bats make several social calls that are audible to humans (‘chirps’, ‘squabbles’ and ‘twitters’; Kulzer et al 1984; Guppy et al. 1985; Pettigrew et al. 1986). The acoustic ecology of the ghost bat is the subject of a PhD currently in progress (Hanrahan et al. 2016).

Their diet consists of small mammals (including other bats), birds, reptiles, frogs and large insects, though it can vary according to region and the seasonal availability of some prey types, and the proportion of larger invertebrates can be high (Pettigrew et al. 1986; Schulz 1986; Boles 1999). Ghost bats forage either by perching from vegetation and ambushing passing prey in the air or on the ground, or by gleaning surfaces, including the ground. Most prey is taken to a feeding perch in trees, rock overhangs, or cave entrances to be consumed, and feeding sites can be relatively common compared to diurnal roost sites. Its prey remains and scat accumulations that can be found towards the entrances of caves and mines provide unambiguous evidence of its presence in an area.

Another distinctive trait of the ghost bat is the relatively high site fidelity of females (Worthington Wilmer et al. 1994, 1999), which results in stable breeding colonies, the tendency of females to stay at the site of their birth, and consequently the low likelihood of short‐term female recolonisation should they be dispersed or extirpated from a breeding site.

Previous studies in the Northern Territory have shown that foraging areas were an average of 1.9 km from roosts and 62 ha in size (Tidemann et al. 1985), however these results were potentially influenced by the limited range of telemetry equipment available at the time, and small sample size. Ghost bat wing morphology suggests they are capable of a much greater nightly range (Bullen and McKenzie 2002). Ghost

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Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019 bats have been recorded foraging at least 10 km from suitable roost sites on Groote Eylandt, indicating that nightly foraging movements can cover relatively large distances (Diete et al. 2016).

Ghost bats emerge from the roost shortly after sunset, moving directly to an area where they forage for approximately two hours. This is generally followed by a period of inactivity until the early morning when feeding activity begins again prior to returning to the roost before sunrise. The timing of emergence and return to the roost is variable across individuals (Tidemann et al. 1985), although the underlying causes for this variability has not been examined. The ghost bat moves between different foraging areas but will also revisit previous foraging areas on consecutive nights (Tidemann et al. 1985).

Females give birth to a single young and more rarely twins (N. Hanrahan, unpublished data). Most females breed by two years of age (Hoyle et al. 2001). Parturition occurs over the period of a month commencing in August in the Top End (Churchill 2008) and as late as mid‐October in Central Queensland. Young can be shifted to other warm caves as summer progresses. Juvenile bats commence flying at seven weeks, with all young capable of flight by the end of January (Toop 1985). Generation time is estimated at 8 years (Woinarski et al. 2014).

2.4 ROOSTING ECOLOGY AND USE OF ARTIFICIAL STRUCTURES

The types of subterranean structures that support the larger colonies of ghost bats and act as breeding sites are generally deep, with a relatively warm, humid microclimate. These sites are less common in the landscape than simple shallow caves and rock overhangs that have microclimates closer to external ambient conditions, and thus roosting opportunities are limited at critical times of the year (Armstrong and Anstee 2000; Threatened Species Scientific Committee 2016). Roosts are found in both natural caves and underground mines, as well as relatively shallow features such as crevices amongst granite rockpiles, rocky rises and sandstone escarpments.

A complicating factor for ghost bat management is their use of historical mining workings. Ghost bats are most likely to occupy horizontal adits, rather than vertical shafts (Armstrong 2001). Colonies of significant size (more than 5 individuals) will be more likely to form in deeper adits, especially those that are more than a simple small horizontal drive. Ghost bats have established colonies of significant size in these artificial underground structures, some of which are in the vicinity of ore bodies with remaining economic mining potential. There are several examples where mine adits and historical workings have allowed an increased area of occupancy at a landscape scale for obligate cave‐roosting bats, including the ghost bat and several horseshoe, leaf‐nosed and diamond‐faced bat species (Hall et al. 1997).

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These artificial roosts can provide critical maternity sites, routine roost sites, dispersal stop‐over roosts and hibernation sites for bats (Hall et al. 1997). Issues arise when a mining proposal requires reworking of old deposits where historical adits are present, or where easy human access to an adit results in high levels of disturbance (Hall et al. 1997). Many old mine sites constructed in gold rush periods following the 1880’s, including many in the Pine Creek region, are prone to deterioration and collapse, either excluding bats or trapping and killing large numbers inside the roost (Hall et al. 1997). While these old workings are not natural landscape features, there is still a legislated requirement to avoid mortality and prevent operations from contributing to the decline of the ghost bat, particularly at roost sites.

Ghost bats are especially vulnerable when occupying a diurnal roost. When disturbed by daytime entry of people, their response is typically to fly into daylight where they are exposed to predatory birds and unsuitable ambient conditions. A significant increase in the likelihood of mortality is expected in such a case. This has implications for a mining operation in close proximity to a roost site, in that it may:

 Introduce levels of noise and vibration that may cause an exit of bats into daylight;

 Cause night‐time relocation to an alternate site when there are few suitable nearby roosts; and/or

 Disrupt breeding activity.

2.5 VULNERABILITY OF GHOST BATS TO NOISE AND VIBRATION

Very little is known about how much noise and vibration from mining‐related activities, and its proximity, would cause an exodus response in bats. This applies to disturbance during the day, or over the longer term when bats do not return to a disturbed site. There have been two published studies of relevance in the Pilbara region of Western Australia that monitored the response of ghost bats to nearby daytime drilling activity:

• At the Klondyke Queen mine near Marble Bar, no detectable response of ghost bats (no daylight exodus; no decrease in number of individuals emerging at dusk on a subsequent night) was observed during RC drilling—for a minimum distance of 25 m from the adit entrance without a booster (84 m from estimated underground roost point; hole depth 60 m) and 38 m with a booster (105 m from estimated underground roost point; hole depth 90 m) (Armstrong 2010).

• In a similar study involving natural caves at Poondano, south of Port Hedland, no ghost bats were observed to exit the caves during the daytime drilling activity; and longer‐term occupancy of at least one cave by ghost bats continued—for a minimum distance of 25 m of a cave entrance (50 m from estimated underground roost point) (Bullen and Creese 2014).

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It is important to note that these studies were opportunistic and did not have the opportunity to control much of the ‘experimental design’, however they are the only relevant published studies that are available in the public domain. The distances are not directly applicable to the situation at Union Reefs because aspects of the exploration and mining program, ghost bat colony size and proximities differ.

3.0 Ghost Bat Environmental Values – Supporting Data

3.1 LOCATION OF GHOST BATS USING THE PROPOSAL AREA

3.1.1 Geographic Extent of the Regional Population The ghost bat ranges from the Pilbara and Kimberley regions of Western Australia, through the Top End and Gulf Fall country of the Northern Territory, to parts of northern Queensland (Churchill 2008; McKenzie and Hall 2008; Woinarski et al. 2014). Once distributed throughout most of the continent, ghost bats declined in the Holocene and after European settlement (Molnar et al. 1984, Churchill and Helman 1990). The ghost bat now exists as a fragmented group of geographically and genetically isolated populations across northern Australia—in the Pilbara and Kimberley regions of Western Australia, the Top End of the Northern Territory, and three groups in Queensland (Worthington‐Wilmer et al. 1994; 1999).

Estimates of the total population size for the species have differed among authors over the years, with Worthington Wilmer (2012) suggesting somewhere between 4,000–6,000 and the previous IUCN Red List account containing an estimate of 7,000–9,000 (McKenzie and Hall 2008). All population estimates agree that there are less than 10,000 individuals in existence (Woinarski et al. 2014). The current listing as Vulnerable under the Commonwealth Government’s Environment Protection and Biodiversity Conservation Act 1999 is predicated on a total population size of less than 10,000 individuals and a demonstrated ongoing population decline, in addition to other criteria.

The structuring of the continental range of populations is a consequence of the highly philopatric nature of females, which seldom move from their birthplace (“natal roosts”; Worthington Wilmer et al. 1994; 1999). Additional population genetic studies have revealed the effect of roost philopatry within regions, which also promotes population structuring on a smaller scale (K.N. Armstrong et al. unpublished data).

Deeper caves and mine adits that can support the specific roost conditions required by ghost bats are relatively uncommon, which limits roosting opportunity and area of occupancy. In general, ghost bats prefer warm, humid roost microclimates, with temperatures of 27–28.5 °C and vapour density of 20–24 g m‐3 recorded at roosts in the Northern Territory (Churchill 1991). These requirements are linked to a limited ability of the ghost bat to maintain heat and water balance in cooler conditions, and ghost bats are unable

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Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019 to enter torpor to save energy (Leitner and Nelson 1967; Kulzer et al. 1970; Armstrong and Anstee 2000; Baudinette et al. 2000). This results in congregations of ghost bats at relatively few subterranean structures (TSSC 2016; Armstrong and Anstee 2000). The roost microclimate requirements for breeding, especially after young are born, are unknown. However, larger colonies with breeding activity tend to be in deep caves with relatively warm and humid microclimates (Hall et al. 1997; Armstrong 2001). Single or small numbers of individuals are sometimes observed in caves or disused mines with microclimates that are cooler and drier than where larger colonies congregate, especially those containing individuals in breeding condition. Such individuals are often males that are presumably dispersing between breeding sites (K.N. Armstrong unpublished observations).

Important Northern Territory ghost bat populations occur within the Pine Creek, Katherine, Kakadu and Litchfield regions (Figure 1.1), centred on both natural and artificial (historical mine sites) roosts (Threatened Species Scientific Committee 2016). Important natural cave roost sites are located in Litchfield National Park, Kakadu National Park and in limestone karst landscapes at Claravale Station and Cutta Cutta Caves Nature Park (Table 3.1; Figure 1.1). The Pine Creek and south‐east Kakadu areas contain several historical mine sites, and these areas have become an important region of ghost bat distribution in the Northern Territory. Several extremely important roost and maternity sites are located in historical mine adits in the Pine Creek region (Threatened Species Scientific Committee 2016). Lager colonies (greater than 100 individuals) are present at two locations within 15 km of the Union Reefs project area, including the Kohinoor adit at Pine Creek and Spring Hill to the north (Figure 1.2).

While some of the NT Fauna Atlas records (Figure 2.1; 2.2) are likely to be observations of free‐flying bats remote from roost sites or bats detected at temporary feeding roosts such as road culverts, many were detected during searches of caves and historical mine sites (S. Churchill, personal communication). A subset of ghost bat records of the species away from a roost site are associated with rocky landscapes that support natural cave roosts or at sites with historical mine workings. Sightings of ghost bats in the vicinity of old mine workings potentially indicate the presence of roost sites in historical adits. Important historical mining areas in the region where ghost bats currently occur, or where bat colonies are known to have occupied historical gold adits (based on NT Government Fauna Atlas data and existing data) include Pine Creek, Union Reefs, Spring Hill, Frances Creek, Mount Wells, Grove Hill, Ban Ban Springs (Woolwonga) and Burrundie (Frances Hill) (Figure 2.1).

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3.1.2 Geographic Location and Size of Known or Predicted Ghost Bat Colonies In the Northern Territory, ghost bats roost in deep limestone or sandstone caves, shallow sandstone caves with domed ceilings or in disused mine adits (Churchill 2008). Culverts, out‐buildings and other artificial structures are also used as short‐term days roosts (Armstrong and Barden 2018). The current range of the ghost bat in the Northern Territory includes the Darwin Coastal, Pine Creek, Arnhem Coastal (including Groote Eylandt), Arnhem Plateau, Central Arnhem, Victoria Bonaparte, Daly Basin, Gulf Falls and uplands and Gulf Coastal Bioregions (Figure 2.1). The calculated area of occupancy (AOO) is 412 km2 based on roost site locations (Woinarski et al. 2014).

Larger known colonies of ghost bats in the area between Katherine and Batchelor occur in both natural cave systems and man‐made (adit type) structures. Important ghost bat roosts are present at Pine Creek (Kohinoor adit), Spring Hill, Claravale Station, Kakadu National Park and Litchfield National Park (Threatened Species Scientific Committee 2016; N. Hanrahan unpublished data; Figure 2). Important natural cave roost sites are located in sandstone escarpments in Litchfield and Kakadu National Parks and in limestone (karst) landscapes at Claravale, Tindal and near Beswick south of Katherine (Table 3.1; Figure 2.1). Smaller natural transitory roosts are likely to be associated with boulder piles and plateau margins in other geological provinces in the Pine Creek region.

The NT Fauna Atlas contains 123 records of the ghost bat in the greater Pine Creek region, with only 8.9% dated from recent (post‐2000) observations (NT Fauna Atlas 2019; Figure 2.1; Figure 2.2). Many of these records were compiled during regional surveys conducted in the late 1980’s and early 1990’s by the Northern Territory Government or Sue Churchill (Table 3.1). Combined counts from the late 1980’s indicate a regional population around Pine Creek of approximately 2,360 ghost bats at that time, with larger aggregations at the Kohinoor adit, and in mine adits through the historical mining areas to the north of Pine Creek, including sites at Woolonga, Frances Creek, Union Reefs, Spring Hill, Mount Masson and Mount Wells (Table 3.1; Figure 2.2).

In the interim period (post‐1990), several sites supporting ghost bat roosts have been destroyed by mining, including at Union Reefs, Woolwonga and Frances Creek. Long term counts at other locations, including the Kohinoor adit, have indicated an overall decline in ghost bat numbers over time. A comparison of counts from the late 1980’s at sites that have been revisited in the past 3 years, and assuming that bats at destroyed sites have been removed from the population, indicates a potential loss of approximately 1,070 (45 %) ghost bats from the Pine Creek region and 2,420 (58 %) ghost bats from the combined Pine Creek/Katherine/Kakadu region between 1989 and 2019 (Table 3.1; Figure 2.1). There are numerous sites

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Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019 that have not been revisited in recent times, indicating that there is still a level of uncertainly about current population numbers. A few sites, including Cutta Cutta Caves Nature Park, Tolmer Falls and Spring Hill, have remained stable or shown increases in ghost bat numbers over this period. The combined increases across these sites, if they are not artefacts of the counts, account for less than 200 ghost bats.

Existing data indicates a regional ghost bat population centred on Pine Creek and including Spring Hill to the north and Claravale Station to the south at 570 to 1,132 individuals—with a caveat that some locations in this area have not been inspected recently, other roost sites are likely to be present but undocumented, and some sites have been lost or damaged during post‐1990 mining operations. However, a large proportion of this regional population estimate (98 %) was generated from sites where there is recent count data, including Kohinoor adit, Spring Hill, Union Reefs and Claravale Station. The Pine Creek regional ghost bat population potentially includes 8.1 % to 12.5 % of the national (global) ghost bat population, based on recent count data and the total ghost bat population estimate for the IUCN Red List (total population estimates: 7,000–9,000 by McKenzie and Hall 2008; <10,000 by Woinarski et al. 2014; Threatened Species Scientific Committee 2016). Based on these population figures, the Union Reefs population potentially represents 2.6 % of the estimated regional ghost bat population and 0.3–0.4 % of the estimated national (global) ghost bat population. Note that as ghost bat populations are not known to occur outside of Australian territorial areas, the national (Australian) and global population estimates are the same.

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Figure 2.2 Pine Creek Region 120�6 140000 160000 Ghost Bat Records Mapping data source: GEOScience Australia/ALA/NT Fauna Atlas 2019 Datum: Map Grid of Australia 94 Zone 52/GDA94 UTM Original mapping layer data Copyright EMS Pty Ltd 2019 [email protected] Client: KLG Project: UR Ghost Bat EIS Date: 20 Sept 2019 Author: PB Kakadu NP

8500000

Map Area

Legend 8480000 8480000

� Ghost Bat NT Fauna Atlas Post-2000 • Ghost Bat NT Fauna Atlas Pre-2000

♦ Union Reefs GB Records 2018 - 2019

c, Ghost Bat Records ALA 8460000 roads Umbrawarra Gorg� 1-+-+ railways 0 Mineral Titles Granted

National Parks

8440000 0 10 20 km

ECOLOGICAL MANAGEMENT SERVJCES 120000 140000 200000 EMS ENVIRONMENTAL CONSULTANTS

Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

Table 3.1 Summary of Recent and Historical Ghost Bat Count Estimates for the Northern Territory

Colony number estimates based on existing data (NT Fauna Atlas), historical count data and recent counts at roost sites. Historical count data from the Pine Creek, Katherine and Litchfield regions are derived mainly from surveys conducted by Sue Churchill. Highlighted rows indicate summary regional, Northern Territory and national population estimates.

Date of Most Historical Recent Recent Recent (pre‐1990) Lower Upper Number Region Location Site Name Roost Type Estimate Count Estimate Estimate Lost Data Source Notes Global Australia Australia Mixed 2008 7,000 9,000 McKenzie & Hall 2008 Estimate of global ghost bat population NT NT Northern Territory Mixed 2008 2,500 3,500 Worthington‐Wilmer 2012 Estimate of NT ghost bat population Pine Creek Union Reefs Adit G and H Adit 1992 200 0 170 NSR 1993a, S. Churchill Ghost bats excluded and adits destroyed during excavation of Crosscourse Pit.

Pine Creek Frances Creek Mine Frances Creek Conveyor Tunnel 2006 0 50 Low 2006 Dispersed and roost destroyed following recommencement of mining

Pine Creek Union Reefs Union North/OK Adit (Historical) Jul‐05 20 30 Armstrong/Barden/Hanrahan May support a colony that moved from Adit G and H after mining in the 1990s.

Pine Creek Pine Creek Kohinoor Adit Adit (Historical) 2015‐2018 1,500 400 800 700 S. Churchill, N. Hanrahan Pine Creek Pine Creek Jensen’s Adit Adit (Historical) 1988 10 0 Jolly 1988 No recent counts at this location Pine Creek Mount Wells (South) Deans Camp Adit (Historical) 1989 250 0 S. Churchill No recent count data at this location Pine Creek Mount Wells Adits Adit (Historical) 1989 40 0 S. Churchill No recent counts at this location Pine Creek Spring Hill Adit (Historical) 2018 60 100 200 SLR 2019 Pine Creek Grove Hill Adit (Historical) 1988 1 1 NT Atlas (S. Churchill) Pine Creek Ban Ban Springs Woolwonga Mine Adit (Historical) 1989 250 0 250 S. Churchill Ghost bats not sighted after re‐commencement of mining 1989 (S. Churchill)

Pine Creek Burrundie Frances Hill Adit (Historical) 1989 1 1 NT Atlas Pine Creek Mount Evelyn Mine Mt Evelyn/Moline Adit (Historical) 1989 25 0 S. Churchill No recent counts at this location Pine Creek Mount Masson Mount Masson Adit (Historical) 1989 70 0 S. Churchill No recent counts at this location Pine Creek Nitmiluk NP Edith Falls ‐ Lelyin Sandstone 1987 10 S. Churchill No recent counts at this location Pine Creek Claravale Station Claravale Station Cave (Limestone) 2016‐2018 50 100 N. Hanrahan Pine Creek Pine Creek Region SUM All Pine Creek Adits + Caves 2,367 570 1,132 1,170 Various sources

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Date of Most Historical Recent Recent Recent (pre‐1990) Lower Upper Number Region Location Site Name Roost Type Estimate Count Estimate Estimate Lost Data Source Notes Katherine Kintore Caves CA Kintore Cave Cave (Limestone) 1987 2 S. Churchill No recent counts at this location Katherine Beswick Tree Roost Prison Cave (Limestone) 1988 200 S. Churchill No recent counts at this location Katherine Tindal Cutta Cutta Caves Cave (Limestone) 2019 10 5 12 S. Churchill (2019) A total of 12 counted on flyout. Very limited Nature Park amounts of GB scats in main tourist cave. Litchfield Litchfield NP Tolmer Cave 2018 250 305 S. Churchill, N. Hanrahan (Sandstone) Litchfield Litchfield NP Bamboo Creek Cave, adit 2018 3 5 S. Churchill, N. Hanrahan Kakadu NP Kakadu NP Central Kakadu Cave 2016 1,500 150 1,350 NT Atlas, White et al. 2016, White et al. (2016) reported very low numbers (Sandstone) TSSC 2016, Hanrahan + (41 individuals) at 8 Kakadu sites. Barden and Barden Hanrahan both recorded a post‐2000 count of 150 at one site.

Pine Creek Pine Creek/ Litchfield Combined counts from the Pine Litchfield/Katherine/ Regional Sum Adits + Caves 4,132 575 1,604 2,520 Various sources Katherine Creek/Litchfield/Katherine/Kakadu Region Kakadu Region Kakadu

Lower Gulf Pungalina Station Pungalina Station Cave (Limestone) 2018 100 180 N. Hanrahan Cave Lower Gulf Redbank Redbank 2013 1 1 Armstrong, Barden, Hogan (Sandstone)

Cave 3 sandstone escarpment roosts with 1 or 2 Groote Eylandt Groote Eylandt Various 2018 5 P. Barden (Sandstone) ghost bats. Total NT 4,331 675 1,790 2,420

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Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

3.1.3 Characteristics of Known and Likely Natural and Artificial Roosts in the Proposal Area Early gold mining in the Pine Creek area commenced in 1870 and continued until 1915. This early mining phase was highly selective and concentrated on high‐grade veins (Edwards and Keily 2017). Mining was undertaken using highly selective shallow pits, shafts and narrow adits that systematically followed the auriferous lodes. These mines were largely confined to the oxide zone and stopped at the water table. A large number of historical gold mining sites from this period are located within the hills surrounding the Union Reefs project area. However, the majority of these sites are scrapes, pits and shafts that are unsuitable as ghost bat roost sites (Armstrong and Barden 2018). These historical mines occur within a landscape that has been modified by recent (post‐1990) open cut mining, which has resulted in the development of several large open‐cut pits and tailings deposition areas. These activities are known to have removed a number of historical workings, including several occupied by ghost bats prior to the 1990’s (NSR 1993a).

There are four records of ghost bats within 10 km of the Union Reefs mill dating from between 1987 and 1995 in the Northern Territory Fauna Atlas (DENR 2019). The closest observations are 1.8 and 2.2 km south‐ east of the Union Reefs mill, however the location data appended to these observations is imprecise. Ghost bats were first detected on the Union Reefs site in 1987 and 1988, when biologists from the Northern Territory Conservation Commission (CCNT, Sue Churchill) discovered roost sites in the Union Reefs Adit (Adit G) and Lady Alice Adit (Adit H) (NSR 1993a). 200 ghost bats were identified in Adit H and up to six ghost bats were observed in Adit G during surveys (NSR 1993a). CCNT bat specialists concluded that the presence of lactating females and young in Adit H indicated that the site functioned as a maternity roost (Sue Churchill, personal communication to P. Barden).

Monitoring was undertaken at Adit G and H following recommendations of the Draft EIS (NSR 1993a) and the ghost bats were later excluded using physical barriers during the exploration operations in the early 1990’s (NSR 1993a). NSR (1993a) reported that the entrances to most adits at the site were covered with rubble during the 1992 exploration phase, however ghost bats were still present, with approximately 75 to 100 observed in Adit H following completion of the exploration program. Six other adits in the vicinity of the Crosscourse Pit were closed and subsequently destroyed by the site operator during the early 1990’s, with unknown consequences for local ghost bat populations (NSR 1993a; CCNT 1993; unpublished internal Shell Company of Australia documents). Internal mine documents indicate that during an attempt to close Adit H in 1994 using 40 mm wire mesh and shade cloth, up to 20 ghost bats were entangled and several were killed. Following consultation with the Northern Territory Government, Adit G was permanently closed in 1995 using mounded earth at the entrance and adit H was closed using a plywood barrier in January 1996. Both adits were subsequently partially or completely destroyed during open cut mining between the Union North

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Pit and Crosscourse Pit. The precise location of the adit G and H is unknown, but based on historical mapping they appear to correspond with the current Prospect Pit. The internal dimensions of these adits were not documented prior to their destruction or closure (NSR 1993a; 1993b).

Given the absence of landscape and geological features supporting natural cave systems within the Union Reefs project area, sites supporting ghost bat colonies are restricted to historical mine workings. This observation is supported by historical and recent surveys in the Union Reefs area (Armstrong and Barden 2018). A survey of old mine workings with the immediate vicinity of the Union Reefs project area was undertaken in 2018 (Armstrong and Barden 2018). This survey involved detailed examinations in the project area using previously documented historic mine locations and geological mapping as a guide. All of the mapped sites were inspected on foot, and other suitable locations within the project area were inspected during the survey (Armstrong and Barden 2018). All pit walls within the project area were visually checked for remnants of old underground mine workings. Mine workings were not entered for safety reasons. Adits that could be accessed at the external portal were investigated using a pole‐mounted camera with a light source and this method was used to obtain video recordings a few metres from the entrance (Armstrong and Barden 2018). Each historical mine working encountered was mapped and described, and sites thought to be potentially suitable as a ghost bat roost were subjected to additional non‐invasive assessment, including acoustic monitoring and fly‐out counts using thermal and infra‐red video cameras (Armstrong and Barden 2018).

The survey identified three adits, one shaft and two parts of a mostly‐filled stope that had the potential to extend further than could be seen from the entrance as potential roosts (Figure 1). The Union North adit (Figure 3) and OK adit (Figure 4) were confirmed as being occupied by ghost bats (Armstrong and Barden 2018). These adits exist as open portals in the side walls of mine pits and are the remnants of larger structures that were mostly removed during excavation of the pits. Since the discovery of ghost bats at these sites in mid‐2018, they have been subjected to monitoring using permanent 24‐hour acoustic recorders and periodic fly‐out counts using thermal/infrared cameras (Barden and Hanrahan 2019). The monitoring has identified approximately 20 to 30 ghost bats that use both the OK adit and Union North adit as daytime roost sites, with the roosting restricted to the Union North adit for most of the dry season (Barden and Hanrahan 2019).

During the monitoring program, an additional short adit was discovered in the Prospect Pit (Figure 2; Figure 5) and is thought to have been exposed during a recent rock fall. The Prospect adit is used as a nocturnal feeding site and occasional day‐time roost for one or two ghost bats (Barden and Hanrahan 2019). The Lady Alice adit (Figure 6) is currently almost completely blocked by fallen debris and rubble and ghost bats have

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Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019 not been detected using this site. However, this location has been identified by KLG as a potential site that could be re‐opened to create additional ghost bat roost habitat within the project area at a later date. The internal microclimate of this adit is likely to be suitable for this species, as orange diamond‐faced bats have been observed roosting at this location (Armstrong and Barden 2018).

The structural dimensions and known roost characteristics of the four adits are included in Table 3.2 and Figures 3‐6. Two other nocturnal feeding sites were identified in the vicinity of the Union Reefs project area during the 2018 survey, and both are located in storm water culverts on the railway line to the west of the lease (Figure 2).

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Table 3.2 Structure of Adits at the Union Reefs Project Area

Based on observations at the entrance using a pole‐mounted camera and laser range finder. The OK adit has been subjected to an internal inspection.

Est Depth Est Depth Height Entrance Entrance of Side Ghost bat Ghost bat Adit from Internal Width Height Side Drive Drive number number Inspection Name Location Entrance (m) (m) (m) (m) Present (m) minimum maximum Type Comments Union Union North 62 1.2 1 1.5 Unknown 20 30 Entrance Depth measured using laser range finder from the entrance. North Pit Internal structures unknown—will be subjected to inspection by KLG. Used by 20 – 30 ghost bats as a diurnal roost on a regular basis across the wet and dry season. Bats tend to move to the OK adit periodically during the wet season and use the Union North adit in the dry season.

Ok Prospect Pit 18 1.5 1.5 1.2 Yes 10 20 30 Internal Internal structure determined using pipe inspection camera Inspection and internal investigation by KLG staff. A group of 20 – 30 ghost bats roost at the end of the southern drive during the wet season. These bats switch to the Union North Adit in the dry season.

Prospect Prospect Pit 8 1.5 0.4 0.4 No N/A 1 1 Entrance Short remnant of a formerly larger adit, with only a small opening allowing access for bats. Thought to have been exposed by a rock fall during 2018. Mainly used as a nocturnal feeding site, but occasionally used by small numbers or individual ghost bats as an overnight roost in 2019.

