Pardoo Beef Corporation Pty Ltd

Pardoo Irrigated Agriculture Project - Stage 3 EPA Referral Supporting Document (Environmental Review)

P07-J06

31 January 2018

www.enviroworks.com.au

DISCLAIMER, CONFIDENTIALITY AND COPYRIGHT STATEMENT © EnviroWorks Consulting. All rights reserved. No part of this work may be reproduced in any material form or communicated by any means without the permission of the copyright owner. This document is confidential. Neither the whole nor any part of this document may be disclosed to any third party without the prior written approval of EnviroWorks Consulting and Pardoo Beef Corporation Pty Ltd. EnviroWorks Consulting undertook the work, and prepared this document, in accordance with specific instructions from Pardoo Beef Corporation Pty Ltd to whom this document is addressed, within the time and budgetary requirements of Pardoo Beef Corporation Pty Ltd. The conclusions and recommendations stated in this document are based on those instructions and requirements, and they could change if such instructions and requirements change or are in fact inaccurate or incomplete. EnviroWorks Consulting has prepared this document using data and information supplied to EnviroWorks Consulting by Pardoo Beef Corporation Pty Ltd and other individuals and organisations, most of whom are referred to in this document. Where possible, throughout the document the source of data used has been identified. Unless stated otherwise, EnviroWorks Consulting has not verified such data and information. EnviroWorks Consulting does not represent such data and information as true or accurate, and disclaims all liability with respect to the use of such data and information. All parties relying on this document, do so entirely at their own risk in the knowledge that the document was prepared using information that EnviroWorks Consulting has not verified. This document is intended to be read in its entirety, and sections or parts of the document should therefore not be read and relied on out of context. The conclusions and recommendations contained in this document reflect the professional opinion of EnviroWorks Consulting, using the data and information supplied. EnviroWorks Consulting has used reasonable care and professional judgment in its interpretation and analysis of the data. The conclusions and recommendations must be considered within the agreed scope of work, and the methods used to carry out the work, both of which are stated in this document. This document was intended for the sole use of Pardoo Beef Corporation Pty Ltd and only for the use for which it was prepared, which is stated in this document. Any representation in the document is made only to Pardoo Beef Corporation Pty Ltd. EnviroWorks Consulting disclaims all liability with respect to the use of this document by any third party, and with respect to the use of and reliance upon this document by any party, including Pardoo Beef Corporation Pty Ltd for a purpose other than the purpose for which it was prepared.

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REPORT DETAILS

Project Number:

Report Name:Pardoo Irrigated Agriculture Project - Stage 3 EPA Referral Supporting Document (Environmental Review)

AUTHORISATION FOR ISSUE

Report Version Date: 31 January 2018

Approved for Issue Name: Signature: Date: Director Laura Todd 31/01/2018

Please Note: This document is considered uncontrolled once printed.

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... 1 INTRODUCTION, BACKGROUND AND CONTEXT ...... 1 OVERVIEW OF THE PROPOSAL ...... 1 KEY CHARACTERISTICS OF THIS PROPOSAL – STAGE 3 ...... 1 ENVIRONMENTAL VALUES ...... 3 EXISTING CONDITION ...... 3 CONSERVATION SIGNIFICANT SPECIES ...... 3 RAMSAR AND NATIONALLY IMPORTANT WETLAND ...... 3 SUMMARY OF POTENTIAL IMPACTS, MITIGATION AND OUTCOMES ...... 4 HOLISTIC IMPACT ASSESSMENT ...... 10 1 INTRODUCTION ...... 11 PURPOSE AND SCOPE ...... 11 PROPONENT ...... 11 ENVIRONMENTAL IMPACT ASSESSMENT PROCESS ...... 13 ENVIRONMENTAL PROTECTION ACT 1986 (WA) ...... 13 ENVIRONMENT PROTECTION AND BIODIVERSITY CONSERVATION ACT 1999 (CTH) 13 OTHER APPROVALS AND REGULATION ...... 13 TENURE AND STATE AGREEMENT ...... 14 1.4.1.1 LAND TENURE PATHWAY FOR IRRIGATED AGRICULTURE ...... 14 NATIVE TITLE AGREEMENTS AND ILUA ...... 14 2 THE PROPOSAL ...... 16 BACKGROUND ...... 16 JUSTIFICATION ...... 16 PROPOSAL JUSTIFICATION ...... 16 PROPOSAL ALTERNATIVES ...... 18 OPTIMISATION OF STAGE 3 TO REDUCE ENVIRONMENTAL IMPACTS ...... 18 PROPOSAL DESCRIPTION ...... 19 PIVOT IRRIGATION ...... 19 PARDOO IRRIGATED AGRICULTURE PROJECT ...... 20 THIS EPA REFERRAL – STAGE 3 ...... 20 KEY CHARACTERISTICS OF THIS PROPOSAL – STAGE 3 ...... 21 CROP PROPOSED ...... 22 SITE LAYOUT ...... 22 DESCRIPTION OF CLEARING AND CROP ESTABLISHMENT PROCESS ...... 25 DESCRIPTION OF IRRIGATION AND FERTIGATION ...... 25 PESTICIDES AND OTHER CONTAMINANTS ...... 25 DESCRIPTION OF CATTLE OPERATIONS ...... 26 CATTLE NUMBERS ...... 26 HISTORIC AND FUTURE APPLICATIONS ...... 26 PREVIOUSLY APPROVED – STAGES 1 AND 2 ...... 26 POTENTIAL FUTURE PROPOSAL – STAGES 4, 5 AND 6 ...... 26

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LOCAL AND REGIONAL CONTEXT ...... 27 SOCIAL VALUES ...... 27 ENVIRONMENTAL VALUES ...... 27 2.5.2.1 EXISTING CONDITION ...... 27 2.5.2.2 CONSERVATION SIGNIFICANT SPECIES ...... 27 2.5.2.3 RAMSAR AND NATIONALLY IMPORTANT WETLAND ...... 32 3 STAKEHOLDER ENGAGEMENT ...... 34 KEY STAKEHOLDERS ...... 34 STAKEHOLDER ENGAGEMENT PROCESS ...... 34 STAKEHOLDER CONSULTATION ...... 34 4 ENVIRONMENTAL PRINCIPLES AND FACTORS...... 37 PRINCIPLES ...... 37 FACTORS ...... 38 FLORA AND VEGETATION ...... 38 EPA OBJECTIVE ...... 38 POLICY AND GUIDANCE ...... 39 RECEIVING ENVIRONMENT ...... 39 4.3.3.1 REGIONAL CONTEXT ...... 39 4.3.3.2 STUDY METHODS...... 41 4.3.3.3 VEGETATION COMMUNITIES ...... 41 4.3.3.4 THREATENED AND PRIORITY ECOLOGICAL COMMUNITIES ...... 45 4.3.3.5 ECOLOGICAL CONDITION AND FOLIAGE COVER ...... 45 4.3.3.6 FLORA ...... 47 4.3.3.7 CONSERVATION FLORA ...... 47 POTENTIAL IMPACTS ...... 49 4.3.4.1 DIRECT LOSS OF VEGETATION AND PRIORITY FLORA ...... 50 4.3.4.2 INDIRECT IMPACTS TO VEGETATION ...... 50 4.3.4.3 QUANTIFICATION OF IMPACTS ...... 51 ASSESSMENT OF IMPACTS ...... 52 MITIGATION ...... 52 PREDICTED OUTCOME ...... 52 TERRESTRIAL ENVIRONMENTAL QUALITY ...... 53 EPA OBJECTIVE ...... 53 POLICY AND GUIDANCE ...... 53 RECEIVING ENVIRONMENT ...... 53 4.4.3.1 REGIONAL CONTEXT ...... 53 4.4.3.2 STUDY METHODS...... 53 4.4.3.3 SOIL TYPES ...... 56 4.4.3.4 ACID SULPHATE SOILS ...... 56 4.4.3.5 SOIL INFILTRATION RATES ...... 56 4.4.3.6 SOIL CHEMISTRY ANALYSIS ...... 59 POTENTIAL IMPACTS ...... 59 4.4.4.1 DIRECT DISTURBANCE OF TERRESTRIAL ENVIRONMENT ...... 60 4.4.4.2 INDIRECT DISTURBANCE TO TERRESTRIAL ENVIRONMENT ...... 60

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4.4.4.3 QUANTIFICATION OF IMPACTS ...... 60 ASSESSMENT OF IMPACTS ...... 61 MITIGATION ...... 61 PREDICTED OUTCOME ...... 61 TERRESTRIAL FAUNA ...... 61 EPA OBJECTIVE ...... 61 POLICY AND GUIDANCE ...... 61 RECEIVING ENVIRONMENT ...... 63 4.5.3.1 REGIONAL CONTEXT ...... 63 4.5.3.2 STUDY METHODS...... 63 4.5.3.3 FAUNA HABITAT ...... 63 4.5.3.4 TERRESTRIAL FAUNA ASSEMBLAGE ...... 65 4.5.3.5 CONSERVATION FAUNA ...... 65 POTENTIAL IMPACTS ...... 68 4.5.4.1 DIRECT LOSS OF HABITAT ...... 68 4.5.4.2 INDIRECT IMPACTS TO FAUNA ...... 68 4.5.4.3 QUANTIFICATION OF IMPACTS ...... 69 ASSESSMENT OF IMPACTS ...... 69 MITIGATION ...... 71 PREDICTED OUTCOME ...... 71 HYDROLOGICAL PROCESSES ...... 71 EPA OBJECTIVE ...... 71 POLICY AND GUIDANCE ...... 71 RECEIVING ENVIRONMENT ...... 72 4.6.3.1 REGIONAL CONTEXT ...... 72 4.6.3.2 STUDY METHODS...... 72 4.6.3.3 SURFACE WATER HYDROLOGICAL PROCESSES ...... 73 4.6.3.4 GROUNDWATER HYDROLOGICAL PROCESSES ...... 78 POTENTIAL IMPACTS ...... 83 4.6.4.1 SURFACE WATER FLOWS AND GROUNDWATER INFILTRATION ...... 83 4.6.4.2 GROUNDWATER ABSTRACTION ...... 84 4.6.4.3 MONITORING ...... 84 4.6.4.4 QUANTIFICATION OF IMPACTS ...... 87 ASSESSMENT OF IMPACTS ...... 87 MITIGATION ...... 87 PREDICTED OUTCOME ...... 87 INLAND WATERS ENVIRONMENTAL QUALITY ...... 88 EPA OBJECTIVE ...... 88 POLICY AND GUIDANCE ...... 88 RECEIVING ENVIRONMENT ...... 88 4.7.3.1 REGIONAL CONTEXT ...... 88 4.7.3.2 STUDY METHODS...... 88 4.7.3.3 SURFACE WATER...... 88 4.7.3.4 GROUNDWATER ...... 89 POTENTIAL IMPACTS ...... 90

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4.7.4.1 IRRIGATION AND FERTIGATION ...... 90 4.7.4.2 SEDIMENT CONTAMINATION OF SURFACE WATER ...... 91 4.7.4.3 CONTAMINATION ...... 92 4.7.4.4 MONITORING ...... 92 4.7.4.5 QUANTIFICATION OF IMPACTS ...... 92 ASSESSMENT OF IMPACTS ...... 92 MITIGATION ...... 92 PREDICTED OUTCOME ...... 93 SOCIAL SURROUNDINGS ...... 93 EPA OBJECTIVE ...... 93 POLICY AND GUIDANCE ...... 93 RECEIVING ENVIRONMENT ...... 93 4.8.3.1 STUDY METHODS...... 93 4.8.3.2 ABORIGINAL RESERVES AND COMMUNITIES ...... 94 4.8.3.3 ABORIGINAL HERITAGE AND CULTURE ...... 94 4.8.3.4 EUROPEAN HERITAGE ...... 96 POTENTIAL IMPACTS ...... 96 ASSESSMENT OF IMPACTS ...... 96 MITIGATION ...... 96 PREDICTED OUTCOME ...... 96 5 OTHER ENVIRONMENTAL FACTORS OR MATTERS ...... 97 SUBTERRANEAN FAUNA ...... 97 6 OFFSETS ...... 98

7 HOLISTIC IMPACT ASSESSMENT ...... 99

8 REFERENCES ...... 101

LIST OF TABLES

Table 1: Other approvals ...... 13 Table 2: Evaluation of Alternatives ...... 18 Table 3: Summary of the Proposal ...... 21 Table 4: Location and proposed extent of physical and operational elements ...... 21 Table 5: Stakeholder consultation ...... 35 Table 6: EP Act principles ...... 37 Table 7: Pre-European Vegetation ...... 39 Table 8: Structural Vegetation Communities ...... 42 Table 9: Population estimates of Bonamia oblongifolia at Pardoo, Wallal Downs and Anna Plains ...... 47 Table 10: Vegetation predicted direct and indirect loss Stage 3 ...... 51 Table 11: Predicted proportional loss of vegetation locally and regionally ...... 51 Table 12: Predicted proportional loss of priority flora regionally ...... 51 Table 13: Summary of Infiltration Test Results ...... 56 Table 14: Predicted proportional disturbance of terrestrial environment ...... 60 Table 15. Composition of expected vertebrate fauna assemblage of the survey area ...... 65 Table 16. Conservation significant fauna species expected to occur in the project area...... 65 Table 17: Predicted proportional cumulative loss of fauna habitat within a 15 km buffer of Stage 1, 2 and 3 69 Table 18: Summary of Proposed Groundwater Monitoring Program ...... 85

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Table 19: Summary of groundwater quality monitoring data selected local bores ...... 90 Table 20: Predicted proportional infiltration of nutrients to the Broome Aquifer ...... 92 Table 21: Aboriginal Heritage Sites ...... 94

LIST OF PLATES

Plate 1: Existing Stage 1 Pivots at Pardoo Station ...... 19 Plate 2: Acacia Shrubland – grazed ...... 30 Plate 3: Acacia Shrubland - burnt ...... 30 Plate 4: Completely degraded vegetation caused by long term grazing and trampling ...... 31

LIST OF FIGURES

Figure 1: Regional Location ...... 12 Figure 2: Land Tenure and Native Title ...... 15 Figure 3: Historic Approvals and Current Proposal ...... 17 Figure 4: Site Layout ...... 23 Figure 5: Disturbance Footprint ...... 24 Figure 6: Regional Context ...... 28 Figure 7: Ecological Condition and Priority Flora ...... 29 Figure 8: Ramsar and Nationally Important Wetland ...... 33 Figure 9: Pre-European Vegetation ...... 40 Figure 10: Vegetation Communities ...... 44 Figure 11: Vegetation Condition and Density ...... 46 Figure 12: Conservation Flora ...... 48 Figure 13: Surface Geology ...... 54 Figure 14: Soils ...... 55 Figure 15: Soil Landscapes ...... 57 Figure 16: Acid Sulphate Soils ...... 58 Figure 17: Conservation Significant Fauna ...... 67 Figure 18: Habitat Loss...... 70 Figure 19: Surface Water Catchments ...... 74 Figure 20: Groundwater Management Context ...... 75 Figure 21: Flood Extent and Duration ...... 77 Figure 22: Regional Groundwater Cross-Section ...... 79 Figure 23: Groundwater Contours and Flows ...... 80 Figure 24: Groundwater Dependent Ecosystems ...... 82 Figure 25: Groundwater Monitoring Network ...... 86 Figure 26: Aboriginal Heritage ...... 95

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LIST OF APPENDICES

APPENDIX A. ENVIRONMENTAL MANAGEMENT PLAN

APPENDIX B. RAMSAR & NATIONALLY IMPORANT WETLAND CRITERIA

APPENDIX C. CONSULTATION LETTERS - TRADITIONAL OWNERS

APPENDIX D. FLORA AND VEGETATION STUDY

APPENDIX E. HYDROLOGY AND NUTRIENTS STUDY

APPENDIX F. SOIL CHEMISTRY ANALYSIS

APPENDIX G. TERRESTRIAL FAUNA STUDY

APPENDIX H. GROUNDWATER MONITORING SUMMARY

APPENDIX I. STYGOFAUNA HABITAT ASSESSMENT

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EXECUTIVE SUMMARY

INTRODUCTION, BACKGROUND AND CONTEXT

Pardoo Station is located north of the Great Northern Highway, approximately 100 kilometres (km) east-northeast of Port Hedland and 365 km south west of Broome.

