Oakajee Terrestrial Port Development

OAKAJEE TERRESTRIAL PORT DEVELOPMENT

REVISION 1

PUBLIC ENVIRONMENTAL REVIEW ASSESSMENT NO. 1817

SUMMARY OF PUBLIC SUBMISSIONS & MATTERS TO BE ADDRESSED

This document forms a summary of public submissions regarding the Public Environmental Review.

The public submission period for the proposal commenced on 2 August 2010 for a period of four weeks, ending 30 August 2010.

The principal issues raised in the submissions included environmental, social and planning issues. Other issues focussed on questions of fact and technical aspects of the proposal. Although not all of the issues raised in the submissions are environmental, the proponent is asked to address all issues, comments and questions, as they are relevant to the proposal.

A total of 12 submissions were received.

TERRESTRIAL PORT PER

No. Submitter 1 Shire of Chapman Valley 2 Department of Indigenous Affairs 3 Asmussen Family Trust Drummond Cove Progress 4 Association 5 Public Submission DEC Environmental 6 Management Branch 7 Main Roads WA 8 DEC Noise Regulation Branch 9 Department of Water 10 Department of Planning 11 Department of Health DEC Air Quality Management 12 Branch

1 Table of Contents

1. Vegetation & flora ...... 4 1.1 Impacts to restricted communities/associations ...... 4 1.2 Priority species ...... 18 1.3 Access roads ...... 22 1.4 Weed management ...... 24 1.5 Impact footprint & monitoring ...... 24 1.6 Revegetation ...... 28 2. Offsets ...... 29 3. Marine Environment ...... 40 3.1 Coastal Processes ...... 40 3.2 Benthic Habitat ...... 41 3.3 Monitoring ...... 41 3.4 Water Quality ...... 43 3.5 Groundwater impacts to heritage values ...... 43 3.6 Desalination plant ...... 46 3.7 Water Availability ...... 46 4. Dust and Air Quality ...... 47 4.1 Dust management - community ...... 47 4.2 Dust management – Industrial Estate ...... 53 4.3 Dust management – construction ...... 53 4.4 Dust management – operational ...... 54 4.5 Dust management – general ...... 55 5. Noise ...... 56 5.1 Noise - operational ...... 56 6. Waste Management ...... 60 6.1 Contamination ...... 60 6.2 Wastewater ...... 61 7. Safety and Risk ...... 62 7.1 Southern Access Roads ...... 62 7.2 Traffic management & interface requirements ...... 62 7.3 Fire Management ...... 63 7.4 Pesticide Safety ...... 64 7.5 Mosquito-borne disease control ...... 65 8. Social Values ...... 66 8.1 Impacts to Recreational Access & Activities ...... 66 8.2 Visual Amenity ...... 67 8.3 Aboriginal & social heritage ...... 70 8.4 Complaints register ...... 73 8.5 Jobs ...... 73 9. Power generation ...... 74 9.1 Renewable energy ...... 74 9.2 Selection ...... 75 10. Perceived omissions & errors of fact ...... 75 10.1 Flora & Fauna ...... 75 10.2 Visual Amenity ...... 78 10.3 Social values ...... 79 10.4 Cumulative Impacts ...... 80 11. References ...... 82

Tables

Table 1 – Currently known Juncus kraussii closed sedgeland locations (Ecologia, 2010a & b) ...... 5 Table 2 – Study Area impacts to vegetation sub-association 2 mapped by Ecologia (2010a) ...... 5 Table 3 - WA Herbarium records or Ficinia nodosa or Juncus kraussii in potentially similar vegetation units to sub-association 2 ...... 8 Table 4 – Impact to Vegetation Sub-Association 8 ...... 12 Table 5 - WA Herbarium records of Borya sphaerocephala in potentially similar vegetation units to sub-association 8 (Ecologia, 2010a) in the vicinity of the Oakajee Port Study Area ...... 14 Table 6 – Impact to Priority Flora ...... 19 Table 7 – Impact to Conservation Values – Priority 1 Flora (Melaleuca huttensis) .... 31 Table 8 – Impact to Conservation Values – Coastal Vegetation ...... 33 Table 9 – Impact to Conservation Values – Moresby Range and Coastal Dune Linkages ...... 37 Table 10 – Predicted pollutant concentrations compared to assessment criteria ...... 74

Figures

Figure 1 Potential Juncus kraussii locations to the south of the Port Terrestrial Study Area (Ecologia 2010, unpublished) ...... 7 Figure 2 Potential Grevillea – melaleuca (vegetation sub-association 8) locations in proximity to the Port Study Area ...... 13 Figure 3 Melaleuca huttensis locations within the Port Study Area and Revised Proposal Footprint ...... 21 Figure 4 Location of Dust Generation Sources and Receptors Modelled (Figure 7.5 within the Port Terrestrial Proposal) ...... 49 Figure 5 Predicted Maximum 24-hr PM10 Ground Level Concentrations (µg/m3) for Oakajee Port (Figure 7.6 within the Port Terrestrial Proposal) ...... 50 Figure 6 Predicted Maximum 24-hr TSP Ground Level Concentrations (µg/m3) for Oakajee Port (Figure 7.7 within the Port Terrestrial Proposal) ...... 51 Figure 7 Predicted Maximum Monthly Deposition Levels (g/m3) for Oakajee Port (Figure 7.8 within the Port Terrestrial Proposal) ...... 52 Figure 8 Oakajee Deepwater Port and Terrestrial Iron Ore Facility Predicted Noise Levels Assuming All Plant Operating - Wind from All Directions ...... 58 Figure 9 White Peak and Park Fall Estates ...... 69 Figure 10 Drummond Homestead ...... 72

3 1. Vegetation & flora

1.1 Impacts to restricted communities/associations

Issue 1: Submitter Submission and/or issue PER (sub #) modified DEC – Submitter is concerned that the vegetation sub- No Environmental association 2 is situated alongside the proposed land Management based dredge disposal area and the substantial iron Branch (6) ore stockyard, and is therefore likely to be subject to indirect impacts.

Submitter has requested the opportunity to review supplementary information in the context of determining the conservation significance of vegetation sub-association 2 and the significance of the impacts proposed on this community.

Vegetation sub-association 2 (Ecologia, 2010a) is situated alongside and down- gradient of the proposed land based dredge disposal area and the substantial iron ore stockyard. This area of vegetation is likely to be subject to indirect impacts from the location of this infrastructure. It is possible that most, if not all of the area of vegetation sub-association 2 (Ecologia, 2010a) in the Proposal area will be impacted. Based on current data, this will reduce the known extent of this sub-association within the Bioregion by approximately 44%. Oakajee Port and Rail Pty Ltd (OPR) believes that this vegetation sub-association occurs beyond the boundaries of the Proposal, as discussed in more detail below (refer to Section 7.2.3.1 Sub- Association 2 – Juncus kraussii closed sedgeland within the Port Terrestrial PER). Nevertheless, OPR has commissioned a field survey, to verify additional locations of vegetation sub-association 2, which will occur in the coming weeks and will assist in the development of management strategies to ensure the vegetation sub-association 2 (Ecologia, 2010a) is managed appropriately.

Issue 2: Submitter Submission and/or issue PER (sub #) modified Department of Given the restricted nature of vegetation sub- No Planning (10) associations 2 & 8, and limited knowledge of their regional extent, it is recommended that further consideration be given to their retention within the proposal area.

Vegetation Sub-Association 2 As outlined previously, vegetation sub-association 2 is situated alongside and down- gradient of the proposed land based dredge disposal area and the substantial iron ore stockyard. This area of vegetation is likely to be subject to indirect impacts from the location of this infrastructure, primarily due to localised changes in surface and shallow groundwater hydrology arising from the water draining and infiltrating away from the dredge disposal area. For the purpose of impact assessment, OPR has

4 anticipated that most, if not all, of the sub-association in proximity to the Proposal infrastructure could be lost. OPR is investigating practicable measures to manage this issue but cannot be certain that it will be able to prevent indirect changes in vegetation down-gradient of the dredge disposal area. This vegetation unit corresponds to that described within the Geraldton Regional Flora and Vegetation Survey (GRFVS) as Community 4: Swale: Ficinia nodosa. Further examination of the area has established that a small portion is dominated by Ficinia nodosa and the majority of this community is dominated by Juncus kraussii. Ecologia conducted an additional and broader survey in March 2010 which confirmed that vegetation sub-association 2 was likely to occur further afield, specifically at least in two additional locations in proximity to Port Gregory, approximately 60 km north of the Study Area and the northern boundary of the GRFVS area (Figure 7.3, Table 7.3 and 7.4 within the Port Terrestrial Public Environmental Review (PER)). Table 7-3 and 7-4 as outlined within the Port Terrestrial PER are depicted as Table 1 and 2 in this Response to Submissions document, respectively. Table 1 outlines the current known Juncus kraussii locations within proximity of the Proposal, whilst Table 2 is a summary of Table 7-4 as outlined within the Port Terrestrial PER, which identifies the study area impacts to vegetation sub-association 2. Table 1 – Currently known Juncus kraussii closed sedgeland locations (Ecologia, 2010a & b)

Site Identification Area (ha) % of known extent (refer to Figure 5.12) SW1 (Proposal Area) 0.964 44.3 SW2 (north of Port Gregory) 0.933 42.9 SW3 (north of Port Gregory within Utcha 0.280 12.9 Well Nature Reserve)

Table 2 – Study Area impacts to vegetation sub-association 2 mapped by Ecologia (2010a)

Area Proposed Disturbance within % impacted Vegetation Sub-Associations (Ecologia, 2010a) Area Study within Study 1 (ha) Area (ha) Area 2. Juncus kraussii closed sedgeland on swale 2.21 0.961 44.31 1 For sub-association 2 Juncus kraussii, a revised Study Area extent and additional areas identified by Ecologia (2010b) surveys to the north of Port Gregory, have been included within the total areas and impact calculations, see more detailed discussion above and Appendix C of the Port Terrestrial PER (Ecologia 2010b). Otherwise, the known extent is based on data from the Study Area (Ecologia, 2010a).

The March 2010 survey was not exhaustive due to private land access constraints and it remains highly probable that additional locations occur within the Geraldton Sandplains Bioregion because of the occurrence of the areas that are similar in topography, soils and coastal proximity to that in which this sub-association has been found. An examination of high resolution aerial imagery of the area surrounding the Study Area was recently conducted for the purpose of locating further potential populations. However, it is difficult to detect this community within available imagery as it tends to occur in very small, narrow areas within the swales of dunes and is not highly coloured or have a distinct appearance from surrounding vegetation. Notwithstanding this limitation, several additional potential locations have been identified to the south of the Study Area, which will require inspection to confirm species composition (as depicted in Figure 1).

5 The regional significance of vegetation sub-association 2 is not clearly established. The lack of mapping regionally is likely to be at least partially attributable to the very small scale at which it occurs rather than its rarity (Ecologia, 2010b). Surveys of areas containing this community type which did not directly sample locations at which it occurs may incorporate those areas into broader community types. An examination of Western Australian Herbarium records for Ficinia nodosa and Juncus kraussii indicates that a subset of the lodged specimens for this species occur across a broad range of habitats that are very similar to that presented within the Study Area (seasonally damp areas in the swales of coastal dunes) with a similar suite of associated specimens (Table 3). In many instances there is insufficient detail within the voucher notes regarding associated species and vegetation structure to establish how closely the vegetation at these locations correlates to that present within the Port Study Area; however it does demonstrate that these species have an extremely large range and that they do occur in similar landforms to those identified at Oakajee. Given that neither Ficinia nodosa nor Juncus kraussii are Priority taxa, specimens would not be mandatorily lodged with the Herbarium for all surveys in which they were collected. Hence the vouchered specimens are likely to underestimate the likely distribution of these two species within this or any other community type.

The widespread nature of these species (J. kraussii and F. nodosa) and, what appears to be a common occurrence within coastal swale systems suggests that this sub-association is highly likely to be commonly found at other locations to the north and south of the Proposal area. On this basis, OPR is of the view that this vegetation sub-association is not restricted and is therefore unlikely to be of conservation significance. Notwithstanding this, OPR has commissioned further aerial photo review and supporting field inspections, to verify additional locations of the community, which will occur in mid to late October 2010. The study results will further assist OPR in developing an appropriate management strategy for vegetation sub-association 2.

6 !(

!( !( Legend !( !( Potential swale locations !( Oakajee Study Area !( Confirmed area of Sub-community 2 K !( 0 2 4

Kilometres Absolute Scale - 1:250,000

Potential Juncus kraussii Figure: 1 Drawn: CM Project ID: 1288 Date: 12/10/10 (vegetation sub-community 2) locations to the south of Coordinate System Unique Map ID: MXXX Name: GDA 1994 MGA Zone 50 the Port study area Projection: Transverse Mercator Datum: GDA 1994 A4 Table 3 - WA Herbarium records or Ficinia nodosa or Juncus kraussii in potentially similar vegetation units to sub-association 2

WA Herbarium Species Habitat Locality Associated vegetation Frequency Coordinates Date Voucher No. Lat: 28° 18' Near a salty depression in White sand on Associated with sparse dwarf scrub. 10.0" S Long: PERTH 06228690 Ficinia nodosa NW part of island, North frequent. 20‐Nov‐99 aeolianite island. Olearia axillaris and Scaevola crassifolia. 113° 35' 42.0" Island, Abrolhos Islands E (GDA94) Swale in stable dunes. Lat: 32° 17' Some leaf litter, dry. Mersey Point Reserve, Clumps in a swale. Heath A, Acacia 49.6" S Long: PERTH 05336783 Ficinia nodosa occasional. 30‐Aug‐98 Grey‐white sand over Shoalwater Bay, Rockingham, rostellifera, Trachyandra divaricata. 115° 42' 20.4" Quindalup dunes. E (GDA94) Acacia ligulata/rostellifera Heath A over On white soil with 8% Olearia axillaris Open Dwarf Scrub C over Lat: 26° 14' limestone pavement Steep Point, Shark Bay, Swainsona sp.Shark Bay (Trudgen 5788)‐ 52.0" S Long: PERTH 05270146 Ficinia nodosa surface cover and 75% approximately 8 km SE of not noted 22‐Sep‐97 Scaevola anchusifolia‐Senecio lautus Open 113° 18' 1.0" E surface cover of litter, Mount Direction Herbs over Juncus krausii Dense Tall (GDA94) in swale. Sedges. Fish Creek 26 km ESE of Lat: 34° 54' Interdune peat Lepidosperma gladiatum, Evandra Windy Harbour, swamp 0.0" S Long: PERTH 04126548 Ficinia nodosa swamp, subject to aristata, Diuris heberlei, Microtis spp., Common. 05‐Jan‐95 immediately behind coastal 116° 17' 24.0" winter inundation. Haloragis brownii. foredunes. E (GDA94) Lat: 33° 37' Sandy soil, adjacent to locally 0.0" S Long: PERTH 04073215 Ficinia nodosa Fisheries Road to Israelite Bay Beach dune heaths, not burnt. 16‐Nov‐94 the beach. common. 123° 51' 40.0" E (GDA94) Low area, between Lat: 26° 15' mobile and stabilised Juncus (50%), Isolepsis nodosa (20%), 19.0" S Long: PERTH 1231685 Ficinia nodosa dunes; creamy Shark Bay not noted 25‐Nov‐89 Acacia (1‐3%). 113° 18' 0.0" E calcareous sand, (GDA94) damp below surface. In coarse leached white shelly sand on S bank of the Swan River at In closed rush community of Juncus Lat: 32° 2' S PERTH 02313111 Ficinia nodosa edge of river at Alfred Cove Nature Reserve draussii, Lepidosperma sp. and Gahnia common. Long: 115° 49' 2 April 1980 interzone with approx. 6 km from Fremantle trifida with emergent Jacksonia furcellata. E (GDA94) samphires