Lady East of 30 1.5 0.4 0.2 Unknown 0 0 Entrance/ Ghost bats not detected in the internal structure. The entrance Alice Union North shaft has been largely blocked except for a narrow opening. The Pit internal structure remains open and intersects a shaft that exits to the surface approximately 30m to the east. Re‐opening and modifying the structure is Action 4 in the Action Plan (Armstrong et al. 2019b).

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Figure 3. Union North Adit Internal Structure. Structure estimated from external observations and minimum straight line depth measure derived from a laser range finder at the entrance. This adit will be subjected to further investigations and mapping. The location of the preferred ghost bat roost location currently unknown. Inset photo (upper): Union North adit exterior. Inset photo (lower): Union North adit at the entrance.

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Figure 4. OK Adit Internal Structure. Structure described from internal inspections of the adit. The main ghost bat roost location is at the end of the 10 m southern drive, based on observations at the adit entrance and accumulated guano. Inset photo (upper): OK Adit exterior. Inset photo (lower): OK adit internal structure, main drive; note the back of the tunnel is visible.

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Figure 5. Prospect Adit Internal Structure. Structure estimated based on observations at the entrance. The entrance is highly unstable and is thought to have opened recently due to shifting shale. This is supported by the very low level of guano at the entrance when this adit was first inspected, indicating very recent occupation by bats. Inset photo (upper): Prospect Adit exterior, with 25 mm conduit housing the acoustic monitoring microphone cable visible at the entrance. Inset photo (lower): Prospect Adit internal structure from the entrance, showing the far end blocked by fallen rubble.

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Figure 6. Lady Alice Adit Internal Structure. Structure estimated based on observations at the entrance and at the shaft. The internal structure of this adit will be the subject of further investigation. The entrance is extremely narrow due to accumulation of rubble and debris at the entrance. The depth of the shaft and internal structure of the adit are unknown. Ghost bats have not been observed at this site, however orange diamond‐faced bats (Rhinonicteris aurantia) have been observed roosting in the internal structure. Inset photo (upper): Lady Alice exterior, with the entrance largely blocked by rubble and other material. Inset photo (lower): Lady Alice adit interior, viewed from the opening.

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3.2 SEASONAL USE OF THE UNION REEFS AREA BY GHOST BATS

3.2.1 Occupation and Seasonal Use of Adits by Ghost Bats at Union Reefs Monitoring for the presence of bats using ultrasonic sound recorders (‘bat detectors’; Titley Scientific AnaBat Swift bat detectors) began at Union North and OK adits on the 22 October 2018 and at Prospect adit on the 31 October 2018. This monitoring has continued, with only minor interruptions due to technical issues, until October 2019, and is ongoing. To date, the monitoring effort has sampled across most of two breeding seasons.

Bat detectors were placed at the entrance of the adits with microphones directed inside the structures. Extension leads have since been added to allow microphones to be placed inside the entrance of each adit, and to reduce any disturbance to the roosts during maintenance of the detectors and retrieval of data. Acoustic data is recovered weekly by KLG environment staff, and data analysis has been conducted by Nicola Hanrahan.

Bat calls are detected and grouped based on the similarity of their signature structure into preliminary clusters by Wildlife Acoustics Kaleidoscope Pro version 4.5 software. Examples within each cluster are then checked manually, and identified as ghost bat echolocation or social calls, or else echolocation calls of other bat species. Results are exported for graphical summarisation using an [R] computing language script. Video recordings have also been collated at regular intervals over the monitoring period using a FLIR Tau 320 thermal camera connected to a SportDV digital video recorder. Video files are examined manually to determine the number of ghost bats exiting and re‐entering the roost and the minimum and maximum colony size is calculated.

The monitoring has confirmed ongoing use of the Union North and OK adits as diurnal roosts by ghost bats (Figure 7). The changing pattern of nightly activity levels across survey nights indicates that a local colony of 20–30 ghost bats moves between these two roosts. The factors driving these movements are unknown, but may be partly dependent on season and possibly disturbance levels. The OK adit is a shallow structure measuring c. 18 m in depth, with one crosscut tunnel (drive) to the south around 10 m deep entering approximately halfway down the main tunnel. The shallow depth of the OK adit is sufficient to maintain a suitable warm and humid roosting microclimate for the ghost bat during the wet season, but it is probably unsuitable as a diurnal roost in the dry season. Despite this, the adit is still used as a nocturnal refuge and feeding refuge during the dry season. The Union North adit is much deeper, measuring approximately 62 metres in depth (estimated using a laser range finder).

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The continued presence of orange diamond‐faced bats (Rhinonicteris aurantia) across the wet and dry season at the Union North adit suggests that microclimate conditions in this adit would also be suitable for the ghost bat across the range of seasonal conditions, so the roost switching of the ghost bat between the Union North and OK adits is not related primarily to an unsuitable roost microclimate at Union North. There are currently no observations that support a clear explanation for the patterns of movement of ghost bats between the two adits. The seasonal use of the OK adit commenced in November 2019, however the shift to this adit was earlier in 2019, with ghost bats present during the day in September 2019. The Prospect adit, by comparison, has a much lower level of activity than the other two locations (Barden and Hanrahan 2019). This site appears to be used occasionally as a diurnal roost for a small number of individuals and as a nocturnal refuge and feeding perch at other times.

3.2.2 Regional Use of Adits and Caves by Roosting Ghost Bats Significant ghost bats colonies in the region are situated at Pine Creek within the Kohinoor adit (up to 800 individuals), Spring Hill (up to 200 individuals) and Claravale (up to 100 individuals) to the south. The two major roosts adjacent to Union Reefs are 10 km north (Spring Hill) and 13 km south (Kohinoor) and are potentially within the nightly ghost bat foraging range (given measurements of flight capability in Bullen and McKenzie 2002). There are likely to be numerous transitory roosts in the intervening area, including shallow mine workings, culverts and small cave features in boulder piles and plateau margins. These may allow the movement of individuals among the major known colonies.

The adits in the Union Reefs project area have been occupied over a 32 year period since their discovery in October 1987 (NSR 1993a), with intervening periods where disturbance and mining resulted in declines in numbers and shifts to alternative roost locations. The colony at Kohinoor adit in Pine Creek has been present at this site since its discovery in the late 1950’s, a period of approximately 60 years of constant occupancy. The longevity of other regional roosts is less well known, however these sites are likely to have been occupied by ghost bats over extended periods.

The site with the longest history of monitoring, the Kohinoor adit, has shown relatively stable numbers over the period since discovery to around 1990 (NSR 1993a), across a period where the main Darwin to Alice Springs highway was located within 30 m of the entrance. The site has been subject to disturbances from human intrusion and mining exploration (NSR 1993a). Historical counts at Kohinoor were 1,200– 1,500 individuals, but more recent estimates with video technology have been between 400 to 800 individuals (N. Hanrahan unpublished data). Other declines have been observed in the Pilbara region of Western Australia and Queensland (Augusteyn et al. 2018; K.N. Armstrong unpublished observations).

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The continued occupation of sites at Union Reefs and Pine Creek across periods of sometimes high levels of disturbance is indicative of the high level of importance of these roosts in the landscape. The high level of sensitivity of ghost bats to disturbance (Threatened Species Scientific Committee 2016; Woinarski et al. 2014) suggests that if alternative suitable sites were available, stronghold roosts at Pine Creek and Union Reefs would very likely be abandoned—with individuals moving to less disturbed sites.

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Ghost bat activity at three adits at the Union Reefs mine site 1600

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bat

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18 18 18 18 18 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 18 18 18 18 18 18 19 19 19 19 19 19 19 19 19 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ghost

July July July July July May May May May June June June June April April April April April Total March March March March August August August January January January January October October February February February February December December December December December November November November November Date

Union North OK Prospect

Figure 7. Seasonal Use of Adits in the UR Project Area 2018 – 2019. Based on acoustic monitoring data. Gaps indicate periods when monitoring was paused. The activity peaks for the OK adit occurred in the period between October and February, with low levels of activity in July and August 2019. Low levels of ghost bat activity were detected at Union Reefs adit across the dry season (May – August), with peak activity in August to November.

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3.3 SIGNIFICANCE OF ADITS FOR GHOST BATS

3.3.1 Significance of Proposal Area Adits for Ghost Bats As the ghost bat relies on roost sites that have very specific microclimate criteria, which are extremely restricted in their availability in the landscape, any suitable roost site would have to be considered critical habitat for the survival of the species in a region. For ghost bats, a hierarchy of significance can be applied to roost sites, with deep and humid caves and mines that provide roost habitat across a range of seasonal conditions being the most restricted in terms of availability, and therefore the most important for the survival of a regional population. Roosts that can be used primarily across the wet season, when ambient temperature and humidity result in a larger set of roost sites becoming available, are more common and therefore potentially of lesser significance. In the case of the Union Reef project area, the most important roost site is the Union North adit. The proposal does not require direct disturbance at this location, and impacts are likely to be limited to insignificant levels of vibration or noise during the construction and operation of the underground mine (Velasco 2019).

The two roosts proposed for temporary closure (OK and Prospect adits) as a temporary measure to minimise disturbance to roosting bats during the mining phase appear to be used only as wet season diurnal roosts (Armstrong and Barden 2018; Hanrahan et al. 2019; Barden and Hanrahan 2019). The impact of the temporary loss of these locations is proposed to be offset by opening and renovating an alternative roost (Lady Alice adit) and the provision of artificial roosts to provide alternative habitat during and following the project.

3.3.2 Regional Significance of Union Reefs Adits for Ghost Bats The proportion of the regional population of ghost bats within the Union Reefs project area has been estimated at 2.6 % of the regional population, and 0.3 % of the national (global) ghost bat population. The ghost bats occupying local adits are likely to be a component of a larger regional population, and the site potentially represents an important transitional roost between two larger regional colonies at Spring Hill to the north and Pine Creek to the south. In this context, the ghost bats within the Union Reefs project area are at least of regional significance. The proposal requires temporary closure of two seasonal (mainly wet season) roosts during operations to mitigate impacts on ghost bats from noise and vibration at these locations. These measures are predicted to not result in the long term decrease in the numbers of ghost bats in the Union Reefs project area, given that the Union North adit will remain intact, and that other measures are proposed to provide additional seasonal roost options to offset the closures (see attached Action Plan; Armstrong and Barden 2019b). These additional sites, in combination with the Union North

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adit, are likely to continue to facilitate the use of the Union Reefs project area by ghost bats, and allow for continuation of transitional movements between regional colonies.

3.3.3 Existing and Required Genetic Information Several studies that have used genetic markers to investigate the geographic limits of populations and the connectedness of colonies in various parts of the range of the ghost bat. The first study that examined population structuring across the entire extant range of the species was conducted by Worthington Wilmer et al. (1994, 1999), which used mitochondrial and microsatellite markers. This seminal study demonstrated that the range of the species consisted of several non‐unconnected interbreeding groups (=populations). Subsequently, work by Dr Kyle Armstrong used microsatellites to integrate Western Australian populations (Pilbara, Kimberley) into the national dataset generated by Worthington Wilmer et al. (1994, 1999), as well as resequencing with new, powerful next‐generation DNA markers (single nucleotide polymorphisms; using a technique called “DArTseq”) (K.N. Armstrong, manuscript in preparation). Some of the raw data from this effort is the basis for a new individual‐recognition marker set for identifying individuals from scats, which is being developed by the Western Australia Department of Biodiversity, Conservation and Attractions (for identifying individuals from scats; Dr Kym Ottewell; see comments elsewhere about the applicability of this resource in the present context). The PhD study of Ms Nicola Hanrahan used the same DArTseq approach to investigate the connectedness of some selected colonies in the Northern Territory, and correlate genetic similarity in the context of acoustic call variation (Hanrahan et al. manuscript in preparation). These DArTseq resources (held by Armstrong and Hanrahan) can be made available as context for the efforts in the present proposal (see Action 10 in Armstrong et al. 2019).

All genetic studies on ghost bat made to date show that there is relatively little movement among colonies, but we know from other observations that some individuals do move around the landscape as part of natural patterns.

The present proposal identified a knowledge gap relevant to contingencies involving alternative roost sites following the closure of the OK adit. Having a better understanding of the connectedness of colonies in the region can be achieved using a genetic approach. The DArTseq method incorporates thousands of independent markers across the genome and therefore has the power to resolve relatively fine‐scale relationships of animal groups—in this case, bat colonies. The method also allows the recognition of individuals if they are recaptured and genotyped (DNA‐sequenced) again at a second location, however

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establishing the connectedness of colonies is not reliant on detecting individual migration events, as the analyses are sensitive to multiple movement events and interbreeding over longer timescales.

What is required for the present proposal is a reasonable level of non‐lethal biopsy sampling of each of the major colonies in the region so that the question of their connectedness can be addressed. There is scope for more detailed analyses on movements and behaviour as part of Action 11 (Appendix 2), but in order to make a simple demonstration that any Ghost Bats that may be disturbed at the Union North adit are capable of reaching other sites already in use by ghost bats by other individuals, the genetic study outlined in Action 10 should be sufficient, along in concert with the other Actions.

4.0 Potential Impacts and Risks

4.1 NOISE AND VIBRATION

4.1.1 Susceptibility of Ghost Bats to Low Level Vibration and Noise A modelling study that estimated the magnitude of vibrations surrounding the numerous blast points planned in the excavation of the underground mine below the Prospect Pit was conducted by Marco Velasco (Acoustic Engineer – Noise and Vibration, GHD Pty Ltd) (Velasco 2019). Noise levels were also calculated in this model. The coordinates of seven locations where the ghost bat had been recorded in the Union Reefs project area were considered. Details can be found in the appended report (Appendix 1).

The magnitude of vibrations from blasting, for Geological Strength Indices (GSI) of 30 and 50, was estimated at 29.6 mm/sec and 54.6 mm/sec, respectively, for the OK adit (minimum distance between estimated position of roost site and blast point 33 m) and 15.7 mm/sec and 28.9 mm/sec for the Prospect adit (minimum distance between estimated position of roost site and blast point 51 m). The remaining locations all had values between 0.1 and 2.5 mm/sec. For comparison, work conducted by Rio Tinto at Koodaideri in the Pilbara adjacent to a colony of the Pilbara diamond‐faced bat (R. aurantia) suggested that vibration levels below 10 mm/sec is sufficient not to cause a significant disturbance to this species (Bullen 2013), which is also sensitive to intrusion within its roosts. The results of the present modelling study demonstrate:

 The OK adit and Prospect adit are likely to experience what can be considered significant levels of vibration during the many planned blasts.

 This is good justification for a plan that excludes ghost bats from the area that will receive relatively high levels of vibration.

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 The other locations, in particular the Union North adit (1.2 and 2.3 mm/sec), appear to be well away from areas where relatively high vibrations are expected.

Noise levels produced by blasting are not expected to present a significant negative effect to the ghost bat. This is because the blasting will take place underground, so noise will be ground‐borne, i.e. re‐radiated from the ground into the airspace of a tunnel. Levels were modelled to be relatively low (75 dBZ at OK adit; 62 dBZ at Union North), roughly equivalent to human conversation at 1–2 metres. Noise will also be at the lower frequency limit of hearing of the species, if they will detect it all (the majority of energy between 1 Hz to 50 Hz). There is some opinion from consultants working in the Pilbara about what level of noise will disturb ghost bats (see discussion in Northern Resource Consultants 2018), but within‐roost levels of machine or blast noise have never been measured (the A‐weighted acoustic measurements of Bullen and Creese 2014 were taken 2–3 m within a cave entrance, and the distance to an inferred roost site was c. 50 m from the source). An empirical assessment of disturbance threshold (for a variety of possible responses; e.g. see Armstrong 2010) has not been undertaken. Noise levels from blasting are of significantly shorter duration than drilling, which might take 12 hours or more. Whether bats become habituated to short, relatively minor, low frequency noises associated with periodic underground blasts is unknown, but longer duration sounds from nearby drilling certainly did not cause daytime roost exodus in the two published studies available (Armstrong 2010; Bullen and Creese 2014).

4.1.2 Damage to Roost Sites – Internal Blockages and Collapse Damage to the structure of the Union North adit (internal collapse or entrance blockage) is the most relevant to consider, because this site will likely constitute the focus for the Union Reefs colony following the closure of the OK adit. The risk of such damage occurring is unknown because the internal structure has not yet been surveyed. However, from a vantage point at the entrance, the adit looks stable, and the pit walls above the entrance portal do not show signs of instability that might indicate the possibility of a minor ‘landslide’ that would cover it. The likelihood of collapse of the structure cannot be predicted without information on internal stability (see Action 2 in the Action Plan; Armstrong et al. 2019b).

Three Actions have been outlined (see Section 5 on Mitigation and Minimisation) that will address this risk:

 As part of Action 2: The interior structure of the Union North adit and OK adit will be inspected to determine depth and extent, stability, the presence of crosscuts/stopes/shafts/etc, and the position of guano piles indicating roost position.

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 As part of Action 3: Plans are underway to provide several alternative horizontal tunnel habitats, not only to replace the OK adit, but to provide further redundancy via multiple new roosting options within the Union Reefs project area to minimise or remove the risk of elevated mortality from the mining‐related activity and OK adit closure.

 As part of Action 7, the Union North adit portal will be inspected during regular visits to maintain electronic acoustic and video monitoring equipment. In the event of a collapse affecting the entrance portal, any blockage to the entrance of the Union North adit will be removed. Subsequently, and if safe for human entry, the effect on ghost bats will be evaluated by inspecting the interior for individuals that may have perished. These will be reported to DENR, and any carcasses submitted to the MAGNT.

4.1.3 Relocation to Sub‐optimal Roosts The precautionary principle is applied commonly when assessing the possible impacts of a proposed development on the ghost bat. This species has a physiological requirement for a roost with a relatively warm, humid microclimate (Leitner and Nelson 1970; Kulzer et al. 1973), and only a small proportion of caves in the Australian landscape typically provide these conditions (e.g. Churchill 1991; Armstrong and Anstee 2000; Armstrong 2001). Any exodus response to mining‐related activity at the Union North adit or the proposed exclusion at the OK adit might produce one of two scenarios:

1. Ghost bats relocating to either a known roost with an optimal or acceptable microclimate (given seasonal changes); or

2. Ghost bats relocating to a ‘random’ cave that is too shallow to provide a suitable microclimate. In the latter case, bats would need to move again until they find a suitable roost.

Mortality of these individuals from actions in the Proposal need not be assumed. The likelihood for ‘self‐ relocation’ to a suboptimal roost, and a resultant elevated risk of mortality, is considered low, for the following reasons:

• The proposed exclusion of the ghost bat from the OK adit will be undertaken in the least invasive way possible. A key tactic is to time the exclusion of bats from the OK adit in a period when bats have shifted their attention to the Union North adit, and when there is no activity of ghost bats at the OK adit (based on patterns observed to date (Hanrahan et al. 2019; see also Figure 7) and monitoring that will be undertaken in the future (see Action 7 in the Action Plan; Armstrong et al. 2019b);

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 The close proximity of the Union North adit means that at least one alternative roost is nearby if individuals are searching close to dawn;

 As mentioned in a section above, the risk of exodus and relocation from the Union North adit due to elevated noise and vibration levels from blasting is considered unlikely;

 The two largest colonies in the region are nearby and probably within the nightly flight range of the ghost bat. The colonies at Pine Creek and Spring Hill are both within 15 km from the Union Reefs adits, and ghost bats are likely to be able to fly this distance in a single night (Bullen and McKenzie 2002).

 In addition, there are multiple proposed Actions (see Section 5 on Mitigation and Minimisation) that can be used in an adaptive management approach to minimise the risk of elevated mortality from relocation to suboptimal roosts, and provide information on whether this is likely to have occurred.

4.2 IMPACTS OF A TEMPORARY EXCLUSION FROM THE OK ADIT

The temporary closure of the OK adit will have the following consequences:

 It will remove temporarily one of two ghost bat diurnal roost sites in the Union Reefs area, i.e. loss of redundancy in the event that one roost becomes unsuitable or is disturbed.

 It will remove temporarily what appears to be a seasonal or occasional focus for bats in this area.

 It will remove temporarily what appears to be a relatively shallow structure (18 metres maximum tunnel depth, one shorter crosscut), and thus the analogue of a relatively shallow natural cave, which are more common than deeper structures.

 It might or might not provide an impetus for the movement of individuals, with predicted connections to unknown natural cave sites in the surrounding hills, and the major colonies c. 15 km away at both Pine Creek and Spring Hill.

 Given that closure will be timed for when ghost bats are congregated in the Union North adit (most likely the months of June, August, October, November), or at least when numbers have previously been observed to be low in the OK adit (March to August) it will avoid significant disruption when females are giving birth and raising young (based on reproductive information in Churchill 2008).

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Based on the observations derived from the 2018‐2019 monitoring program at UR, the most likely scenario is that most individual bats will remain in the Union North adit. It is predicted that some will move elsewhere, either into natural caves surrounding the project area if they exist, or the larger colonies at Pine Creek and Spring Hill.

Two assumptions have been created to arrive at this scenario:

1. At least one natural cave in the hills surrounding the Union Reefs project area provides a suitable microclimate for ghost bat roosting, and at times relevant to the closure of the OK adit;

2. There are indeed regular movements within the region, amongst the Pine Creek, Spring Hill and Union Reefs colonies and surrounding caves.

Both of these assumptions can be tested in the coming months, providing a validation of the above scenario. Further redundancy for ghost bat movement will be provided by proactive management solutions, including:

 Field surveys for ghost bat diurnal roosts in caves in the hills surrounding the Union Reefs project area.

 A genetic study that will provide evidence on whether connections are likely between these three colonies. Given fluctuations in colony size observed in the Union reefs project area since August 2018, it is expected that genetic markers will confirm the connectedness of regional colonies.

In addition, further confidence may be gained by considering that artificial habitats will be established in other areas of the Union Reefs project area, sited away from mining‐related activity, and designed via thermal modelling to provide a suitable microclimate for roosting. The design phase of this artificial roost project component was commenced in October 2019 by Ecological Management Services/Specialised Zoological. Construction should begin as soon as possible to give bats the maximum available time to find and colonise them.

An alternative worst case scenario is considered much less likely—where bats are excluded from using the OK adit and respond by moving to shallow natural overhangs, mining infrastructure or trees where they would be exposed to predators, further mining‐related disturbance, and profoundly unsuitable environmental conditions for roosting.

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4.2.1 Exclusion Impacts at Various Scales This section discusses the impacts at each level of individual, colony(s) and the regional population resulting from ghost bats leaving closed adits in the period following the closure. The overall impact of a temporary closure of the OK adit is predicted to be relatively minor, as described throughout this assessment, considering inferred responses based on the ghost bat monitoring data and in the context of planned mitigation measures and Actions.

The most likely scenario is that the colony occupying the two roost sites at Union Reefs will continue to occupy the protected location (Union North adit) and continue to move throughout the region. Thus, we expect the impact of the proposed OK adit temporary closure to be insignificant at the level of individual, colony and population:

 Individual: each ghost bat is unlikely to find itself without an alternative optimal roost, and females with young will not be reliant on this site, at the time the entrance closure is undertaken. This is relevant in both the short and long term. Alternative optimal roosts include: Union North adit, as well as the Kohinoor adit at Pine Creek, Spring Hill stopes (to be confirmed by genetic analysis), plus a modified Lady Alice adit and several artificial roosts with the Union reefs area (assuming the modelled microclimates are suitable).

 Colony: the colony currently has more than one roosting option in the Union Reefs project area (as described for individuals), and the colony appears to change in size because of the movement of individuals in and out of the project area (e.g. there were typically less than 10 calls per night at both adits combined in March–May 2019; colony size has been counted at between 11 and c. 30 individuals throughout monitoring since October 2018). The temporary blockage of a relatively shallow roost (the OK adit) is predicted to be insignificant given access to known and predicted alternatives of greater depth.

 Regional Population: given the indirect evidence that ghost bats can readily move in and out of the Union Reefs project area to sites known and possibly unknown, the impact of the closure of the OK adit is unlikely to be significant for the regional population. If the Union North adit can be maintained as a protected roost site, and if other planned additional sites are indeed provided, then the Union Reefs area will likely remain an important stepping‐stone between Pine Creek, Spring Hill and any other sites used by ghost bats in the region.

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4.3 CAPACITY OF OTHER SITES TO ACCOMMODATE EXCLUDED BATS

4.3.1 Union North Adit This site appears to be optimal for roosting at certain times of the year based on our monitoring of activity levels since October 2018, and is potentially available as a roost all year round. It is the deeper of the occupied adits in the project area (main tunnel c. 60 m in length; Armstrong and Barden 2018), and occupied during the period when ghost bat young are being born (relatively high activity in July–August 2019) and during development in the weeks afterwards (activity in October–November 2018). While only superficial inspections of the interior have been undertaken to date, it appears stable, and has remained so since the pit it exists within was excavated—i.e., blasting and earthworks within the pit did not collapse the structure that exists today.

There is some evidence that the rear of the adit is subject to some level of flooding during heavy rain, but planned detailed inspections will be able to inform how much water can build up in the structure, and whether it is practical to simply pump this water out at times of heavy rain. Other than the issue of flooding that can be circumvented, there is nothing to suggest that this adit will change to become less suitable for the ghost bat. Planned inspections of the interior by a suitably experienced mining engineer (as soon possible when monitoring shows that bats are absent or there is relatively little activity at the roost) will provide further confirmation and information. Numbers of other cave‐roosting bats in the Union North adit (orange diamond‐faced bat Rhinonicteris aurantia; common sheath‐tailed bat Taphozous georgianus; Finlayson’s cave bat Vespadelus finlaysoni) are likely to be greater than in the OK adit, based on compiled activity data of R. aurantia (Hanrahan et al. 2019) and the greater depth of the Union North adit.

4.3.2 Lady Alice Adit This small adit c. 150 m east of the Union North entrance portal (referred to as the adit at waypoint 118 in Armstrong and Barden 2018) appears to be a straight horizontal tunnel of unknown length, but probably not much more than 30 metres. The entrance portal is partially occluded by earth, with the aperture only accessible to species such as the orange diamond‐faced bat, which was detected inside and on a bat detector recording (Armstrong and Barden 2018). There is also a shaft entrance further up the slope that connects to the horizontal adit. Calls of the ghost bat were recorded at the entrance of the adit well after dusk, indicating nocturnal visitation, but the structure is currently unsuitable for roosting of ghost bats. It is proposed to remove some of the earth obstructing the entrance to allow ghost bat entry, and seal the shaft entrance to increase the humidity inside (monitored by dataloggers). Given that ghost bats are

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already aware of the site, and vibration and noise modelling predicts a similar level of minimal disturbance as with the Union North adit, it is suggested that augmentation and protection of the Lady Alice adit could provide a good alternative to the OK adit. It will be included in any long‐term monitoring effort. Any augmentation of the Lady Alice adit is likely to maintain accessibility to other bat species.

4.3.3 Kohinoor Adit Pine Creek This site supports perhaps the largest known colony of ghost bats in Australia, and has done so for many years despite continued disturbance in the local area, including mining exploration, road construction, vehicle movements and frequent intrusion by curious tourists and local people. Rather than suggesting that ghost bats are tolerant of regular roost intrusions, we may instead infer that this site is of high importance to the species because there are no structures nearby that provide similar habitat quality. Indeed, the presence of ghost bats at Union Reefs and Spring Hill might be a response to disturbances at Pine Creek. There have been various estimates of colony size within the Kohinoor adit over the years, which are likely dependent to some degree on method, but it is clear that this structure has the capacity to support up to and possibly exceeding 1500 individual ghost bats. In the context of up to 30 individuals from Union Reefs relocating themselves to Pine Creek, this would represent less than 4% of the current maximum estimated colony size of 800 individuals based on recent counts. To ensure that the Kohinoor adit continues to support ghost bats during the period of proposed mining at Union Reefs, several management Actions have been proposed, including:

1. Improved cautionary signage;

2. A program focusing on public education, particularly in relation to the dangers of entering the adit, the significance of the ghost bats at this site and their vulnerability to disturbance;

3. Measures to promote community and traditional owner involvement in conservation and management of the ghost bats at the site; and

4. Novel ways to shift attention away from the site itself, such as providing live video feed of the colony in the township.