The pastoral lease contains large tracts of prime grazing land. However, the pastoral station requires a dry- season feeding capability to improve cattle welfare, condition and throughput during the dry-season when dry conditions result in limited cattle feed availability.

Therefore, the owner of Pardoo Station, Pardoo Beef Corporation Pty Ltd (PBC), is proposing to develop a centre-pivot irrigated feed crop production facility. Centre-pivot irrigation (sometimes called central pivot irrigation, waterwheel irrigation, circle irrigation or pivot irrigation), is a method of crop irrigation in which equipment rotates around a pivot and crops are watered with sprinklers. PBC is proposing to further develop its pivot irrigated cattle feed crop production capability.

OVERVIEW OF THE PROPOSAL

This Environmental Protection Authority (EPA) Referral is for Stage 3 of the Pardoo Irrigated Agriculture Project, located approximately 4 km inland from the coast with a direct disturbance footprint of 280 ha in total including:

 Three 50 ha pivots, one 40 ha pivot and two 38 ha pivots (total of 266 ha); and  14 ha for proposed support infrastructure such as fencing, pipelines, bores and roads.

Based on the vegetation density across the project area (which is quite sparse) the project will clear approximately 96 ha of vegetation and indirectly disturb 31 ha of vegetation (EnviroWorks Consulting, 2017a).

KEY CHARACTERISTICS OF THIS PROPOSAL – STAGE 3

The Stage 3 project key characteristics are summarised in the tables below.

Table ES1: Summary of the Proposal

Summary of the proposal Proposal title Pardoo Irrigated Agriculture Project - Stage 3 Proponent name Pardoo Beef Corporation Pty Ltd (PBC) Short description It is proposed to develop a centre-pivot irrigated feed crop production facility to improve cattle welfare, condition and throughput at Pardoo Station, a pastoral lease located north of the Great Northern Highway approximately 100 kilometres (km) east- northeast of Port Hedland and 365 km southwest of Broome. The proposal includes the construction of pivot irrigation areas and associated infrastructure/activities (access roads; laydown areas; production bores; diesel generators; water pipelines; fencing; pivot irrigators; and cattle fodder crops).

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Table ES2: Location and proposed extent of physical and operational elements

Element Indicative location Existing Proposed Proposed extent Approval change authorised Physical elements 6 pivot fodder Within the 368 ha None Not applicable Up to 266 hectares cropping areas Development Envelope Ancillary Within 368 ha None Not applicable Up to 14 hectares infrastructure (access Development roads; laydown Envelope areas; production bores; diesel generators; water pipelines; fencing; pivot irrigators; and cattle fodder crops) Fenced paddock Within 368 ha None Not applicable Up to 88 hectares areas (for cattle Development containment) Envelope Operational elements Abstraction of From the 14.8 GL per None No additional water groundwater for production bores, annum for required irrigation - proposed with irrigation onto Pardoo Station abstraction already 266 ha of pivots of which 4.123 GL will be used licensed: for Stage 3 GWL158616(16) (already licenced by Groundwater Well Licence 158616(16)) Application of NPK Onto 266 ha of None Not applicable Up to 186 t per fertiliser pivots annum Nitrogen Up to 5.3 t per annum Phosphorus Up to 53 t per annum Potassium Power Generation Diesel Generators None Not applicable 0.096 MW Diesel Consumption Diesel Generators None Not applicable 30 kL (in generators)

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ENVIRONMENTAL VALUES

EXISTING CONDITION

Pardoo Station has been continuously grazed for over 100 years. The Stage 3 Development Envelope can be described as sparsely vegetated with areas of degradation due to long term historical cattle grazing, trampling and fire.

The Stage 3 project Development Envelope:

 Was burnt by a severe wildfire in 2015 thought to be started via lightning strike (covering 139 ha) with most of the vegetation in the fire’s path destroyed;  Contains 10.3 ha of completely degraded vegetation mostly around stock watering points or along cattle movement trails; and  Due to the existing impacts above, has quite sparse vegetation with an average vegetation density (foliage cover) of only 35% (EnviroWorks Consulting, 2017a).

CONSERVATION SIGNIFICANT SPECIES

Two species of conservation significance were detected within or in close proximity to the Stage 3 study area – Bonamia oblongifolia (Priority 1) and Tribulopis marliesiae (Priority 3). Impacts to these species are not expected to be significant with 0.013% of the estimated regional population of B. oblongifolia and 0% of the known population of T. marliesiae proposed to be impacted.

The expected vertebrate fauna assemblage includes 37 species which are listed under legislation or regulatory lists as conservation significant. Impacts to these species are not expected to be significant. In terms of habitat disturbance, the 1028 ha of disturbance/impact from Stages 1, 2 and 3 at Pardoo represents 1.7% of the 61,143 ha of native vegetation from the Nita Land System the within a 15km buffer around the three project areas. Indirect impacts to fauna and habitat such as water/nutrient run-off, habitat fragmentation, mortality from vehicle/equipment strike, fire, entrapment, toxicants from contamination, behavioural changes and increases in feral species will be avoided as described in Appendix A – Environmental Management Plan.

RAMSAR AND NATIONALLY IMPORTANT WETLAND

The Eighty-mile Beach site was established as a Ramsar wetland under the Ramsar Convention in 1990 by meeting Ramsar criteria 1, 2, 3, 4, 5 and 6, as outlined in Appendix B. The Eighty Mile Beach System (WA018) is also listed in A Directory of Important Wetlands in Australia (Environment Australia, 2001).

The majority of the Eighty-mile Beach Ramsar and Nationally Important Wetland boundary occurs along the coastal strip of Eighty-mile Beach. However, an area of coastal plain south of Cape Keraudren and extending 4 km inland, is included in the wetland boundary, adjacent to the Stage 3 Development Envelope.

It should be noted that the predominant wetland values which resulted in the Ramsar and Nationally Important Wetland listings are located along the coastal strip of eighty-mile beach 4 km away from the Stage 3 Project Development Envelope. Most of these values are related to the tidal mudflat and coastal beach environment which creates habitat for migratory birds and flatback turtle.

A buffer for Stage 3 Development Envelope of 100 m from the Ramsar Wetland boundary is proposed. Significant impacts on the wetland and its ecosystem will be avoided as described in Section 4 of this referral document and Appendix A – Environmental Management Plan.

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SUMMARY OF POTENTIAL IMPACTS, MITIGATION AND OUTCOMES

PBC has identified the following key environmental factors for the Proposal:

 LAND o Flora and Vegetation o Terrestrial Environmental Quality o Terrestrial Fauna  WATER o Hydrological Processes o Inland waters Environmental Quality  PEOPLE o Social Surroundings

Table ES3: Summary of potential impacts, proposed mitigation and outcomes

Key Environmental Factor Flora and Vegetation EPA To protect flora and vegetation so that biological diversity and ecological integrity are maintained. objective Policy and EPA: guidance  Environmental Factor Guideline: Flora and Vegetation (Environmental Protection Authority, 2016d).  Technical Guidance – Flora and Vegetation Surveys for Environmental Impact Assessment (Environmental Protection Authority, 2016k).

Other:  WA Environmental Offsets Policy (Government of Western Australia, 2011).  WA Environmental Offsets Guidelines (Government of Western Australia, 2014).  “Appendix B: Potentially contaminating industries, activities and land uses” in Assessment and management of contaminated sites: Contaminated sites guidelines (Department of Environmental Regulation, 2014). Potential  Direct loss of vegetation and conservation significant flora through clearing impacts  Indirect impacts resulting from: o Introduction and spread of weeds o Increased trampling by cattle concentration increasing around pivots o Dust deposition due to increased cattle movement o Altered fire regimes due to operational activities causing fire o Water run-off from irrigation creating an altered vegetation structure in the surrounding environment resulting in an artificial ecosystem o Nutrient/fertiliser run-off or leaching could affect the condition of local vegetation and cause the proliferation of weed species o Erosion due to increased cattle movement and/or clearing activities o Contamination through: . Disturbance of acid sulphate soils . Hydrocarbon spills from generators, earthmoving and harvesting equipment . Spills of fertiliser . Inappropriate waste disposal

Quantification:  96 ha of direct vegetation loss  31 ha of indirect vegetation impact via trampling  0.15% of Pindan 32 and 0.002% of Mandora Coastal Plain pre-European vegetation types directly and indirectly impacted  0.013% of estimated regional population of Bonamia oblongifolia (P1) directly and indirectly impacted  0% of known population of Tribulopis marliesiae (P3) impacted.

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Key Environmental Factor Mitigation  Avoid: o Direct disturbance of vegetation will be avoided outside the Stage 3 Development Envelope, by fencing the Development Envelope to contain cattle within it. o The surveyed population of Tribulopis marliesiae (Priority 3) has been completely avoided by fencing and exclusion of cattle. o A buffer of 100 m is proposed from the adjacent Ramsar wetland. o Indirect impacts to vegetation such as weeds, fire, water/nutrient run-off and contamination will be avoided as described in Appendix A – Environmental Management Plan.  Minimise: o Impacts to regional vegetation types have been minimised by impacting only 0.15 and 0.001% of regional Pre-European Vegetation communities Pindan 32 and Mandora Coastal Plain 73. o Impacts to the population of Bonomia oblongifolia (Priority 1) have been minimised with only 0.013% of the known population of the species to be impacted. o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan. Outcomes With successful implementation of the Environmental Management Plan (Appendix A), any residual impacts should be minor. Given the Project will avoid or minimise direct and indirect impacts on flora and vegetation, it is concluded that the EPA objective for this factor can be met. Terrestrial Environmental Quality EPA To maintain the quality of land and soils so that environmental values are protected. objective Policy and EPA: guidance  Environmental Factor Guideline: Terrestrial Environmental Quality (Environmental Protection Authority, 2016i) Potential  Direct disturbance of native soils beneath the pivots and other infrastructure (due to mechanical impacts clearing and changes in soil structure/composition because of crop establishment, irrigation and fertilisation)  Indirect changes to native soils within the fenced areas where cattle are contained, due to additional trampling and manure accumulation  Surface run-off or lateral leaching of nutrients from the pivot areas causing elevated nutrient levels in surrounding soils outside the pivots  Erosion by surface water flows, irrigation or wind  Contamination of local soils through: o Disturbance of acid sulphate soils o Hydrocarbon spills from generators, earthmoving or harvesting equipment o Spills of fertiliser o Inappropriate waste disposal

Quantification:  0.025% of soil type 117 Nt proposed to be impacted regionally. Mitigation  Avoid: o Direct disturbance of the terrestrial environment will be avoided outside the Stage 3 Development Envelope, by fencing the Development Envelope to contain cattle within it. o A buffer of 100 m is proposed from the adjacent Ramsar wetland. o Indirect impacts such as nutrient run-off/leaching and contamination will be avoided as described in Appendix A – Environmental Management Plan.  Minimise: o Impacts to regional soil types have been minimised by impacting only 0.025% of regional soil landscape type 117Nt. o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan.

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Key Environmental Factor Outcomes With successful implementation of the above management measures, any residual impacts should be minor. Given the Project will avoid or minimise direct and indirect impacts on terrestrial environmental quality, it is concluded that the EPA objective for this factor can be met. Terrestrial Fauna EPA To protect terrestrial fauna so that biological diversity and ecological integrity are maintained. objective Policy and EPA guidance  Environmental Factor Guideline: Terrestrial Fauna (Environmental Protection Authority, 2016h).  Technical Guidance: Terrestrial fauna surveys (Environmental Protection Authority, 2016n).  Technical Guidance: Sampling methods for terrestrial vertebrate fauna (Environmental Protection Authority, 2016l).  Technical Guidance: Sampling of short range endemic invertebrate fauna (Environmental Protection Authority, 2016m).