8 WA Herbarium Species Habitat Locality Associated vegetation Frequency Coordinates Date Voucher No. S bank of the Swan River at Along foreshore of Lat: 32° 2' S Alfred Cove Nature Reserve PERTH 02313030 Ficinia nodosa river, in white coarse Juncus kraussii. common. Long: 115° 49' 2 April 1980 approx. 6 km up river from white shelly sand. E (GDA94) Fremantle Estuary bank. Wet, Herbs, low sedges. Atriplex prostrata, Lat: 33° 39' S PERTH 07010702 Ficinia nodosa white sand, sediment Toby Inlet estuary Trachymene pilosa, Juncus krausii, common. Long: 116° 1' E 30‐Jan‐05 over limestone. Sporobolus virginicus. (GDA94) Low shrubland. With Allocasuarina obesa, Lat: 32° 33' Melaleuca cuticularis, Juncus kraussii Long Island, Creery wetlands, 22.0" S Long: PERTH 06914322 Ficinia nodosa Tidal wetland. reedy grasses, Frankenia pauciflora, not noted 15‐Oct‐04 Mandurah 115° 43' 55.0" Halosarcia sp., Suaeda australis. E (GDA94) Collection site: reserve. Lat: 32° 0' Estuary beach Very sparse vegetation (low to medium Opposite 31 Melville Beach 54.3" S Long: PERTH 06841201 Ficinia nodosa adjacent to roadside. trees) and disjointed narrow bands of 6‐20 plants. 18‐May‐04 Road 115° 49' 44.7" Wet, white sand. sedges on an otherwise sandy beach E (GDA94) Landform: sand dunes. Soil surface: dry beach sand with Lat: 32° 26' S little leaf litter. Soil First three dunes from ocean Olearia axillaris, Spinifex longifolius andS. PERTH 06417329 Ficinia nodosa occasional. Long: 115° 45' Oct‐02 colour: whit/grey. Soil front at Singleton Beach hirsutus. E (GDA94) type: beach sand. Underlying geology: limestone. Lat: 32° 22' In open heath of Scaevola crassifolia, 10.6" S Long: PERTH 06192041 Ficinia nodosa On sand dune. PK/2, Port Kennedy Olearia axillaris, Acanthocarpus preissii not noted 21‐Jun‐02 115° 43' 4.4" E and Pelargonium capitatum. (GDA94) Drummonds Cove along Lat: 28° 41' S Secondary dune face. gravel track to Water PERTH 05623685 Ficinia nodosa Coastal dune scrub. Olearia, Acacia. infrequent. Long: 114° 37' 12‐Nov‐01 Bare, off white sand. Reserve, bush between there E (GDA94) and ocean

9 WA Herbarium Species Habitat Locality Associated vegetation Frequency Coordinates Date Voucher No. Coastal dune, W ca 1 km S of Greenough River frequent in Lat: 28° 52' facing. Along strand mouth, access from N across Coastal scrub. 3 leaf legume, Scaevola sand drift area 0.3" S Long: PERTH 05948673 Ficinia nodosa 15‐Oct‐01 line. Beige sand, shell river mouth and along dune tetragona. ‐ front line, 114° 39' E and leaf litter. tracks, ocean. (GDA94) Lat: 32° 16' Wet flat surrounded 2.1" S Long: PERTH 07270240 Juncus kraussii Twilight Cove Not recorded not noted 10‐Aug‐04 by sand dunes. 126° 2' 43.5" E (GDA94) Acacia ligulata/rostellifera Heath A over On white soil with 8% Olearia axillaris Open Dwarf Scrub C over Lat: 26° 14' limestone pavement Steep Point, Shark Bay. Swainsona sp Shark Bay (Trudgen 5788)‐ 52.0" S Long: PERTH 05270138 Juncus kraussii surface cover and 75% Approximately 8 km SE of Mt not noted 22‐Sep‐97 Scaevola anchusifolia‐Senecio lautus Open 113° 18' 1.0" E surface cover of litter, Direction Herbs over Juncus krausii Dense Tall (GDA94) in swale. Sedges. Acacia ligulata/rostellifera Low Scrub A On white to grey sand over A. ligulata/rostellifera‐ Olearia Lat: 26° 21' Approximately 100m north of to sandy loam with axillaris‐Rhagodia latifolia ssp latifolia 6.0" S Long: PERTH 05262909 Juncus kraussii Crayfish Bay Well, Edel Land, not noted 19‐Aug‐97 60% surface cover of Dense Heath B over Anthobolus 113° 18' 35.0" Shark Bay. litter, in swale. foveolatus Dwarf Scrub C over Juncus‐ E (GDA94) Isolepis Open Tall Sedges. Lat: 28° 11' ort Gregory rubbish tip, 2.5 39.5" S Long: PERTH 04963334 Juncus kraussii Salt lake. Sedgeland. dominant. 08‐Jul‐97 km SE of town State: WA 114° 16' 28.1" E (GDA94) Lat: 33° 47' Vegetated dunes Point Malcolm camping area, Lepidosperma gladiatum (KW 9235). Low 37.0" S Long: PERTH 06068669 Juncus kraussii occasional. 01‐Dec‐94 behind beach. Israelite Bay lying area with Melaleuca surrounding it. 123° 45' 5.0" E (GDA94) Pinkish grey sand. Topography: Lat: 34° 43' Seasonally wet flat Malimup Beach, 7.0" S Long: PERTH 3141985 Juncus kraussii behind foredune. D'Entrecasteaux National Juncus krausii Tall Sedges. not noted 02‐May‐91 115° 56' 39.0" Geology: Pleistocene‐ Park E (GDA94) Recent calcareous sand.

10 WA Herbarium Species Habitat Locality Associated vegetation Frequency Coordinates Date Voucher No. Low area between Lat: 26° 15' mobile and stabilised Juncus (50%), Isolepsis (20%), Acacia (1‐ 19.0" S Long: PERTH 1232797 Juncus kraussii dunes; creamy Shark Bay not noted 23‐Nov‐89 4%). 113° 18' 0.0" E calcareous sand, (GDA94) damp below surface. Lat: 28° 48' S Chapman River, Geraldton, PERTH 04374339 Juncus kraussii Not recorded Not recorded not noted Long: 114° 37' 04‐Jul‐80 near estuary mouth E (GDA94) Along river foreshore where it may be inundated at high S bank of the Swan River at In closed rush community of Gahnia Lat: 32° 2' S tides. In coarse PERTH 03925099 Juncus kraussii Alfred Cove Nature Reserve trifida, Leptocarpus sp. and Lepidosperma Common. Long: 115° 49' 02‐Apr‐80 leached white shelly ca 6 km from Fremantle sp. with emergent Jacksonia furcellata. E (GDA94) sand on edge of river at interzone with samphires. Lat: 27° 42' Mouth of Murchison River ‐ quite 36.0" S Long: PERTH 04342771 Juncus kraussii Not recorded Not recorded 08‐Aug‐72 Kalbarri abundant. 114° 9' 29.0" E (GDA94) Lat: 34° 22' 59.0" S Long: PERTH 03917134 Juncus kraussii Not recorded Sand near sea. Not recorded not noted 30‐Jan‐72 119° 23' 0.0" E (GDA94) Forming continuous Lat: 33° 15' belt (ca 50 m across) Leschenault Inlet, 9 miles N Continuous 0.0" S Long: PERTH 04342828 Juncus kraussii Not recorded 05‐Dec‐71 above high water of Bunbury belt 115° 43' 0.0" E level. (GDA94) Lat: 32° 22' S In marsh behind PERTH 04342798 Juncus kraussii Long Point, Warnbro Sound Not recorded not noted Long: 115° 44' May‐69 foredunes. E (GDA94) Lat: 31° 58' In the littoral of sandy large clumps, 11.0" S Long: PERTH 04342860 Juncus kraussii Pelican Point Not recorded 29‐Nov‐56 shore. occasional. 115° 47' 53.0" E (GDA94)

11 Vegetation Sub-Association 8 OPR acknowledges the concerns regarding any impact to sub-association 8 and has refined Proposal engineering design to reduce impacts to vegetation communities within the Proposal area. As a result of refining the engineering design for the Proposal, it has been determined that a 5.61 ha reduction in impact on vegetation sub-association 8 is achievable. This represents approximately 35% less impact than predicted within the PER, which includes cumulative impacts on mapped vegetation sub-associations from the combined Approved Port (Ministerial Statement 469 (MS469)) and the Port Terrestrial Proposal. Table 4 outlines the comparison between impacts described within the PER and the most recent Proposal footprint. Table 4 – Impact to Vegetation Sub-Association 8

Vegetation Sub-Association (Ecologia Area within Proposed Revised 2010) study area (ha) Disturbance - Proposed PER (ha) Disturbance (ha) 8. Grevillea – Melaleuca and other low 52.6 15.9 (30.2% loss 10.29 (19.56% shrubs over Borya sphaerocephala mats within the Study loss within the on laterite/sandstone area) Study area)

To inform OPR’s mitigation and management for sub-association 8, OPR will implement a targeted and regionally focused survey within remnant vegetation beyond the Study Area. Ahead of this regional survey, OPR has conducted further desktop assessments, including: 1. a review of aerial photography of the surrounding region, which has identified several additional locations to the north and south of the Proposal, where this sub-association is considered likely to occur (Figure 2). 2. identification of potential locations of this community (Table 5) from a review of the WA Herbarium records for Borya sphaerocephala, a species which is dominant within the ground cover of sub-association 8 (Ecologia unpublished, 2010). These potential areas of additional sub-association 8 are a subset of the records for B. sphaerocephala within the Geraldton Sandplains regions or its immediate east, which occur on low lateritic – sandstone outcropping formations, or with some similarity (where noted) to the species present in sub-community 8. However, because B. sphaerocephala also occurs on other soil types including clay, sand and loamy soils and a variety of vegetation associations, it is likely that only a subset of the locations in Table 5 will correspond to sub-community 8 upon field inspection. Conversely, as the occurrence of B. sphaerocephala or any other species within this sub-community is not exhaustively represented in the WA Herbarium records, it also possible that additional records of sub-community 8 occur for which there are no voucher records at present. Therefore the search for further occurrences of this sub- community will use both the distribution of favourable habitat (based on geological mapping) and voucher specimen locations to provide points of investigation.

This list of potential locations is unlikely to be exhaustive is considered likely to include some locations which, on field inspection, prove to be dissimilar to sub- association 8 (Ecologia unpublished, 2010).

12 (!

(! (! (!

(! Legend (! (! !( Potential Community 8 locations Confirmed area of sub-community 8 (! Oakajee Study Area K 0 2 4

Kilometres Absolute Scale - 1:250,000

Potential Grevillea - Melaleuca Figure: 2 Drawn: CM Project ID: 1288 Date: 12/10/10 (vegetation sub-community 8) locations in proximity to Coordinate System Unique Map ID: MXXX Name: GDA 1994 MGA Zone 50 the Port study area Projection: Transverse Mercator Datum: GDA 1994 A4 Table 5 - WA Herbarium records of Borya sphaerocephala in potentially similar vegetation units to sub-association 8 (Ecologia, 2010a) in the vicinity of the Oakajee Port Study Area

WA Herbarium Species Habitat Locality Associated vegetation Coordinates Date Voucher No. PERTH 01942212 Borya On and amongst rocks, In shallow Howatharra Hill Reserve, Not recorded Lat: 28°32' 11"S 10‐Aug‐74 sphaerocephala clay soil, muddy and wet in Moresby Range, 21 road miles Long: 114°37' 41" N winter. N of Geraldton PERTH 01955128 Borya Not recorded Spalding Park, 3 miles N of Not recorded Lat: 28°43' 0"S Long: 30‐Aug‐65 sphaerocephala Geraldton 114°36' 0" N

PERTH 01965956 Borya On granite, clay soil. 325 miles peg, Geraldton Not recorded Lat: 28°41' 59"S 14‐Aug‐76 sphaerocephala Highway, Moresby Range area Long: 114°40' 0" N

PERTH 04235088 Borya Small rocky hill near homestead. Jindabyne Farm, 57.5 km SE of In low heath of Grevillea sp., Lat: 28°5' 0"S Long: 31‐Jul‐95 sphaerocephala Sand over granite rocks. Kalbarri on Ogilvie Dryandra sp., Eutaxia sp., 114°24' 0" N Scaevola spp., Boronia sp. and grasses.

PERTH 04525760 Borya Rocky breakaways, brown sand Gravel pit (disused), 7.3 km Scrub, Solanum sp., Lat: 27°42' 35"S 09‐Aug‐96 sphaerocephala over sandstone. from Kalbarri and .7 km NW of Thryptomene sp., Grevillea Long: 114°13' 57" N Ajana/ Kalbarri road thelemanniana, Conostylis sp. PERTH 05396263 Borya Outcrop, dry red ?loam. Thin soil Lot 3157, Isseka Road, East Not recorded Lat: 28°25' 0"S Long: 13‐Apr‐99 sphaerocephala on depressions on granite sheet. Northampton, 114°41' 0" N PERTH 05397820 Borya Granite depressions. Thin soil on Lot 3157 Isseka Road East, 13 Not recorded Lat: 28°25' 0"S Long: 23‐Aug‐98 sphaerocephala granite. km SE of Northampton 114°11' 0" N PERTH 05423880 Borya Yam, Thryptomene, yellow Lot 3157 Isseka Road, E Herbs. Yam, Thryptomene, Lat: 28°25' 0"S Long: 07‐Aug‐99 sphaerocephala brushes, weeds. Northampton, yellow brushes, weeds. 114°41' 0" N PERTH 05476011 Borya Mid slope of breakaway, W Greg Burrows block, S of Olsen Low Heath. Melaleuca sp., Lat: 28°31' 0"S Long: 29‐Jul‐99 sphaerocephala slope. Wet, gravel; quartz and Road, Oakajee State Sedges sp., Egg and Bacon, ? 114°41' 0" N laterite and dead wood. Brown, Verticordia sp., Hakea sp. fine to medium. Over laterite‐