4.3.4 Spring Hill A study in 2017 by Northern Resource Consultants (2018) recorded 96 ghost bats emerging from ‘stope 13’, and a total of seven individuals from two other stopes, giving a total colony size of approximately 100 individuals. Other stopes might have contained ghost bats, but there was evidence of ‘tampering’ prior to the survey that might have caused the relocation or worse of ghost bats (NRC 2018). Further details on

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whether these could support ghost bats in the future is unavailable. If the location of the main structure containing ghost bats at Spring Hill does not coincide with plans for further mining, and management at that site is appropriate for their long term persistence, then Spring Hill might remain an important site for the ghost bats, including those individuals that might originate at other sites such as Union Reefs and Pine Creek.

4.4 CONSEQUENCES OF A TOTAL LOSS OF GHOST BAT ROOSTING HABITAT AT PINE CREEK

Given the information presented in this assessment, it is very unlikely that the closure of the OK adit would lead to the total loss of the c. 30 individuals comprising the colony in the Union Reefs area. However, if this loss occurred through an event associated with mining, the region would have lost less than 3% of the known regional population (at least 1,100 individuals), and less than 0.3% of the global population (less than 10,000; as estimated by Woinarski et al. 2014). While the loss of individuals would be unfortunate, maintaining the presence, protection and suitability of underground roost structures in the Union Reefs area would still allow individuals that might move between Pine Creek and Spring Hill to stage their dispersal via the intermediate position of Union Reefs.

4.4.1 Significance of Residual Impacts Following Avoidance Measures The Terms of Reference ask for the EIS to “Provide a robust justification to support claims that impacts considered would not be significant due to the implementation of avoidance measures or no impact pathway.” In the mitigation hierarchy, the closure of the OK adit during the period of mining could best be considered as a ‘minimisation’ measure. While reducing the proximity of ghost bats in the OK adit to planned infrastructure, moving machinery, and the effects of underground blasting by closing the structure to their use is designed to ‘avoid’ an impact on them, the action itself is a mitigation against disturbances. Thus, if mining the ore body is to proceed, there is no possible scenario where an avoidance or no impact pathway could be implemented. In response, we present evidence in this assessment to support minimal impact based on minimisation, rehabilitation and offset strategies. The planned opening of the Lady Alice adit, the installation of artificial roosts and the provision of the new mine given over as ghost bat habitat following cessation of mining is designed to remove any residual impact (Armstrong et al. 2019b). Moreover, if mining proceeds as proposed, it is expected implementation of the eleven Actions in the Action Plan (Armstrong et al. 2019b) will actually lead to an improvement in the situation of the ghost bat in the region.

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4.4.2 Likelihood of Unknown, Unpredictable or Irreversible Events or Impacts There is a requirement in the TOR (EPA 2019) to consider whether any relevant impacts are likely to be unknown, unpredictable or irreversible. We have proposed to account for any of these by increasing the possible number of roost sites within the Union Reefs area (modification of the Lady Alice adit; building several artificial roost structures), and extending proactive management to regional colonies that are predicted to be within the nightly flight range of ghost bats at Union Reefs (Pine Creek, possibly Spring Hill). Thus, while we have considered all of the most likely impacts from the mining proposal, our strategy is to provide redundancy and protections at a broader geographic scale in an effort to nullify any unpredicted impacts should they occur. Such unpredictable events might be the collapse of the Union North adit, the malevolent actions of persons at any site (similar to what occurred at Spring Hill; Northern Resource Consultants 2018), a poorly conceived and overlapping research program from other biologists (i.e. lack of consultation about potentially confounding actions at the same sites), or the discovery that the hills surrounding the Union Reefs area lacks any natural caves suitable for the diurnal roosting of ghost bats. The occurrence of these could be addressed given that long term monitoring of all colonies will occur during mining. Some of these have been addressed in other parts of this response (collapse of Union North adit; malevolent actions).

4.4.3 Short Term and Long‐Term Impact Pathways, and Their Consequences The TOR (EPA 2019) requires that the assessment of impacts should identify relevant short‐term and long‐ term impact pathways and the full extent of any consequences. This is particularly relevant where the likelihood of impact is low, yet the consequence of impact may be high.

Most conceivable impacts have low risk (based on a 5 x 5 standard risk matrix; Table 4.1; see also the Risk Register). The greatest risk identified was malevolent actions by individuals at roosts, especially at Pine Creek. Occupancy of underground structures with suboptimal roost microclimates in the event of a forced exodus is thought unlikely to result in mortality of most or all individuals because individuals have been observed in relatively cool, dry roosts in the Pilbara (e.g. near Nullagine; K.N. Armstrong unpublished observations). Potential impacts that are catastrophic and result in the loss of an entire colony are likely to have long‐term consequences, especially at the two larger colonies. Thus, monitoring at all sites throughout the period of mining will not only provide context for any changes that may occur at the Union North adit, but provide assurance that alternative sites to those at Union Reefs remain available habitats.

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Table 4.1. Potential Impacts and Risks: Ghost Bats at the Union Reefs Project Site. [Note that further details on each entry are available in the overall Risk Register].

Consequence Level Likelihood A‐Minor B‐Medium C–Serious D–Major E–Catastrophic 1–Almost Certain Medium High High Extreme Extreme 2–Likely Medium Medium High High Extreme 3–Possible Low Medium Medium High High 4–Unlikely Low Low Medium Medium High 5–Rare Low Low Low Medium Medium

Intolerable ‐ Risk reduction is mandatory wherever practicable. Residual risk can only be Extreme accepted if endorsed by senior management

Intolerable or tolerable if managed to as low as reasonably practicable ‐ Senior High management accountability

Intolerable or tolerable if managed to as low as reasonably practicable ‐ Management Medium responsibility

Low Tolerable ‐ Maintain systematic controls and monitor

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Potential Event Initial Risk Planned controls Residual Risk [Impact pathway] 1. Vibration emissions from mining activities result in disturbance of/or Action 1—Exclude the Ghost Bat from the OK adit. damage to roost site for individual bats, or a small population of bats in Action 2—Characterise the internal dimensions of the OK adit and Union OK and Prospect adits. [medium] North adit. Action 3—Create several artificial habitats. High Medium Action 4—Re‐open and rehabilitate the Lady Alice adit. [Likely, Major] Action 5—Manage the Union North adit to exclude visitation from mining [Unlikely, Major] personnel. Action 7—Monitor the Ghost Bat at known local and regional roosts.

2. Temporary closure of OK adit during mine development and mine Action 1—Exclude the Ghost Bat from the OK adit. operations. [medium] Action 3—Create several artificial habitats. Action 4—Re‐open and rehabilitate the Lady Alice adit. Action 5—Manage the Union North adit to exclude visitation from mining High personnel. Medium [Almost Certain, Action 6—Implement management and protection measures at the Pine [Possible, Medium] Medium] Creek roost. Action 7—Monitor the Ghost Bat at known local and regional roosts. Action 9—Conduct field surveys for Ghost Bat diurnal roosts in natural caves. Action 10—Investigate the connectedness of Ghost Bat colonies in the region.

3. Vibration emissions from mining activities result in disturbance of Low Action 7—Monitor the Ghost Bat at known local and regional roosts. Low individual bats or a small population of bats in Union north adit and other [Unlikely, [Unlikely, Medium] modelled locations. [medium] Medium] 4. Ground‐borne noise emissions from mining activities result in Low None required Low disturbance of individual bats or the colony of bats in the URPA. [medium] [Unlikely, Minor] [Unlikely, Minor] 5. Union North adit is flooded during the wet season. [long] Action 2—Characterise the internal dimensions of the OK adit and Union North adit. Action 3—Create several artificial habitats. High Action 4—Re‐open and rehabilitate the Lady Alice adit. Medium [Possible, Major] Action 5—Manage the Union North adit to exclude visitation from mining [Unlikely, Major] personnel. Action 7—Monitor the Ghost Bat at known local and regional roosts.

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Potential Event Initial Risk Planned controls Residual Risk [Impact pathway] 6. Damage to the structure of Union North adit ‐ entrance blockage or Action 2—Characterise the internal dimensions of the OK adit and Union internal collapse associated with mining or not. [long] North adit. Action 3—Create several artificial habitats. Medium Action 4—Re‐open and rehabilitate the Lady Alice adit. Medium [Unlikely, Major] Action 5—Manage the Union North adit to exclude visitation from mining [Rare, Major] personnel. Action 7—Monitor the Ghost Bat at known local and regional roosts.

7. Malevolent actions at a roost that cause disturbance and/or mortality Action 5—Manage the Union North adit to exclude visitation from mining of bats, in particular Kohinoor adit at Pine Creek that is easily accessible to High personnel. Medium the public. [long] [Possible, Major] Action 6—Implement management and protection measures at the Pine [Rare, Major] Creek roost. 8. Collapse or blockage of historical adit from random deterioration (Pine Medium Action 7—Monitor the Ghost Bat at known local and regional roosts. Medium Creek, Spring Hill). [long] [Rare, Major] [Rare, Major] Action 1—Exclude the Ghost Bat from the OK adit. 9. A disturbance to a roost site, including OK adit, at a critical part of the Low Low breeding cycle that causes an interruption to breeding activity and Action 5—Manage the Union North adit to exclude visitation from mining lowered reproductive output. [medium] [Rare, Serious] personnel. [Unlikely, Minor] Action 11—Provide support for further academic research on the Ghost Bat. 10. Coincident, uncoordinated and non‐prioritised research resulting in Low Low unnecessarily elevated levels of disturbance through duplication of effort. [short or long] [Unlikely, Minor] [Unlikely, Minor] Action 3—Create several artificial habitats. 11. Field surveys in the hills surrounding Union Reefs reveal no alternative Low Low natural roosts. [short] Action 4—Re‐open and rehabilitate the Lady Alice adit. [Possible, Minor] Action 10—Investigate the connectedness of Ghost Bat colonies in the region. [Possible, Minor] Action 3—Create several artificial habitats. 12. Bats disperse to suboptimal roosts, rather than Union North adit or Low Low larger stronghold roosts, after the OK adit is closed. [short] Action 4—Re‐open and rehabilitate the Lady Alice adit. [Possible, Minor] Action 10—Investigate the connectedness of Ghost Bat colonies in the region. [Possible, Minor] 13. Dewatering for the mine reduces levels of groundwater that keep Low Action 2—Characterise the internal dimensions of the OK adit and Union Low North adit. roosts humid for ghost bats. [medium] [Possible, Minor] [Possible, Minor] Action 1—Exclude the Ghost Bat from the OK adit. 14. Young bats in the later stages of development perish after being Low Low abandoned in roosts by adults moving out of the Union Reefs area in response to a disturbance or closure of the OK adit. [medium] [Rare, Serious] [Possible, Minor] 15. Waste‐water in open pit mine voids contains pollutants that might Low Action 11—Provide support for further academic research on the Ghost Bat. Low reduce rates of survival in ghost bats. [long] [Rare, Minor] [Rare, Minor]

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4.5 LIKELY IMPACTS AT LOCAL, NATIONAL AND REGIONAL SCALE

The TOR (EPA 2019) requested a detailed assessment of any likely impacts that the mining proposal may impose on the ghost bat at the local, regional, state and national scale in accordance with the EPBC Act 1999. As has been described elsewhere in this assessment, the risk of a significant impact that results in mortality has been calculated to be low within Union Reefs. This assessment has balanced the available information with the precautionary principle that might take a conservative view of the likelihood of survival of ghost bats in suboptimal roosts should they relocate temporarily.

The observations made to date provide justification for confidence that the proposed exclusion of the ghost bat from the OK adit will not have a significant impact on the species at colony and population level include:

 Activity levels demonstrate that bats move naturally between the OK adit and Union North adit.

 Activity levels suggest that some individuals may move in and out of the Union reefs project area on a night‐to‐night or seasonal basis.

 Colony size counts have varied over time, which is attributed to natural factors, and suggests that some individuals may move in and out of the Union reefs project area on a night‐to‐night basis.

 Thus, the results from monitoring consistently suggest that bats have the propensity to move and the opportunity to find roosts elsewhere but within the nightly flight range that have a suitable roost microclimate.

This can only be resolved by two actions: a genetic study to demonstrate the connectedness of colonies and a survey for roosts in natural caves surrounding Union Reefs (Armstrong et al. 2019b). KLG has committed to funding these studies as a component of ongoing ghost bat assessment and research.

5.0 Mitigation and Minimisation

5.1 MITIGATION MEASURES

This section discusses the proposed mitigations and minimisations, in the context of both the mitigation hierarchy and specific requirements under the Terms of Reference, to address any possible impacts of the KLG proposal on ghost bats in the UR project area. Several of these were mentioned briefly in the previous section. It also builds on a previous commitment to ghost bat management regionally by the proponent (Armstrong et al. 2019a). Eleven minimally‐invasive Actions are proposed, which are expected to deliver a net improvement in the situation of ghost bats in the region. The mitigations and

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minimisations are described in full in a separate management plan (as per the request in the Terms of Reference; Armstrong et al. 2019b) (Appendix 2).

5.1.1 Summary of Proposed Actions  Action 1. Exclude the ghost bat from the OK adit based on a carefully planned protocol. [both Avoidance and Mitigation/Minimisation]

 Action 2. Characterise the internal dimensions of the OK adit and Union North adit, and the position of ghost bat roost areas within. [Research to support Minimisation]

 Action 3. Create several artificial habitats for the roosting of ghost bats in the Union Reefs project area, for both contingencies and redundancy. [both Mitigation/Minimisation and Offset]

 Action 4. Re‐open and rehabilitate the Lady Alice adit so that it is suitable for ghost bat occupancy . [both Mitigation/Minimisation and Offset]

 Action 5. Manage the Union North adit during the period of mining to exclude visitation from mining personnel. [Mitigation/Minimisation]

 Action 6. Implement management measures at the Kohinoor adit at Pine Creek to protect the ghost bat roost. [Mitigation/Minimisation]

 Action 7. Conduct a programme of continuous monitoring of ghost bat presence, activity levels and colony size at all known (Union North adit) and potential (Lady Alice adit, artificial roost habitats newly created) roosts within the project area, and other key sites in the region (Pine Creek; Spring Hill; any newly discovered caves of significance surrounding the project area). [Mitigation/Minimisation]

 Action 8. Provide a portion of the new mine for ghost bat occupancy once mining has been completed. [Rehabilitation or Offset]

 Action 9. Conduct field surveys for ghost bat diurnal roosts in natural caves in the hills surrounding the Union Reefs project area. [Research to support Minimisation]

 Action 10. Investigate the connectedness of ghost bat colonies in the region using an advanced genetic method based on genome‐scale DNA sequencing. [Research to support Minimisation]

 Action 11. Provide support for further academic research on the ecology of the ghost bat. This would include coordinating the development of a Recovery Plan, which is required under the EPBC Act 1999, but has not yet been developed. [Research to support overall management]

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5.1.2 Action Plan Sequence These Actions are expected to be conducted in several phases, with some Actions extending over more than one phase, as follows:

Phase 1. Before new underground mine construction.

Action 2—Characterise the internal dimensions of the OK adit and Union North adit. Action 3—Create several artificial habitats. Action 4—Re‐open and rehabilitate the Lady Alice adit. Action 7—Monitor the Ghost Bat at known local and regional roosts. Action 9—Conduct field surveys for Ghost Bat diurnal roosts in natural caves. Action 10—Investigate the connectedness of Ghost Bat colonies in the region.

Phase 2. Exclusion Phase, immediately prior to site works in the Prospect pit.

Action 1—Exclude the Ghost Bat from the OK adit. Action 7—Monitor the Ghost Bat at known local and regional roosts.

Phase 3. During mining.

Action 5—Manage the Union North adit to exclude visitation from mining personnel. Action 6—Implement management and protection measures at the Pine Creek roost. Action 7—Monitor the Ghost Bat at known local and regional roosts. Action 11—Provide support for further academic research on the Ghost Bat.

Phase 4. After mining has been completed.

Action 7—Monitor the Ghost Bat at known local and regional roosts. Action 8—Provide a portion of the new mine for Ghost Bat occupancy. Action 11—Provide support for further academic research on the Ghost Bat.

5.2 EFFECTIVENESS AND STATUTORY OR POLICY BASIS FOR MITIGATION MEASURES

The anticipated effectiveness and policy basis for each is summarised in Table 5.1. A summary of the environmental consequences, risk, cost and benefits of each alternative (short, medium and long‐term advantages and disadvantages of the options) is provided in Table 5.2.

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Table 5.1. Ghost Bat Action Plan, Union Reefs: Effectiveness and Rationale.

A summary for each Action of the expected or predicted effectiveness of mitigation measures, and the statutory or policy basis for mitigation measures, as matched against the relevant Threat Factor and Specific Actions listed under Conservation and Management Actions, Survey and Monitoring Priorities, and Information and Research Priorities in the Conservation Advice for the species (Threatened Species Scientific Committee 2016).

Action Effectiveness, Threat Factor and Action

Action 1 Effectiveness: Closure of the adit will be fully effective for diverting ghost bat usage of the OK adit back to the Union North adit and other alternatives. OK adit exclusion Baseline monitoring has established that ghost bats regularly use the Union North adit, and there is evidence they move in and out of the Union Reefs area, though additional Actions are proposed to investigate this latter aspect in more detail.

Threat factor: Habitat loss.

Specific Action: Protect roost sites from disturbance. In this case, it is acknowledged that the Action itself is a disturbance (temporary loss of a confirmed diurnal roost site and possible breeding site), but the Action is designed to avoid other disturbances (proximity of machinery and blasting).

Action 2 Effectiveness: The Union North adit and Lady Alice adit will be surveyed at night by the entry of trained and experienced personnel with appropriate Survey of internal equipment. A previous effort to perform a survey Union North with a remotely controlled pipe inspection camera was ineffective, leaving the only adit structures reasonable option as an entry. Threat factor: Disturbance to roost sites, breeding sites.

Specific Action: Monitor populations at key sites and where impacts from mining are occurring or likely.

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Action Effectiveness, Threat Factor and Action

Action 3 Effectiveness: The creation of artificial habitat for the ghost bat in Australia, as well as species such as the orange diamond‐faced bat, is still essentially Construct artificial experimental. There is very little information publicly available on the success of current efforts in the Pilbara region, and each situation will likely be habitats unique. In the present case, there are three parts of the design that are included to maximise the chance of success: 1. Dimensions likely to provide conditions suitable for ghost bat roosting based on extensive experience of other roost sites; 2. Confirmation of the suitability of the microclimate that will form within through modelling with computational fluid dynamics; and 3. Provision of redundancy to maximise the chance of ghost bats occupying at least one of several artificial roosts spread through the Union Reefs project area. The Conservation Advice for the ghost bat mentions that the establishment of artificial roosts are to be as a last resort only, as does Cramer et al. (2015) that outlined research priorities for the Pilbara leaf‐nosed bat. Thus, despite a growing number of projects in the Pilbara implementing this action, we certainly consider this Action to be still experimental for this species, and only one of several strategies to minimise the impact of the Proposal on the regional population of the ghost bat. Thermal modelling of the microclimates will be undertaken using a Computation Fluid Dynamics approach with the assistance of experienced engineers. This is a standard approach for ensuring that the heat balance of buildings meets requirements. The details of the design will be developed and adjusted as part of this process.

Threat factor: Habitat loss.

Specific Action: Establish new or artificial roost sites, and evaluate their success. Action 4 Effectiveness: The ghost bat, and other cave‐dwelling bat species readily move into underground mines following the cessation of mining, though Re‐open Lady Alice over what timescale is unknown. Given reasonable knowledge of the roost requirements of the ghost bat, the Action to open access of the Lady Alice adit adit to the ghost bat, and conduct a modification (block an open shaft that intersects the adit midway) to ensure that it retains a suitable warm, humid microclimate is anticipated to be effective at attracting bats to roost within if access to the OK adit is removed. The species has already been recorded at two points near the entrance (Armstrong and Barden 2018a), it is of similar depth to the OK adit (based on current information), and the entrance portal is only around 150 m from that of the Union North adit. Combined with management that prevents casual visitation, the sum of these provides confidence that it could become an alternative to the OK adit relatively quickly.

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Action Effectiveness, Threat Factor and Action

Threat factor: Habitat loss.

Specific Action: Establish new roost sites and evaluate their success; Protect roost sites from disturbance; Modify roost sites to reduce risk of collapse. Action 5 Effectiveness: Managing the Union North adit is a core part of the strategy to manage the colony of ghost bats in the Union Reefs area during the Manage Union North proposed mining period, given that this adit will be the colony’s closest known suitable diurnal roost. Thus, excluding casual visitation from this area adit and other sites with potential ghost bat habitat (Lady Alice adit, artificial roosts to be constructed) will be a priority for the company. Threat factor: Disturbance to roost sites, breeding sites.

Specific Action: Protect land with significant colonies; Protect roosts from disturbance; Educate staff regarding access and disturbance in the vicinity of ghost bat roosts. Action 6 Effectiveness: The Kohinoor adit is currently protected from human intrusion by a low stock fence without barbed wire, so any additional measures Manage Pine Creek will improve the situation. The Spring Hill mine is currently owned by another company but KLG commits to facilitate changes at Spring Hill with the and Spring Hill ghost owners of that lease. The measures described to manage the ghost bats at these two sites have been proposed based on the unique conditions at each site. Fencing and other solutions involving earthworks at the Kohinoor adit are not likely to be resolve the situation of casual entry by the public, bat sites so signage, diverting attention away from the site and public education are considered to be the best first steps for protecting this nationally important roost.

Threat factor: Disturbance to roost sites, breeding sites

Specific Action: Protect land with significant colonies; Protect roosts from disturbance; Educate people not to disturb roost sites.

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Action Effectiveness, Threat Factor and Action

Action 7 Effectiveness: Monitoring draws upon the considerable experience of the specialist consultants engaged to undertake this work, as well as their Monitoring Program experience with the monitoring of ghost bats at Union Reefs since August 2018. One of the greater challenges in a long‐term study is the ability to rapidly process ever‐increasing batches of recordings, where the periods of recordings are maximised so as to build as complete a picture of site usage as possible. Given the importance of colony size estimates, the current program of monitoring has involved a development component, whereby new video recording technology able to make multiple scheduled recordings over consecutive nights has been tested and used to collect critical information on ghost bat colony size. The new technology, which is based on inexpensive micro‐computers, initially involved infrared video and manual inspection of recordings, but has now transitioned to thermal video and a semi‐automated analysis system capable of processing larger datasets in a shorter amount of time. Likewise, the expedient analysis of acoustic datasets, is based on the development efforts of two of the specialist consultants, and the process is likely to continue to be streamlined. Acoustic recordings are also made in high quality full spectrum format (with Titley Scientific AnaBat Swift bat detectors), which is essential for the efficient recognition of echolocation and social signals made by the ghost bat. Thus, a monitoring study based on both acoustic and video recordings, conducted by experienced analysts with the most advanced recording and analytical systems currently available is highly likely to be effective at collecting information on bat presence and usage levels (see Sections 6.1.4 and 6.1.5 for further comment on triggers and contingencies).

Threat factor: Disturbance to roost sites, breeding sites.

Specific Action: Monitor populations at key sites and where impacts from mining are occurring or likely; Develop cost‐effective monitoring protocols (e.g. thermal tracking software) at a set of standardised sites that contain most of the know population.

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Action Effectiveness, Threat Factor and Action

Action 8 Effectiveness: Ghost bats and other cave‐dwelling species of bat in northern Australia are well known for their tendency to occupy underground mine Facilitate post‐ workings after mining activity has finished (e.g. Hall et al. 1997). In addition, the continued use by ghost bats of the lower remnants of two complex mining occupation of underground mines following the cessation of open cut mining that left the Union North and Prospect pits provides reassurance that ghost bats will find and use the main drive of the proposed underground mine in the Prospect Pit. The new mine will be profoundly deeper and more complex than mine workings by the Union North adit and OK adit, and very likely to provide suitably warm and humid microclimates. By making at least part of such a structure ghost bats available to ghost bats following the cessation of mining provides excellent potential for ghost bat numbers to build up, and be maintained in the long term in a site that might eventually become more important for the regional population than the Kohinoor adit at Pine Creek. This strategy has a very high potential to become one of the most effective and significant Actions.

Threat factor: Disturbance to roost sites, breeding sites

Specific Action: Establish new or artificial roost sites, and evaluate their success.

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Action Effectiveness, Threat Factor and Action

Action 9 Effectiveness: Understanding if the ghost bat colony using the adits in the Union Reefs project area has alternatives in natural caves in the surrounding Cave and mine roost hills will give reassurance that there are alternative roost sites very close to sites that might be subject to mining‐related disturbance. The methods survey for non‐invasive discovery and monitoring of ghost bats are effective if applied correctly. High quality acoustic recordings give sufficient detail for recognition of ghost bat echolocation and social calls through both manual inspection and automated recognition processes. Thermal and infrared video give sufficient detail on bat size and shape to recognise the ghost bat as it emerges from roost, and automated detection systems are only used to limit long videos to periods when individual bats emerge from a roost site. Neither acoustic nor video recordings present a disturbance to ghost bats that might roost within a structure, especially if investigators do not enter and attempt to minimise noise when deploying equipment.

Threat factor: Disturbance to roost sites, breeding sites

Specific Action: Survey the local area (outside previously sampled area) for undiscovered ghost bat roost sites. Action 10 Effectiveness: Older techniques that used mitochondrial and microsatellite genetic markers (e.g. Worthington Wilmer et al. 1994, 1999) gave Genetic study reasonable information on the structuring of ghost bat populations. Newer methods using markers spread across the genome, and associated new methods designed to analyse such datasets, give unprecedented power for resolving the connectedness of ghost bat colonies. Given the demonstrated effectiveness of using call playbacks to enhance trapping success of ghost bats away from sensitive roost sites (Hanrahan et al. in review), and the availability of context genetic data that will assist a genetic study focussed on the population of interest (Hanrahan and Armstrong et al. publications in prep.), the planned genetic study should be able to obtain an adequate sample size without disturbing roost sites, and have sufficient power to resolve the questions posed. Analyses of connectedness among colonies in other parts of the range of the ghost bat has already shown limited movement and population structuring at various scales (K.N. Armstrong unpublished data; N. Hanrahan unpublished data).

Threat factor: Disturbance to roost sites, breeding sites

Specific Action: Assess population size and significance of all known subpopulations [note: the genetic study helps to define what are populations].

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Action Effectiveness, Threat Factor and Action

Action 11 Effectiveness: While there has been increasing levels of study focus given to the ghost bat in recent years, there is still much to be understood about Support ghost bat this species, especially how colonies are distributed and connected across the regions they occupy. There is also still relatively little understood about research the timing of their breeding cycles in different populations (these may vary; Churchill 2008), and despite a recent intensive focus in a PhD study (N. Hanrahan manuscripts in review and preparation) of their acoustic ecology, questions still remain about the meaning of their various social call types and how they might be interpreted in the context of environmental impact assessments. Providing funding for a postdoctoral research program is highly likely to add significantly to our ability to assess threats to ghost bats more effectively in the future. Further academic‐based research will be welcomed because it will generate information that will be available in the public sphere, it will be conducted by a suitably qualified person, and it will become increasingly relevant given the projected declines in this species (Threatened Species Scientific Committee 2016).

Threat factor: Relevant to most threat factors listed in Threatened Species Scientific Committee (2016).

Specific Action: Relevant to most specific actions listed in Threatened Species Scientific Committee (2016).

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Table 5.2. Summary of the environmental consequences, viability, risk, cost and benefits of each alternative Action.

Includes short, medium and long‐term advantages and disadvantages of the options. Action Consequences, risks, costs and benefits, short, medium and long‐term advantages and disadvantages

Action 1 Consequences: Temporary restriction of access to of one, relatively shallow diurnal roost and possible site for breeding individuals, but removes OK adit exclusion ghost bats from the proximity of mining‐related activity at the entrance portal to the proposed new mine, and minimises the risk of a negative impacts of noise and vibration from blasting underground on any individuals that might otherwise occupy the OK adit.

Risks: The risk of elevated mortality to the colony in the Union Reefs project area is considered to be low given the continued protection of the Union North adit, the provision of alternatives in the project area (Lady Alice adit, several new artificial creations), proactive protections of alternative sites at Pine Creek and Spring Hill, and the confirmation that surveys might bring of natural cave roosts in hills surrounding the project area.