Other:  Significant impact guidelines for 36 migratory shorebird species (EPBC Act Policy Statement 3.21) (Department of the Environment, Water, Heritage and the Arts, 2009).  Survey Guidelines for Australia’s Threatened Bats (Department of the Environment, Water, Heritage and the Arts, 2010).  Survey Guidelines for Australia's Threatened Birds (Department of the Environment, Water, Heritage and the Arts, 2010).  Survey Guidelines for Australia's Threatened Mammals (Department of Sustainability, Environment, Water, Population and Communities, 2011a).  Survey Guidelines for Australia’s Threatened Reptiles (Department of Sustainability, Environment, Water, Population and Communities, 2011b).  Industry guidelines for avoiding, assessing and mitigating impacts on EPBC Act listed migratory shorebird species (Department of the Environment and Energy, 2017).  National Recovery Plan for the Northern Quoll Dasyurus hallucatus (Hill & Ward, 2010).  Approved Conservation Advice for Calidris ferruginea (Curlew Sandpiper) (Threatened Species Scientific Committee, 2015a).  Approved Conservation Advice for Limosa lapponica baueri (Bar-tailed godwit (western Alaskan)) (Threatened Species Scientific Committee, 2016e).  Approved Conservation Advice for Limosa lapponica menzbieri (Bar-tailed godwit (northern Siberian)) (Threatened Species Scientific Committee, 2016f).  Approved Conservation Advice for Numenius madagascariensis (Eastern Curlew) (Threatened Species Scientific Committee, 2015b).  Commonwealth Conservation Advice on Sternula nereis nereis (Fairy Tern) (Threatened Species Scientific Committee, 2011).  Approved Conservation Advice for Calidris tenuirostris (Great knot) (Threatened Species Scientific Committee, 2016b).  Approved Conservation Advice for Calidris canutus (Red knot) (Threatened Species Scientific Committee, 2016a).  Approved Conservation Advice for Charadrius leschenaultii (Greater sand plover) (Threatened Species Scientific Committee, 2016c).  Approved Conservation Advice for Charadrius mongolus (Lesser sand plover) (Threatened Species Scientific Committee, 2016d).  Threat Abatement Plan for Predation by the European Red Fox (Department of the Environment, Water, Heritage and the Arts, 2008).  Threat abatement plan for predation by feral cats (Department of the Environment, 2015a).  Wildlife Conservation Plan for Migratory Shorebirds (Department of the Environment, 2015b).  Threat abatement plan for the biological effects, including lethal toxic ingestion, caused by cane toads (Department of Sustainability, Environment, Water, Populations and Communities, 2011c).  WA Environmental Offsets Policy (Government of Western Australia, 2011).  WA Environmental Offsets Guidelines (Government of Western Australia, 2014).  “Appendix B: Potentially contaminating industries, activities and land uses” in Assessment and management of contaminated sites: Contaminated sites guidelines (Department of Environmental Regulation, 2014).

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Key Environmental Factor Potential  Habitat loss as a result of vegetation clearing impacts  Water run-off from irrigation creating an altered vegetation structure in the surrounding environment resulting in an artificial ecosystem, affecting fauna behaviour and assemblages  Habitat fragmentation due to fencing and pivots creating a barrier  Loss and injury of fauna as a result of vehicle and/or equipment strikes  Loss of fauna and habitat due to altered fire regimes  Fauna entrapment in excavated trenches and behind fences  Exposure of fauna to toxicants and contamination through: o Disturbance of acid sulphate soils o Hydrocarbon spills from generators, earthmoving and harvesting equipment o Spills of fertiliser o Inappropriate waste disposal  Noise, lighting, access to water and food waste causing fauna behaviour changes including changes to predator/prey relationships  Increase in feral fauna species, particularly cats and foxes, as a result of increased accessibility and use of linear infrastructure (e.g. impacts of increased predation and competition)  Increased potential habitat for cane toads.

Quantification:  The 1028 ha of disturbance/impact from Stages 1, 2 and 3 at Pardoo represents 1.7% of the 61,143 ha of native vegetation from the Nita Land System the within a 15km buffer around the three project areas  Indirect impacts to fauna and habitat such as water/nutrient run-off, habitat fragmentation, mortality from vehicle/equipment strike, fire, entrapment, toxicants from contamination, behavioural changes and increases in feral species will be avoided as described in Appendix A – Environmental Management Plan. Mitigation  Avoid: o Direct disturbance of habitat will be avoided outside the Stage 3 Development Envelope, by fencing the Development Envelope to contain cattle within it. o A buffer of 100 m is proposed from the adjacent Ramsar wetland. o Indirect impacts from water/nutrient run-off, mortality from vehicle/equipment strike, fire, entrapment, toxicants from contamination and increases in feral species will be avoided as described in Appendix A – Environmental Management Plan.  Minimise: o Impacts to regional habitat types have been minimised by impacting only 1.7% of the 61,143 ha of native vegetation from the Nita Land System the within a 15km buffer around the Stage 1, 2 and 3 project areas. o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan. Outcomes With successful implementation of the above management measures, any residual impacts should be minor. Given the Project will avoid or minimise direct and indirect impacts on terrestrial fauna, it is concluded that the EPA objective can be met. Hydrological Processes EPA To maintain the hydrological regimes of groundwater and surface water so that environmental values are objective protected. Policy and EPA: guidance  Environmental Factor Guideline: Hydrological Processes (Environmental Protection Authority, 2016e).  Australian groundwater modelling guidelines (Waterlines Report Series No. 82) (Barnett, et al., 2012). Other:  Operational Policy 5.12 - Hydrogeological reporting associated with a groundwater well licence (Department of Water, 2009).  Rights in Water and Irrigation Act 1914.

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Key Environmental Factor  A Directory of Important Wetlands in Australia (Australian Nature Conservation Agency, 1993).  WA Environmental Offsets Guidelines (Government of Western Australia, 2014) Potential  Changes in surface water flows or infiltration as a result of clearing, earthworks or irrigation and impacts consequential impacts such as: o Changes to terrestrial ecosystems (creation of an artificial ecosystem or water starving of ecosystems) o Changes to flooding in the adjacent Ramsar site o Erosion of soils o Increase in groundwater recharge due to irrigation

Quantification:  The scale of impact due to surface irrigation is considered insignificant because: o There will be no changes to surface flows. o Very little (or none) of the irrigation water will infiltrate to groundwater. o Heavy rainfall will still infiltrate through the crop root zone to the groundwater (as is the case naturally within the Pindan soils prior to crop establishment). Mitigation  Avoid: o Impacts to surface water flows have been avoided given no pre-development surface flows exist in the project area and none will be created post-development. o Impacts on groundwater dependent springs and wetlands (located 20 – 120 km away) have been avoided by their distance from the project.  Minimise: o Impacts to infiltration of surface water have been minimised by only irrigating with minimal water required for plant growth. As a result, very little (or none) of the irrigation water will infiltrate to groundwater. Heavy rainfall will still infiltrate through the crop root zone to the groundwater (as is the case naturally within the Pindan soils prior to crop establishment). o A detailed groundwater monitoring program is in place under the Operating Strategy required by Groundwater Well Licence 158616(16) as summarised in Appendix A – Environmental Management Plan. o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan. Outcomes With successful implementation of the above management measures, any residual impacts should be minor. Given the Project will avoid or minimise direct and indirect impacts on hydrological processes, it is concluded that the EPA objective can be met. Inland Waters Environmental Quality EPA To maintain the quality of groundwater and surface water so that environmental values are protected. objective Policy and EPA: guidance  Environmental Factor Guideline: Inland Waters Environmental Quality (Environmental Protection Authority, 2016f) Other:  Australian and New Zealand Guidelines for Fresh and Marine Water Quality (Australian and New Zealand Environment and Conservation Council & Agriculture and Resource Management Council of Australia and New Zealand, 2000).  Australian groundwater modelling guidelines (Waterlines Report Series No. 82) (Barnett, et al., 2012).  Rights in Water and Irrigation Act 1914.  State Water Quality Management Strategy No. 6: Implementation Framework for Western Australia for the Australian and New Zealand Guidelines for Fresh and Marine Water Quality and Water Quality Monitoring and Reporting (Guidelines Nos. 4 & 7: National Water Quality Management Strategy) (Report No. SWQ 6) (Government of Western Australia, 2004).  A Directory of Important Wetlands in Australia (Environment Australia, 2001).  “Appendix B: Potentially contaminating industries, activities and land uses” in Assessment and management of contaminated sites: Contaminated sites guidelines (Department of Environmental Regulation, 2014).

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Key Environmental Factor Potential  Over irrigation causing the shallow ground water table to rise and resulting in the mobilisation of salts impacts as the water comes into contact with salts entrained in local sediments  Over application of fertilisers causing nutrient leaching into surface water or groundwater  Erosion causing sedimentation of surface water  Contamination of surface water or groundwater through: o Disturbance of acid sulphate soils o Hydrocarbon spills from generators, earthmoving and harvesting equipment o Spills of fertiliser o Inappropriate waste disposal

Quantification:  Nitrates are expected to increase by only 0.02% within the groundwater beneath the project.  Contamination, erosion and over irrigation will be avoided as described in Appendix A- Environmental Management Plan. Mitigation  Avoid: o Impacts to surface water quality have been avoided given no pre-development surface flows exist in the project area and none will be created post-development. o Very little (or none) of the irrigation water applied to the project will infiltrate to the groundwater. Therefore, over irrigation causing the shallow ground water table to rise and resulting in the mobilisation of salts will not occur. o Impacts such as contamination will be avoided as described in Appendix A – Environmental Management Plan.  Minimise: o Nutrient increases in the Broome aquifer has been minimised by only applying the minimum fertiliser needed for plant growth. o A detailed groundwater monitoring program is in place under the Operating Strategy required by Groundwater Well Licence 158616(16) as summarised in Appendix A – Environmental Management Plan. o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan. Outcomes With successful implementation of the above management measures, any residual impacts should be minor. Given the Project will avoid or minimise impacts on inland waters environmental quality, it is concluded that the EPA objective can be met. Social Surroundings EPA To protect social surroundings from significant harm. objective Policy and EPA: guidance  Environmental Factor Guideline: Social Surroundings (Environmental Protection Authority, 2016g)  Guidance Statement 41 – Assessment of Aboriginal Heritage (Environmental Protection Authority, 2004). Other:  Aboriginal Heritage - Due Diligence Guidelines (Version 3.0) (Department of Aboriginal Affairs & Department of the Premier and Cabinet, 2013).  Aboriginal Heritage Act 1972. Potential  Loss/disturbance to Aboriginal heritage sites. impacts  Disturbance to cultural associations within the area.  Temporary and/or permanent constraint on traditional cultural activities.  Prevention or change of access to a site.  Alterations to hydrological processes. Mitigation  PBC will meet its obligations under the Aboriginal Heritage Act 1972.  Heritage management measures are described in the Environmental Management Plan – Appendix A. Outcomes With implementation of the above mitigation measures, it is considered that residual impacts should be acceptable and that the EPA objective can be met.

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HOLISTIC IMPACT ASSESSMENT

The mitigation hierarchy has been applied to the Proposal with emphasis on avoiding impacts to significant environmental values, including (but not limited to) vegetation and flora, habitat for significant fauna and the adjacent Ramsar Wetland.

Proposed impacts of the Stage 3 Irrigated Agriculture Project to vegetation are considered small in the context of the region with only 0.15% of Pindan 32 and 0.002% of Mandora Coastal Plain pre-European vegetation types directly and indirectly impacted. Similarly, only 0.013% of estimated regional population of Bonamia oblongifolia (Priority 1) will be directly and indirectly impacted, whilst 0% of the known population of Tribulopis marliesiae (Priority 3) will be impacted. Direct disturbance of fauna habitat will be avoided outside the Stage 3 Development Envelope, by fencing the Development Envelope to contain cattle within it. Indirect impacts to fauna from water/nutrient run-off, mortality from vehicle/equipment strike, fire, entrapment, toxicants from contamination and increases in feral species will be avoided as described in Appendix A – Environmental Management Plan.

The predominant wetland values which resulted in the Ramsar and Nationally Important Wetland listing of Eighty-Mile Beach, are located along the coast 4 km away from the Stage 3 Project Development Envelope. Most of these values are related to the tidal mudflat and coastal beach environment of Eighty-Mile Beach which creates habitat for migratory birds and flatback turtle. The portion of the Ramsar wetland adjacent to the proposed Stage 3 project is a coastal floodplain that only floods approximately every 10 years (Water Technology, 2017). Much of the adjacent Ramsar site supports dense acacia and melaleuca thickets. This means that even when flooded, migratory waterbirds that rely on wetland environments would find only small areas of open, shallow wetlands in grasslands. The abundance of waterbirds that use these short lived, ephemeral wetlands adjacent to the project is not expected to be high due to the small area of suitable habitat and infrequency of flooding (Bamford Consulting Ecologists, 2017). The abundance of grassland-dependent waterbirds is also not expected to be high, as the area of dry grassland adjacent to the project is small. It is concluded that the key values of the Eighty-Mile Beach wetland occur on the coastal flats and beaches 4 km away from the Stage 3 project (Bamford Consulting Ecologists, 2017). A buffer for Stage 3 Development Envelope of 100 m from the Ramsar Wetland boundary is proposed and management measures will be implemented to prevent impacts on the wetland related to hydrological processes and inland waters environmental quality. Therefore, it is concluded there will not be any significant impacts on the Ramsar or Nationally Important Wetland as a result of the Stage 3 project.

Cumulative impacts of the Stage 1, 2 and 3 irrigation projects at Pardoo are also considered minor. Total disturbance/impact for all three stages is estimated to be approximately 1028 ha. This represents only 0.2% of the Pindan 32 and Mandora Coastal Plain pre-European vegetation types that occur within the region. In terms of fauna habitat, the 1028 ha of disturbance/impact from Stages 1, 2 and 3 at Pardoo represents 1.7% of the 61,143 ha of native vegetation from the Nita Land System the within a 15km buffer around the three project areas. The area of habitat loss across the largely intact landscape is proportionately small, and therefore the impact upon fauna biodiversity from habitat loss is predicted to be negligible. The potential cumulative impact of groundwater abstraction of 14.8 GL per annum on Pardoo Station has been assessed as part of the approval process for Groundwater Well Licence 158616(16) and the groundwater licence was approved, indicating cumulative impacts are predicted to be acceptable by DWER.

Mitigation and management measures as outlined in Appendix A (Environmental Management Plan) will further reduce the risk of impact to environmental values. Residual environmental impacts are not expected to be significant for any environmental factors. With implementation of the proposed mitigation and management measures, it is considered that the Proposal will meet the EPA’s objective for each environmental factor.

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1 INTRODUCTION

PURPOSE AND SCOPE

Pardoo Station is a pastoral lease located north of the Great Northern Highway within the Shire of East Pilbara, approximately 100 kilometres (km) east-northeast of Port Hedland (Town of Port Hedland) and 365 km southwest of Broome (Shire of Broome) (Figure 1). The pastoral lease contains large tracts of prime grazing land. However, the pastoral station requires a dry-season feeding capability to improve cattle welfare, condition and throughput during the dry-season when dry conditions result in limited cattle feed availability. Therefore, it is proposed to develop a pivot irrigated feed crop production facility to improve cattle welfare, condition and throughput.