14 WA Herbarium Species Habitat Locality Associated vegetation Coordinates Date Voucher No. sandstone.

PERTH 05775124 Borya Flat area, sandy, yellow sand Indarra Springs Reserve, site B, Dense heathland, casuarinas, Lat: 28°41' 20"S 11‐Sep‐98 sphaerocephala first windmill between both Myrtaceae spp., Thryptomene, Long: 115°2' 0" N tracks below hill. etc. PERTH 06138411 Borya Gully. Moist dark brown sandy ‐ Moresby Conservation Heath, Acacia. Lat: 28°37' 0"S Long: 11‐Aug‐01 sphaerocephala clayey loam. Reserve, access via White Peak 114°38' 0" N Road, SW facing gully PERTH 06162614 Borya Stony outcrop, large lumps of 97 m [miles] E Geraldton on Not recorded Lat: 28°46' 0"S Long: 02‐Aug‐72 sphaerocephala quartz on surface, grey soil over Geraldton to Yalgoo Road 116°12' 0" N granite. PERTH 06321496 Borya Breakaway edge. Sandy gravel Chapman Park, Fairfax carpark Low heath. Melaleuca radula, Lat: 28°44' 0"S Long: 11‐Sep‐02 sphaerocephala over laterite. to South Thryptomene stenophylla, 114°39' 0" N Moss. PERTH 06481957 Borya Well drained site with Adjacent Quadrat 17 Bushland Melaleuca megacephala [Big‐ Lat: 28°49' 45.5"S 29‐Aug‐99 sphaerocephala moderately steep NE facing Plant Survey of remnant headed Honeymyrtle] Closed Long: 114°3' 10.2" N slope. Brown (wet) skeletal vegetation on Greg and Tanya Heath over Scholtzia ciliata and loamy‐clay with sandstone Burrows property Hawkrise in Grevillea pinaster Low Open exposed to 30% of surface over the Shire of Chapman Valley c. Heath over Lepidosperma sandstone at depth. 24 km N and 35 km NE of the tenue Open Sedgeland. Geraldton Townsite. (c. 450 km N of Perth). The bush block straddles the Oakajee and Buller North‐East Catchments PERTH 06597548 Borya Topography: Gentle upper SW On S side of Campbells Road, Melaleuca uncinata, Acacia Lat: 28°24' 46.6"S 27‐Oct‐98 sphaerocephala slope. Soil: White‐grey loamy clay 2.1 km E of Bindoo Road, East acuminata open scrub, over Long: 115°1' 59.5" N over permian siltstone at 20 cm. Yuna Nature Reserve, c. 37 km Melaleuca nematophylla, WNW of Mullewa. Baeckea aff. grandis low scrub A, over Verticordia dasystylis open dwarf scrub D, over Borya constricta, Waitzia acuminata herbs. PERTH 06597904 Borya Topography: Gentle E midslope. On W side of North West Melaleuca uncinata, Petrophile Lat: 28°10' 10"S 14‐Aug‐99 sphaerocephala Soil: Brown clay over laterite at 5 Coastal Highway and E side conifera dense heath B, over Long: 114°3' 48.9" N

15 WA Herbarium Species Habitat Locality Associated vegetation Coordinates Date Voucher No. cm. Borya sphaerocephala open herbs. PERTH 06820883 Borya Topography: Gentle upper NE On E side of railway line, 1.7 Acacia acuminata, Lat: 28°52' 40.4"S 26‐Oct‐98 sphaerocephala slope. Soil: Gritty red loam over km N along railway Calycopeplus ephedroides Long: 115°5' 38.6" N granite fragments at 10 to 30 cm. scrub, over Melaleuca fulgens, Baeckea megaflora, Grevillea tenuiloba low scrub B, over Trachymene ornata, Velleia rosea, Brachyscome iberidifolia, Schoenia PERTH 08147302 Borya W slope. Gravelly beige loam. Bella Vista Reserve, Bella Vista Very open shrubland over Lat: 28°32' 9.4"S 17‐Jul‐08 sphaerocephala Road N off Howath herb/sedgeland. With Long: 114°40' 25.5" Jacksonia, Acacia acuminata, N Hakea recurva, Dianella, Olearia, Diosorea. PERTH 1339532 Borya Near foot of hill in undulating Kalbarri ‐ Ajana Road, 3.6 km E Not recorded Lat: 27°55' 0"S Long: 08‐Aug‐86 sphaerocephala terrain. Red loamy soil. of Kalbarri Nation 114°34' 0" N

PERTH 1339540 Borya In swampy flat, dark brown clay‐ 8.8 km S of Ogilvie W road on Low scrub of Melaleuca Lat: 28°9' 0"S Long: 08‐Aug‐86 sphaerocephala loam and gravel. Yerina Springs road undulata, M. radula and Hakea 114°24' 0" N obliqua. PERTH 1965131 Borya Red clayey sand. 14.4 km S of Northampton Open scrub. Lat: 28°30' 0"S Long: 21‐Aug‐83 sphaerocephala along NW Coastal Highway 114°38' 0" N PERTH 1965166 Borya Brown clayey sand. 22.1 km S of Northampton‐ Open scrub. Lat: 28°34' 0"S Long: 21‐Aug‐83 sphaerocephala Nanson turnoff 1 km SE of NW 114°38' 0" N Coastal Highway PERTH 1965174 Borya Red clayey sand, hillslope. HIlls Lookout Nanson‐ High shrubland. Lat: 28°43' 0"S Long: 24‐Aug‐83 sphaerocephala Geraldton road, S Moresby Ran 114°43' 0" N PERTH 1965298 Borya Brown sandy clay on hilltop. 4.4 km NE of Moonyoonooka Open scrub. Lat: 28°40' 0"S Long: 25‐Aug‐83 sphaerocephala turnoff Nanson‐Geradlton 114°43' 0" N

16 WA Herbarium Species Habitat Locality Associated vegetation Coordinates Date Voucher No. PERTH 1965425 Borya In clay on sandstone. SE corner of property of C.H. Tall opens shrubland. Lat: 28°33' 0"S Long: 13‐Sep‐77 sphaerocephala Royce, Howatharra St 114°40' 0" N PERTH 1966030 Borya In damp depressions on rocky Near NW Coastal Highway, 41 Low Acacia woodland. Lat: 28°28' 0"S Long: 27‐Sep‐82 sphaerocephala hillside. km N of Geraldton 114°39' 0" N

PERTH 3153010 Borya On sandstone and poor sandy Kalbarri National Park, Wattle and myrtle scrub. Lat: 27°32' 42"S 02‐Oct‐91 sphaerocephala soil. Murchison River Gorge, The Long: 114°27' 48" N

PERTH 6924271 Borya Well drained gentle E facing Quadrat VALLEY 01 on Eurardy Verticordia polytricha, Lat: 27°32' 0.3"S 29‐Aug‐03 sphaerocephala slope. Yellow sand over laterite. Station, which is ca 43 km N of Allocasuarina campestris, Long: 114°34' 0.7" N Kalbarri turn‐off on the North Melaleuca concreta, Hakea West Coastal Highway and N of orthorrhyncha var. filiformis the Murchison River in the Open Heath over Borya Shire of Northampton State sphaerocephala Very Open Herbland. Assoc. species: Acacia oldfieldii, Petrophile conifera, Calothamnus homallophyllus, Scholtzia sp. Eurardy (J.S. Beard 6886), Micromyrtus aff. racemosa, Comesperma integerrimum, Leptosema aphyllum, Lachnostachys ferruginea, Melaleuca lara, Grevillea pinaster.

17 Noting the outcome of this desktop survey, it is anticipated that the regional site survey will extend the known range of this sub-association within the Geraldton Sandplain Bioregion. Nevertheless, it is expected that OPR’s impacts to vegetation sub-association 8 will be much less than 19.56% currently predicted to be impacted by the Proposal. OPR will endeavour to implement its activities such that impacts to this vegetation sub- association are further minimized. In terms of managing indirect impacts from the Proposal, during the final and more detailed phases of engineering OPR will further investigate options to ensure that potential indirect impacts are appropriately managed. These management actions will include the implementation of a vegetation health monitoring program, which sets specified limits for acceptable decline in vegetation health and will form part of the Vegetation and Flora Management Plan.

1.2 Priority species

Submitter Submission and/or issue PER (sub #) modified DEC – Of the priority listed flora that will be impacted by the Yes Environmental proposal, Lasiopetalum oppositifolium (P3), Management Acanthocarpus parviflorus (P3) and Melaleuca Branch (6) huttensis (P1) will be most significantly impacted (33%, 16.5% and 7% loss of known plants, respectively).

The significance of this impact has not been quantified in the context of long-term viability of local populations.

The PER suggests further survey is expected to extend the range of these species and states targeted survey for these priority flora will be undertaken prior to construction

Submitters expect the conservation significance of these impacts to be quantified in the context of long- term viability of local population, and that this be determined in consultation with DEC, and reported to the EPA, through targeted surveys prior to on-ground disturbance or construction.

Has a framework for this determination been designed and factored into the project’s implementation strategy?

Since publishing the PER for the Port Terrestrial Proposal, OPR has been reviewing Proposal design in order to identify opportunities to further minimise impacts on the environment. This design review has identified an opportunity to significantly reduce impacts to the species listed above. Further to this, additional surveys of the distribution of Lasiopetalum oppositifolium (P3) and Melaleuca huttensis (P1) within the Study Area and region were conducted in October 2010 to understand the regional distribution of these species (Ecologia 2010c; Ecologia 2010 d). Current Proposal design has reduced impacts to priority flora in comparison to those impacts described within the PER. Table 6 provides a comparison between the

18 impacts stated within the PER and current Proposal design, which shows a 90% and 56% decrease in impacts to Acanthocarpus parviflorus (P3) and Melaleuca huttensis (P1) respectively. Table 6 – Impact to Priority Flora

Priority Flora No. of Plants Proposed % impact on Revised % impact on within GS Cumulative total known Cumulative total known Bioregion Disturbance no. Plants Proposed no. Plants - PER (PER Disturbance (revised (number of Footprint) (number of footprint) plants) plants) Acanthocarpus 715 118 16.5 11 1.54 parviflorus (P3) Melaleuca 4976 335 6.73 161 3.24 huttensis (P1) 1Although the PER stated a that for Melaleuca Huttensis there was a known population of 4976 plants and that the Proposal would impact a total of 335 plants (6.7% of the known population), these values have been amended based on more recent population data (Ecologia 2010c).

OPR will endeavour to further minimise priority flora plant loss during the detailed design phases ahead of implementation of the Proposal. OPR will also endeavour to incorporate priority flora species within site rehabilitation programs that will be implemented post construction.

Lasiopetalum oppositifolium (P3) No additional records of Lasiopetalum oppositifolium were located within the Study Area. Furthermore, all previous voucher specimens within the Study Area, including an earlier specimen lodged at the WA Herbarium in 1997 were reexamined and identified as Lasiopetalum angustifolium, a species that is morphologically very similar to Lasiopetalum oppositifolium (Ecologia, 2010d). The redetermination of these collections as L. angustifolium has been verified by Drs. Kelly Shepherd and C. Wilkins of the WA Herbarium. Both Dr. Shepherd and Wilkins have confirmed that they consider Lasiopetalum oppositifolium to be confined to a very restricted range in the Kalbarri area and that the soils of the Oakajee Port Study Area do not provide suitable habitat for this species. Given that L. oppositifolium is not present within the study area and L. angustifolium is not a Priority flora species, neither species will be discussed further within this document. Melaleuca huttensis (P1) An initial Melaleuca huttensis survey was conducted by Ecologia in March 2010, the results of which estimated a total of 4976 plants in the GS bioregion (Ecologia 2010a). However, it was considered likely that the abundance of these species outside the Study Area had been significantly underestimated and inferred that further populations were highly likely to be found within unsurveyed remnant vegetation located on private landholdings surrounding the Study Area. A further survey of the distribution of Melaleuca Huttensis within the Study Area and region was conducted in October 2010 to provide a more detailed understanding of the distribution of this species (Ecologia, 2010c). The survey focused on the vegetation within the Port Study Area and within the Oakajee Industrial Estate. Due to access restrictions private landholdings were not accessed during this survey. An additional 136 locations of Melaleuca huttensis were located during the October 2010 survey (Ecologia, 2010c). The results of this study increased the known

19 population of Melaleuca huttensis in the Geraldton Sandplains bioregion to a total of 7009 plants. The revised Proposal design has reduced the width of the rail corridor and removed the Construction Services Road (formerly situated alongside the rail alignment). These design amendments have resulted in a decrease in the total number of M. huttensis plants impacted by the Proposal from approximately 397 (PER Proposal) to 176 (revised Proposal) (Error! Reference source not found.). Error! Reference source not found. shows the known distribution of Melaleuca huttensis within the study area. With respect to the local ongoing viability of this species, it is already known that communities of M. huttensis have survived within highly fragmented remnant vegetation located within the northern sections of the Oakajee Industrial Estate (OIE) Buffer (Figure 3). In a number of circumstances, these fragmented remnants are considerably more fragmented than those areas of vegetation in proximity to the Proposal and that will remain once the Proposal is implemented. It is noted that the clearing around these highly fragmented areas to the north of the Proposal was most likely to have occurred in excess of 50 years ago. Despite these circumstances it is clearly demonstrated that populations of M. huttensis have the capacity to persist within a highly fragmented landscape.

Acanthocarpus parviflorus (P3) Recent refinement in the Proposal’s design has resulted in a significant reduction to the number of Acanthocarpus parviflorus being impacted from 11% to 1.5%. Noting this significant reduction in impact, and given that this species is known to occur at a number of locations to the north and south of the Port Study Area, the Proposal is considered unlikely to affect the local or regional viability of this species. As such, OPR believes that the information available regarding this priority flora is sufficient for the purposes of this assessment.

To ensure that impacts to M. huttensis, L. oppositifolium other Priority species are minimised as much as possible during implementation of the Proposal and conservation status is maintained or improved OPR will also ensure that: • final design attempts to further reduce direct impacts to these species as much as practicable; • location of temporary construction facilities (roads, laydown, turkey nests) avoid these species as much as practicable; • indirect impacts from dust, saltwater, off track driving are avoided; and • these species are included within any rehabilitation works where suitable.

OPR is currently finalising an Offsets Strategy in consultation with the EPA and DEC EMB which will identify the scope of an appropriate offsets package to mitigate significant residual environmental impacts to Priority flora.

Figure 3 Melaleuca huttensis locations within the Port Study Area and Revised Proposal Footprint

1.3 Access roads

Issue 1: Submitter Submission and/or issue PER (sub #) modified DEC – The PER indicates that the development of the Yes Environmental proposed southern port access road will result in a Management 44.3% impact on the restricted vegetation sub- Branch (6) association 2.

If vegetation sub-association 2 is determined to be of regional significance, further investigations are to be undertaken – as proposed by the proponent in the PER – prior to on-ground disturbance to ensure adequate conservation of this vegetation outside the impact area.

As an outcome of consultation with Department of State Development (DSD), LandCorp and the Geraldton Port Authority (GPA), OPR’s Proposal has been modified to exclude the requirement to seek approval for both the northern and southern port access road simultaneously. Instead, OPR has designed a northern port access road that avoids the area of remnant vegetation located to the south of the Proposal, which was identified by the Environmental Protection Authority (EPA) as having significant environmental values. It is understood that DSD, GPA and LandCorp’s requirement for a southern access road will be included within future master planning proposals being discussed with the EPA. It is understood that these agencies are also working to identify an alignment that reduces impacts to these valuable coastal vegetation associations to the south of the Proposal. OPR prepared and submitted a supplementary report for the revised Proposal which excludes the southern access road and includes the new northern port access road. The OPR Terrestrial Port Development Supplementary Advice to the PER Revision 1 (OPR 2010) presents the revised cumulative impacts associated with both the approved Oakajee Deepwater Port and the revised Port Terrestrial Proposal. Although most of the information contained within this report has been incorporated within OPR’s response to PER submissions, for completeness, OPR has submitted the Supplementary Advice document (OPR 2010) to the EPA and the DEC Environmental Management Branch (EMB) to assist in the assessment process. Nevertheless, regardless of the final location of this access road this vegetation sub- association is situated alongside the land based dredge disposal area and the substantial iron ore stockyard and is likely to be subject to indirect impacts from the location of this infrastructure, such as saline seepage from the dredge relocation area. Consequently, OPR anticipates complete loss of the sub-association in proximity to the Proposal, which would reduce the currently known extent of this sub- association within the Bioregion by approximately 44%.