Costs: Temporary restriction of access to of one, relatively shallow diurnal roost and possible site for breeding individuals.

Benefits: Discouraging the presence of ghost bats in close proximity to noise, vibration and disturbance associated with machinery and blasting in the Prospect Pit, and therefore any risk of elevated mortality.

Advantages: The OK adit is not used on a continuous basis by a large colony of bats because of its relatively shallow depth. [short to medium term]

Disadvantages: Temporary restriction of access to of one, relatively shallow diurnal roost and possible site for breeding individuals. [short to medium term]

Contingency status: Not applicable.

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Action Consequences, risks, costs and benefits, short, medium and long‐term advantages and disadvantages

Action 2 Consequences: Ghost bats may be disturbed if entry for an inspection of the Union North adit and OK adit is made when they are present. This will Survey of internal be avoided, specifically by entering the adits at night after ghost bats are observed to have left. adit structures Risks: The risk of entry to a roost is that ghost bats will abandon the structure when disturbed. However, this will be avoided by entering at night.

Costs: There is no cost to the ghost bat if entry is made when they are absent.

Benefits: Having more knowledge of the internal structure allows a better understanding of how important the structure might be to the species. It will also provide information on low‐level seasonal flooding that occurs in the Union North adit, which might require a management solution to keep this structure with optimal conditions for the ghost bat.

Advantages: More knowledge of adits will lead to a better management strategy. [short to long term]

Disadvantages: Entry of a confined space and the roost of a threatened species is required. [short term]

Contingency status: Not applicable. Action 3 Consequences: Creating artificial habitats will provide several alternative possible roosts for when the OK adit is closed. Construct artificial Risks: It is possible that the structures will not be used by ghost bats at all. The design, which is based on knowledge of the species roost habitats requirements, as well as thermal modelling, will hopefully be suitable for use by ghost bats.

Costs: There is no cost to the ghost bat.

Benefits: Having more than one possible replacement for the OK adit within the Union Reefs area, as well as any that may exist further afield within the nightly flight range of the ghost bat, gives redundancy if ghost bats occupy more than one alternative.

Advantages: Artificial habitats are a way to inflate the number of potential suitable roosts, which is typically a rare resource in the northern Australian landscape. [short to medium term]

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Action Consequences, risks, costs and benefits, short, medium and long‐term advantages and disadvantages

Disadvantages: Artificial habitats may remain suitable as bat roosts for time periods much less than for adits or caves, but they only need to support ghost bats for the period that the OK adit is closed, at minimum. [short to medium term]

Contingency status: Will provide a possible contingency, and redundancies, if ghost bats do not use the Union North adit at specific times of the year, or are disturbed at the Union North adit and require an alternative roost site nearby in the Union Reefs project area. Action 4 Consequences: Opening and modifying the Lady Alice will provide a potential replacement for when the OK adit is closed. Re‐open Lady Alice Risks: It is possible that the structure will not be used by ghost bats at all. The planned modifications, which will be made based on knowledge of adit the species roost requirements, will hopefully make the structure suitable for use by ghost bats.

Costs: There is no cost to the ghost bat.

Benefits: Having a possible replacement for the OK adit within the Union Reefs area, might reduce the impact of the OK adit closure, especially if it is of similar structure or better.

Advantages: Opening the Lady Alice adit may reduce the effect of the closure of the OK adit by providing a replacement. [short to medium term]

Disadvantages: The Lady Alice adit is relatively shallow, and is less likely to attract ghost bats than a much deeper structure, but it could still be made suitable with the planned modifications. [short to medium term]

Contingency status: Will provide a possible contingency, and redundancies, if ghost bats do not use the Union North adit at specific times of the year, or are disturbed at the Union North adit and require an alternative roost site nearby in the Union Reefs project area. May provide an effective replacement for the OK adit.

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Action Consequences, risks, costs and benefits, short, medium and long‐term advantages and disadvantages

Action 5 Consequences: Without managing the Union North adit against casual visitation by people, there is a possibility that mine personnel might enter Manage Union the Union North adit, which would create a disturbance to the ghost bat, and possibly cause them to exit into daylight where they would be exposed North adit to raptorial birds and unsuitable ambient conditions.

Risks: The likelihood of this occurring is very low given the typical high standards of safety on Australian mine sites, so the risk of disturbance is low.

Costs: There is no cost to the ghost bat.

Benefits: The Union North adit will remain undisturbed and a refuge for ghost bats.

Advantages: Ghost bats will have the opportunity to continue to use the Union Reefs adit, and thus preserve the possibility that the site can be used as a stepping‐stone between Pine Creek, Spring Hill and other sites. [short to medium term]

Disadvantages: There are no disadvantages to managing the colony of ghost bats at the Union North adit.

Contingency status: This Action needs to be effective to prevent the requirement for contingency roosts. Note that ghost bats may move away from this roost at times because of natural factors as well, and contingency roosts might become alternative roost sites. Action 6 Consequences: Without some level of effort to protect and manage colonies that probably represent alternative roost sites for ghost bats in the Manage Pine Creek region, the colony at Union Reefs may have fewer options for dispersal to undisturbed sites. Concurrent disturbances within the Pilbara region have and Spring Hill been identified as an issue previously (Armstrong 2010). A colony with a small number of bats is unlikely to be viable in the long term in isolation. ghost bat sites Risks: While ghost bats are still present despite a long history of disturbance at the Kohinoor adit, and recent disturbances at several workings within the Spring Hill area, there is a continuing risk that a random event will produce a catastrophic disturbance.

Costs: The planned management actions will be installed with as little disturbance to colonies as possible (nocturnal entries).

Benefits: A greater focus on these two sites, particularly the Kohinoor adit, will help to increase the security of the whole regional population.

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Action Consequences, risks, costs and benefits, short, medium and long‐term advantages and disadvantages

Advantages: A regional focus to ghost bat management recognises that colonies are connected by the movement of individuals. Management strategies are therefore more effective because they consider colonies as parts of a larger population. [short to long term]

Disadvantages: There are no disadvantages to managing other colonies in the region.

Contingency status: These roosts are important as contingency roosts in the event that ghost bats need an alternative to roosts in the Union Reefs project area. It is therefore important that they remain as viable roost sites, and that it is shown that ghost bats using the Union Reefs project area are connected with these roosts (see Action 10). Action 7 Consequences: Extending the current monitoring program at Union Reefs to the longer term and additional sites within and outside the Union Reefs Monitoring project area will provide information relevant for continuous assessment of whether mining‐related activity might be affecting the presence, activity Program levels and colony size of ghost bats in the Union Reefs, and other sites in the region.

Risks: There is no risk to ghost bats from monitoring as the methods are non‐invasive.

Costs: There is no cost to the ghost bat.

Benefits: Information about presence and levels of usage at monitoring sites provides the basis for triggers and contingencies.

Advantages: This information will be the basis for future adaptive management responses that might be required. [short to medium term]

Disadvantages: There are no disadvantages to having current information on ghost bat usage of sites, and no risk from the methods of data collection.

Contingency status: Will provide information on whether contingency roosts are being used.

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Action Consequences, risks, costs and benefits, short, medium and long‐term advantages and disadvantages

Action 8 Consequences: The consequences of providing a large, secure, stable underground structure for longer term use by ghost bats could be profound— Facilitate post‐ resulting in a stable centre for the regional population that provides a better focus than the Kohinoor adit. mining occupation Risks: There is unlikely to be any risk with giving over a mine to use by ghost bats. The mine will be deep enough to maintain a suitable microclimate, of mine workings by ghost bats and stable enough for the long term. In addition, the entrance will be made secure against entry by people. The remoteness of the site from the nearest town will help to limit interest from tourists.

Costs: There is no cost to the ghost bat.

Benefits: A new, additional major roost resource for ghost bats.

Advantages: A new, additional major roost resource for ghost bats. [medium to long term]

Disadvantages: There are no disadvantages to adding further secure roosting resources for ghost bats.

Contingency status: Not applicable, though the new mine may represent a contingency in the event that the OK adit is no longer suitable for ghost bats at the end of the mining period. Action 9 Consequences: Without information on whether roosts in natural caves exist in the hills surrounding the Union reefs project area, it can only be Cave and mine assumed that individual ghost bats will have alternative roosts close to the OK adit when the exclusion is implemented. roost survey Risks: There is a risk that ghost bats may fly into daylight if investigators enter caves. Thus, cave entry will not be conducted. All detections will be made remotely.

Costs: If cave entry is not undertaken, there is no cost to the ghost bat.

Benefits: Information relevant to the exclusion of bats at the OK adit, as well as knowledge about the longer‐term presence of the species in and around the Union Reefs project area.

Advantages: Decisions made on the basis of empirical observations rather than assumptions. [short to long term]

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Action Consequences, risks, costs and benefits, short, medium and long‐term advantages and disadvantages

Disadvantages: There are no disadvantages to having current information on ghost bat usage of natural caves, and no risk from the methods of data collection.

Contingency status: Will provide information on whether contingency roosts, in the form of natural caves, are close to the Union Reefs project area. Action 10 Consequences: Without a genetic study, connections among colonies within the region, especially between the Union Reefs colony and those at Genetic study Pine Creek and Spring Hill, can only be assumed. Risks: This study will require capture of bats. If this is done at the entrance, there is a significant risk that ghost bats will vacate the structure, and move to suboptimal sites. The difference between this situation and the proposed exclusion at the OK adit is that the latter will be timed for periods when the ghost bat is not present. Capture will therefore be made away from the entrance, so that ghost bats do not associate the roost site with the disturbance.

Costs: A relatively low level of disturbance to ghost bats near several known roost sites.

Benefits: Confirmation that bats can readily move amongst the known colonies in the region, providing reassurance that the closure of the OK adit will simply prompt individuals to seek other roost sites within their nightly flight range.

Advantages: Decisions made on the basis of empirical observations rather than assumptions. [short to long term]

Disadvantages: Capture of ghost bats is required, but overall disturbance, levels of manipulation and invasiveness will be minimised. [short to medium term]

Contingency status: Will provide information on whether contingency roosts are likely to be available at sites c. 15 km from the Union reefs project area at Pine Creek and Spring Hill.

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Action Consequences, risks, costs and benefits, short, medium and long‐term advantages and disadvantages

Action 11 Consequences: A better overall understanding of ghost bat ecology that can be applied to environmental impact assessment and conservation and Support ghost bat management strategies. research Risks: Some of the techniques might require capture of individuals or entry of roost sites, potentially causing disturbance and disruption to normal patterns of behaviour. The use of various techniques will need to be rationalised against the value of the information gained.

Costs: Potentially some level of disturbance to ghost bats near several known roost sites.

Benefits: A more informed basis for recommending strategies for the conservation and management of ghost bats, and better distributional information on the regional population.

Advantages: Observation‐based rather than assumption‐based conservation and management strategies. [short to long term]

Disadvantages: Capture of ghost bats is required, but overall disturbance, levels of manipulation and invasiveness will be minimised. [short to medium term]

Contingency status: Not applicable.

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5.3 DISCUSSION OF ACTIONS IN THE CONTEXT OF A MITIGATION HIERARCHY

The Actions proposed in the accompanying Action Plan (Armstrong et al. 2019b) mostly fit into the category of Minimisation and Mitigation, or else are efforts for knowledge generation that are to support impact minimisation. The position of each Action in the context of the mitigation hierarchy is indicated where they are listed. Given that the new mine needs to be established in very close proximity to the OK adit because of the location of the orebody, there is essentially no option to avoid likely impacts to any bats occupying the OK adit. Thus, the overall strategy involves:

1. Minimising the effect of the construction and operation of the planned new mine, by providing new opportunities for roosting with redundancy within the project area; and

2. Supporting predictions and assumptions around ghost bat movements on a broader scale with efforts for empirical testing of these.

It is important to note that we have attempted to balance the needs of generating the minimum amount of new information relevant for managing ghost bats, with the invasiveness of the study method options. While there is much still to be understood about ghost bat ecology, we have prioritised possibilities that would be sufficient to address the scope of the present proposal.

5.4 CONSIDERATION OF PROJECT ALTERNATIVES

The primary Action at the core of the entire strategy for minimising impact of the Proposal on ghost bats using the Union Reefs project area—temporary closure of the OK adit to ghost bat roosting—is a Minimisation action. The Avoidance measures mentioned as examples in the Terms of Reference (“active relocation, artificial roost sites, no mining”) are problematic, still require the exclusion of ghost bats at the OK adit, or are not justifiable given the relative size and importance of the colony and the degree to which the OK adit is used.

The suggestion in the Terms of Reference to consider active relocation is not a valid technique for ghost bats here, for two reasons:

1. It would require capture of bats and physical emplacement of these individuals elsewhere. But since ghost bats regularly move between the Union North adit and OK adit, this operation would need to performed ad infinitum if the OK adit was not closed to their ‘self‐ reintroduction’, should that occur. In short, winged mammals are not distributable and able to be retained in enclosure areas in the same way that the non‐volant species are.

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2. It is an incredibly invasive technique and has no precedent. While ghost bats do well in captivity and regularly breed, in the wild ghost bats are sensitive to disturbance of their roost sites. The actions that would be performed under a relocation represent a greater level of disturbance than simple entry of their roost sites, which has been recognised as a significant threat to the species (TSSC 2016). A simple exclusion when bats are not present requires absolutely no direct physical manipulation of individuals and allows ghost bats to find their way to roosts that they consider suitable by their own volition.

Artificial roost sites are an integral part of the overall strategy to manage ghost bats in the context of this Proposal. However, as is acknowledged elsewhere in this assessment, this strategy is still experimental and a method of last resort. In the present case, the role of having several artificial roosts is for redundancy to maximise the likelihood that ghost bats are able to find a suitable alternative roost not far from the OK adit. Simply having artificial roosts available will not constitute an avoidance strategy if ghost bats are not prevented from occupying the OK adit. Furthermore, artificial roosts often represent ‘like‐for‐like’ habitat replacement as part of an offset. This is certainly so in the present case, but because they are designed to play an active role in maintaining the survivability of the Union Reefs colony following an exclusion, they also have a role in minimisation.

The suggestion of ‘no mining’ is not something we can easily elaborate upon—the scope of the present assessment is contingent on mining going ahead. However, all historical mines in the Union Reefs area are greater than 100 years old, and over time natural collapse and infill is likely to exclude ghost bats from these sites, and potentially kill large numbers of bats if they are trapped by sudden collapses (Hall et al. 1997). A no‐mining option would potentially mean that monitoring and maintenance of historic adits would cease or become less frequent and these sites would eventually become unsuitable as roost sites. There are currently no external (non‐mining, government) programs designed to conserve or monitor historical mine workings in the Northern Territory. Investment in mining is very likely to bring a net improvement in the situation of ghost bats in the Union Reefs area, and the region generally (Armstrong et al. 2019b).

If mining proceeds, the proximity of the OK adit to the ore body means that various disturbances are unavoidable. Thus, the only realistic strategy is to undertake a carefully planned (details in Armstrong et al. 2019b) exclusion when ghost bats are absent.

There are no plans to rehabilitate the OK adit, as there is not expected to be any damage to the structure, but it can be re‐opened on completion of the mining phase. In the event that there is damage to the structure, the site might remain of little use to the species because the upper portion of the new mine will

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be given over to ghost bat conservation upon completion of mining. This would represent an offset, and it should be acknowledged that the new mine will represent a significantly greater resource for the ghost bat, given its dimensions and likelihood of retaining suitable microclimates for both daily refuge and breeding.

In assessing the applicability of the proposed eleven Actions, it is important to be clear about the situation, as there are possible ways that it could be misunderstood if commonly considered concepts are misapplied here.

5.4.1 Closure is Temporary The planned closure of the OK adit is temporary, not permanent. Thus, this is not a situation of net loss in the long term. The planned Actions will actually result in a net overall gain of potential roost sites through:

1. Opening (widening) of the Lady Alice adit entrance nearby the Union North adit, to make it accessible to ghost bats (detected flying around the entrance; Armstrong and Barden 2018a);

2. Construction of several (number yet to be determined) artificial roost sites with dimensions appropriate to maintain suitable microclimates for ghost bat roosting at UR (as modelled with a computational fluid dynamics approach);

3. Providing access and protection of some portion of the new mine to be developed for ghost bat roosting after mining has been completed;

4. Re‐opening the OK adit for ghost bat usage after the conclusion of mining.

5. Undertaking proactive conservation work at the Kohinoor adit at Pine Creek to help maintain it as an important site for ghost bat conservation into the long term.

Note: The action of sealing the entrance of the OK adit is not a ‘relocation’. It is simply denial of access to one resource that is used at certain times of the year by either all or a smaller proportion of the colony. Use of the word ‘relocation’ implies physical manipulation in the form of capture and moving to a novel site. This is not being proposed.

5.4.2 Population Augmentation The restriction of bats to the Union North adit does not represent a ‘population augmentation’. Some relocation programs rely on moving individuals within one part of their range or habitat that is to be impacted, to another area of their existing range. If other individuals in the same population (or the same species if it is a different disjunct population) are present, then assisted movement of animals simply increases the population size in a smaller area, and has the potential to change population dynamics and

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access to resources for all individuals. The practice in Queensland of ‘Spotter‐Catchers’ moving animals out of areas to be cleared is an example of this at typically a much smaller scale. In the present case, this concept does not fit for two main reasons. First, there is a single colony of variable size that shares both the Union North adit and OK adit, with the majority of individuals switching between them in at different times of the year. Second, these individuals are predicted to have the opportunity to share roosts with members of other colonies within nightly flight range, for example at Pine Creek, Spring Hill, or in natural caves closer to the Union Reefs project area—confirmation of these aspects is planned (see Actions 9 and 10 in the Action Plan; Armstrong et al. 2019b). The numbers at Pine Creek and Union Reefs have been shown to fluctuate, so change to colony size appears to be either natural, or a common outcome from influences at other sites. Therefore, while one roost might be removed (temporarily, and with additional sites provided instead), its closure should not be considered the cause of a population augmentation.

5.4.3 Sub‐optimal Actions There are numerous aspects to ghost bat ecology that we do not understand, and unfortunately obtaining information can be invasive and constitute a disturbance. One of the major identified sources of disturbance to ghost bat colonies in northern Australia is the entry of roosts by biologists conducting environmental impact assessments (Woinarski et al. 2014). The eleven Actions listed above were chosen to provide sufficient information to both assess whether, and ensure that, the temporary closure of the OK adit would not pose a significant impact to the regional population of ghost bats. If a proposed action requires capture and handling of ghost bats or regular intrusions into a roost, then it should be considered whether the benefit of having that information outweighs any negative impacts from collecting it.

For example, a mark‐recapture would require that multiple roosts are disturbed more than once to mark individuals, and then detect them at an alternative site. This would constitute an unacceptable level of disturbance when connectedness amongst colonies could be established with a genetic study that would require a single capture event nearby each roost to collect biopsies. PIT tagging (with transponders the size of a rice grain) could also be undertaken at the time animals are biopsied, but the introduction of the PIT tag is a second invasive procedure requiring more handling time, and thus more of an impact on individuals. Such confounding factors need to be rationalised carefully, and so all Actions presented in this Proposal are those that are considered minimally invasive, and able to provide the minimum amount of information necessary to confirm predictions about how ghost bats move in the region.

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6.0 Monitoring and Reporting

The ghost bat colony in the Union Reefs project area has been monitored since it was formally ‘rediscovered’ in August 2018 (Armstrong and Barden 2018a; Hanrahan et al. 2019). The goal of the current program of ghost bat monitoring has been to determine the seasonal presence and size of this colony, and minimise the possible impacts of a nearby drilling program (Armstrong and Barden 2018b).

The details of proposed monitoring before, during and after the works in the current Proposal are encapsulated under Action 7, and elaborated in the updated regional management plan (Armstrong et al. 2019b). Various aspects are also expanded upon here to address the Terms of Reference.

6.1 FUTURE MONITORING TIMEFRAMES

If approval is given to close off the OK adit, then a comprehensive monitoring plan that builds upon the drilling program will be implemented (Action 7 in the Action Plan; Armstrong et al. 2019b). The duration of this program will be matched to the duration of mining in the Prospect Pit, plus six months.

6.1.1 Continuous Monitoring The monitoring program will be focussed mainly at the Union North adit before, during and after the OK adit entrance exclusion. Context monitoring will be conducted at the two known largest regional colonies (Pine Creek, Spring Hill) and any natural caves sites functioning as a significant diurnal roost discovered in areas around the Union Reefs project area. Monitoring will be continuous up until the exclusion (sealing of the entrance) at the OK adit. Monitoring will occur at the blocked entrance of the OK adit every night for one week after sealing of the entrance.

Ghost bat presence, overall activity and colony size will be assessed through both acoustic and video recordings, both of which will not present a disturbance to the colony. High quality acoustic recordings capable of providing detailed representations of ghost bat social calls will be made with Titley Scientific AnaBat Swift bat detectors, and activity levels based on counts of social calls will be derived from these recordings and a semi‐automated processing system (in the commercial software Kaleidoscope, via optimised settings developed by N. Hanrahan as part of a postgraduate research study). Activity levels provide information on both presence of the target species and the relative usage of a roost site, and a large acoustic dataset from a continuous recording effort is straightforward to analyse. Other species of bat present will also be represented in the recordings by their echolocation calls, and their presence/absence will also be reported.

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The best indicator of usage comes from counts of colony size. Autonomous thermal video recorder systems will be deployed at adit entrances to capture at least the first three hours after sunset when most or all of the ghost bat colony emerging for nightly foraging. Ghost bats can be distinguished from other species of bat by their large size even in thermal recordings. Recordings will be made at 30–60 frames per second to ensure that sufficient frames are available to capture the swiftly moving animals, and bat size can be calibrated against the size of the portal. The recordings will be processed by a semi‐automated method (K.N. Armstrong unpublished) to clip out periods of non‐activity, and the emergences will be identified and counted manually.

6.1.2 Sustained and Expanded Regional Focus The monitoring program will need information on surrounding colonies to determine whether activities outside the Union Reefs project area might be having an effect on how many ghost bats are detected within the project area. Both of the two known major colonies within 20 km of the Union North adit are on other mining leases and may be subject to the effects of activities not related to the current Proposal. The Pine Creek and Spring Hill colonies will also be monitored using acoustic and thermal video recorders, though on a less regular basis — for a total of two consecutive nights per fortnight, for the duration of the program.

6.1.3 Regularity of Monitoring A summary of how often recordings will be made and processed at the various study sites is provided in Table 6.1. Further details of how the exclusion at the OK adit will be monitored are found Appendix 2.

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Table 6.1. Planned Ghost Bat Monitoring and Reporting Frequency

Includes the active mining phase and for six months after completion of mining in the Prospect Pit and re‐opening of the OK adit. Location Recording Recording Frequency Reporting Frequency Type OK Adit Acoustic Nightly for one week before exclusion Quarterly summary, annual Nightly for one week after exclusion report OK Adit Thermal video Nightly for one week before exclusion Quarterly summary, annual Nightly for one week after exclusion report Union North Adit Acoustic Nightly for duration of the program ***Fortnightly internal memorandum, Quarterly summary, annual report Union North Adit Thermal video Two consecutive nights every two weeks Quarterly summary, annual report Lady Alice adit / Acoustic Nightly for duration of the program ***Fortnightly internal Artificial Roosts memorandum, Quarterly summary, annual report Lady Alice Adit/ Thermal video Two consecutive nights every two weeks Quarterly summary, annual Artificial Roosts report Kohinoor Adit, Pine Creek Acoustic Nightly for duration of the program Quarterly summary, annual report Kohinoor Adit, Pine Creek Thermal video Two consecutive nights every two months, at Quarterly summary, annual minimum report Spring Hill Mine Acoustic Nightly for duration of the program Quarterly summary, annual report Spring Hill Mine Thermal video Two consecutive nights every two months, at Quarterly summary, annual minimum report Natural Caves surrounding Acoustic Nightly for duration of the program Quarterly summary, annual the Union Reefs project report area (*as dependent on discovery; 1–2 of the largest/most active confirmed diurnal roosts) Natural Caves Thermal video Two consecutive nights every two months, at Quarterly summary, annual minimum report

6.1.4 Triggers Two sets of separate, independent factors might cause ghost bat movement and therefore periods of absence at the Union North adit—natural factors, and mining‐related activities. Being certain about which of the two has caused a period of absence is simply not possible, unless there is clear evidence of a major disturbance of the site, or a major change in the form of the underground tunnel structure (including major flooding). Baseline monitoring based on long‐term acoustic recordings has so far documented periods of at least 23 days of the absence of ghost bat calls at Union North adit (Barden and Hanrahan

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2019). Therefore, defining a trigger that is robust to false positives but sensitive to possible negative effects on ghost bats is a challenge. The following structure is suggested:

 Trigger Type 1. In the months that have had the highest documented activity of the ghost bat (October, January, February), an absence of any calls over more than 7 days is to be considered a trigger. [will lead to Action Type 1]

 Trigger Type 2. In any other month, an absence of more than 30 days is to be considered a trigger.

6.1.5 Contingencies The Action Plan (Armstrong et al. 2019b) has already considered responses to the possibility that Ghost Bats cease using the Union North adit, if the implementation of Action 5 is not sufficient for maintaining their usage of the site. Rather than reactive actions in response to Trigger Types 1 and 2 above, provision has been made for dispersing individuals through Actions that require a longer period of preparation, and that are specifically designed to provide a contingency roost and redundancy (Actions 3 and 4). Other Actions describe efforts to determine whether contingencies already exist in the form of alternative roosts already known to the species, thereby providing reassurance that dispersing individuals might be reaching known, optimal roost sites if they vacate the Union North adit (Actions 6, 9 and 10). Monitoring via Action 7 may also provide reassurance that bats from the Union North adit have appeared at other sites. This might be more obvious at sites where smaller colonies are usual, such as cave sites.

However, in direct response to either of the two triggers, monitoring frequency will be undertaken straight away at alternative sites to provide reassurance that Ghost Bats might have reached these other roosts.

6.2 RESIDUAL IMPACT

The Action Plan (Armstrong et al. 2019) (Appendix 2) has been written to account for all residual impacts. In summary, the strategy that has been outlined in this plan includes a net gain of roosts or potential roosts—temporary loss of one [OK adit], and the gain of the Lady Alice adit, the upper parts of the new mine upon completion of mining, and several [number yet to be determined] artificial roosts. It also includes significant investment in knowledge generation at local and regional levels, via regular acoustic and video recordings, genetic analyses, and the further efforts that will be undertaken as part of supporting a postdoctoral position at Charles Darwin University. Of particular importance, the scope is not limited to the Union Reefs project area, but also extends to two other regionally‐significant colonies at Pine Creek and Spring Hill, which will involve regular monitoring and targeted novel conservation actions.

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The commitment in this Action Plan represents one of the largest proactive and multi‐disciplinary responses to ghost bat management in Australia, and especially given the limited scope of the disturbance.

7.0 EPBC SIGNIFICANT IMPACT CRITERIA - MNES

An action is likely to have a significant impact on a vulnerable species if there is a real chance or possibility of a series of consequences, as set out in the Commonwealth Matters of National Environmental Significance (MNES) Significant impact guidelines 1.1 (Commonwealth of Australia 2013). These EBPC Act 1999 significant impact criteria are discussed below in relation to the project. A summary is presented in Table 6.2 (the same risk matrix as Table 4.1 is used).

Ghost bats within the Union Reefs project area have been estimated to represents 2.6 % of the estimated regional ghost bat population, and 0.3 % of the estimated national (global) ghost bat population. The ghost bats occupying the Union Reefs adits are a component of a larger regional population, and the site potentially represents an important transitory roost between two larger regional colonies at Spring Hill and Kohinoor adit (Pine Creek). In the context of numbers present, the regional Pine Creek ghost bat population (which the Union Reefs ghost bat colony is a part of) is considered an important population, as it represents a relatively high percentage (12.5 %) of the national (global) ghost bat population.