This Environment Review Document (ERD) has been prepared by EnviroWorks Consulting (EnviroWorks) on behalf of the Pardoo Beef Corporation Pty Ltd (PBC, the Proponent), following the Environmental Review Document template (Environmental Protection Authority, 2017), to support the formal referral of the Pardoo Irrigation Agriculture Project – Stage 3 Proposal (this Proposal) to the Environmental Protection Authority (EPA) under section 38 of the Environmental Protection Act 1986 (EP Act) (WA).

The purpose of the document is to present an Environmental Review of the principal components of this Proposal, including a detailed environmental impact assessment and description of proposed environmental management strategies for preliminary key environmental factors.

PROPONENT

EnviroWorks Consulting has been engaged by PBC to manage the Environmental Impact Assessment (EIA) and Approvals for the proposed Pardoo Irrigated Agriculture Project – Stage 3.

The proponent for the Proposal is Pardoo Beef Corporation Pty Ltd (PBC) (ACN: 601 968 165)

Contact: Brett Blanchett Position: Chief Executive Officer Address: Level 5 Number 189 St Georges Tce Perth WA 6000 Phone: (08) 9322 3888 Email: [email protected]

EnviroWorks Consulting contact details are as follows:

Contact: Laura Todd Position: Managing Director Address: Level 29 Number 221 St Georges Tce Perth WA 6000 Phone: (08) 9221 9500 Email: [email protected]

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ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

ENVIRONMENTAL PROTECTION ACT 1986 (WA)

This document has been prepared as a supporting document for referral of the Proposal to the EPA under section 38 of the EP Act.

ENVIRONMENT PROTECTION AND BIODIVERSITY CONSERVATION ACT 1999 (CTH)

The Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) provides for the referral and assessment of Proposals which, if implemented, may have a significant impact on Matters of National Environmental Significance (MNES). The Proponent considers that the Proposal will not have significant impacts on MNES and therefore has not undertaken referral under the EPBC Act.

OTHER APPROVALS AND REGULATION

This Proposal is also subject to compliance with other relevant state legislation and regulations and is guided by relevant key over-arching state policies and strategies. In addition, there are EPA Factor Guidelines and Technical Guidance documents that have been used to determine the significance of the environmental impacts of the Proposal. Other approvals and legislation relevant to this Proposal are outlined in Table 1.

Table 1: Other approvals

Proposal activities Land tenure Type of approval Legislation regulating the activity / access Construct groundwater Pastoral lease Licence to Construct Wells Section 26D of the Rights in Water and bores Irrigation Act 1914 (Department of Water and Environmental Regulation) Groundwater extraction Pastoral lease Licence to Take Section 5C of the Rights in Water and Groundwater Irrigation Act 1914 (Department of Water and Environmental Regulation) Growing of Fodder Crop Pastoral lease Permit to Diversify Part 7 Division 5 of the Land on Pastoral Lease Administration Act 1997

Additional decision-making authorities (DMAs) may be identified during the assessment process.

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TENURE AND STATE AGREEMENT

Stage 3 is located within the Pardoo Station Pastoral lease, which PBC purchased in early 2015.

This Pastoral Lease is considered appropriate tenue for all current and proposed pivot irrigation infrastructure.

However, PBC are looking to establish a private lease (the “Land Tenure Envelope” following the Land Tenure Pathway for Irrigated Agriculture (LTPIA) (see section 1.4.1.1). This is not required to implement the project, which can be done under the existing Pastoral Lease, however is being pursued by PBC for long term security rather than for any immediate need.

1.4.1.1 LAND TENURE PATHWAY FOR IRRIGATED AGRICULTURE

The Land Tenure Pathway for Irrigated Agriculture (LTPIA) project, administered by the Department of Planning, Lands and Heritage:

“With the aim of stimulating greater economic development and investment across the State for irrigated agriculture, this project will assist proponents (including pastoralists and third party investors) to obtain more secure land tenure.

A policy framework has been developed in the scope of what is currently possible under the Land Administration Act 1997 and the Native Title Act 1993 (Cth). The project has defined a specific land tenure pathway for irrigated agriculture, using policy principles as a foundation, which were approved by the State Government in August 2015.”

(Department of Planning, Lands and Heritage, n.d.)

In simple terms, the LTPIA “clarifies the process for changing existing Crown land tenure to a form of tenure suitable for large scale irrigated agriculture. Changing tenure is complex and takes time; the LTPIA makes this process clearer.” (Department of Lands, 2017).

PBC has begun this process, with the proposed Land Tenure Envelope shown in Figure 2.

NATIVE TITLE AGREEMENTS AND ILUA

The Land Tenure Envelope is predominantly overlapped by the Ngarla and Ngarla 2 (Area A) native title claim (NNTT Reference: WC1999/026; Federal court reference: WAD6185/1998; Registered Native Title Body Corporate: Wanparta Aboriginal Corporation) (Figure 2).

The previous lease holders were party to a registered Indigenous Land Use Agreement (ILUA), the Ngarla Indigenous Land Use Agreement (Tribunal ID: WI2006/002). This ILUA granted non-exclusive right to the Proposal area. PBC purchased Pardoo Station in early 2015 and was not a party to the previous ILUA.

However, Traditional owner approval has since been granted to PBC, and a new ILUA has been drafted (anticipated for signing in Quarter 1 2018). The new ILUA covers the proposed Stage 3 irrigation project area.

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2 THE PROPOSAL

BACKGROUND

Since Pardoo Beef Corporation (PBC) purchased Pardoo Station in early 2015, it has adopted and accelerated the existing plans to develop irrigated agriculture. To date, this has consisted of Stage 1 and Stage 2 pivot developments (Figure 3) approved under native vegetation clearing permits.

This Proposal for Stage 3 is a new proposal (Figure 3), albeit a progression of PBC’s previous pivot irrigation activities, and this is the first time it has been referred to the EPA for assessment.

JUSTIFICATION

In accordance with Clauses 5 and 10.2.4 of the Environmental Impact Assessment (Part IV Divisions 1 and 2) Administrative Procedures 2016 (Environmental Protection Authority, 2016b), this section outlines the justification for this Proposal and summarises the alternative options considered. The intent of this section is to provide an overview of the options that have been considered by the Proponent to minimise the potential environmental impacts resulting from this Proposal.

PROPOSAL JUSTIFICATION

Pardoo Beef Corporation (PBC) purchased Pardoo Station in early 2015 and has adopted and accelerated the existing plans to develop irrigated agriculture. The pastoral lease contains large tracts of prime grazing land; however, the pastoral station requires a dry-season feeding capability to improve cattle welfare, condition and throughput during the dry-season when dry conditions result in limited cattle feed availability. Therefore, it is proposed to develop a pivot irrigated feed crop production facility to improve cattle welfare, condition.

The Pardoo Irrigated Agriculture Project is receiving technical assistance and advice from the WA Government in progressing this project as part of the Water for Food and Transforming Agriculture in the Pilbara Government initiatives. The project was also recognised as “a project of major strategic importance to Western Australia” in a letter dated 30th August 2016 from the State Government.

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PROPOSAL ALTERNATIVES

A range of proposal alternatives have been considered including:

 Trucking hay feed from other agricultural areas not on Pardoo Pastoral Lease;  Locating the project in other parts of the Pardoo Pastoral Lease;  Moving cattle off the Pardoo Pastoral Lease to other feeding areas during the dry season; and  Continuing operations as they are currently, without proposing Stage 3.

The feasibility of each alternative is discussed below in Table 2.

Table 2: Evaluation of Alternatives

Alternative Evaluation Feasible Trucking hay feed from Hay would need to be trucked very long distance, which is not No other agricultural areas economically feasible. In addition, the quality of hay as cattle feed is well not on Pardoo Pastoral below the quality of the cattle fodder crops proposed to be grown at Lease Pardoo and hay therefore would not result in the same benefits in terms of cattle welfare and productivity. Locating the project in The stage 3 project is located in an area where the combination of high No other parts of the groundwater flows, high groundwater pressure and low groundwater Pardoo Pastoral Lease salinity are co-located with suitable soils, topography and scale to support a significant development. Poorer quality groundwater occurs to the west of Cape Keruadren, and the available artesian water pressure declines to the south where ground elevations increase. It is not feasible to transport water from one region to another due to the additional capital and operating costs of pipelines and pumping. Moving cattle off the The cattle would need to be trucked a very long distance, which is not No Pardoo Pastoral Lease economically feasible. In addition, there is extremely limited availability to other feeding areas of alternative pasture grounds available in WA for young cattle to be during the dry season transported to and continue their weight gain. In addition, this would create unnecessary stress for the cattle. Live export of relatively Live export is the only potential market for relatively low weight cattle. No low weight cattle which This alternative is considered economically undesirable as the weight of have not been able to each animal is not maximised prior to sale. Pardoo’s business model is gain weight on the based on maximising the weight of each animal and not doing live pastoral station due to export. Instead Pardoo sell a boxed wagyu beef product overseas, lack of fodder where the weight of each animal has been maximised and is not availability exported live. Continuing operations The need for the stage 3 pivot fodder crops has been identified by PBC No as they are currently, in order to improve cattle welfare, condition and throughput during the without proposing dry-season when dry conditions result in limited cattle feed availability. Stage 3 Not providing this additional feed for the station’s cattle will severely limit the productivity of the station.

OPTIMISATION OF STAGE 3 TO REDUCE ENVIRONMENTAL IMPACTS

Every effort has been made to optimise pivot size within the Development Envelope while placing pivots to have minimal environmental impact, particularly with respect to conservation significant flora and fauna and the neighbouring Eighty Mile Beach wetland system, which is both a Ramsar and Nationally Important wetland.

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PROPOSAL DESCRIPTION

PIVOT IRRIGATION

Centre-pivot irrigation (sometimes called central pivot irrigation, waterwheel irrigation, circle irrigation or pivot irrigation), is a method of crop irrigation in which equipment rotates around a pivot and crops are watered with sprinklers (Plate 1).

Plate 1: Existing Stage 1 Pivots at Pardoo Station

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PARDOO IRRIGATED AGRICULTURE PROJECT

PBC is proposing to develop an innovative cattle irrigated feed crop production project at Pardoo cattle station. This involves:

 Establishment of bores to supply groundwater for irrigation.  Clearing of circular areas of land where crops are proposed to be grown.  Fencing of paddocks around the pivot areas (including some additional land outside each pivot) in order to contain cattle.  Planting of seed crop (Rhodes grass, refer to Section 2.3.5 below).  Application of water and minimal quantities of fertiliser.  Growing of the crops until maturity.  Allowing cattle into selected pivot crop areas to graze directly.

Strict environmental management measures are employed during the pivot establishment and maintenance process to mitigate and minimise potential environmental impacts (refer to Appendix A – Environmental Management Plan).

THIS EPA REFERRAL – STAGE 3

This Environmental Protection Authority (EPA) Referral is for Stage 3 of the Pardoo Irrigated Agriculture Project, located approximately 4 km inland from the coast (Figure 1) with a footprint of 280 ha in total including:

 Three 50 ha pivots, one 40 ha pivot and two 38 ha pivots (total of 266 ha); and  14 ha for proposed support infrastructure such as fencing, pipelines, bores and roads (Figure 4).

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KEY CHARACTERISTICS OF THIS PROPOSAL – STAGE 3

Table 3: Summary of the Proposal

Summary of the proposal Proposal title Pardoo Irrigated Agriculture Project - Stage 3 Proponent name Pardoo Beef Corporation Pty Ltd (PBC) Short description It is proposed to develop a centre-pivot irrigated feed crop production facility to improve cattle welfare, condition and throughput at Pardoo Station, a pastoral lease located north of the Great Northern Highway, approximately 100 kilometres (km) east-northeast of Port Hedland and 365 km southwest of Broome (Error! Reference source not found.). The proposal includes the construction of pivot irrigation areas and associated infrastructure/activities (access roads; laydown areas; production bores; diesel generators; water pipelines; fencing; pivot irrigators; and cattle fodder crops).

Table 4: Location and proposed extent of physical and operational elements

Element Indicative location Existing Proposed change Proposed extent Approval authorised Physical elements 6 pivot fodder cropping Within the 368 ha None Not applicable Up to 266 hectares areas Development Envelope shown in Figure 4 Ancillary infrastructure Within 368 ha None Not applicable Up to 14 hectares (access roads; laydown Development areas; production Envelope shown in bores; diesel Figure 4 generators; water pipelines; fencing; pivot irrigators; and cattle fodder crops) Fenced paddock areas Within 368 ha None Not applicable Up to 88 hectares (for cattle containment) Development Envelope shown in Figure 4 Operational elements Abstraction of From the production 14.8 GL per None No additional water groundwater for bores, with irrigation annum for required irrigation - proposed onto 266 ha of pivots Pardoo Station abstraction already shown in Figure 4 of which 4.123 licensed: GL will be used GWL158616(16) for Stage 3 (already licenced by Groundwater Well Licence 158616(16)) Application of NPK Onto 266 ha of pivots None Not applicable Up to 186 t per annum fertiliser shown in Figure 4 Nitrogen Up to 5.3 t per annum Phosphorus Up to 53 t per annum Potassium Power Generation Diesel Generators None Not applicable 0.096 MW Diesel Consumption (in Diesel Generators None Not applicable 30 kL generators)

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CROP PROPOSED

The crop proposed to be grown in the Stage 3 pivots is Rhodes grass (Chloris gayana), a summer-growing, stoloniferous perennial, whose runners provide good soil cover for erosion control. Rhodes grass is adapted to a wide range of soils and provides excellent quality fodder for cattle (Department of Agriculture and Fisheries Qld, 2017).

SITE LAYOUT

A site layout diagram is provided in Figure 4. The site layout consists of:

 A fenced Development Envelope of 368 ha.  A fenced main access road and ring road surrounding the central pivot (Pivot 18) which allows access into all of the pivot areas via gates.  Five fenced cattle holding paddocks containing the five perimeter pivots (Pivot numbers 13, 14, 15, 16, and 17) and small amounts of additional land around each pivot which act as dry resting ground for cattle.  A fenced central pivot (Pivot 18). This pivot does not have additional area fenced around it (only the pivot itself is fenced), which means that cattle need to be moved frequently to other paddocks to access dry resting ground.  Three groundwater abstraction bores (PB8, PB9 and PB10) and pipelines to the centre of each pivot.  Access roads to the centre of each pivot.  A laydown area for equipment and vehicles located along the main access road.

A map showing the disturbance footprint (both direct and indirect disturbance) is provided in Figure 5.

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DESCRIPTION OF CLEARING AND CROP ESTABLISHMENT PROCESS

Clearing is carried out in a way which minimises erosion. Both the initial clearing and replanting strategy is timed to prevent erosion.