As outlined within Section 1.1 of this Response to Submissions, OPR has commenced a regional investigation that will increase the knowledge of this sub- association and assist in clarifying its conservation significance. The study results will also assist OPR in developing an appropriate management strategy for this vegetation sub-association. OPR is of the view that vegetation sub-association 2 is

22 not restricted to the footprint of the Proposal given previous identification of this sub- association to the north of Port Gregory and at the northern boundary of the GRFVS area.

It is considered that this sub-association is likely to occur as a disjunct series of very small areas confined to the swales of coastal dunes that provide adequate levels of moisture to sustain it. The apparent rarity of this sub-association is likely to be at least partially attributable to the small areas it encompasses and the difficulty in detecting and mapping these areas from aerial imagery. As discussed above, OPR has undertaken a review of high resolution aerial imagery to detect additional locations and, notwithstanding the difficulties in discriminating this sub-association, has located several additional potential locations to the south of the Proposal Study Area (Figure 1). These locations will required field inspection to confirm their species composition.

Issue 2: Submitter Submission and/or issue PER (sub #) modified DEC – The PER does not provide a clearly documented Yes Environmental quantitative comparison of the direct impacts of the Management southern and alternative port access routes. Branch (6) It is understood & expected that the proponent will submit supplementary information relating to the alignments of the northern and southern port access road route requirements prior to completion of the EPA assessment process.

As an outcome of consultation with DSD, LandCorp and the GPA, OPR’s Proposal has been modified to exclude the requirement to seek approval for both the northern and southern port access road simultaneously. Instead, OPR has designed a northern port access road that avoids the area of remnant vegetation located to the south of the Proposal, which was identified by the EPA as having significant environmental values. It is understood that DSD, GPA and LandCorp’s requirement for a southern access road will be included within future master planning proposals being discussed with the EPA. It is understood that these agencies are also working to identify an alignment that reduces impacts to these valuable coastal vegetation associations to the south of the Proposal. OPR prepared and submitted a supplementary report for the revised Proposal which excludes the southern access road and includes the new northern port access road. The OPR Terrestrial Port Development Supplementary Advice to the PER Revision 1 (OPR 2010) presents the revised cumulative impacts associated with both the approved Oakajee Deepwater Port and the revised Port Terrestrial Proposal. Although most of the information contained within this report has been incorporated within OPR’s response to PER submissions, for completeness, OPR has submitted the Supplementary Advice document (OPR 2010) to the EPA and the DEC Environmental Management Branch (EMB) to assist in the assessment process. In summary, the supplementary submission identifies:  The Northern Port Access Road Option requires the least amount of vegetation clearing, compared to the Southern Port Access Road with a total of 23 ha now required in comparison to 34 ha for the original access road development.

23  The Northern Port Access Road option will impact on no Priority flora species, whereas the Southern Port Access Road contains 10 Grevillea triloba (P3) plants.  The Northern Port Access Road does not impact known Short Range Endemic’s (SRE), whilst the original Southern Port Access Road contained known SRE Bothriembryon species.  Development of the original Southern Port Access Road had the potential to fragment coastal vegetation types considered by the EPA to be floristically important.

1.4 Weed management

Submitter Submission and/or issue PER (sub #) modified Drummond Cove Are weed surveys to be a regular occurrence in Yes Progress the future? Association (4)

A weed and pathogen control program will be implemented both during construction and operation.

The weed and pathogen control program will include targeted weed assessments/ surveys along identified high risk areas for infestation on a regular basis throughout construction and operation. The program will be designed to ensure that seasonal variation is considered when preparing the weed and pathogen control program.

1.5 Impact footprint & monitoring

Issue 1: Submitter Submission and/or issue PER (sub #) modified DEC – Submission does not consider that the proponent has Yes Environmental adequately delineated areas that will be subject to Management indirect impacts. Branch (6) Suggests that a condition be applied to the proponent that ensures impacts on significant flora and vegetation communities are limited to an agreed direct & indirect disturbance footprint.

OPR has included buffers around the Proposal footprint to take into account potential zones in which indirect impacts, such as from weed invasion, dust, erosion and changes in runoff, could occur. OPR’s assessment has assumed that 100% of the vegetation within this buffer will be affected for the purpose of assessing environmental impact. It is noted that the likelihood of all vegetation within the buffer succumbing to OPR’s Proposal is unlikely particularly noting that OPR will be managing construction and operation to avoid or minimise such effects. Due to refined engineering design, OPR has been able to achieve a reduction in predicted impact. Consequently, revised buffers around Proposal infrastructure, to take into account potential indirect impacts, are now a 10 m buffer around road footprints, 20 to 200 m buffer around stockpile areas1 and 15m buffer around the rail corridor. Refined buffer design has determined a smaller area of direct and indirect

24 impact than originally anticipated within the Port Terrestrial PER. It is still expected that construction impacts will be much less than these conservative estimates, due to the measures that will be in place to limit disturbance. OPR agrees that it will be necessary to monitor vegetation health to prove that impacts are within the agreed limits. Despite a reduction in expected indirect impacts on vegetation due to revised Proposal design, OPR is committed to reducing indirect impacts on vegetation by implementing a vegetation health monitoring program, which is detailed within OPR’s Vegetation and Flora Management Plan. The vegetation health monitoring program will include agreed limits for direct and indirect impacts on vegetation and flora. Appropriate ‘triggers’ will be set for remedial or contingency actions should monitoring indicate these limits have not or are in threat of being exceeded. Furthermore, OPR is committed to implementing a vegetation health monitoring program which will:  Be designed to assess the indirect impacts on flora and vegetation resulting from the Proposal, beyond the specified buffers.  Establish monitoring sites, during operation, beyond the proposed buffer zones of the disturbance footprint, for example, 10 m around roads, 20 m to 200 m around stockpiles1 and 15m around rail, to monitor potential indirect impacts to vegetation health. OPR will also establish reference monitoring sites to determine if changes in environmental values are attributable to the Proposal or natural variances.  Investigate the use of remote sensing technology to locate areas of potential vegetation health impacts beyond the specified buffers. Should the cause of decline in vegetation health be attributed to the Proposal’s activities, management measures will be reviewed and amended as required. A buffer, or zone of potential indirect impact, has not been applied and included in the estimate of total impact for the northern port access road, because engineering design has significantly advanced and cut and fill requirements have already been taken into account. These cut and fill areas will be used for laydown and storage during construction and due to the short construction timeframe, it is anticipated there will be low to no indirect impacts outside this footprint. Once complete, the northern access road will be sealed with a hard surface to ensure dust does not impact on surrounding vegetation and conditions for weed infestation will be reduced. In addition, appropriate stormwater controls will be used to ensure indirect impacts are not caused by runoff and the bed and banks of the Oakajee River are protected. Vegetation monitoring will still however include areas either side of the road to confirm impacts are not occurring. Issue 2: Submitter Submission and/or issue PER (sub #) modified DEC – Submitter suggests a zone of indirect impacts Yes Environmental (adjacent to areas approved for disturbance) be Management defined for this project by the proponent, and within Branch (6) which, significant flora and vegetation condition and health may decline to agreed limits.

1 The south western edge of the dredge disposal area is located adjacent to a downward sloping gradient. Interception trenches or other infrastructure may be required to mitigate against the potential for saline water to form a south westerly migrating plume with potentially harmful effects to vegetation. Furthermore, in order for return water associated with dredge disposal on land and within the reclaim area to meet water quality objectives for the protection of benthic primary producer habitat, additional infrastructure (i.e. settlement ponds and associated access tracks) may be required within this 200m buffer area.

25 As discussed previously, OPR has included buffers around the Proposal footprint to take into account potential zones in which indirect impacts. OPR has further refined engineering design and buffers (or zones of potential indirect impact) relating to the Proposal footprint. Buffers are now more accurately proposed including 20m to 200m for the stockyards1, 10 m for roads and 15 m for the rail corridor. OPR is committed to implementing a vegetation health monitoring program which includes vegetation health triggers. OPR will include the vegetation health monitoring program within a Vegetation and Flora Management Plan, which will also include management and contingency actions to ensure potential impacts are managed appropriately and prior to worst case impacts being realised. Trigger levels are discussed in more detail, within Section 1.5 - Issue 4 of this Response to Submissions document.

Issue 3: Submitter Submission and/or issue PER (sub #) modified DEC – The extent of indirect impacts of the project on Yes Environmental significant flora and associated vegetation Management communities is not clearly presented in the PER. Branch (6) It is not clear if quantitative descriptions of impacts (i.e. tables 7-2, 7-4, 7-6, 7-7 & 7-8) include indirect impacts.

It is important that all impacts proposed by this development, if approved, are made clear and confined as closely as possible to the identified total disturbance footprint.

Have indirect impacts been factored into the total disturbance footprint in the PER?

Quantitative descriptions of impacts as outlined within Table 7-2, 7-4, 7-6, 7-7 & 7-8 of the Port Terrestrial PER include direct and indirect impacts. The total Proposal impact area of 211 ha provides for a level of flexibility in the location of peripheral Proposal infrastructure and an allowance for some level of indirect impact (e.g. dust from construction). For example, buffers had been applied around areas of impact representing potential zones of indirect impact. On this basis the total predicted footprint for the Proposal represents an overestimate of impacts.

Since the publication of the PER, OPR has refined engineering design including buffers relating to the Proposal footprint. Buffers are now more accurately defined, including 20 m to 200 m for the stockyards1, 10 m for roads and 15 m for the rail corridor. The application of more accurate buffers has reduced the Port Terrestrial footprint, which includes both direct and indirect impacts. The management of both direct and indirect impacts are discussed in Section 7.2.4.2 and Table 7-10 of the Port Terrestrial PER. Issue 4: Submitter Submission and/or issue PER (sub #) modified DEC – Submitter suggests the proponent has not developed Yes Environmental a monitoring and management program for areas

26 Management delineated as being subject to indirect impacts. Branch (6) The proponent should develop a flora health and vegetation condition monitoring program applicable to the defined indirect impact zone, including baseline measurements for areas potentially impacted and where practical, measurements at suitable reference sites that will provide comparative data for measuring impacts.

It is recommended that the program is developed in agreement with DEC for areas where significant flora and associated communities are affected and be capable of measuring change in relation to trigger levels.

Please refer to Section 1.5 (Issue 1 and 2) of this Response to Submissions.

27 Issue 5: Submitter Submission and/or issue PER (sub #) modified DEC – Trigger levels referred to above should be No Environmental developed and applied to the management of the Management project in key areas, specifying: Branch (6) 1. the level of acceptable decline in significant flora and vegetation condition and health within the defined indirect impact zone areas; and 2. the level of flora health and vegetation condition change at which contingency measures are to be applied to avert further condition and health decline.

Suggest the proponent report annually to the OEPA and DEC on results of the monitoring and any contingency action implemented in response to trigger exceedance.

A key source of impact to native vegetation is from dust that is emitted from stockpiles. OPR believes its dust management system will adequately manage dust emissions which will ensure adverse impacts to vegetation health are avoided. Nevertheless, as discussed previously within Section 1.5 Issue 1 to 4 above, OPR is committed to implementing a vegetation health monitoring program and detailing vegetation health triggers, management and contingency actions within a Vegetation and Flora Management Plan, which will ensure potential impacts are managed appropriately and prior to worst case impacts being realised. Vegetation health monitoring will be conducted, which includes the collection of baseline data (prior to construction) for vegetation health and monitoring of vegetation health during construction and operation. The vegetation health monitoring program will be developed in consultation with DEC and will include areas of direct and indirect impacts, as defined in Section 1.5, Issue 1 and Issue 4. OPR will report annually to DEC and Office of the Environmental Protection Authority (OEPA) with regards to monitoring results and the implementation of any contingency actions. Detailed contingency measures are currently being prepared, to improve product handling in the circumstance that unacceptable dust emissions are observed, which includes for example:  Chemical suppressants;  Fogging systems;  Belt cleaning; and  Strict traffic management and plant hygiene).

1.6 Revegetation

Submitter Submission and/or issue PER (sub #) modified Shire of Submission suggests proposed landscaping and No Chapman revegetation should be comparable with the direct Valley (1) loss.

28 OPR will prepare and implement a Flora and Vegetation Management Plan and a Conceptual Closure and Rehabilitation Management Plan which will include:  Rehabilitation prescriptions for different vegetation types and soil types to include local native species with seed sourced locally.  Where practicable direct seeding and/or planting will be undertaken to stabilise surfaces and integrate landforms into the surrounding landscape and ecosystems.  Rehabilitated areas will be constructed to blend in and allow suitable habitat for recolonising fauna.  Topsoil management procedures will be developed and implemented to ensure that suitable topsoil and cleared vegetation is available for rehabilitation of cleared areas. OPR is currently finalising an Offsets Strategy in consultation with the EPA and DEC EMB which will take into consideration direct loss of significant flora and vegetation as a result of Project implementation. 2. Offsets

Submitter Submission and/or issue PER (sub #) modified DEC – Requests suitable commitments be made for No Environmental conservation offset measures to mitigate the residual Management impacts of the project on conservation values and Branch (6) DEC’s potential management liability for recovery of affected species.

Impacts to conservation values mentioned as requiring offset measures included:  reduction in foraging habitat of Carnaby’s black cockatoo;  impacts to Priority 1 flora species Melaleuca huttensis;  reduction and fragmentation of coastal vegetation types that are associated with significant flora species, have been significantly reduced in extent and condition due to fragmentation from land clearing and are not represented in the formal conservation reserve system;  reduction and further fragmentation of inland vegetation remnants and associated significant flora populations occurring in a largely cleared landscape, that currently provides important habitat and faunal linkages between the Moresby Range and coastal dunes.

OPR is currently finalising an Offsets Strategy in consultation with the EPA and DEC EMB which will detail the efforts that have been made to avoid and mitigate impacts to environmental values. The Strategy will also describe any commitments, and mechanisms for their implementation, particularly for any potential significant residual

29 impacts. The Strategy will recognise that development agreements with the State have constrained OPR to develop the Proposal in vegetated areas situated within the OIE Buffer. OPR has specifically been directed to avoid development within areas that are already cleared within the OIE buffer. Nevertheless OPR has actively designed the Proposal to minimise impacts as much as possible and will commit to providing environmental offsets with the cooperation of the State Government.