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Table 6.2. Risk of the significant impact criteria Consequence description Severity of consequence Likelihood Level of risk

1—Long term decrease of an Serious Rare Low important population

2—Reduction in AOO of an important Serious Rare Low population

3—Fragmentation of a population Medium Rare Low

4—Actions affecting habitat critical Minor Possible Low for survival

5—Actions that may disrupt the Medium Unlikely Low breeding cycle

6—Actions that cause decline Medium Unlikely Low because of habitat modification

7—Introduction of invasive species Minor Rare Low

8—Introduction of disease Medium Rare Low

9—Actions that interfere with Minor Rare Low recovery

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7.1 ACTIONS THAT MAY LEAD TO A LONG-TERM DECREASE IN THE SIZE OF AN IMPORTANT POPULATION OF A SPECIES

The proposal requires temporary closure of two seasonal (wet season) roosts during operations to mitigate impacts on ghost bats from noise and vibration. These measures should not result in the long‐ term decrease in the numbers of ghost bats at the UR project area, in the context of the following:

 The proposal does not include loss of significant areas of foraging habitat for ghost bats in the local area (estimated clearing for the project is 1 ha of regrowth vegetation comprising new haul road section and clearing out old magazine area and a small area above the portal for water tanks, substation and vents), therefore Actions to address loss of foraging habitat are not relevant to this proposal;

 An alternative roost that is used by ghost bats is present (Union North adit) 650 m to the north and will be retained in its current state during the project lifetime. Ghost bats will be monitored during this period;

 KLG is proposing to renovate an additional underground structure (Lady Alice adit) that has been rendered unsuitable as a ghost bat roost by fallen rocks and debris, to provide an offset to the temporary loss of the wet season roost at OK adit; and

 KLG is proposing to construct several artificial roosts to act as alternative wet and dry season roost sites to offset the temporary closure of the OK adit. These artificial roosts will potentially provide alternative roost sites for ghost bats into the future as historical mine sites in the local area continue to deteriorate and eventually become blocked by debris and rockfall (Hall et al. 1997).

 KLG is proposing that components of the new underground mine be made available as a ghost bats as a roost in the post‐mining period.

7.2 ACTIONS THAT MAY REDUCE THE AREA OF OCCUPANCY (AOO) OF AN IMPORTANT POPULATION

The proposal will not alter the ghost bat area of occupancy, as there is no requirement to exclude the bats from the Union North adit (located 650 m north of the prospect adit). The proposal would only require the temporary exclusion of ghost bats from two wet season seasonal roosts as a measure to minimise disturbance from mining at these locations, allowing the bats to continue to occupy the project area and forage in surrounding habitats. Additionally, as the proposed mining is underground, it is not proposed to modify or reduce the area of ghost bat foraging habitat in the local area.

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Area of occupancy assessments were conducted following IUCN criteria, which sets out a number of standard procedures for determining AOO. The standard measure used by the Threatened Species Scientific Committee and other assessors (Woinarski et al. 2014) is to assign an occupancy to a 2 km x 2 km grid (4 km2) where are record or roost site is located in the landscape. For assessments of ghost bats, the occupancy has been linked to roost sites due to lack of survey across the range and the limitation of the species to roost locations that are relatively uncommon at a landscape scale (Woinarski et al. 2014; McKenzie and Hall 2008). For the current project, the continued occupancy of ghost bats at Union North adit will result in the project having no impact (reduction) on the projected AOO. Measures proposed by KLG to mitigate impacts (e.g. restoration of the Lady Alice adit, construction of artificial roost/s) will potentially consolidate the presence of the ghost bat in the local area and stabilise the AOO at this location.

7.3 ACTIONS THAT MAY FRAGMENT AN EXISTING POPULATION INTO TWO OR MORE POPULATIONS

The proposal does not require the removal of the local population or all roost sites in the Union Reefs project area. It is therefore unlikely to have a fragmentary effect on the existing population in the local or regional area.

7.4 ACTIONS THAT MAY ADVERSELY AFFECT HABITAT CRITICAL TO THE SURVIVAL OF A SPECIES

The two roosts proposed for temporary closure (OK adit and Prospect adit) as a measure to minimise disturbance to bats during the mining phase, are mainly used as wet season diurnal roosts (Armstrong and Barden 2018; Barden and Hanrahan 2019; Hanrahan et al. 2019). These sites cannot be considered critical to the survival of ghost bats in the Union Reefs project area, as there is an alternative roost nearby that is used on a regular basis (Union North adit). The impact of the temporary loss of OK and Prospect adits is proposed to be offset by opening and renovating an alternative dry season roost (Lady Alice adit) and by providing artificial roosts as alternative habitat during and following the project.

7.5 ACTIONS THAT MAY DISRUPT THE BREEDING CYCLE OF AN IMPORTANT POPULATION

The presence of breeding of ghost bats in recent times has not been detected at Union Reefs, although it is likely that a maternity colony was present in the past (S. Churchill personal communication to P. Barden) and it is possible that breeding occurs in the Union North adit. If breeding is occurring at the site, it is more likely to be associated with the much deeper Union North adit. Larger colonies with breeding activity tend to be in deep caves or adits with relatively warm and humid microclimates (Hall et al. 1997; Armstrong 2001).

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7.6 ACTIONS THAT MAY MODIFY, DESTROY, REMOVE OR ISOLATE OR DECREASE THE AVAILABILITY OR QUALITY OF HABITAT TO THE EXTENT THAT THE SPECIES IS LIKELY TO DECLINE

The project will require temporary closure of two seasonally‐used (dry season) roosts. The closure is designed to mitigate the potential impact of noise and vibration on roosting bats during the daytime, and will not require destruction of these sites. These impacts can be avoided because a suitable alternative roost is nearby and used currently by the same group of bats (Union North adit), which will be protected and monitored. In addition, an alternative dry season roost will be provided by opening and renovating a nearby adit (Lady Alice adit) and artificial roosts will be constructed in the Union Reefs project area. The proposal does not include loss of significant areas of foraging habitat for ghost bats in the Union Reefs project area. The maximum estimated clearing for the project is 1 ha of regrowth vegetation comprising new haul road section, and clearing out an old magazine area and a small area above the portal for water tanks, substation and vents. Under these circumstances, the project is unlikely to lead to the decline of ghost bats in the local area.

7.7 ACTIONS THAT MAY RESULT IN INVASIVE SPECIES THAT ARE HARMFUL TO A VULNERABLE SPECIES BECOMING ESTABLISHED IN THE VULNERABLE SPECIES’ HABITAT

The proposal will not lead to the establishment of invasive species in the habitat of the ghost bat. The monitoring that is proposed for the ghost bat roost sites within the Union Reefs project area will potentially benefit the management of these sites by enabling detection and management of any threats or invasive species in the vicinity of the roosts.

7.8 ACTIONS THAT MAY INTRODUCE DISEASE THAT MAY CAUSE THE SPECIES TO DECLINE

The project proposal and associated actions are unlikely to involve introduction of diseases. Any research that involves capture and handling of ghost bats will require consideration of strict hygiene protocols for personnel and equipment, particularly in relation to equipment to be used at different roost sites within the region.

7.9 ACTIONS THAT MAY INTERFERE SUBSTANTIALLY WITH THE RECOVERY OF THE SPECIES

None of the actions proposed for the current proposal are expected to interfere substantially with the recovery of the ghost bat. A number of actions specifically related to the project and resulting from associated research may substantially assist in the regional recovery of the species. This includes providing a greater understanding of the structure and movements of the regional population, enhanced

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management of the nationally important maternity site at Pine Creek, construction of artificial roosts that may be used as an improved management template at other sites, and provision of a post mining roost that may become of regional significance.

7.10 EPBC CONCLUSION

The proposal will result in the temporary restriction of ghost bat access to one of two known diurnal roosts (which may also be the focus of at least some part of the breeding cycle) in the Union Reefs project area, which represents around 3 % of the known regional population of the species. This will be met with a multi‐disciplinary program of management, research, and capacity building that will provide significantly greater roosting opportunity for the ghost bat than currently exists, provide the impetus and resources to resolve long‐standing conservation issues at two major stronghold colonies in the region, and provide a much greater understanding of ghost bats through both applied and academic research. The Action Plan details measures that will preserve Area of Occupancy, avoid population fragmentation, and increase several‐fold the amount of habitat critical to the survival of the species (no net decrease in the availability of critical habitat).

Monitoring and research will provide further information on breeding activity, with an adaptive management response to follow any update in understanding of the activities of the local colony. These various Actions meet the goal of sustainability because the program is designed to improve the situation of the entire regional population, not just the local occurrence in the Union Reefs project area—the scope is relatively broad‐scale; as well as create redundancy and pre‐empt the requirements of contingency situations. The precautionary principle has guided the development of all 11 Actions in the Action Plan, which were developed to address the most relevant and highest priority needs in the context of the proposal—all methods will be either non‐invasive, or else they will be conducted in such a way to reduce significantly the chance that individuals will be exposed to an increased risk of mortality. The comprehensive scope of the Action Plan has also allowed residual impacts and risks to be addressed, mainly through the provision of extra roosting opportunity in the Union Reefs project area. Certainly, no previous effort by industry for ghost bat management and conservation in the Northern Territory, and possibly within Australia, has been as comprehensive or as sensitive to investigator‐derived impacts as the current Action Plan.

Ecological Management Services Pty Ltd/Specialised Zoological

22 November 2019

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8.0 References

Armstrong, K.N. (2010). Assessing the short‐term effect of minerals exploration drilling on colonies of bats of conservation significance: a case study near Marble Bar, Western Australia. Journal of the Royal Society of Western Australia 93: 165–174. Armstrong, K.N. (2001). The roost habitat and distribution of the orange leaf‐nosed bat, Rhinonicteris aurantius, in the Pilbara region of Western Australia. Wildlife Research 28: 95–104. Armstrong, K.N. and Anstee, S.D. (2000). The ghost bat in the Pilbara: 100 years on. Australian Mammalogy 22: 93–101. Armstrong, K. and Barden, P. (2018). Targeted survey for the Ghost Bat Macroderma gigas in the Union Reefs Project Area, Northern Territory. Unpublished report by Ecological Management Services Pty Ltd and Specialised Zoological to Kirkland Lake Gold Ltd, 5 October 2018. Armstrong, K. and Barden, P. (2019). Ghost bat Macroderma gigas monitoring for the Union Reefs Exploration Drilling Program 2018 – 2019. Unpublished report by Ecological Management Services Pty Ltd and Specialised Zoological to Kirkland Lake Gold Ltd, Version R3, 3 February 2019. Hanrahan, N. Armstrong, K. and Barden, P. (2019). Union Reefs Exploration Drilling Program Ghost bat Macroderma gigas Monitoring: Interim Report October 2018 – February 2019. Unpublished report by Ecological Management Services Pty Ltd and Specialised Zoological to Kirkland Lake Gold Ltd, R1: 5 April 2019. Armstrong, K., Barden, P. and Hanrahan, N. (2019a). An Action Plan for the management of Ghost Bats in the Union Reefs project area. Unpublished document by Specialised Zoological, Ecological Management Services Pty Ltd and Nicola Hanrahan Consulting Services to Kirkland Lake Gold Ltd, version 4 June 2019. Armstrong, K., Barden, P. and Hanrahan, N. (2019b). An Action Plan for the management of Ghost Bats in the Union Reefs project area. Unpublished document by Specialised Zoological, Ecological Management Services Pty Ltd and Nicola Hanrahan Consulting Services to Kirkland Lake Gold Ltd, version 29 October 2019. Armstrong, K. (2018 in litt.). Drilling near potential roosts of the ghost bat in the Union Reef Project Area. Letter from Kyle Armstrong of Specialised Zoological to Michelle Berryman of Kirkland Lake Gold Ltd, 3 August 2018. Augusteyn, J., Hughes, J., Armstrong, G., Real, K. and Pacioni, C. (2018). Tracking and tracing central Queensland’s Macroderma–determining the size of the Mount Etna ghost bat population and potential threats. Australian Mammalogy 40: 243–253. Barden, P.A. and Hanrahan, N. (2019). Bat Monitoring at Union Reefs, 03 October 2019. Unpublished memorandum to KLG, October 2019. Baudinette, R.V., Churchill, S.K., Christian, K.A., Nelson, J.E. and Hudson, P.J. (2000). Energy, water balance and the roost microenvironment in three Australian cave‐dwelling bats (Microchiroptera). Journal of Comp. Physiology B 170: 439–446.

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Baynes, A., Merrilees, D. and Porter J.K. (1976). Mammal remains from the upper levels of a late Pleistocene deposit in Devil’s Lair, Western Australia. Journal of the Royal Society of Western Australia 58: 97–126. Boles, W.E. (1999). Avian prey of the Australian ghost bat Macroderma gigas (Microchiroptera: Megadermatidae): prey characteristics and damage from predation. Australian Zoologist 31: 82– 91. Bullen, R.D. and McKenzie, N.L. (2002). Scaling bat wingbeat frequency and amplitude. Journal of Experimental Biology 205: 2615–2626. Bullen, R.D. and Creese, S. (2014). A note on the impact on Pilbara leaf‐nosed and ghost bat activity from cave sound and vibration levels during drilling operations. The Western Australian Naturalist 29: 145–154. Churchill, S.K. (2008). Australian bats. 2nd ed. Allen and Unwin, Crows Nest, NSW. Churchill, S.K. (1991). Distribution, abundance and roost selection of the orange horseshoe‐bat, Rhinonicteris aurantius, a tropical cave‐dweller. Wildlife Research 18: 343–353. Conservation Commission of the Northern Territory (1993). Union Reefs Project Environmental Assessment Report and Recommendations. Assessment Report 18. Northern Territory Government, Darwin. Commonwealth of Australia (2013).Commonwealth Matters of National Environmental Significance (MNES) Significant impact guidelines 1.1. Canberra, Australia https://www.environment.gov.au/system/files/resources/42f84df4‐720b‐4dcf‐b262‐ 48679a3aba58/files/nes‐guidelines_1.pdf DENR (2019). NT Fauna Atlas Data Search: Ghost Bat Macroderma gigas. NR Maps Data Portal. Accessed October 2019. Diete, R.L., Dixon, K.M. and Barden, P.A., 2016. Predation of pitfall‐trapped rodents by the ghost bat, Macroderma gigas. Australian Mammalogy 38(2), pp.249‐252. Douglas, A.M. (1967). The natural history of the ghost bat, Macroderma gigas (Microchiroptera, Megadermatidae), in Western Australia. The Western Australian Naturalist 10: 125–137. Edwards, M. and Keily, J. (2017). Report on the mineral resources and mineral reserves of the Northern Territory Operations, Northern Territory of Australia. Report to Kirkland Lake Gold. Guppy, A., Coles, R.B. and Pettigrew, J.D. (1985). Echolocation and acoustic communication in the Australian ghost bat, Macroderma gigas (Microchiroptera: Megadermatidae). Australian Mammalogy 8: 299–308. Guppy, A. and Coles, R.B. (1988). Acoustical and neural aspects of hearing in the Australian gleaning bats, Macroderma gigas and Nyctophilus gouldi. Journal of Comparative Physiology 162: 653–668. Hall, L., Richards, G., McKenzie, N., and Dunlop, N. (1997). The importance of abandoned mines as habitat for bats. pp. 326–333 In: Conservation outside nature reserves (eds. P. Hales and D. Lamb.). The University of Queensland, Brisbane.

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Hand, S.J. (1996). New Miocene and Pliocene megadermatids (Mammalia; Microchiroptera) from Australia, with comments on broader aspects of megadermatid evolution. Geobios 29: 365–77. Hand, S.J., Dawson, L. and Augee, M. (1988). Macroderma koppa, a new Pliocene species of false vampire bat (Microchiroptera: Megadermatidae) from Wellington Caves, New South Wales. Records of the Australian Museum 40: 343–351. Hand, S.J. and York, A. (1990). Morphological variation in the dentition and skull of the Australian ghost bat Macroderma gigas (Microchiroptera: Megadermatidae). Australian Journal of Zoology 38: 263– 286. Hanrahan, N., Welbergen, J., Turbill, C. and Armstrong, K.N. (2016). Eavesdropping on ghost bats Using bioacoustics to uncover characteristics of social organisation in an iconic bat. Poster presentation at the 17th Australasian Bat Society Conference, Hobart, Tasmania, Australia 29 March–1 April 2016. The Australasian Bat Society Newsletter 46: 53. Hoyle, S.D., Pople, A.R., and Toop G.J. (2001). Mark–recapture may reveal more about ecology than about population trends: demography of a threatened ghost bat (Macroderma gigas) population. Austral Ecology 26: 80–92. Hudson, W.S. and Wilson, D.E. (1986). Macroderma gigas. Mammalian Species 260: 1–4. Kirkland Lake Gold (2018). NT Mining Operations Pty Ltd Union Reefs Project Area Exploration Mining Management Plan and Public Report 2018‐2019 (Authorisation 0961‐01). Compiled for Kirkland Lake Gold, 30 May 2018. Kulzer, E., Nelson, J.E., McKean, J.L. and Möhres, F.P. (1970). Untersuchungen über die Temperaturregulation australischer Fledermäuse (Microchiroptera). Zeitschrift fuer Vergleichende Physiologie 69: 426–438. Kulzer E., Nelson J.E., McKean J.L. and Moehres F.P. (1984). Prey‐catching behaviour and echolocation in the Australian ghost bat, Macroderma gigas (Microchiroptera: Megadermatidae). Australian Mammalogy 7: 37–50. Leitner P. and Nelson, J. E. (1967). Body temperature, oxygen consumption and heart rate in the Australian False vampire Bat Macroderma gigas. Comparative Biochemistry and Physiology 21: 65– 74. Lundelius, E.L. (1957). Additions to knowledge of the ranges of Western Australian mammals. The Western Australian Naturalist 5: 173–182. Lundelius, E.L. (1960). Post Pleistocene faunal succession in Western Australia and its climatic interpretation. Report of the International Geological Congress, 21st session, part 4: 142–153. MBS Environmental (2006). Frances Creek Project, Northern Territory: Public Environmental Report Executive Summary August 2006. Unpublished report for Territory Iron Limited. McKenzie, N.L. and Bullen, R.D. (2009). The echolocation calls, habitat relationships, foraging niches and communities of Pilbara microbats. Records of the Western Australian Museum Supplement 78: 123–155.

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McKenzie, N. & Hall, L. (2008). Macroderma gigas. The IUCN Red List of Threatened Species 2008: e.T12590A3362578. http://dx.doi.org/10.2305/IUCN.UK.2008.RLTS.T12590A3362578.en. Downloaded on 08 October 2019. Molnar R.E., Hall, L.S. and Mahoney J.H. (1984). New fossil localities for Macroderma Miller, 1906 (Chiroptera: Megadermatidae) in New South Wales and its past and present distribution in Australia. Australian Mammalogy 7: 63–73. Northern Resource Consultants (2018). Spring Hill Appendix A – Monitoring Plan. Unpublished report to PC Gold. February 2018. Northern Territory Environment Protection Agency (2019). Draft Terms Of Reference For Preparation Of An Environmental Impact Statement: Union Reefs North Underground Mine. Northern Territory Government, Darwin. NSR Environmental Consultants (1993a). Draft environmental impact statement main report. Union reefs Project. Unpublished report by NSR Environmental Consultants Pty Ltd foe The Shell Company of Australian Ltd, CR 697/7, September 1993. NSR Environmental Consultants (1993b). Supplement to the Draft environmental impact statement main report. Union reefs Project. Unpublished report by NSR Environmental Consultants Pty Ltd foe The Shell Company of Australian Ltd, CR 697/8, November 1993. Pettigrew, J., Baker, G.B., Baker‐Gabb, D., Baverstock, G., Coles, R., Conoloe, L., Churchill, S., Fitzherbert, K., Guppy, A., Hall, L., Helman, P., Nelson, J., Priddel, D., Pulsford, I., Richards, G., Schulz, M., and Tidemann, C.R. (1986). The Australian ghost bat at Pine Creek, Northern Territory. Macroderma 2: 8–19. Pettigrew, J.D., Dreher, B., Hopkins, C.S., McCall, M.J. and Brown, M. (1988). Peak density and distribution of ganglion cells in the retinae of microchiropteran bats: implications for visual acuity. Brain, Behavior and Evolution 32: 39–56. Richards, G.C., Hand, S., Armstrong, K.N. and Hall, L.S. (2008). ghost bat Macroderma gigas. pp. 449–450 In: Mammals of Australia, 3rd edition, (eds. S. Van Dyck and R. Strahan). Australian Museum, Sydney. Schulz, M. (1986). Vertebrate prey of the ghost bat, Macroderma gigas, at Pine Creek, Northern Territory. Macroderma 2: 59–62. Shine R., Wang S., Madani G., Armstrong K.N., Zhang L., Li Y.‐M. (2016). Using genetic data to predict the vulnerability of a native predator to a toxic invader. Endangered Species Research 31: 13–17. Simmons, N.B. (2005). Order Chiroptera. pp. 312–529 In: Mammal species of the world: a taxonomic and geographic reference. 3rd edition, (eds. D.E. Wilson and D.M. Reeder). Johns Hopkins University Press, Baltimore. Soisook, P. Prajakjitr, A. Karapan, S. Francis, C.M. and Bates, P.J.J. (2015). A new genus and species of False Vampire (Chiroptera: Megadermatidae) from peninsular Thailand. (PDF). Zootaxa 3931: 528– 550. doi:10.11646/zootaxa.3931.4.4

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Threatened Species Scientific Committee (2016). Conservation Advice Macroderma gigas ghost bat. Canberra: Department of the Environment. Available from: http://www.environment.gov.au/biodiversity/threatened/species/pubs/174‐conservation‐advice‐ 05052016.pdf Tidemann, C. R., Priddel, D. M., Nelson, J. E. and Pettigrew, J. D. (1985). Foraging behaviour of the Australian ghost bat, Macroderma gigas (Microchiroptera: Megadermatidae). Australian Journal of Zoology 33: 705–713. Toop J. (1985). Habitat requirements, survival strategies and ecology of the ghost bat, Macroderma gigas Dobson, (Microchiroptera, Megadermatidae) in central coastal Queensland. Macroderma 1: 37– 41. Velasco, M. (2019 in litt.). Kirkland Lake Gold EIS. Blasting noise and vibration modelling ‐ ghost bats. Letter report by GHD Pty Ltd to Kirkland Lake Gold Ltd, 8 October 2019, Ref 12512776‐47251. Woinarski, J.C.Z, Burbidge A. and Harrison P. (2014). The action plan for Australian mammals 2012. CSIRO publishing, 2014. Worthington‐Wilmer, J., Moritz, C., Hall, L. and Toop, J. (1994). Extreme population structuring in the threatened ghost bat, Macroderma gigas: evidence from mitochondrial DNA. Proceedings of the Royal Society of London B Biological Sciences 257: 193–198. Worthington‐Wilmer, J., Hall, L., Barratt, E. and Moritz, C. (1999). Genetic structure and male‐mediated gene flow in the ghost bat (Macroderma gigas). Evolution 53: 1582–1591. Worthington‐Wilmer, J. (2012). Ghost bat Macroderma gigas. pp. 382–383 In: Queensland’s Threatened animals. (eds L.K. Curtis, A.J. Dennis, K.R. McDonald, P.K. Kyne and S.J.S. Debus). CSIRO Publishing, Melbourne.

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APPENDIX 1 GHD (2019). Kirkland Lake Gold EIS Blasting noise and vibration modelling ‐ ghost bats.

Appendix 1.1

8 October 2019

Sally Horsnell Our ref: 12512776-47251 Your ref: Kirkland Lake Gold Ltd. 2/14 Shepherd Street Darwin NT 0800

Dear Sally

Kirkland Lake Gold EIS Blasting noise and vibration modelling - ghost bats

1 Introduction This blasting vibration impact study report is intended to be included as an appendix to the Kirkland Lake Gold Union Reefs North Underground Mine (the Project) Environmental Impact Statement (EIS). The blasting vibration impact study provides guidance in assessing the potential impacts and risks aspects of the terrestrial flora and fauna section of the NTEPA (2019) Terms of Reference (ToR) for this project. The environmental objectives, as they relate to blasting impacts are as follows: • quantify and discuss the potential for significant impact on ghost bats from noise and vibration disturbance with regard to:

o susceptibility to low level vibration and limits below what is considered for human comfort levels (note Australian Standard – AS2187.2 for human comfort limits from ground vibration is not appropriate for ghost bats)

o justification and rationale for limits from suitably qualified ecologists (chiropterologist) in consultation with acoustic engineers

2 Scope of works This blasting noise and vibration study involved the following tasks:

 Review the existing and proposed locations of the ghost bat colonies (receptor locations) within the Union Reefs North Underground Mine study area

 Review the proposed blasting locations within the Union Reefs North Underground Mine site

 Predict vibration levels (mm/s) to the existing and proposed locations of the bat colonies based on the following parameters: – Worst case blast conditions – Rock type parameters based on the geotechnical report – Slant distance between the blast sites and the receptor locations  Predict indicative regenerated noise levels at the receptor locations due to blasting activities

This study excludes an assessment of airblast/overpressure (airborne noise) and flyrock associated with the Project. It is assumed that all blasting will be conducted underground and as such, the airblast/overpressure and flyrock impacts will be negligible.

The following documents have been used as a basis of the vibration modelling:

 AS2187.2-2006 – Explosives – Storage and use Part 2: Use of explosives, Australian Standards 2006

 Determination of blast-induced ground vibration equations for rocks using mechanical and geological properties, Kumar et al. 2015

 Crocodile Gold Australia, Prospect underground – Mining Geotechnical review, Geotechnical Consulting Pty Ltd, March 2013 The following documents have been used as a basis of the ground-borne noise modelling:

 Assessment of Blasting-Induced Ground Vibration in an Open-Pit Mine under Different Rock Properties, Zhi-qiang Yin et al. 2018

 ANC Guidelines - Measurement and assessment of groundborne noise and vibration, The Association of Noise Consultants (ANC), 2012

3 Union north design An Autocad DXF drawing was provided for the proposed Union North mine. It is assumed that blasting will likely be required at all locations within the mine. As such, the co-ordinates (x,y,z) for each vertices within the drawing was extracted to represent a potential blasting point for the vibration modelling. Table 1, Table 2 and Table 3 shows design of the mine from various perspectives.

Table 1 Union North mine design – top and perspective views

Top view Perspective view

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Table 2 Union North mine design – eastern and western elevations

Eastern elevation Western elevation

Table 3 Union North design – northern and southern elevations

Northern elevation Southern elevation

4 Modelling methodology

4.1 Prediction locations Dr Kyle Armstrong (Specialised Zoological) has provided co-ordinates for seven locations where ghost bats could potentially roost within the study area. Vibration levels associated with blasting are predicted at these locations. These locations are listed in Table 4 and shown in Figure 1.

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Table 4 Prediction locations for modelling

Location MGA94 Zone 52 Min. distance to Description blasting point (m) x y z

L1 801444 8482734 182 33 OK adit – roost location

L2 801209 8483424 182 290 Union north adit – roost location

L3 801368 8483485 192 370 Unnamed shaft

L4 801310 8483401 182 272 Lady Alice adit

L5 800520 8480465 178 2351 Railway culvert

L6 799434 8483753 167 1908 Railway culvert

L7 801373 8482766 201 51 Prospect adit

Figure 1 – Location of blasting vertices and prediction points

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To determine the minimum distance between the blasting vertices and the prediction locations (Table 4), the following equation was used: ( ) = ( ) + ( ) + ( ) 2 2 2 This is considered conservative𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚 𝑑𝑑𝑑𝑑 𝑑𝑑𝑑𝑑𝑑𝑑as 𝑑𝑑the𝑑𝑑𝑑𝑑 equation𝑚𝑚 � calculates𝑥𝑥2 − 𝑥𝑥1 the 𝑦𝑦minimum2 − 𝑦𝑦1 straight𝑧𝑧2 − line𝑧𝑧1 distance between the blasting and the prediction points.

Figure 2 shows the blasting locations relative to the closest prediction points from a side view (western/eastern elevations) and Figure 3 is from a front view (northern/southern elevations).

Figure 2 – blasting points relative to the prediction points (side view) (L5 and L6 not in view)

L7 L4 L3 L1 L2

Figure 3 – blasting points relative to the prediction points (front view) (L5 and L6 not in view)

L3 L7 L4 L2 L2

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4.2 Ground vibration prediction models Appendix J of Australian Standard 2187.2-2006 provides the following equation to estimate ground vibration from blasting:

−1.6  R  V = K   G  1   Q 2 

Where:

V is the peak vector sum ground vibration ppv (mm/s). R is the distance from charge (m).