Firstly, removal of all vegetation within the intended pivot area is undertaken using a bulldozer or similar equipment. Clearing is timed to directly follow the wet season. This ensures minimal opportunity for rainfall or wind mediated erosion of the bare soil before crop emergence under irrigation.

The cleared area is irrigated prior to planting to ensure a high plant germination and density. This irrigation keeps the soil moist preventing wind erosion of the bare soil prior to crop emergence.

Once a crop has matured it is either grazed or harvested down to stubble, leaving the roots intact within the soil structure. This intact stubble and root structure prevents wind and water erosion occurring. Any further replanting is undertaken over a very short time span (usually 2 weeks) with the previous crop’s organic material stabilising the topsoil and improving the soil structure.

DESCRIPTION OF IRRIGATION AND FERTIGATION

Irrigation is applied to all pivots in a manner which maximise the use of water for the irrigated crop to ensure all water is consumed in-situ by the crop. This is achieved by soil moisture monitoring and leaf tissue to analysis to ensure that only the bare minimum of water is applied to achieve crop growth. Water application is expensive, so every effort is made to conserve the water resources.

At the centre of each pivot, a fully enclosed and bunded generator is used to drive pivot irrigation equipment. An appropriately designed and bunded 5000 L liquid nitrogen tank, is used to inject the appropriate amount of liquid nitrogen into the irrigation water for direct application. The other fertilisers are granular and are applied through a spreader.

The operation of the irrigation system will protect groundwater by ensuring that the soils do not reach field capacity, avoiding excessive nitrogen application and applying nitrogen according to plant demand. In summary, in order to effectively manage nutrients, Best Management Practices will be implemented. This will further minimise the risk of nutrient losses, ensuring that nutrients are not freely available to be transported from the site through run-off or leaching. Specifically, nutrients will:

 Be significantly reduced when the groundcover is less than 70%.  Not be applied if heavy rain is forecast.  Not be applied to waterlogged soils (as determined by soil moisture monitoring).  Be prevented from entering water storage areas during application.  Be stored in a manner which will prevent spills (Advanced Fertigation Systems, 2015).

PESTICIDES AND OTHER CONTAMINANTS

No pesticides will be used in the Stage 3 irrigation project. They are not necessary for effective operations.

The only contaminant in use is diesel, required for the diesel generators which drive the pivots. Diesel will be stored and used in a way which prevents spills and contamination (refer to Appendix A – Environmental Management Plan).

If herbicides are required to managed weeds, the Department of Biodiversity, Conservation and Attractions (DBCA) will be consulted and only herbicides agreed with the DBCA will be applied. Herbicides will not be stored on site (they will be brought to site when needed).

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No other chemicals or hydrocarbons are required on site.

DESCRIPTION OF CATTLE OPERATIONS

Cattle will be herded into the Stage 3 Development Envelope via a fenced track from existing cattle station holding yards to the south east – this fenced track will be installed as part of normal cattle station activities under the conditions of the pastoral lease.

Cattle will be herded up the main access road and gates will be opened and shut to facilitate access into the desired pivot area. Cattle will then be allowed to graze on the selected pivot until it is deemed by the operations manager that they should be moved (based on cattle condition/weight and crop fodder remaining, in accordance with the pastoral station’s operational objectives).

CATTLE NUMBERS

The Stage 3 project will carry approximately 3,000 size cattle at 200 kilograms each. This will increase the overall cattle numbers on the station by approximately 3,000 cattle.

HISTORIC AND FUTURE APPLICATIONS

PREVIOUSLY APPROVED – STAGES 1 AND 2

Two previous irrigation capability stages have already been approved as follows and are currently being implemented by the proponent (Figure 3):

 Stage 1 – 270 ha footprint o Two developed 40 ha pivots plus 10 ha of operational areas –approved under Clearing Permit Number CPS 4207 for 90 ha (issued 28 July 2011) o Four developed 40 ha pivots approximately plus 20 ha of operational areas – already approved under Clearing Permit Number CPS 6552 for 180 ha (issued 23 July 2015).

 Stage 2 – 400 ha o Five 55 ha pivots, one 45 ha pivot and one 35 ha pivot currently being constructed (total of 355 ha for pivots) o 45 ha of support infrastructure. o Clearing Permit Number CPS 7312/1 (issued 13 July 2017).

POTENTIAL FUTURE PROPOSAL – STAGES 4, 5 AND 6

PBC is currently considering future referral to the EPA of subsequent irrigation capability Stages 4, 5 and 6. The details of these stages have not yet been determined. However, it is possible that a future referral for Stages 4, 5 and 6 may involve approximately 17 pivots and a footprint of approximately 1000 ha.

These Stages would also occur within the Land Tenure Envelope, but the exact location and layout has not yet been decided.

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LOCAL AND REGIONAL CONTEXT

SOCIAL VALUES

The Shire of East Pilbara is the largest Shire in Australia, covering approximately 372,000 square kilometres (Figure 6). The Shire’s main towns are Newman, Marble Bar and Nullagine, and there are a number of Aboriginal Communities. Mining dominates the economic landscape, contributing an estimated 89% of the economic output and 66% of employment (Remplan Economy, 2017). The dominant land uses in the surrounding area are grazing of native pastures, and unallocated Crown Land (UCL) and Crown reserves (Graham, 2003). The 2016 population for the Shire of East Pilbara is 12,092, with a population density of 0.03 persons per square kilometre (Remplan Economy, 2017).

Pardoo Station is neighboured by De Grey Station, Muccan Station, Desert Telfer and Wallal Downs Station, with Wallal Downs Station approximately 0.5 km east of the Land Tenure Envelope (Figure 6).

The Land Tenure Envelope is overlapped by Native Title and an Indigenous Land Use Agreement (ILUA) has been drafted with the Traditional owners (see Section 1.4.2) – Figure 3.

ENVIRONMENTAL VALUES

2.5.2.1 EXISTING CONDITION

The Stage 3 project Development Envelope:

Plates 2, 3 and 4 below show photographs typical of the above disturbances, whilst Figure 7 shows the existing condition.

2.5.2.2 CONSERVATION SIGNIFICANT SPECIES

Two species of conservation significance were detected within or in close proximity to the Stage 3 study area – Bonamia oblongifolia (Priority 1) and Tribulopis marliesiae (Priority 3) – Figure 7. Impacts to these species are not expected to be significant as described in Section 4.3.

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Plate 2: Acacia Shrubland – grazed

Plate 3: Acacia Shrubland - burnt

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Plate 4: Completely degraded vegetation caused by long term grazing and trampling

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2.5.2.3 RAMSAR AND NATIONALLY IMPORTANT WETLAND

The Eighty-mile Beach site was established as a Ramsar wetland (Figure 8) under the Ramsar Convention in 1990 by meeting Ramsar criteria 1, 2, 3, 4, 5 and 6, as outlined in Appendix B. The Eighty Mile Beach System (WA018) is also listed in A Directory of Important Wetlands in Australia (Environment Australia, 2001) (Figure 8).

 The predominant wetland values which resulted in the Ramsar and Nationally Important Wetland listings are located along the coastal strip of eighty-mile beach 4 km away from the Stage 3 Project Development Envelope. Most of these values are related to the tidal mudflat and coastal beach environment which creates habitat for migratory birds and flatback turtle (Appendix B).  The area of the Ramsar wetland adjacent to the proposed project is a coastal floodplain that only floods approximately every 10 years (Water Technology, 2017).  Much of the adjacent Ramsar site supports dense acacia and melaleuca thickets. This means that even when flooded, migratory waterbirds that rely on wetland environments would find only small areas of open, shallow wetlands in grasslands. By cross-referencing vegetation types (EnviroWorks Consulting, 2017), with flood modelling conducted (Water Technology, 2017), within a 1 km buffer from the Stage 3 Development Envelope, there are 20.8 ha of salt pans/grasslands which would flood for 1 – 2 weeks and 12.6 ha of salt pans which would flood for 3-5 weeks (when the area floods approximately every 10 years). The abundance of waterbirds that use these short lived, ephemeral wetlands adjacent to the project is not expected to be high due to the small area of suitable habitat and infrequency of flooding (Bamford Consulting Ecologists, 2017).  The abundance of grassland-dependent waterbirds is also not expected to be high, as the area of dry grassland adjacent to the project is small, but such species are likely to occur regularly in the September to November period (pre-Wet season). Only three listed migratory birds are likely to occur regularly, and all are grassland-dependent species that forage (mostly on invertebrates) on dry grasslands. These are the Oriental Plover, Little Curlew and Oriental Pratincole (Bamford Consulting Ecologists, 2017).  Large but very rare aggregations of these grassland species are possible, but the likelihood of such aggregations meeting the Ramsar criterion for any of these species adjacent to Stage 3 is extremely low (Bamford Consulting Ecologists, 2017).  The Eighty Mile Beach Ramsar Site is listed on the basis of large aggregations of migratory waterbirds on the coastal flats and beaches 4 km away from the Stage 3 project (Bamford Consulting Ecologists, 2017).  A buffer for Stage 3 Development Envelope of 100 m from the Ramsar Wetland boundary is proposed.  Significant impacts on the wetland and its ecosystem will be avoided as described in Section 4 of this referral document and Appendix A – Environmental Management Plan.

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3 STAKEHOLDER ENGAGEMENT

KEY STAKEHOLDERS

PBC has identified the following government agencies and non-government organisations as key stakeholders for this proposal:

 Government Agencies: o Department of Water and Environmental Regulation (DWER) o Department of Primary Industries and Regional Development (DPIRD) o Department of Planning, Lands and Heritage (DPLH) o Department of Biodiversity Conservation and Attractions (DBCA) o Pilbara Development Commission (PDC) o Pilbara Regional Council (PRC) o Shire of East Pilbara  Traditional Owners: o Ngarla (represented by the Wanparta Aboriginal Corporation)  Interest Groups: o Environs Kimberley

STAKEHOLDER ENGAGEMENT PROCESS

Consultation with stakeholders has been ongoing since operations commenced at Pardoo. PBC will continue to consult with relevant stakeholders (see Section 3.1) during the environmental approval process and implementation of this Proposal. This includes decision-making authorities, other relevant State (and Commonwealth) government agencies and local government authorities, the local community, and environmental non-government organisations.

Stakeholder consultation activities have included and continue to include:

 providing information on the Proposal;  providing the results of key environmental studies;  seeking feedback from key stakeholder on environmental impacts relevant to them; and  incorporating stakeholder feedback into the Proposal design and proposed environmental management.

STAKEHOLDER CONSULTATION

To date stakeholder communication and engagement has focussed on providing information to key stakeholders regarding:

 proposed Project location and scale;  PBC’s commitment to environmental management;  proposed approach for minimising and mitigating environmental impacts and risks; and  anticipated Project timing.

Table 5 below outlines the specific stakeholder consultation that has been undertaken.

Appendix C includes copies of letters received during consultation with the traditional owners.

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Table 5: Stakeholder consultation

Date Issues/topics raised Proponent response / outcome Environmental Protection Authority (EPA) 10/8/2017  Overview of proposed project  EPA Chairman advised that referral to the EPA  Overview of environmental was likely warranted. management measures 29/8/2017  Details regarding proposed referral  EPA Chairman advised that Stage 3 could be of Stage 3 of irrigation project referred if a transparent approach adopted regarding other subsequent stages. Department of Water and Environmental Regulation (DWER) – Previously Department of Water (DoW) and Department of Environment Regulation (DER) 2010 - 2011  Application submitted to then DER  Clearing Permit Number CPS 4207 for 90 ha for Stage 1 Clearing Permit issued 28 July 2011  Ongoing discussion on details conducted 2016 - 2017  Application submitted to then DER  Clearing Permit Number CPS 7312/1 issued 13 for Stage 2 Clearing Permit July 2017.  Ongoing discussion on details conducted Feb 2017 –  Application submitted to then DER  DER advised referral of Stage 3 to EPA may be Aug 2018 for Stage 3 Clearing Permit warranted.  Ongoing discussion on details  PBC commenced discussions with EPA and conducted withdrew Clearing Permit Application 2015 - 2017  Application submitted to then DoW  Groundwater Well Licence 158616(11) was for Groundwater Licence for water issued on 20 March 2015 for 7,740,000 kL/annum abstraction  Groundwater Well Licence 158616(14) was issued on 27 June 2016 for 10,000,000 kL/annum  Ongoing discussion on details  Groundwater Well Licence 158616(16) was conducted issued on 25 January 2017 for 14,822,250 kL/annum Department of Biodiversity Conservation and Attractions (DBCA) Aug – Sept  Requested details regarding the  Details provided regarding the coastal plain 2017 boundary and values of the Eighty boundary and potential flooding of the coastal Mile Beach Ramsar Wetland plain creating waterbird habitat. Department of Planning, Lands and Heritage (DPLH) 2015 - 2017  Applications for Permits to  Permit to Diversify for Stage 1 issued 18 Diversify Submitted November 2015.  Ongoing discussion on details  Permit to Diversify for Stage 2 issued 14 July conducted. 2017. Pilbara Development Commission (PDC) April,  Held ongoing meetings and  PDC have indicated they are supportive of the August & discussions regarding the project project and the potential benefits it brings to the Nov. 2017 and potential benefits to the region. Pilbara. Pilbara Regional Council (PRC) April,  Held ongoing meetings and  PRC have indicated they are supportive of the August & discussions regarding the project project and the potential benefits it brings to the Nov. 2017 and potential benefits to the region. and Jan. Pilbara. 2018 Shire of East Pilbara 2016  Requested confirmation that a  Shire confirmed a Development Application was Shire Development Application not required on 28 October 2016 was not required for the project.

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Date Issues/topics raised Proponent response / outcome Ngarla Traditional owners 2015 - 2017  Indigenous Land Use Agreement  Traditional owners have been supportive of the (ILUA) negotiations. proposed pastoral activities (including Stage 3)  Pardoo has attended meetings and the potential partnership opportunities that with the traditional owners (Ngarla may arise from these activities. people) legal entity the Wanparta  No significant environmental or heritage issues Aboriginal Corporation (WAC) have been raised by traditional owners during Board. These meetings discussed negotiations. all aspects of Pardoo’s proposed  Appendix C includes copies of letters received use of the land for its project and during consultation with the traditional owners. were to negotiate an agreement  ILUA has been drafted. regarding Pardoo’s engagement  It is expected that the ILUA will be signed in with the Ngarla People and Quarter 1 2018. benefits to be provided to them. These meetings occurred on 18 September 2015, 19 August 2016, 25-26 October 2016 and 23 March 2017. Pardoo and its lawyers also met with WAC’s lawyers on 20 March 2017 and 14 November 2017 to discuss matters relating to the agreement and Pardoo’s proposed activities on the freehold envelope.