OPR has refined engineering design and buffers relating to the consideration of potential indirect impacts from the Proposal footprint, such as edge effects, weed invasion, dust deposition, erosion and sedimentation. Proposed buffers or ‘zones of potential indirect impact’ are now more accurately proposed including 20 m to 200 m for the stockyards1, 10 m for roads and 15 m for the rail corridor. Both the refinement in engineering design and the application of more accurate buffers has reduced the Port Terrestrial footprint, which includes both direct and indirect impacts. OPR believes as the Proposal moves into the construction phase, areas of impact may be potentially reduced even further. Carnaby’s Habitat Although not recorded within the Port Terrestrial Proposal Study Area, Carnaby’s Black-Cockatoos are known to feed on the seeds, flowers, nectar and fruit of a wide variety of species, primarily in proteaceous scrub and heath and adjacent eucalypt woodlands and forests (Johnstone and Storr 1998). They have been observed to primarily feed on Banksia, Dryandra, Hakea, Eucalyptus, Grevillea, Pinus, Casuarina and Allocasuarina species (Johnstone and Storr 1998; Cale 2003; DEWHA 2010). However, these habitats are of generally low quality because of weed impacts and grazing, and consist of isolated fragments of habitat. Given that the Oakajee area represents the northern extent of Carnaby’s range and that the vegetation communities found in the region are significantly different to those in the south-west of the state (although with some overlap of plant species distribution), there is limited literature available to identify potential foraging habitat species of Carnaby’s in the Proposal area. Ecologia conducted a site visit in September 2010, which included transects through the northern access road and rail corridor. The survey recorded the habitat type, condition, and presence of potential foraging species for Carnaby Cockatoos. Vegetation condition was assessed using the scale produced by Keighery (Government of Western Australia 2000). Seven vegetation types were observed in varying condition within the study area, each of which contained one or two flora species that may provide feeding habitat for Carnaby’s, including:

 Casuarina obesa;  Eucalyptus camaldulensis;  Grevillea argyrophylla;  Hakea recurva;  Banksia prionotes;  B. Menziesii;  Eucalyptus dolichocera; and  introduced Eucalyptus spp.

OPR subsequently commissioned ELA to conduct a further assessment of the habitat mapping to more accurately estimate the Proposal’s impact on likely suitable habitat based on the criteria established through a detailed literature review (ELA, 2010). Within the Proposal footprint, 56.9 ha of vegetation was assessed as potentially suitable foraging habitat. The assessment took a conservative approach by

30 accounting for species where the actual foraging value at Oakajee is in fact unknown. As a result, the presented impacts of the Proposal to Carnaby’s Black-Cockatoo foraging habitat (56.9 ha) is likely to be a ‘worst case’ assessment. One vegetation type within the Proposal footprint supports E. camaldulensis. This tree species is known to be a nest hollow species for Carnaby’s Black-Cockatoo. Data collected on tree age, based on DBH, identified seven trees of DBH greater than 500 mm within the footprint and eight trees immediately outside of the footprint in this vegetation unit (OPR 2010). On this basis, it is considered that the 0.3 ha of riparian habitat affected by the Proposal may be considered potential breeding habitat for Carnaby’s Black Cockatoo. Priority 1 Flora As discussed in Section 1.2 of this Response to Submissions, regional searches for the species Melaleuca huttensis have identified an additional 136 locations of Melaleuca huttensis, increasing the known population of Melaleuca huttensis in the Geraldton Sandplains bioregion to a total of 7009 plants. With respect to the local ongoing viability of this species, it is already known that communities of M. huttensis have survived within highly fragmented remnant vegetation located within the northern sections of the OIE Buffer (Figure 3). In a number of circumstances, these fragmented remnants are considerably more fragmented than those areas of vegetation in proximity to the Proposal and that will remain once the Proposal is implemented. It is noted that the clearing around these highly fragmented areas to the north of the Proposal was most likely to have occurred in excess of 50 years ago. Despite these circumstances it is clearly demonstrated that populations of M. huttensis have the capacity to persist within a highly fragmented landscape.

Noting the substantial size of remnants that will exist post implementation of the Proposal, it is unlikely that the local long-term viability of M. huttensis in proximity to the Proposal will be affected. Based on the revised Proposal footprint, the maximum likely impact to Priority 1 Flora species M. huttensis has been significantly reduced from 335 plants to 161 plants, as outlined in Table 7. Consequently the Proposal’s potential impacts to this species will be reduced to approximately 2.5% of it’s know population. Table 7 – Impact to Conservation Values – Priority 1 Flora (Melaleuca huttensis)

Priority Flora No. of Plants Proposed % impact on Revised % impact on within GS Disturbance total known Proposed total known Bioregion - PER no. Plants Disturbance no. Plants (number of (PER (number of (revised plants) Footprint) plants) footprint) Melaleuca 4976 3971 5.71 176 2.5 huttensis (P1) 1Although the PER stated a that for Melaleuca huttensis there was a known population of 4976 plants and that the Proposal would impact a total of 335 plants (6.7% of the known population), these values have been amended based on more recent population data (Ecologia 2010c).

Reduction in Fragmentation of Coastal Vegetation

The footprint proposed in the Port Terrestrial PER will result in some fragmentation of coastal vegetation types that are associated with significant flora species (as advised by the DEC during the PER public review process). For this reason and as a result of refined engineering for the Proposal OPR has developed a revised footprint.

31 The coastal vegetation units relevant to the Port Terrestrial Proposal and revised footprints are outlined in Table 8. Based on the revised Proposal footprint, the impact to coastal vegetation habitat has been reduced from 201.76 ha to 200.04 ha, as outlined in Table 8. The impact to Melaleuca huttensis, discussed above, is also indicated in Table 8 and Figure 3. The extent of fragmentation arising from clearing has also reduced.

32 Table 8 – Impact to Conservation Values – Coastal Vegetation

Vegetation Sub-Association Area within Proposed Revised Degree of fragmentation to Impact to Melaleuca (Elcologia 2010a) study area Cumulative Cumulative vegetation as a result of Revised huttensis records (ha) Disturbance Proposed Proposed Disturbance within each - PER (ha) Disturbance vegetation unit (ha) 1. Olearia axillaris low open 53.3 11.4 11.27 The natural distribution of this unit Not relevant as not shrubs, Spinifex longifolius within the Study Area is fragmented recorded to date in this hummock grasses north to south. Revised footprint will unit (+/- Scaevola crassifolia) on result in a minor increase in the degree foredunes of fragmentation; however a large strip of this vegetation is outside the footprint in the northern portion of the Study Area.

2. Juncus kraussii closed 2.2 0.96 0.96 This unit is already confined to small, Not relevant as not sedgeland on swale disjunct areas within the bioregion and recorded to date in this the disturbance footprint will not affect unit the already high level of naturally occurring fragmentation.

3. Acacia rostellifera – 246.2 20.7 25.76 The natural distribution of this unit Records within this unit Stylobasium spathulatum – within the Study Area is fragmented now outside the revised Tetragonia implexicoma – north to south. The revised footprint footprint. Acanthocarpus preissii will result in a minor increase in the degree of fragmentation. The majority of this association within the Study Area occurs to the north of the footprint and will be undisturbed.

33 Vegetation Sub-Association Area within Proposed Revised Degree of fragmentation to Impact to Melaleuca (Elcologia 2010a) study area Cumulative Cumulative vegetation as a result of Revised huttensis records (ha) Disturbance Proposed Proposed Disturbance within each - PER (ha) Disturbance vegetation unit (ha) 4. Acacia xanthina – Melaleuca 226.12 62.1 48.84 The natural distribution of this unit Almost all records of cardiophylla (+/- Grevillea within the Study Area is fragmented this species are outside argyrophylla) closed scrub. north to south and the degree of the revised footprint. Tamala limestone slopes and hill fragmentation has been increased by crests agricultural clearing. The revised footprint will result in an increase to the fragmentation of the northern polygons of this unit. However the removal of the Southern access road from the engineering design has eliminated direct impact to the southern occurrence of this unit within the Study Area. 5. Melaleuca cardiophylla – 192.7 7.6 13.54 The majority of this unit within the All records of this Grevillea argyrophylla scrub or Study Area occurs to the north of the species outside the heath (+/- impact footprint. However the revised footprint Eucalyptus dolichocera mallee Northern Port Access Road will bisect and Diplolaena grandiflora the more southern, smaller polygon of scrub) on this unit within the Study Area. Tamala limestone slopes and ridges 12. Acacia xanthina mid to tall 64.8 0 0 Not impacted by PER or revised Not relevant as not dense scrub on calcareous sand footprint recorded to date in this on stony Tamala limestone hill unit crest 13. Acacia rostellifera tall dense 173.6 99.0 99.67 This unit is almost equally impacted by Not relevant as not scrub on deep calcareous sand both the PER and the revised footprint. recorded to date in this in The proposal will result in a separation unit Holocene secondary dune of the northern and southern swales occurrences. The removal of the Southern access road has reduced the fragmentation of the southern areas of this unit. TOTAL 958.92 201.76 200.04

Within the context of the surrounding region, which is significantly fragmented, the Proposal is not anticipated to increase this fragmentation on a regional scale. However, on a local scale, the Proposal is likely to increase fragmentation (as outlined in Table 8).

Despite the loss of some areas of the vegetation sub-associations outlined in Table 8, it is unlikely that this will impact the genetic distribution of these species which comprise these units, given that each vegetation sub-association extends quite significantly to the north and south along the coast line. Similarly, locations of Melaleuca huttensis occur outside the revised footprint such that populations to the north and south of the area are unlikely to become genetically isolated (refer to Figure 3). The viability of Melaleuca huttensis occurring in highly fragmented environments is also discussed in Section 1.3 of the OEPA Response to Submissions Document.

Furthermore, OPR is currently finalising an Offsets Strategy in consultation with the EPA and DEC EMB which includes:  the conservation and enhancement of an east-west ecological corridor between the coast and Moresby Ranges along the Oakajee River;  the protection of north south coastal ecological corridor along the foreshore north of Oakajee, providing up to 360 ha of suitable vegetation; and  the removal or reduction of threatening processes and the implementation of management measures to improve the condition and extent of the vegetation in relation to ecological corridors.

Moresby Range and Coastal Dune Linkages

The vegetation of the Moresby Ranges (to the east of the Study Area) is highly fragmented but includes species-rich mallee, heath and scrub assemblages floristically somewhat similar to that of the remnant vegetation in the eastern parts of the Study Area (but in better condition). The Oakajee and Buller Rivers are the only incised surface water features or watercourses visible within proximity to the Proposal area. Both rivers and their adjacent vegetation form the most obvious ecological linkages between the intact coastal habitats and the diverse habitats of the Moresby Range to the east. The original PER footprint encroached on the Buller River. The revised Proposal has excluded the southern port access road requirement and therefore avoids this watercourse. With respect to the Oakajee River, apart from the very narrow impact areas associated with the northern port access road where it crosses this feature, the Proposal is located well away from this watercourse. Significant disruptions to the ecological linkage values of this river system with the Moresby Ranges are not proposed. It is noted that remnant vegetation between these two areas is already highly fragmented due to agriculture and a number of other existing roads including the North West Coastal Highway. Consequently, the Proposal is not expected to significantly contribute to an increase in fragmentation in an east-west direction above these existing barriers. Any potential crossing of tributaries to the Oakajee River will be designed to meet the Department of Water (DoW) standards and will not significantly impact surface water flow such that pooling upstream or increased erosion downstream occurs and that maintenance of these riparian ecosystems is maintained.

35 With respect to habitat fragmentation, in meeting DoW requirements, fauna habitat will be considered and impacts managed. The northern port access road has been selected so as to minimise impact to riparian and significant vegetation. Management measures such as the installation of culverts, traffic controls, appropriate signage and fauna egress areas will be adopted during detailed project design to reduce impacts on fauna. Furthermore, potential direct fauna hits which may result from vehicle movements will be managed within the Proposal’s Fauna Management Plan. The Fauna Management Plan will commit OPR to reduce the potential for road kill by enforcing speed restriction on all access roads, and restricting off road traversing by vehicles. A fauna injury/death register will be used to determine short and long-term trends by recording locations of direct fauna hits. This information can be used to determine if there are any areas where fauna strikes are more common, which may be identified as areas that may require further speed reductions or other mitigation (fencing, alert signage etc). Such triggers and contingency measures will be detailed in the Fauna Management Plan. The inland vegetation types which are likely to be affected by the Proposal are outlined in Table 9. Table 9 demonstrates that OPR will not substantially add to the effects of fragmentation, due to the current fragmentation from agricultural clearing within the Proposal area. Despite the Proposal’s avoidance of the Oakajee River, OPR OPR is currently finalising an Offsets Strategy in consultation with the EPA and DEC EMB which includes:  the conservation and enhancement of an east-west ecological corridor between the coast and Moresby Ranges along the Oakajee River;  the protection of north south coastal ecological corridor along the foreshore north of Oakajee, providing up to 360 ha of suitable vegetation; and  the removal or reduction of threatening processes and the implementation of management measures to improve the condition and extent of the vegetation in relation to ecological corridors.

36 Table 9 – Impact to Conservation Values – Moresby Range and Coastal Dune Linkages

Vegetation Sub-Association (Ecologia Area Proposed Revised Degree of fragmentation to Impact to Melaleuca 2010a) within Cumulative Proposed vegetation as a result of huttensis records study Disturbance - Cumulative Revised Proposed Disturbance within each area (ha) PER (ha) Disturbance vegetation unit (ha) 6. Banksia prionotes (+/- Banksia 174.6 15.0 13.25 This unit is already significantly The number of records menziesii) open scrub on sandplains fragmented by agricultural within this unit has clearing within the Study Area. been reduced by The majority of the remnants revision of the rail occur to the north of the footprint. alignment. Revision of the rail alignment has reduced the degree of fragmentation to a small area near the northern boundary of the most southern polygon of this unit within the Study Area. 7. Eucalyptus camaldulensis - Casuarina 106.4 8.3 2.45 These drainage systems are now Not relevant as not obesa low closed forest (+/- traversed by the Construction recorded to date in this Melaleuca rhaphiophylla and Cyperus Service Road and the Northern unit gymnocaulos) on river drainage Port Access Road, causing systems localised impact. The area impact is minimal. The roads will be engineered to ensure flows are not disrupted. 8. Grevillea - Melaleuca and other low 52.6 15.9 10.29 The single polygon of this unit Not relevant as not shrubs over Borya sphaerocephala within the Study Area will be recorded to date in this mats on laterite/sandstone divided into two disjunct areas, unit therefore local fragmentation is significant. The regional distribution of this unit will be assessed following a further survey but is considered likely to occur further east. The linkage between this occurrence and any other occurrences further east is already weak due to agricultural

37 Vegetation Sub-Association (Ecologia Area Proposed Revised Degree of fragmentation to Impact to Melaleuca 2010a) within Cumulative Proposed vegetation as a result of huttensis records study Disturbance - Cumulative Revised Proposed Disturbance within each area (ha) PER (ha) Disturbance vegetation unit (ha) clearing and will not be significantly changed by the Proposal. 9. Acacia acuminata sparse low trees over 203.6 23.1 24.15 The distribution of this unit within Not relevant as not Acacia tetragonophylla shrubs the Study Area is almost entirely recorded to date in this (+/- Eucalyptus spp. Mallees, grasses and to the north of the footprint. Both unit weedy herbs) on low gentle to the PER and revised footprint moderate hill slopes result in fragmentation of the most southern portion 10. Tall shrubs of Grevillea – Melaleuca – 23.9 0.7 0.64 The distribution of this unit within Neither the PER nor Acacia spp. over species rich open heath the Study Area is already revised footprint on sand over laterite on undulating plains fragmented by agricultural impacted records within clearing. As it lies almost entirely this unit. to the east of the revised impact there is negligible impact to the degree of fragmentation. 11. Melaleuca cardiophylla – Grevillea 81.9 52.0 39.55 As a large proportion of this unit The revised footprint argyrophylla dense tall heath on lies within the rail corridor it will be has reduced the degree Tamala limestone hill crests significantly impacted and the of fragmentation of this level of local fragmentation is species as most known high. Regionally the linkage to records are now other areas of this unit is outside the area of negligible due to agricultural and impact. urban clearing 14. Eucalyptus spp. mixed revegetation on 46.0 9.1 2.95 The northern portion of this unit Not relevant as not previously disturbed land will be completely removed. As recorded to date in this this unit results from revegetation unit with species of mixed provenance there is no linkage to other areas regionally.