Q is the maximum instantaneous charge (MIC) (kg).

KG is the ground constant Measurements of blasting activities are generally undertaken at the site to determine the ground constant (KG) and the site exponent (b). AS2187.2 states that a typical value for the site constant is 1140 and a site exponent of -1.6 however these can vary significantly. In the absence of site specific vibration measurements, it is proposed that the model from Determination of blast-induced ground vibration equations for rocks using mechanical and geological properties (Kumar et al, 2015) is used as it takes into account the geological strength index (GSI) of the rock type prevalent in the study area.

The proposed PPV model (equation 8) is as follows: (0.3396 × 1.02 × . ) . × . = 1000 × 𝐺𝐺𝐺𝐺𝐺𝐺 1 13 0 642 −1 463 𝐺𝐺𝐺𝐺𝐺𝐺 𝐷𝐷 𝑉𝑉 Where: 𝛾𝛾 V is the peak vector sum ground vibration peak particle velocity (ppv) (in mm/s).

GSI geological strength index of the rock

D scaled distance (m/kg1/2) – ratio of distance from the charge point, R (m) to the square root of the charge mass, Q (kg) У the unit weight of the rock type (kN/m3)

For this study, Kumar et al, 2015 will be used to predict vibration levels at the seven locations and the equation provided in AS2187 will also be presented as a reference based on typical conditions.

4.2.1 Input parameters To calculate the vibration levels at each prediction point, the following input parameters are to be determined:

 GSI – the geological strength index of the rock in the study area

 The maximum charge mass for the blasting activities associated with the Project (in Kgs)

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 The distance between the blasting location and the prediction point (in metres)

 The unit weight of the rock type (in kN/m3) A review of Crocodile Gold Australia, Prospect underground – Mining Geotechnical review, Geotechnical Consulting Pty Ltd, March 2013 has been undertaken to determine the rock types prevalent at Union Reefs and the surrounding area. The geotechnical report indicates a prevalence of greywacke (variety of sandstone) and shale (clastic sedimentary rock). Table 5 of the geotechnical report presents estimated GSI values for the identified rock types, which ranges from 15 to 50. The significance of a low GSI is that the ground vibration drops off more rapidly and results in lower vibration levels at a distance. A range of GSI values between 30 and 50 has been used for the vibration modelling to represent the ground below the weathered zone, which is of moderate to high strength.

The charge mass range for the blasting associated with the Project is approximately 35 to 40 Kg. For the vibration modelling, a maximum charge mass of 40 Kg has been assumed.

The unit weight of the greywacke or shale rock is approximately 26 kN/m3 and has been used for the unit weight for vibration modelling.

The minimum distance (in metres) between the blast point and the prediction point is based on the minimum distance presented in Table 4.

4.2.2 Vibration modelling results Table 5 presents the predicted vibration levels at the seven locations based on the assumptions and input parameters discussed in Section 3. Vibration contours are provided in Appendix A for the upper GSI value of 50.

Table 5 Predicted vibration levels in mm/s

Location Prediction point (MGA 94 Z52) Closest blasting point (MGA Min. PPV (Kumar) PPV 94 Z52) distance – mm/s (AS2187) (m) – mm/s x y z x y z GSI GSI 30 50

L1 801444 8482734 182 801436 8482730 150 33 29.6 54.6 80.0

L2 801209 8483424 182 801245 8483138 150 290 1.2 2.3 2.5

L3 801368 8483485 192 801245 8483138 150 370 0.9 1.6 1.7

L4 801310 8483401 182 801245 8483138 150 272 1.4 2.5 2.8

L5 800520 8480465 178 801464 8482616 105 2351 0.1 0.1 0.1

L6 799434 8483753 167 801239 8483135 150 1908 0.1 0.1 0.1

L7 801373 8482766 201 801378 8482770 150 51 15.7 28.9 39.9

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4.3 Groundborne noise prediction method Equation C.4 from ANC Guidelines - Measurement and assessment of groundborne noise and vibration, The Association of Noise Consultants (ANC), 2012 provides a method to predict re-radiated noise from vibration measured from the surface of the ground of the receptor space: = 32

Where: 𝐿𝐿𝑝𝑝 𝐿𝐿𝑣𝑣 −

-5 Lp = the rms sound pressure level in the room (dB re 2 x 10 Pa) (z-weighted)

-9 -1 Lv = is the rms vibration velocity levels of the floor in dB re 1 x 10 ms This conversion to groundborne noise should only be used as a guide and is intended for re-radiated noise in buildings rather than rock structures. It should be noted that when applying equation C.4, the guideline states that the predicted noise levels can vary by up to +/- 6 dB depending on which part of the room or space the noise levels applies to (centre, corner or intermediate position).

4.3.1 Groundborne noise results Table 6 presents the predicted indicative groundborne noise levels (Z-weighted – linear) at each of the seven locations based on the vibration levels presented in Table 5.

Table 6 Predicted vibration levels in mm/s

Location Min. distance (m) PPV (Kumar) – mm/s Groundborne noise level (dBZ)

L1 33 54.6 75

L2 290 2.3 62

L3 370 1.6 60

L4 272 2.5 62

L5 2351 0.1 48

L6 1908 0.1 50

L7 51 28.9 73

Site-specific vibration measurements of blasting activities have not been undertaken at the site and as such, the concentration of the vibration energy across the frequency spectrum cannot be calculated. Vibration measurements of different blasting activities were undertaken as part of the study, Assessment of Blasting-Induced Ground Vibration in an Open-Pit Mine under Different Rock Properties, Zhi-qiang Yin et al. 2018. In this study, the blasting vibration signals monitored at a blasting site with different rock masses were used to investigate the attenuation characteristics of blasting vibration through the peak particle velocity (PPV), frequency characteristics, and energy distribution of the blasting vibration signals analyzed with the time-frequency processing method. The results demonstrated that the main vibration frequency of dolomite was 25 Hz and 14 Hz for dolomite and shale, respectively. The results also

12512776/12512776-LET-Blasting_Vibration_Impact_Study.docx 8

indicate that the energy of the blast vibration signal is mostly concentrated within 0 -50 Hz (generally over 95% of the vibration energy). Based on the information above (likely to be relatively representative of the rock type within the Project site), the predicted Z-weighted noise levels presented in Table 5 are likely to be concentrated in the frequencies between 1 – 50 Hz. It should be noted that ghost bats are unlikely to be able to hear frequencies below 1 kHz as these frequencies are below their typical hearing range (Adams, Rick A.; Pedersen, Scott C. (2000). Ontogeny, Functional Ecology, and Evolution of Bats, pp 139-140)

5 Conclusion Vibration levels due to the proposed blasting activities at Union Reefs North Underground Mine have been predicted to seven locations with the study area and range from 29.6 - 54.6 mm/s at L1 (33 metres from the nearest blast location) to 0.1 mm/s at L5 (2351 metres from the nearest blast location). These predictions are based on a maximum charge mass of 40 Kg and the rock parameters for greywacke and shale presented in the geotechnical report for the Project.

Indicative groundborne noise levels have been predicted to the same seven locations and range from an rms sound pressure level of 75 dBZ at L1 to 48 dBZ at L5. It is predicted that the majority of the concentration of vibration/noise energy is in the range of 1 Hz to 50 Hz, which is expected to be outside of a ghost bat’s typical hearing range.

Sincerely GHD

Marco Velasco

12512776/12512776-LET-Blasting_Vibration_Impact_Study.docx 9

Appendix A Vibration contours (GSI 50)

12512776/12512776-LET-Blasting_Vibration_Impact_Study.docx 10 Closest blasting point to Location 1 - OK adit roost

Vibration levels (mm/s) - Kumar et al. prediction model (GSI 50) ■ 11111111111• 1 2 3 4 5 6 7 8 9 10 20 30 40 50 60 Closest blasting point to Locations 2, 3 and 4

"\<-:><:::)' <:::><:::> ea Vibration levels (mm/s) - Kumar et al. prediction model (GSI 50) ,;::,<:::> <-:>cs c� ea<::s �')..., ■'-...l__------'----__J__.L_____j____L___j _ _,______j____L_,._ 6 7 8 9 10 20 30 40 so- 60 ea?' 1 2 3 4 5 Closest blasting point to Locations 5 and 6

n<:) °''\; "°' ' Vibration level (mm/s) - Kumar et al. prediction model (GSI 50)

1 2 3 4 5 6 7 8 9 10 20 30 40 so 60 Closest blasting point to Location 7 - Prospect adit

'?<,:,� q,s:::)">-'

Vibration levels (mm/s) - Kumar et al. prediction model (GSI 50) ■ 11111111111• 1 2 3 4 5 6 7 8 9 10 20 30 40 so 60 Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

APPENDIX 2 Ghost Bat Action Plan (Armstrong, Barden and Hanrahan 2019a)

Appendix 2.1

An Action Plan for the management of Ghost Bats in the Union Reefs project area

Prepared for Kirkland Lake Gold Ltd

Version 2019-11-21

An Action Plan for the management of Ghost Bats in the Union Reefs project area

Version 2019-11-21

Prepared for Kirkland Lake Gold Ltd Client contact Sally Horsnell Job Number (Specialised Zoological) SZ466

Authors Kyle Armstrong, Specialised Zoological, ABN 92 265 437 422 Tel 0404 423 264; [email protected]

Paul Barden, Ecological Management Services Pty Ltd, ACN 084 304 110 PO Box 580, Coolum Beach, Queensland 4573; [email protected]

Nicola Hanrahan, Nicola Hanrahan Consulting Services, ABN 65 360 809 735 [email protected]

Document revision history

28 October 2019 First draft Kyle Armstrong 15 November 2019 Second draft Kyle Armstrong 21 November 2019 Third draft Kyle Armstrong

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Citation Armstrong, K., Barden, P. and Hanrahan, N. (2019). An Action Plan for the management of Ghost Bats in the Union Reefs project area. Prepared by Specialised Zoological, Ecological Management Services Pty Ltd and Nicola Hanrahan Consulting Services for Kirkland Lake Gold Ltd, Version 2019-11-21, Specialised Zoological Job number SZ466.

Page 2 of 39 An Action Plan for the management of Ghost Bats in the Union Reefs project area

Contents

Page Background 4 Glossary 6 Vision 7 Overall goal 7 Specific objectives of the Action Plan 7 Specific questions addressed by the Action Plan 8 Summary of Actions 9 Phased timing of the Actions 10 Action 1—Exclude the Ghost Bat from the OK adit 11 Action 2—Characterise the internal dimensions of the OK adit and Union North adit. 13 Action 3—Create several artificial habitats. 15 Action 4—Re-open and rehabilitate the Lady Alice adit. 19 Action 5—Manage the Union North adit to exclude visitation from mining personnel. 21 Action 6—Implement management and protection measures at the Pine Creek roost. 23 Action 7—Monitor the Ghost Bat at known local and regional roosts. 26 Action 8—Provide a portion of the new mine for Ghost Bat occupancy. 30 Action 9—Conduct field surveys for Ghost Bat diurnal roosts in natural caves. 32 Action 10—Investigate the connectedness of Ghost Bat colonies in the region. 34 Action 11—Provide support for further academic research on the Ghost Bat. 36 References 38

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Background

This Action Plan was developed as part of the Environmental Impact Statement (EIS) for the Union Reefs North Underground Project (the Project) by NT Mining Operations Pty Ltd (NTMO), which is owned by Kirkland Lake Gold Ltd (KLG). They plan to further develop deposits of gold ore in the Union Reefs project area, north of Pine Creek in the Northern Territory, by constructing a new underground mine with an entrance portal in the existing Prospect pit.

The Ghost Bat Macroderma gigas, which is specially protected and listed as Vulnerable under the Commonwealth Government’s Environment Protection and Biodiversity Conservation Act 1999, has been detected in the Union Reefs project area, both in the past (NSR Environmental Consultants 1993), and on recent surveys (Armstrong and Barden 2018—contains a summary of the biology of the species; Hanrahan et al. 2019).

At present, Ghost Bats are known to use two main sites for diurnal roosting within the Union Reefs project area—‘Union North adit’ in the Union North pit; ‘OK adit’ in the Prospect pit. These confirmed diurnal roosts are within the remnants of the lower parts of underground adits that are found extending back from the walls of two open-cut mine pits. The adits are small, with tunnels being around c. 1.5 m high by 1.5 m wide, and are part of the goldfield that was worked mostly between c. 1880 and 1910 (White et al. 1965). The open-cut mine pits are the result of contemporary mining activity in the past three decades. The extent of the underground remnants is unknown as historical maps were not available (White et al. 1965).

A drilling programme being conducted currently has taken into consideration the presence of Ghost Bats in the two adits, and activities have been modified to avoid drilling within close proximity (within 130 m) of roost site positions and entrances (see management plan of Armstrong and Barden 2019). Data from continuous monitoring of Ghost Bat presence and activity conducted since the targeted Ghost Bat survey of August 2018 (encompassing two breeding seasons) has shown that the species is almost always present in the Union Reefs area.

A single colony of the Ghost Bat occurs in the Union Reefs area, using both the Union North adit and OK adit, with the majority of individuals switching between the two sites are various times during the year (Hanrahan et al. 2019; Barden and Armstrong 2019). The size of the colony has been estimated at 20–30 individuals (Armstrong and Barden 2018; Barden and Armstrong 2019; Hanrahan et al. 2019), and the number of individuals varies.

The presence of the Ghost Bat has been noted during most of the breeding cycle (Hanrahan et al. 2019; Barden and Armstrong 2019), but few direct observations associated with breeding have been made (only when observations began in 1987; NSR Environmental Consultants 1993), mainly because the sensitivity of this species to disturbance precludes capture and direct observations.

Two other adits nearby (the ‘Prospect adit’ in the Prospect pit, with an entrance portal c. 90 m from that of the OK adit; and what is thought to be the Lady Alice adit / Adit H, with an entrance portal 155 m to the east of the Union North adit entrance portal) are now visited temporarily or at night only. In 1987, the Lady Alice adit / Adit H contained c. 200 Ghost Bats, including females in breeding condition (NSR Environmental Consultants 1993).

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The key consideration for the management of Ghost Bats in the Union Reefs area in the context of the Union Reefs North Underground Project is their usage of the OK adit as a diurnal roost site, and the proximity of this to the planned entrance portal of the new underground mine. To minimise the chance of mortality of Ghost Bat individuals from mining-related activity within a few tens of metres, it was proposed to temporarily (for the duration of underground mining) close off the OK adit to Ghost bat usage. This action is itself a disturbance to the colony, but will be undertaken alongside ten other ‘Actions’ as part of a broad-scale strategy for Ghost Bat management in the region (the Daly Basin and Pine Creek IBRA bioregions). Ghost Bats are also found within 15 km to the north (underground workings in the Spring Hill active mining area) and within 15 km to the south (abandoned Kohinoor adit at Pine Creek), and are presumably connected by dispersing individuals.

This Action Plan describes each of the 11 Actions that were recommended in the Union Reefs North Underground Project EIS (replacing a previous version of a regionally-focussed Action Plan for Ghost Bats written for a Notice of Intent; Armstrong et al. 2019). The Actions were developed specifically in response to the Terms of Reference that were addressed in the EIS, and are consistence with the relevant “Conservation and Management Actions”, “Survey and monitoring priorities” and “Information and research priorities” that were tabulated in the Conservation Advice for the Ghost Bat (TSSC 2016). A full analysis of the situation of Ghost Bats in the Union Reefs area and the region generally, plus an extended justification for the 11 Actions, has been provided in Barden and Armstrong (2019), which was written as a technical appendix to the EIS.

A glossary of relevant words is provided on the next page. The meaning of certain words can be critical in a management plan, underpinning expectations for activities and outcomes, and providing clarity and a common understanding for the proponent and the regulator. These words are highlighted in blue where the specific objectives of the Action Plan are listed.

This Action Plan will become part of a future Management Plan to be developed as part of KLG's environmental management system, and implemented upon successful project approval, but it should be noted that some Actions have already been initiated.

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Glossary

Adit—a horizontal tunnel extending underground from an entrance portal in a near-vertical or sloped rock face. The adit may link to other horizontal cross-cuts on either side, and to vertical shafts that extend below or above the horizontal tunnels.

Alternative diurnal roost; contingency roost—any underground structure, including underground mine workings, natural caves, or other equivalent structures, which can provide the conditions required for diurnal roosting by the Ghost Bat. These are predicted to occur outside the project area, and within the nightly flight range of a Ghost Bat, but remain to be found. They may also constitute any artificial structures constructed specifically as replacement roost habitat as part of the Project. Suboptimal alternative roosts are those structures that may be used temporarily by Ghost Bats following a disturbance, but they do not provide suitable conditions for longer term roosting.

Bat population—an interconnected set of colonies of Ghost Bats, in this case inferred to occupy an unknown number of roosts within the Daly Basin and Pine Creek IBRA bioregions. Gene flow occurs amongst members of the same population, but may not occur with other population/s (it is not known if gene flow occurs with colonies further north and in other parts of the Northern Territory).

Colony—a set of individual Ghost Bats that occur in an underground diurnal roost at any one time. Members of one colony may move to another colony, and most or all individuals of a particular colony might move from one roost site to another. Based on previous genetic studies (Worthington Wilmer et al. 1994, 1999; K.N. Armstrong unpublished study in prep.), females do not move away or far from their natal roost, and males also show high fidelity to roosts but are more likely to disperse greater distances.

Further afield—the wider region that is occupied by the Ghost Bat population.

Local persistence; local occurrence—presence within the Union Reefs project area.

Persist—present and detectable at one or more roost sites within the project area during the time of the defined activity (the closure of the OK adit and Prospect adit to bats) and for at least 6 months after the OK adit is re-opened.

Project area—all the area within tenements held by Kirkland Lake Gold Ltd and referred to as the Union Reefs project area.

Region—the Daly Basin and Pine Creek IBRA bioregions.

Roost; diurnal roost—an area within an underground structure where Ghost Bats remain during daylight hours, and sometimes during the night.

Stronghold colonies—the large colonies at Spring Hill c. 15 km to the north of Union Reefs project area, and the large colony c. 15 km south in the Kohinoor mine adit adjacent to the town of Pine Creek. These colonies have been known for many years, and are also known to be subject to a range of threats.

Temporary closure—the period in which the OK adit is closed to bats while underground tunnels are excavated and used nearby (accessed from a portal within the Prospect pit), estimated at around two years.

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Vision

Kirkland Lake Gold Ltd will be recognised as a leader nationally in efforts to manage, conserve and support research on the threatened Ghost Bat.

Overall goal

The overall goal of this Action Plan is to enact measures that will protect Ghost Bats from the potential effects of project-related mining activity, anticipate and provide for contingencies, and contribute to knowledge and conservation of the Ghost Bat at local, regional and national scales.

Specific objectives of the Action Plan

Specific objectives are required so that the success of supported management Actions can be assessed. The relevant Actions are listed against the objectives for easier cross-reference. Implementing the various Actions as they are described in this document will allow the objectives to be met.

1. Protect Ghost Bats from disturbances associated with mining-related activity in the Prospect pit. [Action 1]

2. Provide confirmation that the Ghost Bat has continued suitable alternative diurnal roost habitat (contingency roosts) within the Union Reefs project area and further afield. [Actions 2, 7, 9]

3. Confirm if Ghost Bats can maintain connectedness amongst colonies in the population, thus demonstrating the capacity for Ghost Bats to move from the Union Reefs project area to other colonies, including stronghold colonies. [Action 10]

4. Encourage and protect the persistence of the Ghost Bat in the Union Reefs project area during the period of mining, and the period that the OK adit is temporarily closed to Ghost Bats. [Actions 3, 4, 5]

5. Contribute to the long-term persistence of the Ghost Bat in the Union Reefs project area. [Actions 3, 4, 8]

6. Contribute to the long-term persistence of the Ghost Bat in the region by helping to protect stronghold colonies at Pine Creek and Spring Hill. [Actions 6, 7]

7. Seek further understanding of the Ghost Bat distribution, numbers and movements in the region to inform their conservation and management. [Action 11]

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Specific questions addressed by the Action Plan

These questions helped to formulate the objectives and strategy of this Action Plan:

1. Will Ghost Bats continue to use the Union North adit, and thus persist in the project area, following the temporary closure of the OK adit?

2. When Ghost Bats are excluded from the OK adit, are there other alternative diurnal roosts (contingency roosts) nearby if for some reason they cannot use the Union North adit?

3. Is there evidence that individual Ghost Bats move between the Union Reefs project area and other roost sites further afield?

4. Can we improve protections around colonies further afield already identified as key stronghold colonies under threat in the population, so that any unintended effects of mining-related activity in the Union Reefs project area do not significantly compound threats within the bat population.

5. Will Ghost Bats be able to persist in the Union Reefs area in the long-term after the current proposal for mining has concluded?

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Summary of Actions

 Action 1. Exclude the Ghost Bat from the OK adit based on a carefully planned protocol.

 Action 2. Characterise the internal dimensions and microclimates of the OK adit and Union North adit, and the position of Ghost Bat roost areas within.

 Action 3. Create several artificial habitats for the roosting of Ghost Bats in the Union Reefs project area, for both contingencies and redundancy.

 Action 4. Re-open and rehabilitate the Lady Alice adit so that it is suitable for Ghost Bat occupancy.

 Action 5. Manage the Union North adit during the period of mining to exclude visitation from mining personnel.

 Action 6. Implement management measures at the Koohinoor adit at Pine Creek to protect the Ghost Bat roost.

 Action 7. Conduct a programme of continuous monitoring of Ghost Bat presence, activity levels and colony size at all known (Union North adit) and potential (Lady Alice adit, artificial roost habitats newly created) roosts within the project area, and other key sites in the region (Pine Creek; Spring Hill; any newly discovered caves of significance surrounding the project area).

 Action 8. Provide a portion of the new mine for Ghost Bat occupancy once mining has been completed.

 Action 9. Conduct field surveys for Ghost Bat diurnal roosts in natural caves in the hills surrounding the Union Reefs project area.

 Action 10. Investigate the connectedness of Ghost Bat colonies in the region using an advanced genetic method based on genome-scale DNA sequencing.

 Action 11. Provide support for further academic research on the ecology of the Ghost Bat.

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Phased timing of the Actions

The Actions are expected to be conducted in several phases, with some Actions extending over more than one phase, as follows:

Phase 1. Before new underground mine construction.

Action 2—Characterise the internal dimensions of the OK adit and Union North adit. Action 3—Create several artificial habitats. Action 4—Re-open and rehabilitate the Lady Alice adit. Action 7—Monitor the Ghost Bat at known local and regional roosts. Action 9—Conduct field surveys for Ghost Bat diurnal roosts in natural caves. Action 10—Investigate the connectedness of Ghost Bat colonies in the region. Action 11—Provide support for further academic research on the Ghost Bat.

Phase 2. Exclusion Phase, immediately prior to site works in the Prospect pit.

Action 1—Exclude the Ghost Bat from the OK adit. Action 7—Monitor the Ghost Bat at known local and regional roosts.

Phase 3. During mining.

Action 5—Manage the Union North adit to exclude visitation from mining personnel. Action 6—Implement management and protection measures at the Pine Creek roost. Action 7—Monitor the Ghost Bat at known local and regional roosts. Action 11—Provide support for further academic research on the Ghost Bat.

Phase 4. After mining has been completed.

Action 7—Monitor the Ghost Bat at known local and regional roosts. Action 8—Provide a portion of the new mine for Ghost Bat occupancy. Action 11—Provide support for further academic research on the Ghost Bat.

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 Action 1—Exclude the Ghost Bat from the OK adit

Mitigation Hierarchy step: Both Avoidance and Mitigation/Minimisation.

Threat factor/s addressed: Habitat loss.

Knowledge gap addressed: No specific knowledge gap.

Specific priorities addressed in the Conservation Advice by this Action: Protect roost sites from disturbance.

Applicable objectives of the Action Plan Objective 1. Protect Ghost Bats from disturbances associated with mining-related activity in the Prospect pit.

Benefits of the Action: By discouraging the presence of Ghost Bats in close proximity to noise, vibration and disturbance associated with machinery and blasting in the Prospect pit, the risk of elevated mortality from the new mine will be removed. The Action will temporarily restrict access to one relatively shallow diurnal roost and possible site for breeding individuals, but it removes Ghost Bats from the proximity of mining-related activity at the entrance portal to the proposed new mine, and removes the risk of the negative impacts of noise and vibration from blasting underground on any individuals that might otherwise occupy the OK adit.

Details of the Action The Ghost Bat will need to be excluded from the OK adit before it can be closed to their entry. This needs to be done in the least invasive way possible. It will occur when bats have shifted their attention to the Union North adit. When there is acoustic evidence from bat detectors that Ghost Bats are not using the OK adit as a diurnal roost site, the entrance of the OK adit will be sealed at night to prevent their access prior to dawn.

The Exclusion is to proceed as follows:

1. The current programme of acoustic and video monitoring will continue at the OK adit (Phase 1). When Ghost Bats are observed to be absent, the Exclusion Phase (Phase 2) will begin. The Exclusion Phase will occur over three nights. 2. The entrance portal will be monitored with bat detectors and video recorders from dusk to dawn on each night during the Exclusion Phase. 3. On each of the three nights, a bright light will be shone on the entrance from three hours after sunset until dawn to discourage any species of bat from re-entering the structure throughout the night. Introducing the bright light three hours after dusk will give all species of bats sufficient time to leave the structure without disturbance. The remaining time until dawn (with the entrance illuminated) will give bats sufficient time to find an alternative roost. 4. The acoustic and video recordings will be reviewed after each night to determine if bats were seen returning to the structure before dawn. 5. At the end of the third night, the OK adit will be designated as ‘probably empty’ if no bats were seen leaving at dusk on the third night, or re-entering during the night before dawn on the third night.

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6. The application of bright light will be continued after three nights if bats are still using the structure, until they stop using the structure. 7. If bats are absent after the third night, a temporary cloth barricade will be placed over the portal after dawn. 8. At dusk on the fourth night, the blocked entrance will be monitored with bat detectors and with investigators present from sunset for three hours to ensure that no bats of any species are trapped within the structure. Bats remaining in the structure will be let out from behind the cloth barricade after sunset. 9. Once it has been established that no bats remain in the structure, the cloth barricade will be checked for its integrity and then left. 10. The following day after fourth night, the cloth will be replaced by a permanent barricade. Small gaps will be left for reptiles. 11. A report will be produced to document the process.

Monitoring by video (thermal and/or infrared) and acoustic (with AnaBat Swift bat detectors) recorders will continue at the Union North adit for the period that the OK adit is closed (see Action 7).

Acoustic monitoring will also be extended to include other species of bat that occupy the adits, but especially the more physiologically fragile species (Dusky Leaf-nosed Bat Hipposideros ater; Orange Diamond-faced Bat Rhinonicteris aurantia).

Monitoring will continue for six months after the OK adit is reopened to determine if Ghost Bats were able to return. This will coincide with a monitoring effort to determine if the Ghost Bat moves into the new mine after mining has ceased (see Action 8).

It is important that the patterns documented from acoustic and video recordings of Ghost Bat activity in the Union North adit can be correlated with mining-related activity on the site, and ideally with empirical data. One such measure will be the level of ground vibration in the adit during blasting, which will rely on the installation of a vibration datalogger. Vibration data will be recorded continuously, should entry to the structure/s be possible and safe (see Action 2).

Acknowledged risks and limitations It is acknowledged that the Action itself is a disturbance (temporary loss of a confirmed diurnal roost site and possible breeding site), but the Action is designed to avoid other disturbances (proximity of machinery and blasting), and then other Actions will mitigate the residual impacts.

The noise and vibration modelling study (Velasco 2019) predicted that levels of vibration would be significantly greater than 10 mm/sec (29.6 mm/sec to 54.6 mm/sec; an indicative limit used by mining proponents in the Pilbara region of Western Australia) within the OK adit, but less than 2.5 mm/sec at other sites including the Union North adit and Lady Alice adit. The effect of ground-borne noise was also predicted to be around the level of human conversation within the OK adit (75 dBZ), and lower elsewhere, and at frequencies below the limit of hearing in the Ghost Bat. While there has been no systematic study of the responses of bats to different levels of vibration and ground-borne noise, the case presented by Velasco (2019) provides confidence that sites other than the OK adit will not experience significant levels of noise and vibration from blasting (see also Barden and Armstrong 2019).