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4 ENVIRONMENTAL PRINCIPLES AND FACTORS

PRINCIPLES

A summary of the EP Act principles considered in relation to the proposal is provided in Table 6.

Table 6: EP Act principles

Principle Consideration 1. The precautionary principle  Appendix A – Environmental Management Plan outlines Where there are threats of serious or irreversible a range of mitigation measures to prevent impacts and damage, lack of full scientific certainty should not be monitoring to ensure that impacts are monitored with used as a reason for postponing measures to prevent contingencies implemented if triggers or thresholds are environmental degradation. reached.  Buffer of 100 m to Ramsar boundary applied as a In application of this precautionary principle, decisions precaution to protect values of Ramsar wetland. should be guided by:  Operating Strategy in place for the groundwater a) careful evaluation to avoid, where practicable, abstraction to monitor the impacts of groundwater serious or irreversible damage to the abstraction on the surrounding environment with environment; and appropriate triggers and contingency plans in place. b) an assessment of the risk-weighted consequences of various options. 2. The principle of intergenerational equity  The proposed irrigation project will provide high quality The present generation should ensure that the health, cattle feed and reduce the grazing pressure on native diversity and productivity of the environment is vegetation, particularly in times of drought. This is likely maintained and enhanced for the benefit of future to improve the condition of native vegetation in other generations. parts of the pastoral lease.  The project is designed to create a sustainable form of cattle production, whilst ensuring the Pastoral Lease remains in good condition so that it can be passed on to future generations. 3. The principle of the conservation of biological  PBC has undertaken comprehensive baseline studies to diversity and ecological integrity understand and assess potential threats to biological Conservation of biological diversity and ecological diversity and ecological integrity. integrity should be a fundamental consideration.  Management strategies (Appendix A – Environmental Management Plan) have been, and will continue to be, implemented to avoid or minimise threats to biological diversity and ecological integrity wherever possible. 4. Principles relating to improved valuation, pricing It is essential that water, fertiliser and energy use remains as and incentive mechanisms low as possible as these things add significant project cost – (1) Environmental factors should be included in the reducing them will also reduce cost and make the project valuation of assets and services. more economically and environmentally acceptable. (2) The polluter pays principles – those who generate pollution and waste should bear the PBC has, and will continue to, evaluate (and implement cost of containment, avoidance and abatement. wherever possible) opportunities to reduce impact to land, (3) The users of goods and services should pay reduce waste and improve efficiencies in water, fertiliser and prices based on the full life-cycle costs of energy use during the implementation and operation of the providing goods and services, including the use pivot irrigation project (Appendix A – Environmental of natural resources and assets and the Management Plan). ultimate disposal of any waste. Environmental goals, having been established, should be pursued in the most cost-effective way, by establishing incentive structure, including market mechanisms, which enable those best placed to

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Principle Consideration maximise benefits and/or minimise costs to develop their own solution and responses to environmental problems. 5. The principle of waste minimisation All reasonable and practicable measures have been and will All reasonable and practicable measures should be continue to be undertaken by PBC to minimise the generation taken to minimise the generation of waste and its of waste. discharge into the environment. Very few waste products will be produced by the proposed project and those produced will be managed appropriately.

FACTORS

The Proponent has assessed the environmental factors relevant to this Proposal, in accordance with the approach in the EPA’s Statement of Environmental Principles, Factors and Objectives (Environmental Protection Authority, 2016j) and the EPA’s Environmental Factor Guidelines and Environmental Factor Technical Guidance (available from the EPA website: http://www.epa.wa.gov.au/framework-environmental- considerations-eia).

PBC has identified the following key environmental factors for the Proposal:

 LAND o Flora and Vegetation (Section 4.3) o Terrestrial Environmental Quality (Section 4.4) o Terrestrial Fauna (Section 4.5)  WATER o Hydrological Processes (Section 4.6) o Inland waters Environmental Quality (Section 0)  PEOPLE o Social Surroundings (Section 4.8)

PBC considers that the remaining environmental factors are not of significance to warrant further assessment by the EPA, or are impacts that can be regulated by other statutory processes to meet the EPA’s objectives, outlined in the EPA’s Statement of Environmental Principles, Factors and Objectives (Environmental Protection Authority, 2016j) and have therefore been classed as ‘other environmental factors’.

FLORA AND VEGETATION

This Section describes the flora and vegetation within and surrounding the Proposal area. It identifies Proposal activities that may impact (directly or indirectly) upon conservation significant flora species and vegetation communities, assesses the potential impacts, and follows the mitigation hierarchy to ensure that the Proposal meets the EPA’s objectives for flora and vegetation.

EPA OBJECTIVE

To protect flora and vegetation so that biological diversity and ecological integrity are maintained.

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POLICY AND GUIDANCE

EPA:  Environmental Factor Guideline: Flora and Vegetation (Environmental Protection Authority, 2016d).  Technical Guidance – Flora and Vegetation Surveys for Environmental Impact Assessment (Environmental Protection Authority, 2016k).

RECEIVING ENVIRONMENT

4.3.3.1 REGIONAL CONTEXT

The IBRA7 classification divides Australia into 89 large geographically distinct bioregions based on common climate, geology, landform, native vegetation and species information (Department of the Environment and Energy, n.d.). The project is located entirely within the Pindanland subregion (DL2) of the Dampierland bioregion.

Graham (2003) describes the 5,198,904 ha Pindanland subregion climate as hot dry tropical and semi-arid with summer rainfall, averaging 450-700 mm of rain annually. The Pindanland subregion “comprises sandplains of the Dampier Peninsular and western part of Dampier Land, including the hinterland of the Eighty Mile Beach. It is a fine-textured sand-sheet with subdued dunes and includes the paleodelta of the Fitzroy River. The vegetation is described primarily as pindan. This is the coastal, semi-arid, north-western margin of the Canning Basin.” (Graham, 2003, p. 179).

Regional vegetation mapping was undertaken by Beard (1981), with Beeston, Hopkins and Shepherd (2001) converted the existing paper maps to digital format. The Stage 3 Development Envelope occurs predominantly on the pre-European vegetation association 32 “Acacia thicket with scattered low trees over spinifex Acacia eriopoda, Corymbia dichromophloia, Triodia pungens, T. bitextura”, with a small area to the east occurring on pre-European vegetation association 73 “Annual grasses Enneapogon spp. Aristida spp. etc on dry plains and salt water grasses Sporobolus virginicus on the coast” (Figure 9). These Vegetation Units are not considered under threat, with 100% of their original extents remaining (Department of Biodiversity, Conservation and Attractions, 2017a) – Table 7.

Table 7: Pre-European Vegetation

Vegetation Description Original Extent Extent (2012) (ha) Association (ha) Pindan 32 Acacia thicket with scattered low trees 33,389 33,389 (100%) over spinifex Acacia eriopoda, Corymbia dichromophloia, Triodia pungens, T. bitextura Mandora Annual grasses Enneapogon spp. Aristida 249,064 249,064 (100%) Coastal Plain 73 spp. etc on dry plains and salt water grasses Sporobolus virginicus on the coast

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4.3.3.2 STUDY METHODS

A comprehensive Flora and Vegetation Study was undertaken for this project in accordance with Technical Guidance – Flora and Vegetation Surveys for Environmental Impact Assessment (Environmental Protection Authority, 2016k). The study report is contained in Appendix D (EnviroWorks Consulting, 2017a). The study included:

 A Detailed Flora and Vegetation Survey from 11th to 21st July 2016 for the establishment of floristic quadrats and traversals of the Stage 2 and 3 project areas during which plant specimens were collected for later identification. A total of 176 floristic quadrats (each 50 m x 50 m or 2500 m2) were established and analysed and searches for rare and priority species conducted.  A Targeted Priority Flora Survey from 25th – 28th August 2016 within the Stage 2 and 3 project areas and opportunistic regional priority flora searches. Searches were conducted in a grid pattern with survey personnel walking approximately 40 m apart within the Stage 2 and 3 study areas. GPS coordinates, plant counts and photographs were recorded of conservation significant flora.  A Reconnaissance Flora and Vegetation Survey from 21st – 23rd September 2017 of areas to the north of the Stage 3 project area (including the Ramsar wetland) and re-examination of the Stage 3 project area. The survey involved traversal of the study area to carry out structural vegetation mapping and flora species identification and sampling. During traversal, particular attention was paid to determining the extent of Rare and Priority species and, if found, the status of any populations of these species, as well as mapping of vegetation communities.

The 2016 survey timing was selected to occur after significant rainfall, which corresponds with major flowering times in the in region (with the majority of species flowering times being rainfall dependent). The July and August 2016 surveys corresponded with a preceding major rainfall event which occurred in June 2016 and enabled the collection of a large number of priority flora records of species flowering due to the preceding rainfall.

The 2017 survey timing was conducted as a supplementary survey to gather further information and as a result was carried out in the post-wet season period (September 2017).

4.3.3.3 VEGETATION COMMUNITIES

Within Stage 3 Development Envelope, four floristic community types were identified by multivariate analysis. These communities are broadly consistent with the pre-European vegetation mapping described above. Floristic vegetation mapping is provided in Appendix D. The Stage 3 floristic community types are (EnviroWorks Consulting, 2017a):

 Acacia Shrubland A (Pindan): Acacia shrubland on red sandy pindan soil. Open Low woodland B (to 4m) of Bauhinia cunninghamii and Dolichandrone heterophylla over low scrub/scrub to 2m (Acacia stellaticeps, Acacia colei, Carrisa lanceolata, Melaleuca lasiandra), over a variable groundlayer of low grasses (Triodia schinzii, Enneapogon purpurascens, Cenchrus ciliaris, Eragrostis falcata) and herbs (Corchorus sidoides subsp. sidoides, Corchorus parviflorus Sida arenicola, Bonamia rosea, Solanum diversiflorum, Bonamia alatisemina).  Acacia Shrubland B (Pindan): Acacia shrubland on red sandy pindan soil, gravel and rocky outcrops. Open Low woodland B (to 4m) of Bauhinia cunninghamii, Erythrophleum chlorostachys and Dolichandrone heterophylla over low scrub/scrub to 2m (Acacia stellaticeps, Acacia colei, Carrisa lanceolata, Acacia ancistrocarpa, Acacia sericophylla, Grevillea pyramidalis, Acacia monticola), over a variable groundlayer of low grasses (Triodia schinzii, Cenchrus ciliaris, Eragrostis falcata) and herbs (Corchorus sidoides subsp. sidoides, Corchorus parviflorus Sida arenicola, Bonamia rosea, Ptilotus astrolasius, Indigofera monophylla, Jacksonia aculeata).  Mixed Species Shrubland B (Pindan): Mixed species shrubland on red sandy pindan soil. Open Low woodland B (to 4m) of Corymbia hammerslayana, Erythrophleum chlorostachys and Dolichandrone

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heterophylla over low scrub/scrub to 2m (Acacia stellaticeps, Acacia colei, Acacia dictyophleba, Hakea macrocarpa, Acacia ptychophylla, Stylobasium australe, Acacia ancistrocarpa, Acacia sericophylla, Grevillea pyramidalis, Acacia monticola), over a variable groundlayer of low grasses (Triodia schinzii, Eragrostis falcata) , shrubs and herbs (Bonamia rosea, Heliotropium vestitum, Jacksonia aculeata).  Melaleuca-Acacia Shrubland B (Pindan): Melaleuca-acacia shrubland on brown sandy loam and grey/white clay. Open Low woodland B (to 4m) of Melaleuca alsophila and Acacia ampliceps over low scrub/scrub to 2m (Acacia stellaticeps, Acacia colei, Carrisa lanceolata, Melaleuca lasiandra), over a variable groundlayer of low grasses (Cenchrus ciliaris, Triodia epactia, Triodia schinzii) shrubs and herbs (Solanum esuriale, Pluchea ferdinandi-muelleri, Stemodia grossa, Pluchea tetrantha, Pterocaulon sphacelatum, Senna venusta).

A Reconnaissance Level Survey including structural mapping of vegetation communities was carried out of the area to the north of the Stage 3 project area (including the Ramsar wetland). Six structural vegetation communities were mapped. For comparison purposes, the Stage 3 floristic mapping (described above) was translated into structural vegetation mapping as outlined in Table 8 below and shown in Figure 10 (EnviroWorks Consulting, 2017a).

Table 8: Structural Vegetation Communities

Structural Floristic Description Stage 3 Adjacent Vegetation Community Development Study Area Type Envelope including (ha) Ramsar Wetland (ha) Pindan Acacia Pindan shrublands are acacia dominated 346.6 179.2 Shrublands Shrublands A shrubland which occur on red or brown and B sands predominantly with the Stage 3 (Pindan) and project area and are located at a higher Mixed Species elevation in the landscape than the Shrubland B adjacent coastal plain vegetation types. (Pindan). Refer above for descriptions of floristic community types included in this Structural Vegetation Community. Coastal Melaleuca- Coastal Plain thickets and shrublands 10.21 957.7 Plain Acacia occur predominantly in the Ramsar study Thickets Shrubland B area on grey to white clayey silty soil and and brown sandy loam, at a lower elevation in Shrublands the landscape compared with the Pindan shrublands. They consist of Melaleuca alsophila and Acacia ampliceps thickets/shrublands (to 6m) over grasses (Sporobolus australasicus, Cenchrus ciliaris), low herbs (commonly Pluchea spp. Trianthema spp.) and disturbed bare ground, on grey/white clays which are seasonally wet and may be occasionally flooded. Coastal Does not exist Coastal Plain grasslands and low 0 387.2 Plain in Stage 3 shrublands occur predominantly in the Grasslands Ramsar study area on grey to white clayey and Low silty soil, at a lower elevation in the Shrublands landscape compared with the Pindan

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Structural Floristic Description Stage 3 Adjacent Vegetation Community Development Study Area Type Envelope including (ha) Ramsar Wetland (ha) shrublands. These grasslands form a mosaic with the coastal plain thickets and shrublands described above. They consist of grasses (Cenchrus cilliaris, Sporobolus australasicus, Eragrostis sp., Whiteochloa airodies) and low shrubs to 1.5m (Indigofera oblongifolia, Salsola australis, Trianthema spp., Triodia spp.) which are sparse to dense in cover, and occur on grey/white clays. Some areas are likely to be seasonally wet and may occasionally flood after heavy prolonged rainfall. Salt Pans Do not exist in Salt pans occur in minor depressions in the 0 55.9 stage 3 landscape within the Ramsar study are at slightly lower elevation than surrounding areas on grey to white clay. These depressions naturally collect rainfall from surrounding areas after rainfall and evaporation results in the build up of salts over time. They consist of bare salt pan areas and associated low samphire, herblands and shrublands (Trianthema turgidifolia, T. pilosa T cussackiana, Tecticornia auriculata, Frankenia ambiata, Salsola australis). They are likely to be seasonally wet and subject to occasional flooding after heavy prolonged rainfall. Low Do not exist in Low limestone ridges occur in localised 0 60.4 Limestone Stage 3 areas within the Ramsar study with Ridges limestone cap rock visible at the surface. They are sparsely vegetated and occur with shallow red or brown sands. Common plant species include Ptilotus axillaris, Trainthema spp., Cenchrus ciliaris and Cleome uncifera with occasional emergent shrubs of, Acacia coleyi and A. stellaticeps. Completely Completely Areas which have been cleared or are 10.26 73.5 Degraded Degraded devoid of vegetation due to heavy use by (includes cattle (such as stock watering points). Tracks)

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4.3.3.4 THREATENED AND PRIORITY ECOLOGICAL COMMUNITIES

No Threatened or Priority Ecological Communities (TEC’s/PEC’s) were identified within the Stage 3 Development Envelope through the Department of Biodiversity, Conservation and Attractions (DBCA) database search or through field visits.