38 Vegetation Sub-Association (Ecologia Area Proposed Revised Degree of fragmentation to Impact to Melaleuca 2010a) within Cumulative Proposed vegetation as a result of huttensis records study Disturbance - Cumulative Revised Proposed Disturbance within each area (ha) PER (ha) Disturbance vegetation unit (ha) TOTAL 689 124.1 93.28

39 OPR is currently finalising an Offsets Strategy in consultation with the EPA and DEC EMB The proposed offset package will address the loss of Carnaby habitat, Priority 1 floral species and will consider the reduction in vegetation types impacted by the Proposal, including coastal vegetation types. 3. Marine Environment

3.1 Coastal Processes

Submitter Submission and/or issue PER (sub #) modified Public (5) Submission contends that the proposed marine port No infrastructure associated with the terrestrial port will Asmussen permanently interrupt long-shore drift and cause Family Trust changes to the marine environment. (3) It is considered that the burden of cost which will result from impacts to sand displacement and the marine environment caused by proposed infrastructure will become the fiscal responsibility of tax payers into the future.

Suggests permanent sand displacement can be avoided by designing a port that allows 100 metres of jetty on piles where rock wall meets the shore and by moving the rock platform out to sea by a similar distance.

The construction of the ODP facilities and potential longshore drift impacts are not within the scope of the Port Terrestrial PER. This has been previously assessed by the EPA under s38 of the Environmental Protection Act 1986 (EP Act). The EPA concluded, within Bulletin 866, that a port could be placed in this area and managed to ensure that unacceptable impacts to the marine and coastal environment are avoided. The EPA assessed these issues in its consideration of the detailed PER for the port proposal developed by the State Government at the time (Alan Tingay & Associates & Welker Environmental Consultancy, 1997). The issue of long-shore drift and changes to the marine environment are addressed in MS469 (refer consolidated commitment 8 and 9 of MS469) for the approved ODP. The Port Terrestrial Proposal has no additional implications for coastal processes. Consolidated Commitment 8 and 9 of MS469 requires the preparation of a Coastal Stability Management Plan, which includes the development and implementation of a program to monitor the redistribution of sand accumulated against the port breakwater and to minimise the possibility of shoreline erosion. This Coastal Stability Management Plan is currently being developed in consultation with DEC and requires approval from the EPA. Once approved, these plans will be made publically available.

Furthermore, port design, as suggested in this submission (100m jetty on piles), is not considered a viable option. Whilst the suggested design may allow longshore drift in the short term, it would significantly increase the occurrence of long-period wave and substantially reduce harbour tranquillity. This would result in unsafe conditions being created within the harbour impacting on the Port’s operability and

40 therefore viability. Furthermore, the inclusion of gap between the causeway and the Oakajee Beach would unacceptably reduce the integrity of the Port structure. Despite the above, OPR is committed to managing longshore drift effects, should they occur as a result of the ODP. OPR anticipates that longshore drift will be minimal; however, there is currently a body of work being undertaken to assess the sediment transport in the region and the effect that the port development will have on this transport. Preliminary findings suggest that the transport will be minimal, being approximately 50,000m3 of sediment moving northwards annually (with some southern movement during winter). The northerly sand movement may result in sand accumulating against the breakwater. It is anticipated that accumulated sand bypassing will need to be implemented, the details of which will be discussed within the Coastal Stability Management Plan required by Consolidated Commitment 8 and 9 of MS469.

3.2 Benthic Habitat

Submitter Submission and/or issue PER (sub #) modified Drummond Submission believes degradation and severe damage No Cove to the benthic environment & sea bed in particular, Progress should be avoided by using the Geraldton Port grounds Association for anchorage of shipping. (4)

Shipping and potential impacts to the benthic environment are not within the scope of the Port Terrestrial Proposal; however, these aspects will be managed under MS469, as part of the approved ODP. In accordance with the requirements of MS469, an assessment of the proposed anchoring location will include the identification of potential impacts to the benthic environment and any measures implemented to avoid and manage these potential impacts to an acceptable level.

MS469 requires the development and implementation of a series of Environmental Management Plans to ensure that impacts to the marine environment, including Benthic Primary Producer Habitat (BPPH), are managed appropriately. These plans require the approval of the EPA prior to the commencement of construction and operation. Upon completion, these plans will be made publically available.

3.3 Monitoring

Submitter Submission and/or issue PER (sub #) modified Drummond Marine surveys to determine long term impacts to No Cove the surrounding marine environment and its Progress ecosystems, should be ongoing. Association (4)

In accordance with management strategy MR2 (in table 7‐18 of the PER) a Desalination Discharge Environmental Management Plan (DDEMP) has been prepared to document OPR’s monitoring and management commitments to ensure compliance within the LEPA and HEPA. The key commitments of the DDEMP include:

41  Detailed diffuser design to maximise initial dilution of desalination discharge.  Desalination discharge modelling to demonstrate that dilution will enable ecological protection criteria to be met.  A Model Verification Study to confirm that the diffuser is meeting the modelling predictions for dilution.  A Water Quality Monitoring Program to confirm that water quality meets HEPA criteria at the LEPA boundary.  Ongoing Brine Characterisation monitoring (inline) to confirm that brine composition is maintained such that HEPA criteria will continue to be met at the LEPA boundary. Trigger levels, contingency measures and reporting requirements are also documented in the DDEMP.

Ecotoxicity testing at Perth, Adelaide and Wonthaggi desalination plants found that a dilution of 30:1 is more than adequate to provide high protection to the ecosystem (CEE 2010, Appendix A). Based on this information, a conceptual diffuser design was developed by CEE (2010) to reach a minimum initial dilution of 34:1 within 30 m of the diffuser under worst case discharge conditions (i.e. calm current and low discharge velocity). Allowing for some conservatism while still maintaining a relatively small area, the boundary for a low ecological protection area (LEPA) is therefore proposed to extend 50 m in all seaward directions from the diffuser. Beyond that, all areas will be managed as a high ecological protection area (HEPA). The location of the LEPA/HEPA boundary is shown in (Figure 1).

Since publication of the PER, further hydrodynamic modelling has been undertaken (APASA 2010, Appendix B). The model results were assessed against a trigger value for the median salinity difference between the existing and proposed conditions. This trigger value is defined at 0.8 ppt at a depth 0.5 m above the seabed, consistent with high ecological protection areas (HEPA) as described in “Environmental Quality Criteria Reference Document for Cockburn Sound (2003‐2004) ‐ A supporting document to the State Environmental (Cockburn Sound ) Policy 2005” (EPA 2005). The hydrodynamic modelling results are shown graphically in Figure 2 and show that under low energy conditions a maximum median salinity difference of 0.35 ppt would result within the receiving environment and therefore the trigger level As outlined within Section 7.6.3 of the Port Terrestrial PER, the desalination plant will pose insignificant impacts to marine water quality and Benthic Primary Producer Habitat (BPPH) due to the location and design of the desalination plant and diffuser.

As outlined within Section 7.6.3 of the Port Terrestrial PER, the desalination plant will pose insignificant impacts to marine water quality and Benthic Primary Producer Habitat (BPPH) due to the location and design of the desalination plant and diffuser, while any potential impacts will be constrained within the designated LEPA (Figure 7.2 within the Port Terrestrial PER).

Notwithstanding the above monitoring associated with the operation of the desalination plant, MS469 requires a substantial monitoring effort to be implemented prior to the commencement of construction for the approved Port Marine facility. In this regard OPR has implemented a significant marine monitoring program that has collected a substantial volume of information in relation to the following issues:  Marine flora and fauna including marine mammals and benthic primary producer habitat;  Sediment monitoring;  Water quality monitoring;

42  Local meteorological information; and  Local ocean current and wave information. MS469 requires the preparation and implementation of numerous Environmental Management Plans which will monitor and manage potential impacts associated with the approved Deepwater Port facility. Ongoing studies are being undertaken to support these plans. These Environmental Management Plans will undergo extensive consultation and will be submitted to the EPA for approval. Once approved, these plans will be made publically available.

3.4 Water Quality

Issue 1: Submitter Submission and/or issue PER (sub #) modified Asmussen Submission suggested that the proposed development No Family may cause air pollution which could impact on the Trust (3) quality of rainwater in the local area. Properties near the buffer zone are stated as being dependant on rain water, and it is considered that poor drinking water causing adverse impacts to human health may result from the development’s emissions.

It is suggested the proponent connect residents nearby or within the buffer zone to scheme water, at the expense of the proponent.

The provision of a buffer zone around the OIE is intended to address the protection of neighbouring residences from air quality issues, such as dust deposition. In addition, OPR will implement strategies for the management of air quality and dust emissions, as outlined in Section 7.8 of the Port Terrestrial PER. The Port Terrestrial Proposal only includes the storage and handling of Iron Ore products. Iron Ore dust is considered a non-hazardous material; but OPR will still monitor and respond to any issues should they arise.

Existing dust levels at the Oakajee site are relatively high with recorded background levels shown to exceed the National Environmental Protection Measure (NEPM) PM10 standard eight times between July 2007 and June 2008. Despite background levels, modelling suggests that Iron Ore dust levels resulting from Proposal operations, will meet relevant standards at all sensitive receptors surrounding the development and no impact on water quality is expected.

Future proposed developments within the OIE and its Buffer are not within the scope of this Proposal. Nevertheless, it is noted that the Shire of Chapman Valley (SoCV) Town Planning Scheme (TPS) requires that all future proposals within the OIE to be referred to the EPA for consideration under the EP Act.

3.5 Groundwater impacts to heritage values

Issue 1: Submitter Submission and/or issue PER (sub #) modified Department Potential detrimental impacts on Aboriginal heritage No

43 of sites from groundwater drawdown have not been Indigenous addressed directly in the PER. Heritage values of Affairs (2) sites may be altered by changes to groundwater levels in the area and a reduction in groundwater outflow to local areas.

Further information is requested regarding impacts associated with changes to groundwater flow rates.

OPR does not anticipate any significant groundwater abstraction for the Port Terrestrial Proposal, as the majority if not all of water required for construction and operation will be supplied by desalination facilities. Groundwater abstraction is being further investigated for the purpose of supplying the Proposal’s construction requirement along the rail corridor (refer to assessment Rockwater Assessment, August 2010) but it is unlikely to be a suitable primary source of water for the ongoing operational phase of the Proposal. It is noted that groundwater abstraction is managed by the DoW under the Rights in Water and Irrigation Act 1914 (RiWI Act). Licences issued under this Act will ensure that OPR’s groundwater abstraction does not unacceptably impact the environment which will include sites of aboriginal heritage significance. OPR is aware of its obligations under the RiWI Act particularly with regards to the management of groundwater abstraction. OPR will ensure any groundwater abstraction is conducted to ensure the natural landscape, including heritage sites and significant vegetation, are protected and water is drawn in a sustainable manner.

Issue 2: Submitter Submission and/or issue PER (sub #) modified Department Rehabilitation works and contamination of natural No of landscape features from irradiated process water or Indigenous waste product may have detrimental impacts to Affairs (2) cultural heritage values of the area.

It is expected that such impacts be managed in consultation with the Yamatji Marlpa Aboriginal Corporation and traditional owners

Traditional owners are and will continue to be consulted on all aspects of environmental management, in particular in regard to issues that could potentially affect cultural values of the area. Compliance with legislative requirements relating to waste management will ensure that no significant adverse environmental or heritage impacts are experienced as a result of the Proposal. Waste production during both the construction and operational phases, including the production of process wastewater and other wastes, will be no different to similar construction sites and operational port facilities located elsewhere in Western Australia.

The relatively small volumes of controlled and hazardous wastes (mainly hydrocarbons) will be managed and transported in accordance with the Dangerous Goods Safety Act 2004 and the Environmental Protection (Controlled Wastes) Regulation 2004.

Putrescible and construction wastes that are not recycled will be disposed of at an appropriately licensed facility within the local Geraldton region. Liquid waste that is generated from wastewater treatment plants, which are disposed off via irrigation networks, will be done so in accordance with the EP Act and Health Act 1911 (Health Act).

OPR will ensure that its management of waste complies with legislative requirements. OPR is aware of the pollution and environmental harm provisions under Section 49 and 50 of the EP Act, which makes it illegal to cause pollution or environmental harm. OPR will also seek to reduce and minimise its waste production via the implementation of a Waste Management Plan that will be based on the hierarchy of waste minimisation which includes:

 Waste avoidance / reduction;  Reuse, recycling and reclamation;  Waste treatment; and  Waste disposal.

On this basis it is considered that significant impacts on the environment from waste production will be avoided.

45 3.6 Desalination plant

Submitter Submission and/or issue PER (sub #) modified Department It is unclear from the PER as to the intention for the No of Health (11) desalination plant to be used as a potable water supply in the future or not. If there is any possibility of the desalination plant to be used as a potable water supply a full review must be conducted in accordance with the following processes:  Comply with the Australian Drinking Water Guideline 2004  Establish a Drinking Water Quality Management Plan, including the extraction points, water supply pipeline, the water treatment process and storage facilities.  Attention will also need to be given to any potable water tanks located on different sites and how it will be safely transported and maintained.  Establish drinking water quality reporting procedures with WA Health.

Potable water supply for the port terrestrial construction camp will be supplied by a temporary desalination facility, which will be subject to a Department of Health (DoH) Drinking Water Quality Management Plan. Management of the temporary desalination plant will be included within the scope of the Deepwater Port Construction Environmental Management Plan, as required by MS469. OPR is committed to complying with the requirements of the Australian Drinking Water Guidelines 2004 and will obtain necessary approvals from the DoH, including the preparation and implementation of a single Drinking Water Management Plan for the entire Proposal (including the Rail Proposal the subject of a separate assessment), or numerous Drinking Water Quality Management Plan’s for individual water supplies. Should potable water tanks be installed and potable water be supplied to site via water truck, approval will be obtained in accordance with the DoH Guidelines for the Bulk Cartage of Drinking Water.

3.7 Water Availability

Issue 1: Submitter Submission and/or issue PER (sub #) modified Department Any groundwater abstraction associated with port No of Water (9) activities will require a groundwater license under the Rights in Water and Irrigation Act 1914.

OPR is aware of their responsibilities under the Rights in Water and Irrigation Act 1914 and will submit applications, as necessary, to the DoW, prior to the abstraction of ground or surface water.

46 Issue 2: Submitter Submission and/or issue PER (sub #) modified Department Suggests it is not clear if the port facility construction No of Health camp will be supplied by bore or the Water (11) Corporation Northampton line. This needs to be clarified.

The Port facility construction camp does not form part of the Port Terrestrial Proposal. 4. Dust and Air Quality

4.1 Dust management - community

Issue 1: Submitter Submission and/or issue PER (sub #) modified Drummond Submitter is concerned that due to the strong southerly No Cove winds, any vehicle movements in the local area can Progress create problems with the control of dust and that there Association is no water available to control impacts. (4) What are the mechanisms available to control such impacts?