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 Action 2—Characterise the internal dimensions of the OK adit and Union North adit

Mitigation Hierarchy step: Research to support Minimisation.

Threat factor/s addressed: Disturbance to roost sites, Disturbance to breeding sites.

Knowledge gap addressed: The extent and condition of the two adits used by Ghost Bats in the Union Reefs project area, and the position underground where the bats congregate. Understanding how roost microclimates may change seasonally.

Specific priorities addressed in the Conservation Advice by this Action: Monitor populations at key sites and where impacts from mining are occurring or likely.

Applicable objectives of the Action Plan Objective 2. Provide confirmation that the Ghost Bat has continued suitable alternative diurnal roost habitat (contingency roosts) within the Union Reefs project area and further afield.

Benefits of the Action: Having more knowledge of the internal structure and microclimate of the OK adit and Union North adit allows a better understanding of how important the structures might be to the species. A survey of the internal structure of the adits will also provide information on low-level seasonal flooding that occurs in the Union North adit, which might require a management solution to keep this structure with optimal conditions for the Ghost Bat.

Details of the Action The knowledge gaps are relevant to the likelihood of the long-term usage by Ghost Bats of the site, and the proximity of bats roosting underground to mining-related activities that may cause them disturbance. For example, the monitoring plan that set a buffer width for the minimum proximity of drilling to the OK adit and Union North adit had no information on where bats roosted (Armstrong and Barden 2019). The extent of the buffer was set based on predictions of the roost location in each case, in relation to the position of the adit portal and the minimal information available on tunnel length and direction.

A previous effort sought to determine the extent of the OK adit and Union North adit (Armstrong and Barden 2019). A pipe inspection robot, trailing cables to allow video to be viewed outside the structure, was introduced into both adits. Progress of the device was hindered within the Union Reefs adit by rocky debris and standing water, so the extent of the adit could not be confirmed. Other inspection devices might prove to be more effective, and a further effort with an alternative device is one option for obtaining the required information.

Another solution is to have a person suitably experienced in underground work, and with appropriate training and equipment for confined space entry, enter the structures. This would result in the availability of more detailed information, but would be contingent on whether the investigator entering the structures judged them to be stable enough to allow a safe inspection of some or all of the tunnel lengths.

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If entry was indeed possible, within a relatively short period of time, this investigator will be able to confirm the length of the main adit, the presence of any further tunnels or shafts, and determine where Ghost Bats roost in the structure. An electronic laser distance measure and compass can be used to map the structures, and measure where the bat roosts occur.

In addition, and depending on the possibility of a safe entry, it could be very useful to monitor how the roost microclimate changes seasonally. The Ghost Bat is known to prefer warm, humid microclimates, especially where young are born and raised. Having an understanding of roost microclimates would be useful when interpreting changes in the level of usage of structures, and the number of individuals occupying the structure at particular times of the year. Depending on accessibility, dataloggers might be placed that continuously record values of temperature and relative humidity.

A vibration datalogger might also be introduced into the adits to record the level of ground movement that occurs during blasting. Very little information is available for underground structures that are used by animals on the levels of vibration associated with blasts. A datalogger placed in the Union North adit (plus the Lady Alice adit and new artificial roosts; see Actions 3 and 4) could be used to confirm that levels of vibration were not sufficient to cause the exodus of Ghost Bats. A datalogger placed in the OK adit could be used to validate the modelling work of Velasco (2019), which would provide comparative context for future similar studies.

The extent of the Lady Alice adit will also need to be determined (as far as this is possible given constraints on access) so that its suitability as a roost for the Ghost Bat can be confirmed. This information will also be used to plan for enhancements that may need to be made to make the structure more suitable (see Action 4).

The amount of information available from this Action will be dependent on how safe each underground structure is for human entry, or how accessible the structures are with remote- controlled inspection devices.

A report will be produced to document the results.

Acknowledged risks and limitations There is no cost to the Ghost Bat if entry is made when they are absent. The risk of entry to a roost is that Ghost Bats will abandon the structure when disturbed. However, this will be avoided by entering at night after bats have left to forage.

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 Action 3—Create several artificial habitats

Mitigation Hierarchy step: Mitigation/Minimisation.

Threat factor/s addressed: Roost habitat loss.

Knowledge gap addressed: The provision of artificial roost habitat is now considered more frequently as an option to manage Ghost Bats and other species of conservation significance, especially in the Pilbara region of Western Australia (Cramer et al. 2016). Several artificial roosts have been approved and some have been constructed, but there is very little information in the public sphere currently about how successful these have been in attracting and maintaining colonies of bats. Thus, this strategy is still essentially experimental. Creating several structures in the Union Reefs project area therefore provides the opportunity to test several factors that might be relevant for their success. This includes validating thermal models of their microclimates created by Computational Fluid Dynamics for different designs. It also provides the opportunity to determine whether Ghost Bats can be attracted to an artificial roost site based on broadcasts of their social calls.

Specific priorities addressed in the Conservation Advice by this Action: Establish new or artificial roost sites, and evaluate their success.

Applicable objectives of the Action Plan Objective 4. Encourage and protect the persistence of the Ghost Bat in the Union Reefs project area during the period of mining, and the period that the OK adit is temporarily closed to Ghost Bats.

Objective 5. Contribute to the long-term persistence of the Ghost Bat in the Union Reefs project area.

Benefits of the Action: Creating artificial habitats will provide several alternative possible roosts for when the OK adit is closed. Having more than one possible replacement for the OK adit within the Union Reefs area, as well as any that may exist further afield within the nightly flight range of the Ghost Bat, gives redundancy if Ghost Bats occupy more than one alternative. This strategy anticipates the possibility that a trigger will occur (e.g., factors that might cause Ghost Bat movement, and therefore periods of absence at the Union North adit; see details in Barden and Armstrong 2019), and enacts the contingency response before it is actually needed. If a trigger occurs, the contingency sites need to be available immediately.

Details of the Action With the temporary closure of the OK adit, the local occurrence of the Ghost Bat will have fewer opportunities for an alternative nearby roost if an unforeseen event causes them to vacate the Union North adit. This is important because bats are exposed to much a greater risk of mortality from raptors and ambient conditions if they are forced to leave their roost during the day, or are disturbed to a degree that induces them to seek an alternative (possibly sub- optimal) diurnal roost between sunset and sunrise the night following the disturbance. Habitat creation has been considered as a useful mitigative option (it does not meet the strictest definition of an environmental offset) in situations where the interests of mining coincide with

Page 15 of 39 An Action Plan for the management of Ghost Bats in the Union Reefs project area the location of a bat roost site. But habitat creation can also be used to increase the availability of roosts, rather than just maintain the number of roosting options of the species.

It would be ideal if, prior to the closure of the OK adit, several alternative diurnal roosts are available nearby, and also that Ghost Bats are already familiar with them and have been using them at least periodically. These can be thought of as ‘contingency roosts’ (see Glossary).

A contingency roost will be created by modifying the Lady Alice adit so that it is useful for Ghost Bat occupancy (see Action 4). There is currently no other disused underground mine within the Union Reefs project area that is known to, or likely to, support a colony of Ghost Bats. The construction of several artificial roosts will provide both contingency and redundancy for Ghost Bat roosting requirements within the Union Reefs project area.

Given that no guarantee can be given that Ghost Bats (and other species) will move into any newly-created artificial roost habitat, there are several ideas that will be incorporated to maximise the chance of success:

1. Build more than one artificial roost to provide redundancy in case one or more examples has shape or site-related characteristics that do not make it suitable for bat colonisation. There are large areas of tailings / mullock heaps in the Union Reefs project area, which are generally located away from mining-related activity, and are not subject to restrictions that control the clearing of native vegetation. They are also relatively accessible by existing vehicle tracks, which will allow heavy equipment to transport and emplace the units that will make up the structure. More than one site will be chosen in these areas for placement of an artificial roost.

2. Build relatively small structures so that it is cost-effective to have the redundancy of multiple structures. Natural caves used by Ghost Bats in some parts of their range are relatively deep and complex. Artificial structures will be modelled to some degree on known roosts elsewhere to ensure that an optimal roost microclimate can be retained. Rather than a long tunnel, the artificial sites might be ‘bent’ or ‘folded’ to save space, materials and earthmoving costs, and the structure can be inclined slightly to reduce atmospheric flushing of areas at the back where bats might roost. There are numerous shape options for commercially-available prefabricated concrete units (e.g. see https://www.holcim.com.au/humes ), and they are relatively cost effective. These will give several options for the shape of artificial roosts.

3. Encourage bats to roost in areas where optimal microclimate conditions are predicted to occur. If artificial structures are assembled from prefabricated blocks, there will be little opportunity for bats to hang from smooth vertical surfaces. Thus, objects (or perhaps spray-on concrete product) will be attached to the ceiling in various places to allow bats to hang.

4. Ensure that any structures that are designed and constructed are likely to be able to retain optimal roost microclimates. Ghost Bats need a warm, humid microclimate for roosting, and especially for birthing and raising young. The artificial structures will need to be shaped so that they retain high humidity and warm air, and not be subject to flushing from outside air movements that would remove these optimal interior microclimates. To

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confirm that these shapes should be able to retain warm, humid conditions, thermal modelling will be undertaken by an engineer with experience in Computational Fluid Dynamics (CFD), with advice provided by a bat biologist. The shape and extent of more than one example will be modelled with CFD, providing alternatives in case a particular design does not perform as expected.

5. Ensure that Ghost Bats are aware of the structures. If Ghost Bats do not often visit areas where the artificial roosts are placed while out foraging, then they might be attracted to them by broadcasting their social calls. ‘Acoustic lures’ have been used to increase the rate of capture success in several parts of the world, including Australia (Hill et al. 2015). Research submitted for publication (N. Hanrahan et al. manuscript in review) has also demonstrated that Ghost Bats respond to playback of their social calls. These calls are also relatively loud, and suitable for broadcasting. Thus, a small, inexpensive electronic device set to periodically broadcast examples of calls most likely to elicit a response by Ghost Bats will be placed and maintained at each artificial roost until the species is recorded entering them.

6. Prevent disturbance and entry of people to the structures. Ghost Bats are very sensitive to disturbance of their roosts, and the entry of people can cause abandonment. This is obviously undesirable when efforts are being made to attract bats to the structure. Thus, measures will be enforced to prevent casual visitation by non-essential personnel working on-site, and strict guidelines will be implemented for those conducting monitoring work at the structures. In addition, casual entry by any person will be discouraged by several measures including: 1. signs to provide information and safety cautions associated with the structure; 2. an entrance portal that is fully or partly open but situated at the top of a vertical face so that people cannot simply walk in; and 3. restricted access to vehicular tracks approaching the structures.

7. Monitor the conditions of the inside environment. Without feedback on whether microclimate and other aspects of the interior are suitable for Ghost Bats, it will be difficult to evaluate the success of the structures. The structure design will incorporate small vertical access points to allow the introduction of equipment into the roost areas. This equipment will include temperature and relative humidity dataloggers, a vibrational datalogger on a weight, and other devices relevant to making observations on bats.

8. Monitor the presence of bats inside the structure. Given the habit of several species of bat to visit structures at night, but not use them as diurnal roosts, it will be important to confirm diurnal roosting with a method other than the placement of recording equipment at the entrance to the structure. The equipment access point at an area where bats are likely to hang will allow video cameras to view whether bats are present, and bat detector microphones will allow continuous monitoring of presence. These video and acoustic recorders may also detect evidence of breeding if it occurs, given the close proximity to bats. The opportunity to observe Ghost Bats in the roost directly is relatively unique and could provide much information relevant to their management on a national scale.

A full proposal will be developed prior to undertaking this Action, which will contain the details of the designs, the results of thermal modelling and further details about attracting and monitoring bats in the structures. The success of the structures in attracting and retaining

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Ghost Bats will be reported on as part of the long-term monitoring effort that will take place (see Action 7).

Acknowledged risks and limitations There is no cost to the Ghost Bat with this Action. However, it is possible that: 1. the structures will not be used by Ghost Bats at all; or 2. if they are used, that a future disturbance at new artificial habitats might cause mortality. Critical aspects of the design, which is based on knowledge of the species roost requirements, as well as thermal modelling, maximise the chance that they are used by Ghost Bats.

The EIS describes how a ‘relocation’, whereby bats are captured and physically placed into an alternative roost site, is fraught with a range of undesirable factors. It is important to note that this species cannot be ‘forced’ into using certain structures, so the best strategy is to influence site usage by making some sites undesirable (with strong lighting at night; and then closing them off), and maximising the desirability of others through good design and enhancements based on a knowledge of Ghost Bat roost requirements. The various Actions in the present plan will together provide a relatively low impact approach to influencing and monitoring Ghost Bat usage of sites in the Union Reefs project area.

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 Action 4—Re-open and rehabilitate the Lady Alice adit

Mitigation Hierarchy step: Mitigation/Minimisation.

Threat factor/s addressed: Roost habitat loss.

Knowledge gap addressed: It is not known whether Ghost Bats will readily move from a suitable roost to another site nearby if the latter is modified to be more suitable. The effectiveness of certain enhancements in attracting Ghost Bats, and the validity of thermal microclimate modelling are both unknown but very relevant to strategies that provide Ghost Bats with alternative habitat when plans for development coincide with a known roost.

Specific priorities addressed in the Conservation Advice by this Action: Establish new roost sites and evaluate their success; Protect roost sites from disturbance; Modify roost sites to reduce risk of collapse.

Applicable objectives of the Action Plan Objective 4. Encourage and protect the persistence of the Ghost Bat in the Union Reefs project area during the period of mining, and the period that the OK adit is temporarily closed to Ghost Bats.

Objective 5. Contribute to the long-term persistence of the Ghost Bat in the Union Reefs project area.

Benefits of the Action: Opening and modifying the Lady Alice will provide a potential replacement for the OK adit after is closed. Having a possible replacement for the OK adit within the Union Reefs area might reduce the impact of the OK adit closure, especially if it is similar in structure, or even better for Ghost Bat roosting.

Details of the Action This small adit is 155 m east of the Union North entrance portal (referred to as “the adit at waypoint 118” in Armstrong and Barden 2018). It appears to be a straight horizontal tunnel of unknown length, but probably not much more than 30 metres (see drawing in Barden and Armstrong 2019). The entrance portal is partially occluded by earth, with the aperture only accessible to species such as the Orange Diamond-faced Bat Rhinonicteris aurantia, which was detected inside with a camera, and on a bat detector recording (Armstrong and Barden 2018). There is also a shaft entrance further up the slope that connects to the horizontal adit. Calls of the Ghost Bat were recorded at the entrance of the adit well after dusk, indicating nocturnal visitation, but the structure is currently unsuitable for roosting of Ghost Bats.

Together with the construction of artificial roosts (see Action 3), making the Lady Alice adit available to Ghost Bats following the closure of the OK adit will provide roost habitat replacement, contingency and redundancy in the Union Reefs project area, with possibly minimal effort.

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It is proposed to remove some of the earth obstructing the entrance to allow Ghost Bat entry, and seal the vertical shaft entrance at the ground surface to increase the humidity inside. Any augmentation of the Lady Alice adit is likely to maintain accessibility to other bat species.

The internal structure will also be checked to confirm its extent, if it is considered safe to do so (see Action 2).

The effect of the enhancements to the microclimate conditions can also be modelled using CFD, following the survey of the interior to obtain information about its dimensions, and the nature of the rock (for information on ‘boundary conditions’ needed to build the numerical models) (obtained during implementation of Action 2).

Equipment will be introduced, via an access point at the vertical shaft, to monitor the microclimate conditions of the interior, vibration from blasting, and the presence of bats (in a similar way to Action 3).

The site will be included in the long-term monitoring effort to document whether the enhancements have been successful in providing an additional roost for the species (see Action 7).

Acknowledged risks and limitations There is no cost to the Ghost Bat with this Action. However, it is possible that: 1. the structure will not be used by Ghost Bats at all; or 2. if it is used, that a future disturbance at the site might cause mortality. The effect of the enhancements on microclimate condition and stability will be modelled with CFD, and additional site measures incorporated if required. The site will be managed against the entry of people in the same way as the Union North adit and artificial structures.

Given that Ghost Bats are already aware of the site, and vibration and noise modelling predicted a similar level of minimal disturbance as with the Union North adit, it is suggested that augmentation and protection of the Lady Alice adit could provide a good alternative to the OK adit.

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 Action 5—Manage the Union North adit to exclude visitation from mining personnel

Mitigation Hierarchy step: Mitigation/Minimisation.

Threat factor/s addressed: Disturbance to roost sites, Disturbance to breeding sites.

Knowledge gap addressed: No specific knowledge gap.

Specific priorities addressed in the Conservation Advice by this Action: Protect land with significant colonies; Protect roosts from disturbance; Educate people not to disturb roost sites.

Applicable objectives of the Action Plan Objective 4. Encourage and protect the persistence of the Ghost Bat in the Union Reefs project area during the period of mining, and the period that the OK adit is temporarily closed to Ghost Bats.

Benefits of the Action: The Union North adit will remain undisturbed and a refuge for Ghost Bats. Without implementing certain protections for bats using the Union North adit, there is a possibility that mine personnel might enter the roost site, which would create a disturbance to the species, and possibly cause them to exit into daylight where they would be exposed to raptorial birds and unsuitable ambient conditions.

Details of the Action Once the OK adit has been closed, the colony of Ghost Bats in the Union Reefs area will become reliant on the Union North adit, as well as other sites, yet to be determined, nearby. Thus, it is imperative that no disturbance occurs at the Union North adit. A range of restrictions and education measures will be implemented and enforced as part of this Action, including:

1. Prohibition of vehicles and other machinery in the Union North pit, and above the extent of the underground structure (see Action 2).

2. Restriction of the use of heavy machinery within 135 m of the adit portal (consistent with the buffer zone established for the drilling programme; Armstrong and Barden 2019).

3. Adequate signage and blocking vehicular access, to guide personnel on the location of boundaries around important sites for bats.

4. Prohibition of mining and contractor personnel from approaching and entering the Union North adit, unless an approved activity under this Action Plan is being undertaken (e.g. placement/retrieval of acoustic and video monitoring equipment [Action 7]; entry to determine the extent of the structure and placement/retrieval of dataloggers [Action 2]).

5. Inclusion of information in safety and environment inductions about the presence and value of the Ghost Bats on-site, and the restrictions in place around the access of the

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Union North adit, and the other underground structures that might contain Ghost Bats at any time (OK adit, Lady Alice adit, artificial adits).

6. Specification that the prohibition by mining and contractor personnel of entry of adits and the disturbance of Ghost Bats extends to the Kohinoor adit at Pine Creek and underground structures at Spring Hill (should this tenement be acquired by KLG).

7. A reporting requirement, incorporated into the monitoring reports, for any breach of these conditions, which includes details of follow-up actions.

Acknowledged risks and limitations There is no cost to the Ghost Bat with this Action. The likelihood of any disturbance from mining personnel is very low given the typical high standards of safety and behaviour on Australian minesites. Enforcement can be aided by security cameras, if deemed necessary.

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 Action 6—Implement management and protection measures at the Pine Creek roost

Mitigation Hierarchy step: Mitigation/Minimisation.

Threat factor/s addressed: Disturbance to roost sites, Disturbance to breeding sites.

Knowledge gap addressed: No specific knowledge gaps have been identified at the Kohinoor adit, beyond how colony size might change in the future, and how it is connected to other colonies (see Action 10). However, this Action could generate an exemplar for an imaginative and collaborative strategy to conserve Ghost Bats, transforming an undesirable situation where previously there had been very little consideration given to the value of a colony of a vulnerable and declining species.

Specific priorities addressed in the Conservation Advice by this Action: Protect land with significant colonies; Protect roosts from disturbance; Educate people not to disturb roost sites.

Applicable objectives of the Action Plan Objective 6. Contribute to the long-term persistence of the Ghost Bat in the region by helping to protect stronghold colonies at Pine Creek and Spring Hill.

Benefits of the Action: Greater focus on protection of the colony in the Kohinoor adit will help to increase the security of the whole regional population. Without some level of effort to protect and manage stronghold colonies in the region, the colony at Union Reefs may have fewer options for dispersal to undisturbed sites. Concurrent disturbances at multiple roost sites within the Pilbara region has been identified as an issue previously (Armstrong 2010).

Details of the Action The largest known colony of Ghost Bats in Australia (and therefore globally) occurs within the Kohinoor adit on the outskirts of the town of Pine Creek. It is very likely that this site is within the nightly flight range of the Union Reefs project area, and genetic studies may support this (Action 10).

There is widespread knowledge of this site as ‘a place to see Ghost Bats’. Information about the location of the mine is available readily in books and on the internet. This actively encourages people to enter the mine to see the bats, which is entirely undesirable for reasons of safety, liability and the conservation of threatened bats. Local townspeople are also known to enter the mine regularly. Objects such as beer bottles and the remnants of fireworks have been discovered inside the structure in the past. Videos of the roost interior have also been posted on the internet by ‘wildlife tourists’.

Monitoring of the size of the Ghost Bat colony at Pine Creek has been undertaken by Nicola Hanrahan as part of a PhD study since November 2015. The study has found that colony size fluctuates between 300–800 individuals depending on the time of year, with peak numbers counted during the mating season and after the parturition (birthing) period. The study has confirmed that there is frequent human visitation to the colony.

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There is potential to completely turn around the situation at the Kohinoor adit—by transforming a very undesirable situation into one that enhances simultaneously both the conservation of threatened species and provides for other positive outcomes for people in the town. A strategy needs to be introduced to ensure that this colony achieves better protection, and is therefore maintained as a potential refuge for any Ghost Bats that may arrive from the Union Reefs project area.

Such a strategy may need to be developed further in consultation with key people in Pine Creek, but essential first steps include:

1. Reducing access to the ‘attraction’. Impediments to human visitation of the site will include the construction of a suitable fence further away from the entrance, signage warning of danger to entry of a collapsing structure, and natural screening to reduce the visibility of the adit portal from the road.

2. Liaising with the local Government to discuss ways that access to the colony can be reduced, that townspeople and visitors are effectively educated against visitation of the site, and also to discuss ways that proactive management at the site may actually contribute to the ‘well-being’ of the town. The inclusion of Traditional Owners in consultations will also be a valuable opportunity for collaboration.

3. The Kohinoor adit will be included in the long-term monitoring effort (see Action 7), which will involve the deployment of video and acoustic recorders at the entrance.

As part of Step 2 above, the idea of installing permanent, remotely-operated video cameras within the roost area of the adit (when bats are out foraging at night) could be discussed. Continuous video monitoring of individuals inside the roost would be of significant value for obtaining a better understanding of Ghost Bat numbers and behaviour in this roost. Importantly, it could also present an opportunity for public education, and a way to draw the attention of curious tourists away from the actual site if the video can be displayed elsewhere in the town (e.g. a tourist centre, a hotel and bar). If the curiosity of most people could be sated away from the roost, pressure at the site from undesirable visitation might reduce significantly, and a culture of local ownership and protection of the site be developed instead.

A precedent for such an installation can be seen in Naracoorte, South Australia, where permanent, remotely-operated videos can be used by the public in a visitor centre (https://www.naracoortecaves.sa.gov.au/Home ). This is a major and promoted attraction not only for the town of Naracoorte, but for tourism in South Australia. There is enormous potential for a similar operation to be established in Pine Creek, to the benefit of numerous stakeholders—local Pine Creek residents and business people, Traditional Owners and Aboriginal corporations, tourists, biological researchers, the mining proponent, and of course the Ghost Bats.

As a reportable outcome of Step 2 above, a report will be produced, which may be able to expand on the idea of a permanent video link to the roost, should discussions be favourable.

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Acknowledged risks and limitations Ghost Bats are still present in the Kohinoor adit despite a long history of disturbance. They are also still present despite recent disturbances at several workings within the Spring Hill area. Rather than suggesting that Ghost Bats are tolerant of regular roost intrusions, we may instead infer that these two sites are of high importance to the species because there are no structures nearby that provide similar habitat quality—so the species has an obligate reliance on them. There is a continuing risk that a random event will produce a catastrophic disturbance at the Kohinoor adit, and this risk can be reduced significantly by implementing this Action. The planned management actions will be installed with as little disturbance to colonies as possible, with all required entries taking place at night.

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 Action 7—Monitor the Ghost Bat at known local and regional roosts

Mitigation Hierarchy step: Mitigation/Minimisation.

Threat factor/s addressed: Disturbance to roost sites, Disturbance to breeding sites.

Knowledge gap addressed: Despite monitoring the presence, activity levels and colony size of the Ghost Bat at sites within the Union Reefs project area as part of monitoring associated with a drilling programme (Armstrong and Barden 2019), and longer term investigations at the Kohinoor adit by N. Hanrahan as part of a PhD study, understanding of Ghost Bat colony sizes and movements in the region is still relatively poor. In addition, there is a need to understand the responses of Ghost Bats to some of the planned Actions that will be implemented in response to plans for mining in the Union Reefs project area.

Specific priorities addressed in the Conservation Advice by this Action: Monitor populations at key sites and where impacts from mining are occurring or likely; Develop cost- effective monitoring protocols (e.g. thermal tracking software) at a set of standardised sites that contain most of the known population.

Applicable objectives of the Action Plan Objective 2. Provide confirmation that the Ghost Bat has continued suitable alternative diurnal roost habitat (contingency roosts) within the Union Reefs project area and further afield.

Objective 6. Contribute to the long-term persistence of the Ghost Bat in the region by helping to protect stronghold colonies at Pine Creek and Spring Hill.

Benefits of the Action: Information about presence and levels of usage at monitoring sites provides the basis for triggers and contingencies. Extending the current monitoring program at Union Reefs to the longer term and additional sites within and outside of the Union Reefs project area will provide information relevant for continuous assessment of whether mining- related activity might be affecting the presence, activity levels and colony size of Ghost Bats in the Union Reefs project area, and other sites in the region.

Details of the Action Various essential aspects of the monitoring effort are described below:

1. Continuous and broad-scale monitoring. Monitoring will take place at all relevant sites throughout the duration of the Union Reefs North Underground Project. This will include the OK adit (Action 1), Union North adit, newly created artificial roost sites (Action 3), Lady Alice adit (Action 4), the working containing Ghost Bats at Spring Hill, and the Kohinoor adit at Pine Creek plus any other natural caves in the hills surrounding the Union Reefs project area that may be discovered supporting a colony (Action 9).

2. Regularity of monitoring. A different amount of effort will be given to monitoring of different sites, based on their ease of access. A summary of how often recordings will be made and processed at the various study sites is provided in Table 1.

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Table 1. Planned monitoring and reporting frequency during the period of mining, and for six months after completion of mining in the Prospect Pit and re-opening of the OK adit.

Recording Reporting Location Recording frequency type frequency OK adit Acoustic Nightly for one week before Quarterly summary, exclusion annual report Nightly for one week after exclusion Thermal Nightly for one week before Quarterly summary, video exclusion annual report Nightly for one week after exclusion Union North adit Acoustic Nightly for duration of the ***Fortnightly program internal memorandum, Quarterly summary, annual report Thermal Two consecutive nights every two Quarterly summary, video weeks annual report Lady Alice adit / Acoustic Nightly for duration of the ***Fortnightly artificial roosts program internal memorandum, Quarterly summary, annual report Thermal Two consecutive nights every two Quarterly summary, video weeks annual report Kohinoor adit, Acoustic Nightly for duration of the Quarterly summary, Pine Creek program annual report Thermal Two consecutive nights every two Quarterly summary, video months, at minimum annual report Spring Hill mine Acoustic Nightly for duration of the Quarterly summary, program annual report Thermal Two consecutive nights every two Quarterly summary, video months, at minimum annual report Natural caves Acoustic Nightly for duration of the Quarterly summary, surrounding the program annual report Union Reefs project area (*as dependent on discovery; 1–2 of the largest/most active confirmed diurnal roosts) Thermal Two consecutive nights every two Quarterly summary, video months, at minimum annual report

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3. Use of the best available non-invasive technology. Ghost Bat presence, overall activity and colony size will be assessed through both acoustic and video recordings, both of which will not represent a disturbance to the colony. High quality acoustic recordings capable of providing detailed representations of Ghost Bat social calls will be made with Titley Scientific Anabat Swift bat detectors. Activity levels based on counts of social calls will be derived from these recordings using a semi-automated processing system (in the commercial software Kaleidoscope, via optimised settings developed by N. Hanrahan as part of a postgraduate research study). This approach has been undertaken to date in the monitoring effort conducted as part of the drilling programme (Barden and Armstrong 2019; Hanrahan et al. 2019). Activity levels provide information on both presence of the target species and the relative usage of a roost site, and a large acoustic dataset from a continuous recording effort is straightforward to analyse. Other species of bat present will also be represented in the recordings by their echolocation calls, and their presence/absence will also be reported.