A DBCA record of the Eighty Mile Land System Priority 3 PEC occurs 320 m immediately north of the Stage 3 Development Envelope (Figure 10). The buffer of the PEC overlaps the Stage 3 Development Envelope, however the occurrence of the PEC does not.

The Eighty Mile Land System PEC is described as: “Beach foredunes, longitudinal coastal dunes and sandy plains with tussock grasslands and spinifex grasslands” (Department of Biodiversity, Conservation and Attractions, 2017b).

The quadrat based sampling and multivariate analysis within the Stage 3 Development Envelope did not find any occurrences of the Eighty Mile Land System PEC or other locally known PECs. The floristic community types identified within the Stage 3 Development Envelope are ubiquitous shrublands (Acacia Shrublands A and B (Pindan), Mixed Species Shrubland B (Pindan) and Melaleuca-Acacia Shrubland B) which are not similar to the DBCA PEC descriptions (EnviroWorks Consulting, 2017a).

The vegetation to the north of the Stage 3 project area will not be impacted by the Stage 3 project as described under Section 4.3.4 below.

4.3.3.5 ECOLOGICAL CONDITION AND FOLIAGE COVER

The native plant communities present within the study area range from degraded to very good in ecological condition. Weed invasion, fire and physical disturbance associated with cattle station operations are the main disturbances. Completely degraded vegetation covers 84 ha and occurs in association with cattle station activity and stock watering points (Figure 11).

Within the Stage 3 Development Envelope, percentage foliage cover (vegetation density), varies from 0% in areas completely devoid of vegetation (e.g. tracks, fence lines, agricultural infrastructure) to 40-60% in Pindan Shrublands. A fire in 2015 reduced cover in the Pindan Shrublands of the western section of the Stage 3 Development Envelope to 20-30%. Vegetation in this area is currently in a regrowth stage. On average the vegetation cover across the Stage 3 development envelope is estimated to be 35% (EnviroWorks Consulting, 2017a) – Figure 11.

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4.3.3.6 FLORA

129 native plant species representing 79 genera and 35 families were recorded within the Pardoo study areas. The most common plant families included Fabaceae, Malvaceae and Amaranthaceae. Species of Acacia and Melaleuca dominate the shrub flora while Amaranthaceae, Malvaceae, Poaceae and Fabaceae species are most common within the lower strata. Four weed species were recorded (Aerva javanica, Calotropis procera, Cenchrus ciliaris and Tamarix aphylla). Aerva javanica and Cenchrus cilliaris are common weeds associated with grazing (EnviroWorks Consulting, 2017a).

4.3.3.7 CONSERVATION FLORA

 Bonamia oblongifolia (Priority 1) was identified as occurring in the Stage 3 Development Envelope and also further afield. Bonamia oblongifolia is a low scrambling woody perennial. It occurs within Acacia Shrubland A and B communities and extends into Melaleuca-Acacia Shrubland A in the Stage 2 area. Within the study areas, Bonamia oblongifolia occurs as localised populations with plants being found underneath taller shrubs and also exposed on open sandy areas often associated with disturbances. Populations were healthy and in fruit at the time of the field survey. This species was also found to occur more widely within the region, over a 50 km stretch of Great Northern Highway south from 80 Mile Beach Rd and during separate field studies at Wallal Downs and Anna Plains (EnviroWorks Consulting, 2016), (EnviroWorks Consulting, 2017b). The estimated regional population of Bonamia oblongifolia based on these regional surveys is approximately 1,208,577 plants (EnviroWorks Consulting, 2017a). This is an under-estimate because time constraints precluded exploration of additional areas outside of the Pardoo, Wallal Downs and Anna Plains study areas and the species is likely to be widespread in other areas in the region. When clearing is taken into account at Pardoo Stage 2 (50 plants), Wallal Downs (30,752 plants) and Anna Plains (51 plants) the remaining regional population is approximately 1,177,724 plants. Refer to Table 9 and Appendix D for further details (EnviroWorks Consulting, 2017a) .  Tribulopis marliesiae (Priority 3) was located in a small area immediately north of the Stage 3 Development Envelope. The species was found within the Acacia Shrubland B Floristic Community – thirteen plants were identified. The extent of this species at Pardoo and regionally is uncertain. The 13 known plants at Stage 3 will be fenced and cattle excluded, so they will not be disturbed by the Stage 3 development.

Table 9: Population estimates of Bonamia oblongifolia at Pardoo, Wallal Downs and Anna Plains

Location Estimated Population Plants Proposed or Approved to be Cleared Pardoo, Stage 2 –Survey Area (961 ha) 5,544 Pardoo, Stage 2 – Development Envelope (790 ha) 50 50 Pardoo, Stage 3 – Survey Area – not including 714 development envelope Pardoo, Stage 3 – Development Envelope outside pivots 48 48 Pardoo, Stage 3 - Development envelope inside Pivots 110 110 Pardoo, Pivots – Targeted Search Area (1 ha) 145 Wallal Downs - Survey Area (5,600 ha) 1,170,000 Wallal Downs – Homestead Development Envelope 30,752 30,752 Anna Plains – Survey Area (350 ha) 1,163 Anna Plains – Development Envelope (200 ha) 51 51 Total 1,208,577 31,011

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POTENTIAL IMPACTS

Activities that may impact upon flora and vegetation include:

 Clearing of terrestrial vegetation (for pivot irrigation areas and related infrastructure);  Crop establishment;  Fertiliser storage and use;  Irrigation and changes to drainage patterns;  Movement and grazing of cattle associated with pivot operations;  Operational activities (e.g. vehicle movement); and  Storage and handling of contaminants (hydrocarbons and chemicals).

Potential impacts to flora and vegetation include:

 Direct loss of vegetation and conservation significant flora through clearing  Indirect impacts resulting from: o Introduction and spread of weeds o Increased trampling by cattle concentration increasing around pivots o Dust deposition due to increased cattle movement o Altered fire regimes due to operational activities causing fire o Water run-off from irrigation creating an altered vegetation structure in the surrounding environment resulting in an artificial ecosystem o Nutrient/fertiliser run-off or leaching could affect the condition of local vegetation and cause the proliferation of weed species o Erosion due to increased cattle movement and/or clearing activities o Contamination through: . Disturbance of acid sulphate soils . Hydrocarbon spills from generators, earthmoving and harvesting equipment . Spills of fertiliser . Inappropriate waste disposal

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4.3.4.1 DIRECT LOSS OF VEGETATION AND PRIORITY FLORA

The disturbance footprint required for the Stage 3 irrigation project is 280 ha (266 ha for the 6 pivots and 14 ha for support infrastructure). Within this 280 ha footprint it is estimated that direct vegetation loss will be approximately 96 ha based on the average vegetation density (foliage cover) across the vegetation types mapped (refer to Table 10 and Figure 11) (EnviroWorks Consulting, 2017a).

In terms of priority flora, it is estimated that 110 individual plants of Bonamia oblongifolia (Priority 1) will be directly cleared. None of the Tribulopis marliesiae (Priority 3) plants surveyed will be cleared (they will be fenced and cattle excluded as shown on Figure 12.

4.3.4.2 INDIRECT IMPACTS TO VEGETATION

Indirect impacts to vegetation such as weeds, fire, water/nutrient run-off and contamination will be avoided as described in Appendix A – Environmental Management Plan.

However, there may still be some localised areas of indirect impact which are unavoidable due to increased trampling of cattle around the pivots. The fenced areas around the pivots will be used to restrict cattle when grazing on the pivots (Figure 4). These fenced areas contain 88 ha of land (not including the pivots and supporting infrastructure which will be cleared) (Figure 5). The cattle tend to graze preferentially within the pivot crops themselves as they offer more nutritious and high calorie feed than surrounding native vegetation. However, some cattle may move off the pivots to rest after grazing and may impact surrounding native vegetation (via trampling) within the fenced areas when being herded for movement in and out of the fenced areas.

Therefore, it is assumed that there may be some degradation via trampling of the 88 ha of land within the fenced areas. For the purposes of the impact assessment, the entire 88 ha of native land the pivots within the fenced areas is assumed to be impacted by trampling. Within this 88 ha footprint it is estimated that the area of vegetation impacted will be approximately 31 ha based on the average vegetation density (foliage cover) across the vegetation types mapped (refer to Table 10 and Figure 11) (EnviroWorks Consulting, 2017a).

In terms of priority flora, it is estimated that 48 individual plants of Bonamia oblongifolia (Priority 1) will be indirectly impacted by this additional trampling of the 88 ha of native vegetation within fenced areas. None of the Tribulopis marliesiae (Priority 3) plants surveyed will be impacted (they will be fenced and cattle excluded as shown on Figure 12).

There will be no additional trampling or grazing by cattle outside the fenced Development Envelope as cattle movement frequency and density is unlikely to change in these areas (cattle already move and graze freely within the local area as part of normal station activities regulated under the pastoral lease and installation of the pivots will not change this). Cattle will be herded into the Stage 3 Development Envelope via a fenced track from existing cattle station holding yards to the south east – this fenced track will be installed as part of normal cattle station activities under the conditions of the pastoral lease.

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4.3.4.3 QUANTIFICATION OF IMPACTS

Impacts to flora and vegetation are quantified in the tables below.

Table 10: Vegetation predicted direct and indirect loss Stage 3

Local Stage 3 Stage 3 Stage 3 Average Direct Indirect Total Vegetation Direct Indirect Total % Vegetation Vegetation Vegetation Types disturbance disturbance disturbance Foliage Loss Impact Disturbance (ha) – pivots & (ha) – fenced (ha) Cover (based on (based on (based on % ancillary areas for % foliage % foliage foliage infrastructure containing cattle cover) (ha) cover) (ha) cover) (ha) Pindan 265 78 343 35% 93 27 120 Shrublands Coastal 5 8 13 50% 2.5 4 6.5 Plain Thickets and Shrublands Completely 10 2 12 0% 0 0 0 Degraded Total 280 88 368 N/A 96 31 127

Table 11: Predicted proportional loss of vegetation locally and regionally

Vegetation Stage 3 Stage 3 Stage 3 Area of veg. Area of % of veg. % of veg. Types Direct Indirect Total type locally veg. type type type (Beard, disturbance disturbance disturbance (Pardoo regionally locally regionally 1971) (ha) (ha) (ha) Station) (ha)1 (Pardoo (ha)1 Station) Pindan 32 279 84 363 70,484 245,070 0.51 0.15 Mandora 1 4 5 6,279 260,160 0.08 0.002 Coastal Plain 73 Table Note 1. Clearing for previous irrigation project stages has been subtracted to take into account previous cumulative loss Table 12: Predicted proportional loss of priority flora regionally

Species Total Proposed Direct Indirect Loss Stage Cumulative Loss Proportional Estimated Loss (no. plants) 3 (no. plants) (no. plants) loss (%) Population (no. plants) Note 1 Bonamia 1,177,724 110 48 158 0.013 oblongifolia Note 2 (Priority 1) Tribulopis Unknown 0 (plants will be 0 (plants will be 0 0 marliesiae fenced and cattle fenced and cattle (Priority 3) excluded) excluded) Table Note 1. Clearing for previous irrigation project stages has been subtracted to take into account previous cumulative loss. Table Note 2. The estimated regional population is approximately 1,208,577 plants. When clearing is taken into account at Pardoo Stage 2, Wallal Downs and Anna Plains the remaining regional population is approximately 1,177,724 plants. This is an under-estimate because time constraints precluded exploration of additional areas outside of the Pardoo, Wallal Downs and Anna Plains study areas and the species is likely to be widespread in other areas in the region. The estimated population in each survey area is provided in Table 9. Refer to Section 4.3.3.7 and Appendix D for further details (EnviroWorks Consulting, 2017).

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ASSESSMENT OF IMPACTS

The scale of impacts to vegetation is considered to be small in a regional context, with only 0.15 and 0.002% of regional Pre-European Vegetation communities Pindan 32 and Mandora Coastal Plain 73 proposed to be impacted. These vegetation communities are not considered under threat, with 100% of their original extents remaining.

The scale of impacts to vegetation is considered to be small in a local context, with only 0.51 and 0.08% of Pre-European Vegetation communities Pindan 32 and Mandora Coastal Plain 73 proposed to be impacted on Pardoo Station.

The impacts to conservation flora are not considered to be significant, with only 0.013% and 0% of the estimated regional populations of the species Bonamia oblongifolia (Priority 1) and Tribulopis marliesiae (Priority 3) proposed to be impacted.

MITIGATION

The mitigation hierarchy has been applied as described below:

 Avoid: o Direct disturbance of vegetation will be avoided outside the Stage 3 Development Envelope, by fencing the Development Envelope to contain cattle within it. o The local population of Tribulopis marliesiae (Priority 3) has been completely avoided by fencing and exclusion of cattle. o A buffer of 100 m is proposed from the adjacent Ramsar wetland. o Indirect impacts from weeds, fire, water/nutrient run-off and contamination will be avoided as described in Appendix A – Environmental Management Plan.  Minimise: o Impacts to regional vegetation types have been minimised by impacting only 0.15 and 0.001% of regional Pre-European Vegetation communities Pindan 32 and Mandora Coastal Plain 73. o Impacts to the population of Bonomia oblongifolia (Priority 1) have been minimised with only 0.013% of the known population of the species to be impacted. o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan.