It is unlikely that sensitive receptors outside of the OIE will be impacted by any dust emissions from the proposal. Nevertheless, OPR is committed to reducing dust emissions to ensure that the local environment within the OIE is afforded an appropriate level of protection from any potential fugitive dust emissions. In this regard, a comprehensive dust control management strategy will be implemented within the OIE (refer to Section 7.8.4.2 of the Port Terrestrial PER).

As outlined in Section 7.8.4.2 of the Port Terrestrial PER, water carts will be available both during construction and operation, to ensure dust impacts are minimised. Water used to control dust, will be obtained from numerous sources including sea water, desalination water and to a small extent, groundwater.

An Air Quality Management Plan will also be developed and implemented for the operational phase of the Proposal that will include objectives, targets, and detailed management actions to minimise dust emissions at source, monitoring, incident management, and contingency measures, which are based on continuous improvement principles.

Issue 2: Submitter Submission and/or issue PER (sub #) modified Department of Location of sensitive receptors in relation to the No Health (11) OIE is unclear and should be included.

The construction accommodation camp will only be present within the OIE area during the construction phase of the Proposal. OPR will treat the construction accommodation camp as a sensitive receptor and appropriate controls will be

47 implemented to ensure that the workforce is protected. Dust from construction areas is expected to be manageable through the use of water carts and other standard construction dust management techniques. During the operations phase, there will be no sensitive receptors located within the boundary of the OIE. Sensitive receptors surround the OIE buffer; however there are no sensitive receptors situated within the OIE buffer. The sensitive receptors depicted in Figures 7.5 (dust emissions), 7.6 (PM10), 7.7 (Total Suspended Particulates) and 7.8 (dust deposition) were chosen to represent the closest sensitive receptors in each direction, in relation to the Port Terrestrial Proposal and OIE boundary. For the purpose of this Response to Submissions document, Figures 7.5 to 7.8 are outlined below, as Figure 4, 5, 6 and 7. Furthermore, additional dust modelling is currently being conducted, which will assist in the design and location of all dust monitoring equipment within the Proposal area. No significant impacts relating to noise, vibration, air quality, light or visual amenity from the Proposal are anticipated given the significant buffer allowed for the OIE and the distance between the port operations and sensitive receptors.

48 265000mE 270000mE

Beach

Coronation 6840000mN B1 Road B2 6840000mN

R5 B3

I1 I5 6835000mN

6835000mN I2 I6 I9 I12

I3 I7 I10 Highway

B5 I4 I8

Coastal I11

Road Peak 0 1km500m White 6830000mN B6 West R3 Scale R2 MGA94 (Zone 50) R1 6830000mN

LEGEND B7 Oakajee Deepwater Port (MS 469 approved) OPR Terrestrial Port Development B8 (PER Assessment No 1817) Indicative Locations for Support Facilities to the North Approved Port (other Approval Mechanisms) OIE - Special Control Area (Industry Buffer) Dust Emission Source Modelled Receptor Location Sensitive Receptor Cadastral Boundary Reserve Land vested in the GPA

265000mE 270000mE Notes: Drawn: Figure No: Sensitive Receptor and Source Locations supplied by SKM CAD Resources Cadastral Data supplied by Landgate Location of Dust Generation Sources CAD Resources File No: and Receptors Modelled 5 g1660_Pub_PER_P_Resp_F005 265000mE 270000mE

Beach 6840000mN Coronation Road 6840000mN

50 50

70 70

130 130 6835000mN 6835000mN

70 100

190

Highway 50

Coastal

0 500m 1km

Scale

MGA94 (Zone 50) 6830000mN West R3 LEGEND R2 Oakajee Deepwater Port (MS 469 approved)

6830000mN R1 OPR Terrestrial Port Development (PER Assessment No 1817) Indicative Locations for Support Facilities to the Approved Port (other Approval Mechanisms) Maximum 24-hour average (NEPC, 2007) Sensitive Receptor

OIE - Special Control Area (Industry Buffer) North Cadastral Boundary

265000mE 270000mE Notes: Drawn: Figure No: Isopleths Supplied by SKM CAD Resources Predicted Maximum 24-hr PM10 Cadastral Data Supplied by Landgate 3 CAD Resources File No: Ground Level Concentrations (ug/m ) 6 g1660_Pub_PER_P_Resp_F006 for Oakajee Port 265000mE 270000mE

Beach 6840000mN Coronation Road 6840000mN

90 90

150 150

6835000mN

410 410 6835000mN

250

150

Highway 90

0 500m 1km Coastal

Scale MGA94 (Zone 50)

LEGEND 6830000mN Oakajee Deepwater Port (MS 469 approved) OPR Terrestrial Port Development West R3 (PER Assessment No 1817) R2

6830000mN Indicative Locations for Support Facilities to the R1 Approved Port (other Approval Mechanisms) 24-hour Standard Kwinana EPP Area C Standard (EPA, 1992) 24-hour Limit Kwinana EPP Area C Standard (EPA, 1992) Sensitive Receptors

OIE - Special Control Area (Industry Buffer) North Cadastral Boundary

265000mE 270000mE Notes: Drawn: Figure No: Isopleths Supplied by SKM CAD Resources Predicted Maximum 24-hr TSP Cadastral Data Supplied by Landgate 3 CAD Resources File No: Ground Level Concentrations (ug/m ) 7 g1660_Pub_PER_P_Resp_F007 for Oakajee Port 265000mE 270000mE

Beach 6840000mN Coronation Road 6840000mN

2 2 4

6835000mN

16 8

2 6835000mN

4 8

2 Highway

Coastal

0 500m 1km

Scale MGA94 (Zone 50) 6830000mN

LEGEND West R3 Oakajee Deepwater Port (MS 469 approved) R2 OPR Terrestrial Port Development

6830000mN R1 (PER Assessment No 1817) Indicative Locations for Support Facilities to the Approved Port (other Approval Mechanisms) NSW EPA Dust Deposition Standard (2005) Sensitive Receptors

OIE - Special Control Area (Industry Buffer) North Cadastral Boundary

265000mE 270000mE Notes: Drawn: Figure No: Isopleths Supplied by SKM CAD Resources Cadastral Data Supplied by Landgate Predicted Maximum Monthly Deposition CAD Resources File No: Levels (g/m2 ) for Oakajee Port 8 g1660_Pub_PER_P_Resp_F008 4.2 Dust management – Industrial Estate

Issue 1: Submitter Submission and/or issue PER (sub #) modified Shire of Submission requests that the potential impact of dust in No Chapman the industrial estate area in general be expanded upon in Valley (1) the PER.

OPR has considered the potential impacts of dust within the OIE within the Port Terrestrial Proposal. For example, OPR installed a baseline dust monitor within the OIE in February 2010, which determined that existing dust levels at the Oakajee site are relatively high, with recorded background levels shown to exceed the NEPM PM10 numerous times throughout the year. Furthermore, dust modelling that was conducted as part of the Port Terrestrial PER and depicted in Figure 7.6 and 7.7 indicate the likely levels of dust to be experienced within the OIE boundary.

OPR has developed management strategies, which will be implemented during construction and operation, to ensure potential impacts from dust, generated by the Proposal, are avoided. These management strategies will be implemented to protect the area within the OIE boundary as well as the sensitive receptors situated beyond the OIE boundary. These dust control measures are outlined within Section 7.8.4.2 of the Port Terrestrial PER.

Furthermore, prior to construction and commissioning of the Proposal, OPR will be required to comply with prescriptive conditions, applied by the DEC, via the Part V EP Act Works Approvals and Licences. It is anticipated that potential conditions within these approvals may include, but not be limited to:

 Establishing monitoring sites;  Particulates monitoring;  Regular reporting;  Implementation of water suppressing techniques; and  Implementation of additional engineering controls.

4.3 Dust management – construction Issue 1: Submitter Submission and/or issue PER (sub #) modified Department Proposed Dust Management Plan (DMP) does not Yes of Health include the accomodation camp as a sensitive receptor, (11) which appears to be in close proximity to the construction area.

As employees will experience longer periods of exposure to dust they will therefore be at greater risk of acute respiratory dust effects.

DMP should ensure dust levels are kept under control around the camp, and that the accomodation camp is subject to dust management and mitigation measures.

OPR is committed to protecting the workforce from potential dust impacts and will comply with relevant workplace and occupational health and safety requirements. OPR’s construction accommodation camp will be treated as a sensitive receptor and appropriate controls will be implemented to ensure that the workforce is protected. The construction accommodation camp will only be present within the OIE area during the construction and commissioning phase of the Proposal.

OPR will prepare an Air Quality / Dust Management Plan, to be implemented during construction and operation of the camp, which will include dust management procedures. This Air Quality Management Plan will be developed in accordance with the Occupational Safety and Health Act 1984 and in consultation with WorkSafe.

Issue 2: Submitter Submission and/or issue PER (sub #) modified Asmussen Submitter is concerned that saline water is to be used for No Family dust suppression and the residual impacts this will have Trust (3) on vegetation in the region.

It is requested that OPR monitor the health of vegetation focusing on impacts to vegetation from dust or saline water used for dust suppression.

OPR will manage its use of saline water for dust suppression to avoid significant decline in vegetation health. Vegetation health monitoring will be included within the Flora and Vegetation Management Plan, which is discussed in detail in Section 1.5 above. To ensure impacts are avoided, OPR will implement the following:

• Application of salt water to be regulated and road verges to be raised/bunded to ensure that run-off is avoided; • To ensure that vegetation impacts from overspray are avoided, dribble bars will be used instead of spray bars on all water trucks, when in close proximity to native vegetation; • All construction roads will be bunded to prevent salt water run-off; and • Stormwater run-off from roads will be directed to swales and retained in accordance with appropriate standards such that sediments are retained and water is infiltrated in situ.

4.4 Dust management – operational

Issue 1: Submitter Submission and/or issue PER (sub #) modified Department The choice for the location of the beta attenuation No of Health monitor (BAM) is not clear. Wind data suggests during (11) the summer southerly wind dominates.

The BAM appears to be located very close to the coast and not in line with the wind direction.

54 This may not be a problem if the location of the sensitive receptors in this direction were known.

The placement of ambient air monitors will be in accordance with ‘Australian/New Zealand Standard 3580.1.1:2007 Methods for sampling and analysis of ambient air Part 1.1: Guide to siting air monitoring Equipment ’ (AS/NZ 3580.1.1:2007). This provides that the monitor shall be located in a clear area (with a clear sky angle of 120 degrees), and away from potential sources of chemical or physical interference. Air monitors shall be located in consideration of surrounding land uses with the objective of targeting ambient air conditions at the site of sensitive receptors (where applicable), at the Proposal boundary and at the source of Proposal related dust. The locations of dust monitoring equipment as outlined within the Air Quality / Dust Management Plan are conceptual only. OPR is currently conducting baseline dust monitoring at the site and in addition, a detailed dust modelling assessment is currently underway, which will also assist in the design of future dust monitoring program. The detailed dust modelling assessment will:

• incorporate magnetite product specific particle lift information to provide realistic expected dust levels; • determine key sources of dust; • allow accurate determination of the success of a number of dust mitigation measures; and • provide detailed information that can be used to accurately sight dust monitoring locations.

For the operations phase, there will be no sensitive receptors located within the boundary of the OIE buffer; however, sensitive receptors situated beyond the OIE buffer boundary will be taken into account when the location of dust monitoring equipment is considered. Issue 2: Submitter Submission and/or issue PER (sub #) modified Department The Dust Management Plan indicates targets for Total No of Health Suspended Particulates and dust gauges however their (11) locations are not indicated.

Refer response to issue 1 Section 4.4 above. 4.5 Dust management – general Issue 1: Submitter Submission and/or issue PER (sub #) modified DEC – Air It is recommended given the uncertainty regarding No Quality emissions, particularly for magnetite ores, that the Management proponent undertake an emissions validation study Branch (14) once the port is operating to confirm dust levels are within the PER range forecast.

Agreed, OPR has committed to undertake a dust validation study once the port is operating to confirm dust levels are within acceptable levels.

Issue 2: Submitter Submission and/or issue PER (sub #) modified DEC – Air Submission recommends that for future strategic No Quality assessment within the port facility, and the proposed Management adjacent industrial zone, it is recommended that Branch (14) background particulate monitoring be undertaken as soon as possible before the development commences. Site specific monitoring will provide more relevant measures of background air quality than Geraldton data and can be used in subsequent assessments and performance monitoring of dust management controls.

Similarly monitoring should take place in the proposed industrial zone.

Agreed. OPR commenced baseline dust monitoring at Oakajee in November 2009. This monitoring station will continue to perform dust monitoring up until operations commence. Baseline dust monitoring will be used to confirm compliance with Port Terrestrial Proposal forecasts, and will ensure appropriate management actions and contingency controls are refined and implemented before dust becomes an issue. 5. Noise

5.1 Noise - operational

Issue 1: Submitter Submission and/or issue PER (sub #) modified DEC – Noise Submission noted that the noise predictions in the No Regulation PER show the 30dB(A) noise contour from port Branch (8) operations spreading out to the boundary of the Oakajee buffer. While this noise level demonstrates the noise from the port will be at a level that will ‘not significantly contribute’ to an exceedance of the 35dB(A) assigned LA10 level for night time (and is therefore in compliance with the noise regulations), it does not represent best practice management of cumulative noise levels, as outlined in EPA Guidance No.8 – Environmental Noise.

The goal should be that the individual industry noise contributions are established such that the total noise level at the buffer boundary should not exceed 35dB(A) at night.

The predicted noise level at the OIE buffer is not expected to exceed 35dB(A) at night. The noise predictions outlined within the PER demonstrate a 25dB(A) noise contour from port operations spreading towards the boundary of the OIE buffer.

56 Figure 4.4 as contained within Appendix K of the Port Terrestrial PER has been updated, as outlined below, which shows the 25dB(A) more clearly. For the purposes of this document, Figure 4.4 is depicted as Figure 8.

57 Figure 9

Noise level LA10 dB

<= 25 <= 30 <= 35 <= 40 <= 45 <= 50 2 <= 55 >55

Signs and symbols

Oakajee Industrial Area 3 Point source Line source 1 Point receiver

G L Oakajee Deepwater Port and Terrestrial Iron Ore Facility L E Lloyd George Acoustics O O by Daniel Lloyd Predicted Noise Levels Assuming All Plant Operating - Wind from All Directions Y R D G [email protected] E LA10 Noise Level Contours (08) 9300 4188 Acoustics Given the expected individual industry noise contribution from the Proposal is 25dB(A), noise from the port operations would not contribute to a noise that is 35dB(A) or greater at the boundary. No significant impacts relating to noise or vibration from the Proposal is anticipated given the significant buffer allowed for the OIE, and the distance between the port operations and sensitive receptors. The noise modeling indicates that noise emissions for both construction and operations are expected to meet the assigned level criteria as outlined within the Environmental Protection (Noise) Regulations 1997 at all noise sensitive receptors outside of the OIE.

To validate the model outputs OPR will implement a noise monitoring program during both construction and operational phases of the Proposal. Should this monitoring identify any issues, OPR will take action to reduce noise from its activities to acceptable levels. Furthermore, OPR is committed to managing noise using a combination of noise reduction methods and will comply with the Environmental Protection (Noise) Regulations 1997 at all times. Noise reduction methods will include:

 Enclosed transfer points;  Enclosed car dumpers; and  Use of muffling on locomotives.