4. The best indicator of usage comes from counts of colony size. Autonomous thermal video recorder systems will be deployed at adit entrances to capture at least the first three hours after sunset when most or all of the Ghost Bat colony emerging for nightly foraging. Ghost Bats can be distinguished from other species of bat by their large size even in thermal recordings. Recordings will be made at 30–60 frames per second to ensure that sufficient frames are available to capture the swiftly moving animals, and bat size can be calibrated against the size of the portal. The recordings will be processed by a semi-automated method (K.N. Armstrong unpublished) to clip out periods of non- activity, and the emergences will be identified and counted manually.

Video recordings have been used to derive counts of colony size in the present monitoring programme. A FLIR Tau 320 thermal camera connected to a generic miniature Digital Video Recorder (DVR) has been used on numerous occasions. This provides a recording that allows Ghost Bats to be distinguished from other bat species by their size. This equipment relies on investigators being present at dusk to switch the equipment on, and collect it when the recording is finished. A second system was developed during the programme, which relies on a Raspberry Pi 3B+ micro-computer connected to an infrared-capable video camera, and infrared spotlight light source. This system was designed to make an unattended collection of four hours of video during a standardised time period, as set by a scheduled start and stop time, and over 2–3 nights. This allows investigators to set the unit at any time of the day and return to collect it at minimum two days later. While development resolved some low-level technical issues, it is still to present as a reliable longer-term alternative to the Tau-DVR combination. A more reliable system has now been designed and built to replace it, which relies on the same micro-computer that is attached to a FLIR Boson 640 thermal camera. A reliable way of making thermal video recordings is critical to this Action, and experience with this technology may help other projects.

5. Sustained wider focus on context. The monitoring program will need information on surrounding colonies to determine whether activities outside the Union Reefs project area might be having an effect on the number of Ghost Bats within the project area. Both of the two known major colonies within 15 km of the Union North adit are on other mining leases and may be subject to the effects of activities not related to the current

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Proposal. The Pine Creek and Spring Hill colonies will also be monitored using acoustic and thermal video recorders, though on a less regular basis (Table 1).

6. Triggers. Two sets of separate, independent factors might cause Ghost Bat movement and therefore periods of absence at the Union North adit—natural factors, and mining- related activities. Being certain about which of the two has caused a period of absence is simply not possible, unless there is clear evidence of a major disturbance of the site, or a major change in the form of the underground tunnel structure (including major flooding). Baseline monitoring from long-term acoustic recordings has so far documented periods of at least 23 days of the absence of Ghost Bat calls at Union North adit (Barden and Armstrong 2019). Therefore, defining a trigger that is robust to false positives but sensitive to possible negative effects on Ghost Bats is a challenge. The following structure is suggested:

 Trigger Type 1. In the months that have had the highest documented activity of the Ghost Bat at the Union North adit (October, January, February), an absence of any calls over more than 7 days is to be considered a trigger.

 Trigger Type 2. In any other month, an absence of more than 30 days is to be considered a trigger.

7. Contingencies. The present Action Plan has already considered responses to the possibility that Ghost Bats cease using the Union North adit, if the implementation of Action 5 is not sufficient for maintaining their usage of the site. Rather than reactive actions in response to Trigger Types 1 and 2 above, provision has been made for dispersing individuals through Actions that require a longer period of preparation, and that are specifically designed to provide a contingency roost and redundancy (Actions 3 and 4). Other Actions describe efforts to determine whether contingencies already exist in the form of alternative roosts already known to the species, thereby providing reassurance that dispersing individuals might be reaching known, optimal roost sites if they vacate the Union North adit (Actions 6, 9 and 10). Monitoring via Action 7 may also provide reassurance that bats from the Union North adit have appeared at other sites. This might be more obvious at sites where smaller colonies are usual, such as cave sites.

However, in direct response to either of the two triggers, monitoring will be undertaken straight away at alternative sites to provide reassurance that Ghost Bats might have reached these other roosts.

Acknowledged risks and limitations There is no risk to the Ghost Bat with this Action, as the methods for monitoring are non- invasive.

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 Action 8—Provide a portion of the new mine for Ghost Bat occupancy

Mitigation Hierarchy step: Offset.

Threat factor/s addressed: Disturbance to roost sites, Disturbance to breeding sites.

Knowledge gap addressed: We know that Ghost Bats will colonise underground mines that have become derelict or otherwise disused, but the timeframe over which this happens is not well understood. This information, though a minor consideration in the current context, will contribute to any strategy that seeks to provide replacement habitat for the species.

Specific priorities addressed in the Conservation Advice by this Action: Establish new or artificial roost sites, and evaluate their success.

Applicable objectives of the Action Plan Objective 5. Contribute to the long-term persistence of the Ghost Bat in the Union Reefs project area.

Benefits of the Action: A new, additional major roost resource for Ghost Bats. The provision of a large, secure, stable underground structure for longer term use by Ghost Bats could be profound—resulting in a stable centre for the regional population that provides a better focus than the Kohinoor adit.

Details of the Action The underground mine planned for construction as part of the Union Reefs North Underground Project will be relatively deep, and include multiple horizontal tunnels running from a main decline (descending tunnel) that will corkscrew to a depth of around 500 m. If some of this structure, essentially parts that will remain above the water table, are available for the Union Reefs Ghost Bat colony after mining has finished, it could ensure the long-term persistence of the colony in the local area, and possibly in the region.

This Action, the provision of a portion of the new mine to function as a Ghost Bat after the completion of mining, will only be enacted if it is safe to do so. The portal must be able to be made safe from an Occupational Health and Safety perspective, which would include keeping mine waste below the water level in the main decline, and the removal of the risk of oxidation of pit walls and backfilled areas.

Assuming this Action is feasible, the donation of the new mine for Ghost Bat use meets the criterion of ‘like for like’ under an Environmental Offset. While it would not be provided until after mining ceases, the structure is likely to be more suitable for Ghost Bat roosting than the OK adit. Thus, the contribution will exceed the value of the original structure. Together with the relatively non-invasive set of strategies outlined in this Action Plan, not only will the residual effects of the closure of the OK adit be more than accounted for, the Union Reefs area could become a stronghold area for the species based on the quality of the habitat left following mining—artificial roosts, Lady Alice adit and the new mine all contributing to the survival of the Ghost Bat in the long term.

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Several aspects of the mine structure will need to be considered when giving it over to use by Ghost Bats. The stability of the upper portion (any part above the water table) that will be used by bats will need to be checked. If there are no stoped sections in the tunnel ceiling that could hold warm, humid microclimate conditions, then such an ‘aven’ could be created with machinery.

The entrance to the mine will need to be barricaded against entry by people. In addition to warning signs, earthworks could be undertaken to ensure that the portal was fronted by water, or at height above a vertical section of pit, to discourage casual entry. Gating may also be installed, but a gap large enough for Ghost Bats to navigate would need to be maintained above the gate. If the portal was above head height on a vertical wall, additional bars could discourage climbing.

This site would be included in the monitoring of Ghost Bats in the six months following the cessation of mining to demonstrate whether the species was still present in the Union Reefs project area (see Action 7).

Acknowledged risks and limitations There is unlikely to be any risk with giving over a mine to use by Ghost Bats if the design considerations above are met. The mine will be deep enough to maintain a suitable microclimate, and structurally stable in the long term. In addition, the entrance will be made secure against entry by people. The remoteness of the site from the nearest town will help to limit interest from tourists.

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 Action 9—Conduct field surveys for Ghost Bat diurnal roosts in natural caves

Mitigation Hierarchy step: Research to support Minimisation.

Threat factor/s addressed: Disturbance to roost sites; Disturbance to breeding sites.

Knowledge gap addressed: There is no information about whether the Ghost Bat uses caves in the hilly landscape that surrounds in the Union Reefs project area. If the Ghost Bat does use one or more caves, the size of the structure, the size of colonies, and the periods that they are occupied are all relevant to understanding the fluctuations in the size of the colony in the Union Reefs project area, and why this colony switches roosts on occasions.

Specific priorities addressed in the Conservation Advice by this Action: Additional surveys are required in remote parts of the Northern Territory; Assess population size and significance of all known subpopulations.

Applicable objectives of the Action Plan Objective 2. Provide confirmation that the Ghost Bat has continued suitable alternative diurnal roost habitat (contingency roosts) within the Union Reefs project area and further afield.

Benefits of the Action: Will generate information relevant to the exclusion of bats at the OK adit, as well as knowledge about the longer-term presence of the species in and around the Union Reefs project area. Without information on whether roosts in natural caves exist in the hills surrounding the Union Reefs project area, it can only be assumed that individual Ghost Bats will have alternative roosts close to the OK adit when the exclusion is implemented.

Details of the Action Knowledge of the presence of natural roost sites in caves in the hills surrounding the project area will provide further evidence that Ghost Bats have a nearby roost option (contingency roost) if an unforeseen event causes the exodus of Ghost Bats at the Union North adit during the period of mining. There are numerous mesa hills within a 15 km radius surrounding the Union Reefs project area that have not been searched for caves and Ghost Bat roost sites.

The various hill formations surrounding the Union Reefs project area can be examined in the first instance from freely-available satellite imagery and other coverages in a brief GIS study to prioritise areas for on-ground exploration. A targeted ‘ground truthing’ field survey will then be undertaken to check the bluff areas of mesa hills for Ghost Bat roosts. The survey will also consider the possibility of other areas where historical workings are present, and these will be examined and documented in a similar way to the survey of Barden and Armstrong (2018)

The presence of Ghost Bats will be established from scat material accumulations at the entrance of caves, and bat detector and video recordings made at cave entrances. Caves will not be entered initially, given the likelihood of having bats exit into daylight (daytime entry of Ghost Bat roosts has been identified as a threatening process).

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No caves will be entered until safety issues and the perspectives of Traditional Owners have been considered and permission granted from the landowners. Cave entry will only to be undertaken at night after bats have exited, and only if deemed necessary. Most of the pertinent information should be evident on video and acoustic recordings, including presence and colony size.

If Ghost Bats do disappear from the Union North adit (for more than one week), greater attention will be given to determining whether Ghost Bats are present in natural caves (‘contingency roosts’) in the hilly areas surrounding the Union Reefs project area. Regular monitoring will be expanded to determine whether Ghost Bats are present at any roosts discovered in the nearby hills.

Ghost Bats are known to enter large steel culverts beneath roads and railways at night to rest and consume captured prey (e.g., Armstrong and Barden 2018). Culverts may also be used on occasions as diurnal roosts. Studies of Ghost Bat habitat usage can be extended to the examination of these feeding sites, which might assist with understanding foraging range and roost site connectedness. Extending the roost site exploration to include an examination of railway culverts further afield from the Union Reefs area could highlight the importance of culverts for Ghost Bat dispersal on a larger scale, and provide evidence of the connectedness of Ghost Bats within the central part of the Top End. Culverts would be examined in the late Dry season, noting presence of scats, prey remains, size, type and location of culverts.

Selected caves used by Ghost Bats will be monitored periodically and non-invasively during the time of closure of the OK adit, but with longer monitoring intervals than Union North, and depending on the ease of access to their location. An assessment of their inclusion into the monitoring programme can be made following their discovery.

A separate report will be produced to document the results of this survey. The results of any follow-up monitoring will be included in reports summarising the results of monitoring efforts (see Action 7).

Acknowledged risks and limitations If cave entry is not undertaken, there is no cost to the Ghost Bat. There is a risk that Ghost Bats may fly into daylight if investigators enter caves. Thus, cave entry will not be conducted. All detections will be made remotely to remove the possibility of disturbance to Ghost Bats in their roost.

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 Action 10—Investigate the connectedness of Ghost Bat colonies in the region

Mitigation Hierarchy step: Research to support Minimisation.

Threat factor/s addressed: Disturbance to roost sites; Disturbance to breeding sites.

Knowledge gaps addressed: Several colonies are known from the region, and the size of the colony occupying either the Union North adit or OK adit has been observed to vary in the past 12 months (Barden and Armstrong 2019; Hanrahan et al. 2019). It is not known whether bats in these two adits move regularly to caves (as yet unknown) in the hills surrounding the Union Reefs project area, and further afield to stronghold colonies at Pine Creek and Spring Hill.

Specific priorities addressed in the Conservation Advice by this Action: Assess population size and significance of all known subpopulations [note: the genetic study helps to define what are populations; see Glossary; note that the concept of a ‘subpopulation’ is not useful in the present context, at least until larger scale genetic studies are completed].

Applicable objectives of the Action Plan Objective 3. Confirm if Ghost Bats can maintain connectedness amongst colonies in the population, thus demonstrating the capacity for Ghost Bats to move from the Union Reefs project area to other colonies, including stronghold colonies.

Benefits of the Action: Confirmation that bats can move readily amongst the known colonies in the region, providing reassurance that the closure of the OK adit will simply prompt individuals to seek other roost sites within their nightly flight range. Without a genetic study, connections among colonies within the region, especially between the Union Reefs colony and those at Pine Creek and Spring Hill, can only be assumed.

Details of the Action Previous efforts applying genetic markers to samples of Ghost Bats showed structuring of their northern range into disconnected geographical regions (Worthington Wilmer et al. 1994, 1999). Further work with modern techniques has since shown structuring within some regions (K.N. Armstrong unpublished data; N. Hanrahan unpublished data). An advanced genetic study method can be used to show that Ghost Bats move amongst roosts in the Daly Basin and Pine Creek IBRA bioregions (though at minimum among the Pine Creek, Spring Hill, and the Union Reefs areas), and thus are part of the same population.

In performing this study, the level of genetic similarity of individuals from different colonies will be used to determine whether gene flow occurs amongst these sites, which will infer the movement of individuals and the level of connectedness among major known colonies within the region. This type of study gives information at the level of both individuals and the population, and over time-scales that extend from a few generations to much longer. By contrast, intensive studies focused on individuals, such as by radiotracking or genetics-based identification of individuals from scat material, will provide a much narrower understanding of movements.

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The method, a genome-scale high-throughput DNA sequencing method called ‘DArTseq’ (Diversity Arrays, Canberra; https://www.diversityarrays.com/ ), will be used to confirm that colonies of bats are part of the same gene pool, thus confirming contemporary movement among regional colonies. The method provides information about not only population connectedness, but relatedness of individuals and indices relevant to conservation such as genetic diversity and inbreeding coefficients. The priority will be to establish if bats in the Union Reefs project area and surrounding hills are part of the same gene pool as the bats at Pine Creek and Spring Hill.

Usually such a genetic study requires the collection of samples from outside small focal areas of interest to help establish the extent of gene pools and population connectedness. This comparative framework is already available from prior studies across northern Australia conducted by Nicola Hanrahan and Kyle Armstrong, and the data will be made available.

The generation of markers is relatively cost effective per sample, but there is a requirement to use fresh tissue for this. Thus, Ghost Bats will need to be captured so that a non-lethal biopsy skin plug can be sampled from the wing membrane (a standard technique globally for bat studies; the hole closes within 4 weeks; Worthington Wilmer and Barratt 1996; Armstrong 2006; Faure et al. 2009; Weaver et al. 2009). Ideally, capture will be made away from the roost, but nearby, using an acoustic lure next to a harp trap and mist net arrangement. This strategy is based on observations made in the PhD research programme conducted by Nicola Hanrahan that Ghost Bats respond to broadcast playback of their social calls.

A separate report will be produced that details the results of the field and analytical components of the study, and makes conclusions about the connectedness of the known colonies in the region.

Acknowledged risks and limitations A relatively low level of disturbance will be required to Ghost Bats near several known roost sites. This study will require capture of bats, and relevant permits. If this is done at a roost entrance, there is a significant risk that Ghost Bats will vacate the structure, and move to suboptimal sites. The difference between this situation and the proposed exclusion at the OK adit is that the latter will be timed for periods when the Ghost Bat is not present. Capture will therefore be made away from the entrance, so that Ghost Bats do not associate the roost site with the disturbance.

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 Action 11—Provide support for further academic research on the Ghost Bat

Mitigation Hierarchy step: Research to support overall management. Not part of the Mitigation Hierarchy.

Threat factor/s addressed: Relevant to most threat factors listed in TSSC (2016).

Knowledge gaps addressed: A more comprehensive and contemporary understanding of distribution in the region; current size of various colonies and overall population; a deeper understanding of the movements of individuals; better knowledge of the timing of breeding and the bioacoustic characteristics of each stage; other information generated as determined by the researcher.

Specific priorities addressed in the Conservation Advice by this Action: Relevant to most specific actions and priorities listed in TSSC (2016).

Applicable objectives of the Action Plan Objective 7. Seek further understanding of the Ghost Bat distribution, numbers and movements in the region to inform their conservation and management.

Benefits of the Action: A more informed basis for recommending strategies for the conservation and management of Ghost Bats, and better information on the distribution of the regional population. A better overall understanding of Ghost Bat ecology that can be applied to environmental impact assessment and conservation and management strategies.

Details of the Action KLG will support a multi-year postdoctoral position at Charles Darwin University for a researcher to undertake studies on the biology of the Ghost Bat in the Northern Territory, and specifically in the region. Priority will be given to basic research that assists with the management and conservation of the species. The knowledge gaps listed above will be a core focus.

There are many possible themes for the study of Ghost Bats, given how little is known about many aspects of their biology. The Actions in the present document have been devised carefully to provide minimally-sufficient information to achieve the seven objectives of the Action Plan, while simultaneously minimising the invasiveness of the various investigations themselves. Additional efforts to provide further corroborating observations about regional movements are unlikely to change the strategy for managing the colony of Ghost Bats in the Union Reefs project area. By extending the scope of studies beyond the need to maintain the presence of Ghost Bats in the Union Reefs project area, efforts to conserve the species can be more broad-scale in nature, extending to other parts of the region, the Northern Territory, and nationally. However, it will still be relevant to prioritise knowledge gaps and the allocation of available resources so that disturbance from biological studies is minimised and only introduced by an investigator when there is a clear benefit to the species.

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Acknowledged risks and limitations This Action will cause potentially some level of disturbance to Ghost Bats at or near several known roost sites. Some of the techniques might require capture of individuals or entry of roost sites, potentially causing disturbance and disruption to normal patterns of behaviour. The use of various techniques will need to be rationalised against the value of the information gained. Ultimately, it will be the responsibility of the researcher to evaluate, prioritise, and seek approval for methods they consider to be relevant and worth the cost of disturbance to this species.

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References

Armstrong, K.N. (2006). Phylogeographic structure in Rhinonicteris aurantia (Chiroptera: Hipposideridae): implications for conservation. Acta Chiropterologica 8: 63–81.

Armstrong, K.N. (2010). Assessing the short-term effect of minerals exploration drilling on colonies of bats of conservation significance: a case study near Marble Bar, Western Australia. Journal of the Royal Society of Western Australia 93: 165–174.

Armstrong, K. and Barden, P. (2018). Targeted Survey for the Ghost Bat Macroderma gigas in the Union Reefs Project Area, Northern Territory. Unpublished report by Ecological Management Services Pty Ltd and Specialised Zoological to Kirkland Lake Gold Ltd, 5 October 2018.

Armstrong, K. and Barden, P. (2019). Ghost bat Macroderma gigas monitoring for the Union Reefs Exploration Drilling Program 2018 – 2019. Unpublished report by Ecological Management Services Pty Ltd and Specialised Zoological to Kirkland Lake Gold Ltd, Version R3, 3 February 2019.

Armstrong, K., Barden, P. and Hanrahan, N. (2019). An Action Plan for the management of Ghost Bats in the Union Reefs project area. Unpublished document by Specialised Zoological, Ecological Management Services Pty Ltd and Nicola Hanrahan Consulting Services to Kirkland Lake Gold Ltd, 4 June 2019.

Barden, P. and Armstrong, K. (2019). Union Reefs North Underground Project. Environmental Impact Assessment. Ghost Bat Technical Report. October 2019. Unpublished document by Ecological Management Services Pty Ltd and Specialised Zoological to Kirkland Lake Gold Ltd, Final (Revision 3): 14 November 2019.

Cramer V., Armstrong K.N., Bullen R., Ellis R., Gibson L., McKenzie N., O'Connell M., Spate A., van Leeuwen S. (2016). Research priorities for the Pilbara leaf-nosed bat (Rhinonicteris aurantia Pilbara form). Australian Mammalogy. http://dx.doi.org/10.1071/AM15012

Faure, P.A., Re, D.E. and Clare, E.L. (2009). Wound healing in the flight membranes of big brown bats. Journal of Mammalogy 90: 1148–1156.

Hanrahan, N. Armstrong, K. and Barden, P. (2019). Union Reefs Exploration Drilling Program Ghost bat Macroderma gigas Monitoring: Interim Report October 2018 – February 2019. Unpublished report by Ecological Management Services Pty Ltd and Specialised Zoological to Kirkland Lake Gold Ltd, R1: 5 April 2019.

Hill, D.A. Armstrong, K.N. and Barden, P.A. (2015). Preliminary assessment suggests that acoustic lures can increase capture rates of Australian echolocating bats. Australian Mammalogy 37: 104–106.

NSR Environmental Consultants (1993). Draft environmental impact statement main report. Union reefs Project. Unpublished report by NSR Environmental Consultants Pty Ltd foe The Shell Company of Australian Ltd, CR 697/7, September 1993.

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Velasco, M. (2019 in litt.). Kirkland Lake Gold EIS. Blasting noise and vibration modelling - ghost bats. Letter report by GHD Pty Ltd to Kirkland Lake Gold Ltd, 8 October 2019, Ref 12512776-47251.

Weaver, K.N., Alfano, S.E., Kronquist, A.R. and Reeder, D.M. (2009). Healing rates of wing punch wounds in free-ranging little brown myotis (Myotis lucifugus). Acta Chiropterologica 11: 220–223.

White, D.A., Shields, J.W. and Ivanac, J.F. (1965). The geology of the gold prospects at Union Reefs, Northern Territory. Department of National Development, Bureau of Mineral Resources, Geology and Geophysics, Commonwealth of Australia. Records: 1965/201. Available at URL: https://d28rz98at9flks.cloudfront.net/11654/Rec1965_201.pdf

Worthington Wilmer, J., Moritz, C., Hall, L. and Toop, J. (1994). Extreme population structuring in the threatened ghost bat, Macroderma gigas: evidence from mitochondrial DNA. Proceedings of the Royal Society of London B Biological Sciences 257: 193–198.

Worthington Wilmer, J. and Barratt, E. (1996). A non-lethal method of tissue sampling for genetic studies of chiropterans. Bat Research News 37(1): 1–3.

Worthington Wilmer, J., Hall, L., Barratt, E. and Moritz, C. (1999). Genetic structure and male- mediated gene flow in the Ghost Bat (Macroderma gigas). Evolution 53: 1582–1591.

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APPENDIX 3 PROJECT PERSONNEL AND CONSULTATION

Person Organisation Role Qualifications Experience EIS and Union Reefs Monitoring Project (Ghost Bats) Dr Kyle Specialised Baseline ghost bat surveys UR 2018 – 2019 PhD A research and consultant Zoologist with a specialty interest in bats, authoring 55 research Armstrong Zoological Impact assessment report and MNES papers and book contributions and over 550 consultative reports, as well as SPRAT profiles, Design of monitoring protocols (acoustic) Conservation Advice documents and an update of the 'Survey guidelines for Australia's Design of monitoring and impact mitigation Threatened bats' for the Commonwealth Government, and dozens of species reassessments for ghost bats at UR for the IUCN. Completed a PhD on the Pilbara Leaf‐nosed Bat and Ghost Bat in northern Australia and continues to undertake genetic research on bats in Indo‐Australasia.

Paul Barden Ecological Author Ghost Bat Management Plan Union Bachelor of 23 years conducting impact assessment, bat surveys and acoustic identification of bats in the Management Reefs 2019 Baseline ghost bat surveys UR Environmental Science Top End of the Northern Territory, including preparation of impact assessment, Services 2018 – 2019 MSc Environmental management and mitigation measures for threatened cave roosting bats. Long term survey Impact assessment report and MNES Management experience and assessment of bats (including ghost bats) in the Batchelor/Litchfield, Pine Regional review of ghost bat population Creek and Katherine regions. Design of monitoring protocols (acoustic) Experience in the design of monitoring and survey protocols for cave roosting species, Design of monitoring and impact mitigation including ghost bats. for ghost bats at UR

Union Reefs Monitoring Project (Ghost Bats) Nicola Nicola Baseline ghost bat surveys Union Reefs BSc (hons) in Zoology Seven years’ experience as an environmental consultant conducting flora and fauna baseline Hanrahan Hanrahan 2018 – 2019 University College surveys, targeted threatened species surveys and rehabilitation assessments. Specialised in Consulting Design of monitoring protocols (acoustic Dublin. PhD candidate bat acoustic analysis with specific expertise in ghost bat vocalisations. and thermal video) Western Sydney Identification of bat calls and thermal video University Ghost bat (monitoring program) Acoustic Ecology (current)

Appendix 3.1 Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

Person Organisation Role Qualifications Experience Emer KLG Environment Officer BSc Zoology Ghost bat monitoring project, Union Reefs 2018 – 2019 McGowan Ghost Bat Project Officer Second Class Honors Wildlife Sense Turtle Conservation – Field Researcher Site monitoring of ghost bats (thermal National University of Data sampling techniques – National Research Tomsk State University video and acoustic) 2018 – 2019, including Ireland Galway Animal Behavior and Welfare – University of Edinburgh equipment maintenance and data collection

External Experts Dr Bruce Ecology by Expert Peer Review of Impact Assessment Batchelor of Applied 35 years of experience extending across a broad range of conservation, environmental Thompson Design Technical Report and Ghost Bat Science assessment and conservation management. He has specific expertise in the survey, Management Plan PhD identification and conservation management of Australian bats. He has worked on ‘bats and mines’ related projects since 1995.

Sue Independent Input on historical distribution of ghost MSc Surveys of ghost bats in the Northern Territory and northern Australia Churchill Researcher bats in the Pine Creek region, recent survey Research on cave roosting microbats in northern Australia data for Kohinoor and Cutta Cutta Regional surveys of ghost bats in the Pine Creek, Katherine, Litchfield and Kakadu regions, late 1980’s Author Australian Bats (Field guide to Australian Bats)

Government Agencies Northern NT EPA Guidance on impact assessment matters Set TOR for the UR project EIS Territory for ghost bats at Union Reefs EPA Terms of Reference for Impact Assessment

Flora and Northern Discussions relating to monitoring and Key point of contact for the NT Government for bat related threatened species and Fauna Territory impact assessment of ghost bats at the conservation matters Division, Government Union Reefs project area, 2018 – 2019 Department DENR Provided historical CCNT ghost bat data for of the Pine Creek region Environment and Natural Resources

Appendix 3.2 Union Reefs EIS Ghost Bat Technical Report: November 2019 Final (R4): 22 November 2019

APPENDIX 4

Expert Peer Review Correspondence – Dr. Bruce Thompson

Appendix 4.1

Mr Paul Barden

Ecological Management Services

PO Box 580

Coolum Beach, Qld 4573

Dear Mr Barden,

Review of Ghost Bat Management Proposal – Union Reefs North Underground Project

I have read both the Technical Report and Management Plan prepared by EMS, Specialised Zoological (and Nicola Hanrahan Consulting Services for the Management Plan) and would agree that significant impacts as a result of the project are highly unlikely. I believe that this is an excellent outcome for the conservation of Ghost Bats in this critical area of their distribution.

I am fully supportive of the actions proposed and the supporting information. The summary data provided are quite comprehensive and management proposals are realistic and achievable. Like almost all bat species, we have only a basic understanding of ecology, and I think that the plan identifies this issue and provides some excellent contingencies to manage any uncertainties.

Yours Sincerely,

Dr Bruce Thomson