OPR will continue to investigate potential reductions to noise emissions during the final design stage of the Proposal. Any future development within the OIE will be required to ensure that its noise emissions do not cause cumulative noise levels at the buffer boundary to exceed 35dB(A). It is noted that similar ore handling facilities at Port Hedland and Dampier Port are located in closer proximity to residential areas (approximately less than 1 km and 3 km, respectively), which are known to cause noise management issues. To prevent a similar situation from arising, OPR has developed its Proposal within the OIE, which provides for a general buffer allowance when compared to these other ports. The Proposal is situated a significant distance to the nearest sensitive receptor (approximately 6 to 7 km), which will significantly contribute to the management of potential noise issues.

Issue 2: Submitter Submission and/or issue PER (sub #) modified DEC – It is stated that the noise contribution from the port – No Noise one of the most distant noise sources from the buffer Regulation edge – should be set well below 30dB(A), in order that Branch (8) other large industries that will be located closer to the buffer boundary should not be unduly constrained. As a result, the noise contribution from the port facilities should probably be set at a level of about 25dB(A).

The noise predictions outlined within the PER demonstrate a 25dB(A) noise contour from port operations spreading towards the boundary of the OIE buffer. Figure 4.4 as contained within Appendix K of the PER has been updated, as outlined previously as Figure 8, which shows the 25dB(A) more clearly.

Given the expected individual industry noise contribution from the Proposal is 25dB(A), noise from the port operations is not expected to contribute to a noise that

59 is 35 dB(A) or greater at the boundary. Furthermore, despite noise levels being higher at Coronation Beach in comparison to the remainder of the OIE buffer, it is unlikely that the 35dB(A) will be exceeded due to the confining of additional industrial noise within the OIE Area C: Strategic Industrial Zone.

As outlined in Section 5.1 – Issue 1 above, OPR will implement a noise monitoring program to validate model outputs, during construction and operation of the Proposal.

6. Waste Management

6.1 Contamination

Issue 1: Submitter Submission and/or issue PER (sub #) modified Shire of Submission states concern regarding geology of the site Yes Chapman resulting in rapid infiltration for surface water, and the Valley (1) lack of mention of contaminant traps in the PER.

Due to the porous nature of the sands, there is potential for a range of contaminants to be transferred to the groundwater, including salt should saline water be used for construction.

In accordance with Australian Standards and best practice, facilitated infiltration of surface water will only be provided for in areas with low to no risk of contamination. Infiltration will be actively prevented in areas where such risk does exist. Laydown and workshops areas will be contained and will not rely on infiltration, but will utilise collection ponds, sumps and oil-water separators to ensure contaminated surface water does not infiltrate groundwater sources. Pollution from chemicals, including hydrocarbons will be managed through the implementation of a Hazardous Materials and Contamination Management Plan, which will ensure that surface water contamination is avoided. Saline water will only be utilised on cleared areas and away from native vegetation. In addition, groundwater is expected to be relatively saline underlying the Port Terrestrial development, due to the proximity to the coast. Groundwater investigations have determined brackish to saline water is present in bores near the coast at Oakajee (Rockwater, 2010). The use of saline water during construction is unlikely to have any impact on groundwater sources, due to the relatively short construction period and the general lack of fresh groundwater resources in the area.

Issue 2: Submitter Submission and/or issue PER (sub #) modified Shire of Submission considers that the proposed hazardous No Chapman materials and contamination management plan does not Valley (1) give consideration to cumulative impacts associated with multiple vehicle movements and general hydrocarbon loss and exhaust.

Fuel usage for vehicles and vehicle emissions was not considered to be a dominant source of emissions as compared to power generation and clearing and was not included in the discussion of greenhouse gases in the Proposal. OPR acknowledges that although it is unlikely to be a significant source, it could have been presented in the PER and will be included in the scope of the Port Terrestrial Greenhouse Gas Management Plan. Nevertheless, these emissions will be monitored and reported in accordance with the requirements of the National Greenhouse and Energy Reporting Act 2007 (NGER Act).

6.2 Wastewater

Issue 1: Submitter Submission and/or issue PER (sub #) modified Department Submission is concerned that the presentation of Yes of Health method for how the wastewater generated by the port (11) facilities or the slightly distant port construction camp will be treated and disposed of, in the coastal environment is unclear.

Design of the port wastewater treatment plant (WWTP) and construction camp WWTP facilities is currently underway. It is likely that wastewater will be treated at the camp / port site and disposed off via spray irrigation or reused for dust suppression during construction and operation. Wastewater may also be removed via licensed liquid waste disposal contractors and taken to a licensed facility for disposal. Once the method of disposal is confirmed, OPR will obtain the relevant approvals from the DoH, DEC and other relevant government agencies prior to construction and operation of these facilities. Spray irrigation areas will be located a considerable distance from the coastal environment and are therefore unlikely to impact these areas. Furthermore, OPR will manage these facilities in accordance with the requirements of works approvals and licences to be issued by the DEC under Part V of the EP Act.

Issue 2: Submitter Submission and/or issue PER (sub #) modified Department Suggestion that if LandCorp are considering a Yes of Health wastewater treatment facility for the greater industrial (11) zone, the proponent should review whether this is an option to service the port infrastructure and local construction camp.

Noted. Should LandCorp develop a WWTP / facility in time for the OPR Proposal construction, OPR will consider this as an option.

61 7. Safety and Risk

7.1 Southern Access Roads

Issue 1: Submitter Submission and/or issue PER (sub #) modified Asmussen Submissions consider the original southern access road Yes Family alignment proposed by OPR near the Buller River to be Trust (3) unacceptable as it does not achieve required road safety standards on the highway. Main Roads WA (7) The conceptual alternative proposed is considered the preferred option for this reason.

It is also considered to be a more efficient and effective road network solution.

The southern port access road no longer forms a part of the Proposal. OPR will ensure that the final port access road meets the required Main Roads Western Australia (MRWA) safety standards and avoids significant impacts to the environment.

7.2 Traffic management & interface requirements

Issue 1: Submitter Submission and/or issue PER (sub #) modified Main Roads Submission considers the preparation and Yes WA (7) implementation of both a traffic impact assessment and traffic management plan, for both operational and construction phases of the project to be high priority. This will confirm implications of the project on road users and the road networks.

This information has previously been requested of the proponent however has not been provided to date.

OPR agrees, that a detailed traffic impact assessment and Traffic Management Plan is a high priority and will be required prior to construction of the Proposal. Traffic management was addressed broadly under ‘Other Social and Economic Factors’ in the PER (Section 7.14). Detailed site investigations are currently underway to finalise design and site layout plans for access to the Proposal. This information will allow planning for vehicle access, road crossing locations, including connection to the North West Coastal Highway and public interaction. This vehicle access planning will allow accurate input data to be used in the traffic impact assessment. The results of this assessment will be used to develop a detailed Traffic Management Plan in consultation with MRWA, Department of Planning (DOP) and local Shires prior to construction and operation of the Port Terrestrial Proposal. As detailed in the PER, the Traffic Management Plan will include designated traffic areas, measures for safe traffic interactions with the public and arrangements with local government and MRWA. It will include actions, such as:

62 • at intersections with public access roads, maintain a visual inspection and cleanup routine to minimise spill and spread onto public roads; • where practicable, traffic will be minimised at public access areas; and • specify ongoing consultation arrangements with Local Shires and MRWA.

Discussions and agreements are outside of the PER process. Issue 2: Submitter Submission and/or issue PER (sub #) modified Main Roads It is contended that plans and description of road Yes WA (7) access and road interface requirements for the project have only been presented at a general & high level to date.

These aspects of the project require detailed information and liaison with Main Roads WA.

Noted. OPR will consult with MRWA with regards to detailed road access design and road interface requirements for the Proposal’s construction and operational phases.

7.3 Fire Management

Submitter Submission and/or issue PER (sub #) modified Shire of No Fire Management Plan has been mentioned in the No Chapman PER. Water supplies and planned access in the event Valley (1) of fire have not been mentioned either.

Specific measures to limit the risk of inadvertent fire ignition should be incorporated in the proposed Emergency Management Plan.

As outlined in Table 7-10 of the PER for the Port Terrestrial Proposal, an Emergency Management Plan will be developed to limit the risk of inadvertent fire ignition. This will be in effect a Fire Management Plan for such purposes. The Emergency Management Plan will include control measures to be implemented both during construction and operation, regarding vehicle movement and maintenance, firebreaks, fire restrictions, fire fighting equipment, hot work procedures and training. This Emergency Management Plan will identify water supplies and planed access to be used in the event of an emergency or fire. The Emergency Management Plan will be prepared in consultation with Fire and Emergency Services Authority of Western Australia (FESA), the SoCV and the OEPA.

63 7.4 Pesticide Safety

Issue 1: Submitter Submission and/or issue PER (sub #) modified Department A pest management plan should be adopted to ensure Yes of Health (11) that the use of pesticides are minimised in the control of pests. Pests include insects, rodents, weeds, and where appropriate feral animals.

OPR is aware of its obligations under the Health Act and subsidiary regulations and will ensure Management Plans are developed in relevant guidelines. OPR will prepare and implement the following Management Plans and control programs, to ensure pests are appropriately managed:

 Feral animal control program  Weed control program  Vegetation and Flora Management Plan

In addition, the OPR Health and Safety team will prepare and implement an Insect Management Plan, in consultation with the DoH.

Issue 2: Submitter Submission and/or issue PER (sub #) modified Department Where pesticides are applied by a contractor then those Yes of Health (11) person(s) must hold a current pesticides operators license with appropriate endorsements and also hold a current pest management firm registration.

OPR will ensure that its contractors hold valid operator licenses and comply with the Health (Pesticides) Regulations 1956.

Issue 3: Submitter Submission and/or issue PER (sub #) modified Department Where fumigants are applied, a licensed fumigator with Yes of Health (11) the appropriate endorsements and employed by a registered fumigation firm is required. The fumigation must comply with Health (Pesticides) Regulations 1956, Australian Standards (AS 2476:2008) – General Fumigation Procedures and AQIS’ quarantine requirements.

OPR will ensure that its contractors hold valid licenses under the Health (Pesticides) Regulations 1956, Australian Standards (AS 2476:2008) – General Fumigation Procedures and Australian Quarantine and Inspection Service’s (AQIS) quarantine requirements.

64 7.5 Mosquito-borne disease control

Issue 1: Submitter Submission and/or issue PER (sub #) modified Department The mosquito-borne Ross River virus (RRV) can be Yes of Health active in the region, and the much rarer but potentially (11) fatal Murray Valley encephalitis virus has once been recorded as being active as far south as the Midwest (Dongara).

Changes to topography resulting from earthworks (e.g. the installation of pipelines or roads) must not allow run- off to create surface ponding.

The Proposal’s Health and Safety Team will be responsible for the preparation and implementation of an Insect / Mosquito Management Plan. The Insect / Mosquito Management Plan will be developed in consultation with relevant local Shire’s and the DoH and will take into account the key recommendations mentioned within the DoH submission. If required, OPR or its contractors will contact the DoH Mosquito-Borne Disease Control section for further information and during the preparation of the Insect / Mosquito Management Plan. It is anticipated that the majority of land in the proposal area will be relatively free draining and as such, ponding is not expected. OPR will pay particular attention to infrastructure within lower lying areas such as in proximity to the coast, Oakajee River and associated drainage lines. Issue 2: Submitter Submission and/or issue PER (sub #) modified Department Constructed water bodies (drainage ponds and swales, Yes of Health settling ponds, etc) must be located, designed and (11) maintained in a manner such that they do not create favorable mosquito breeding habitat. This may require the regular monitoring and harvesting of invasive vegetation to discourage mosquito breeding and to remove harborage areas for adult mosquitoes.

Noted. Refer to issue 1 Section 7.5 above.

Issue 3: Submitter Submission and/or issue PER (sub #) modified Department Water and effluent-holding tanks and other water- Yes of Health holding containers must be sealed to prevent mosquito (11) access and breeding. If this cannot be achieved, then they must be regularly monitored for mosquito larvae and treated with larvicide as necessary.

Noted. Refer to issue 1 Section 7.5 above.

65 Issue 4: Submitter Submission and/or issue PER (sub #) modified Department Port surrounds must be kept in a sanitary condition to Yes of Health (11) prevent mosquito incursions, requiring that there is no standing water and vegetation is kept to a minimum and proponent to be committed to working effectively with AQIS to prevent mosquito incursions.

A Mosquito Management Plan will be prepared in consultation with the DoH and the SoCV. It will include management actions to ensure areas which may potentially be used for mosquito breeding are checked following a rain event. In addition, OPR is committed to working with AQIS to ensure mosquito incursions are managed appropriately. 8. Social Values

8.1 Impacts to Recreational Access & Activities

Issue 1: Submitter Submission and/or issue PER (sub #) modified Asmussen Submissions highlight the closure of the Buller River- No Family Trust mouth recreation area and the Buller River beach (3) access road due to the Industrial Estate buffer requirements.

It is requested that the Industrial Estate buffer zone be amended to exclude the Buller River-mouth recreational area and that the area be formalised. It is also requested that the access track to the area from North West Coastal Highway (NWCH) be re-opened and facilities upgraded as a ‘trade-off’ for loss of recreational opportunities caused by the port.

The establishment of the OIE buffer zone does not form part of the Port Terrestrial Proposal, and hence the implications for the Buller River mouth recreation area have not been considered in the PER. This land is controlled by the SoCV and LandCorp and any queries and submissions in relation to this land, should be directed to these agencies. OPR will endeavour to discuss the concerns raised with the relevant local government.

Issue 2: Submitter Submission and/or issue PER (sub #) modified Asmussen Submitter requests the Buller River-mouth recreational No Family Trust area be clearly marked on maps within OPR’s (3) Terrestrial Port PER.

The Proposal is located approximately 3 km away from the Buller River at its closest point and will not impact this feature. The land associated with the Buller River is the responsibility of LandCorp and the SoCV; however, the Buller River has been considered were appropriate within the supporting Environmental Management Plans

66 that relate to the Port Terrestrial Proposal and that are required by MS469, including the Recreation, Fishing and Access Management Plan (RFAMP).

Issue 3: Submitter Submission and/or issue PER (sub #) modified Asmussenn Alteration to offshore coastal processes caused by No Family port infrastructure will lead to the degradation of Trust (3) windsurfing conditions in the area, in particular two areas anecdotally titled – “Spot X” and “Oakajee” - will be destroyed by the port and associated infrastructure.

Noted. The impact and implications of the removal of Spot X as a result of development of a port at Oakajee is not within the scope of the Port Terrestrial Proposal. This was addressed in the original PER for the ODP, assessed by the EPA and approved by the State Government in February 1998. The Port Terrestrial PER is an environmental impact statement specifically evaluating the impacts from additional works and infrastructure required by OPR in and around the approved port area, to support its own iron ore operations. Nevertheless, condition 15 and consolidated commitments 20, 21, 22, 23 and 24 of MS469 requires the Proponent to develop and implement a RFAMP, which includes an updated assessment of potential impacts to recreational activities (including surfing and windsurfing) and the removal of ‘Spot X’ and ‘Oakajee’ as a result of the deepwater port construction. This RFAMP will also include control measures and contingency management actions to ensure that remaining recreational areas are not compromised and loss of public amenity within the area is kept to a minimum. As part of the RFAMP