PREDICTED OUTCOME

With successful implementation of the Environmental Management Plan (Appendix A), any residual impacts should be minor. Given the Project will avoid or minimise direct and indirect impacts on flora and vegetation, it is concluded that the EPA objective for this factor can be met.

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TERRESTRIAL ENVIRONMENTAL QUALITY

This Section describes the terrestrial environmental quality within and surrounding the Proposal area. It identifies Proposal activities that may impact (directly or indirectly) upon terrestrial environmental quality, assesses the potential impacts, and follows the mitigation hierarchy to ensure that the Proposal meets the EPA’s objectives for this factor.

EPA OBJECTIVE

To maintain the quality of land and soils so that environmental values are protected.

POLICY AND GUIDANCE

EPA  Environmental Factor Guideline: Terrestrial Environmental Quality (Environmental Protection Authority, 2016i).

RECEIVING ENVIRONMENT

4.4.3.1 REGIONAL CONTEXT

Surface geology mapping available is shown in Figure 13 (Geological Survey of WA, 2017).

Surface geology within the Stage 3 project area consists of the following: Czs: Sand or gravel plains; may include some residual alluvium; quartz sand sheets commonly with ferruginous pisoliths or pebbles; local clay, calcrete, laterite, silcrete, silt, colluvium.

Surface geology within the Ramsar area to the north of the stage 3 project area is paleo-tidal in nature and consists of the following: Qe: Estuarine, tidal delta and lagoonal deposits (paeleo-tidal); coastal mud flats, silt and evaporite deposits (paeleo-tidal); may contain older vegetated black soils.

4.4.3.2 STUDY METHODS

A desktop review of soil types has been conducted by reviewing the following soils datasets:

 Surface geology (Geological Survey of WA, 2017).  Soil landscapes mapping (Department of Primary Industries and Regional Development, 2017).  Acid sulphate soils mapping (CSIRO Land and Water, 2013; 2017).

A soil chemistry analysis was also undertaken by EnviroWorks Consulting of 13 sub-surface soil samples in areas representative of the Stage 3 project area, the adjacent Ramsar area and the Stage 1 operational pivots (see section 4.4.3.6) ((Figure 14).

The soil chemistry analysis suite included: Colwell Phosphorous, Colwell Potassium, Sulphur (KCl 40), Organic Carbon (Walkley-Black), Nitrate Nitrogen, Ammonium Nitrogen, Electrical Conductivity, pH (water), pH (CaCl2), Boron, Trace elements (DTPA: Copper, Zinc, Manganese, Iron) Exchangeable Cations (Calcium, Magnesium, Sodium, Potassium, Aluminium), Phosphorous Buffering Index (PBI).

Soil infiltration testing was also conducted at two locations within the Stage 3 project area and two locations within the adjacent Ramsar area (Water Technology, 2017) (see section 4.4.3.5) (Figure 14).

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4.4.3.3 SOIL TYPES

The soils along the coastal strip of Pardoo Station can be divided into two key categories:

1. Soils of the coastal floodplain (within the Ramsar wetland boundary) which were formed by an ancient paleo-tidal system, have a high silt/clay content and as a result have a low infiltration rate. 2. Soils of the Sandy Desert (including the Stage 3 Project area) - a red sandy “Pindan” soil with a high infiltration rate (Water Technology, 2017).

These two soil categories are clearly seen on the aerial photography as different colour soils (Figure 14).

Soil landscape mapping provides further detail with the project occurring on soil-landscape type: 117 Nt: Sandplains supporting shrubby spinifex grasslands with occasional trees. The Ramsar area to the north of the project contains a range of soil-landscape types which are paleo-tidal in nature and indicative of the resulting silty, clayey soil type (Figure 15).

4.4.3.4 ACID SULPHATE SOILS

National acid sulphate soil mapping is available from the CSIRO Land and Water “Atlas of Australian Acid Sulphate Soils” database (CSIRO Land and Water, 2013; 2017). The majority of the proposal lies within an area of Extremely Low (1-5% chance) acid sulphate soil risk (Figure 16). A small area of High (>70% chance) acid sulphate soil probability occurs in the western corner of the proposal development envelope (Figure 16). However, given there will be no excavation in this area, the risk of acid generation is considered low.

4.4.3.5 SOIL INFILTRATION RATES

Infiltration testing was undertaken at the site to determine the saturated hydraulic conductivity of the soil. Four sites were chosen, two being within the Stage 3 Development Envelope, and the other two within the Ramsar wetland listed area (Figure 14). Table 13 below summarises the results, and the calculations are in Appendix E (Water Technology, 2017). The test locations within the Stage 3 development (tests 1 and 2) are representative of the sandy soils of the wider catchment, which have very high infiltration rates of around 155 mm/hour, as opposed to the lower lying clayey silt areas within the Ramsar wetland area (tests 3 and 4) which have low infiltration rates of 1 – 17 mm/hour.

Table 13: Summary of Infiltration Test Results

Test Location Easting Northing Soil Infiltration Rate (mm/hr) 1 Stage 3 – Proposed 804828 7787463 Pindan - red/brown silty sand 157 Pivot 15 2 Stage 3 – Proposed 804492 7786201 Pindan - red/brown silty sand 155 Pivot 13 3 Ramsar Wetland 803465 7788539 Pale grey clayey silt with minor 17 fine sand with the presence of mud cracks. 4 Ramsar Wetland 804082 7788650 Pale grey clayey silt with minor 1 sand. No evidence of ponding or mud cracks.

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4.4.3.6 SOIL CHEMISTRY ANALYSIS

Thirteen sub-surface soil samples were taken by EnviroWorks Consulting from the 21st – 23rd September 2017 as follows (Figure 14):

 Three samples within or near the Stage 3 project area (sample numbers S301, S302 and S303)  Four samples within the adjacent Ramsar area (sample number R01 – R04)  Six samples within or just outside existing operational Stage 1 Pivots (sample numbers P01 to P06).

The analysis was completed by CSBP Soil Laboratory (Report Number 92763 Dated 4/10/17). The complete results are presented in Appendix F. The analysis shows:

 The soils within the Ramsar site possess a different chemical profile to the soils within the irrigation project.  The Ramsar soils contain elevated levels of nutrients, organics and salts which are several orders of magnitude higher than the soils within the irrigation project area (refer to blue highlighted cells in Appendix F). This is expected given the paleo-tidal nature of the clays and silts within the Ramsar area which would naturally contain higher levels of these analytes, given their origin as ancient saline tidal mudflats. In addition, these areas flood occasionally (approximately every 10 years) after heavy prolonged rainfall (Water Technology, 2017) and natural evaporation processes would lead to the concentration of salts within the soils.  The pH of the irrigation project soils ranges from slightly acidic to neutral, whereas the Ramsar site soils tend to be neutral to slightly basic.  The nutrient levels within the active pivots (sites P01, P03 and P05) are slightly elevated as would be expected given the application of fertiliser to these pivots.  The nutrient levels immediately adjacent to the pivots (sites P02, P04 and P06) do not show evidence of lateral movement of nutrients, as would be expected given the sandy soils which have a high infiltration rate as described above.

POTENTIAL IMPACTS

Activities that may impact upon terrestrial environmental quality:

 Mechanical disturbance during the clearing process;  Installation of equipment on site (generators, pipelines and irrigation equipment);  Trenching and burying water reticulation pipelines;  Fertiliser storage and use;  Waste generation and disposal;  Operational activities (e.g. vehicle movement); and  Storage and handling of hydrocarbons – note: no other chemicals to be used on site.

Potential impacts upon terrestrial environmental quality include:

 Direct disturbance of native soils beneath the pivots and other infrastructure (due to mechanical clearing and changes in soil structure and composition because of crop establishment, irrigation and fertilisation)  Indirect changes to native soils within the fenced areas where cattle are contained, due to additional trampling and manure accumulation  Surface run-off or lateral leaching of nutrients from the pivot areas causing elevated nutrient levels in surrounding soils outside the pivots  Erosion by surface water flows, irrigation or wind  Contamination of local soils through:

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o Disturbance of acid sulphate soils o Hydrocarbon spills from generators, earthmoving or harvesting equipment o Spills of fertiliser o Inappropriate waste disposal.

4.4.4.1 DIRECT DISTURBANCE OF TERRESTRIAL ENVIRONMENT

As discussed in Section 4.3.4.1, the disturbance footprint required for the Stage 3 irrigation project is 280 ha (266 ha for the 6 pivots and 14 ha for support infrastructure). This direct disturbance will occur on red sandy (pindan) soil within the Stage 3 project area.

No direct disturbance of soil will occur within the Ramsar wetland area. It should be noted that a buffer of 100 m is proposed from the adjacent Ramsar wetland boundary.

4.4.4.2 INDIRECT DISTURBANCE TO TERRESTRIAL ENVIRONMENT

Indirect impacts to terrestrial environmental quality such as nutrient run-off/leaching, erosion and contamination will be avoided as described in Section 4.6, 4.7 and Appendix A – Environmental Management Plan.

As described in Section 4.3.4.2, there may still be some localised areas of indirect impact to the terrestrial environment which are unavoidable due to increased trampling of cattle around the pivots and manure build up in these locations. For the purposes of the impact assessment, the entire 88 ha of terrestrial environment surrounding the pivots within the fenced areas is assumed to be impacted by trampling and manure accumulation. There will be no additional trampling or grazing by cattle outside the fenced Development Envelope as cattle movement frequency and density is unlikely to change in these areas (cattle already move and graze freely within the local area as part of normal station activities regulated under the pastoral lease and installation of the pivots will not change this). Cattle will be herded into the Stage 3 Development Envelope via a fenced track from existing cattle station holding yards to the south east – this fenced track will be installed as part of normal cattle station activities under the conditions of the pastoral lease.

4.4.4.3 QUANTIFICATION OF IMPACTS

Quantification of impacts to terrestrial environmental quality is detailed in Table 14 below.

Table 14: Predicted proportional disturbance of terrestrial environment

Soil Type Stage 3 Stage 3 Stage 3 Area of Area of % of soil % of soil Direct Indirect Total soil type soil type type type disturbance disturbance disturbance locally regionally locally regionally (ha) (ha) (ha) (Pardoo (ha)1 (Pardoo Station) Station) (ha)1 117 Nt: Sandplains 280 88 368 159,300 1,405,008 0.23 0.026 supporting shrubby spinifex grasslands with occasional trees Table Note 1. Clearing for previous irrigation project stages has been subtracted to take into account previous cumulative disturbance.

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ASSESSMENT OF IMPACTS

The scale of impact to terrestrial environmental quality is considered to be small in a regional context, with only 0.025% of soil type 117 Nt proposed to be impacted regionally.

The scale of impact to terrestrial environmental quality is considered to be small in a local context, with only 0.22% of soil type 117 Nt proposed to be impacted on Pardoo Station.

MITIGATION

The mitigation hierarchy has been applied as described below:

 Avoid: o Direct disturbance of the terrestrial environment will be avoided outside the Stage 3 Development Envelope, by fencing the Development Envelope to contain cattle within it. o A buffer of 100 m is proposed from the adjacent Ramsar wetland. o Indirect impacts such as nutrient run-off/leaching and contamination will be avoided as described in Appendix A – Environmental Management Plan.  Minimise: o Impacts to regional soil types have been minimised by impacting only 0.025% of regional soil landscape type 117Nt. o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan.

Further detail on mitigation of impacts is discussed in Appendix A – Environmental Management Plan.

PREDICTED OUTCOME

With successful implementation of the above management measures, any residual impacts should be minor. Given the Project will avoid or minimise direct and indirect impacts on terrestrial environmental quality, it is concluded that the EPA objective for this factor can be met.

TERRESTRIAL FAUNA

This Section describes the terrestrial fauna recorded and potentially occurring within the Proposal area and surrounding area. It identifies Proposal activities that may impact (directly or indirectly) upon conservation significant fauna species, assesses the potential impacts, and follows the mitigation hierarchy to ensure that the Proposal meets the EPA’s objectives for terrestrial fauna.

EPA OBJECTIVE

To protect terrestrial fauna so that biological diversity and ecological integrity are maintained.

POLICY AND GUIDANCE

EPA  Environmental Factor Guideline: Terrestrial Fauna (Environmental Protection Authority, 2016h).  Technical Guidance: Terrestrial fauna surveys (Environmental Protection Authority, 2016n).

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 Technical Guidance: Sampling methods for terrestrial vertebrate fauna (Environmental Protection Authority, 2016l).  Technical Guidance: Sampling of short range endemic invertebrate fauna (Environmental Protection Authority, 2016m).

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RECEIVING ENVIRONMENT

4.5.3.1 REGIONAL CONTEXT

Pardoo Station, including the area proposed for a new Pivot irrigation system (Pivot Area 3) and the nearby Ramsar site, falls into the western extremity of the Dampierland bioregion (Thackway and Cresswell, 1995).

The Stage 3 area and nearby Ramsar site lie across two of these major components of the Dampierland bioregion: Stage 3 - Quaternary sandplain overlying Jurassic and Mesozoic sandstones; and Ramsar site - Quaternary marine deposits on coastal plains with samphire - Sporobolus grasslands, and Melaleuca acacioides low forests (although most thickets and low forest were composed of a tall Acacia species) (Thackway and Cresswell, 1995).

Land Systems (Rangeland) mapping has been prepared by the Western Australian Department of Agriculture from data in van Vreeswyk, Leighton, Payne and Hennig (2004). Land Systems are comprised of repeating patterns of topography, soils, and vegetation (i.e. a series of “land units” that occur on characteristic physiographic types within the Land Systems). The Stage 3 project area occurs predominantly within the Nita Land System described as “Sandplains supporting shrubby spinifex grasslands with occasional trees.”

4.5.3.2 STUDY METHODS

A Level 1 terrestrial fauna assessment of the project area was undertaken as reported in Appendix G (Bamford Consulting Ecologists, 2017) in accordance with Technical Guidance: Sampling methods for terrestrial vertebrate fauna (Environmental Protection Authority, 2016l).

The project area was visited on 12th – 14th July 2016 by Dr Mike Bamford - BSc (Biol.), Hons (Biol.), PhD (Biol.) and Cameron Everard - BSc (Env. Sci.), MSc (Env. Mgt.) and on 18th – 21st September 2017 by Dr Mike Bamford (B.Sc. Hons. Ph.D. Biol.) and Mr Tim Gamblin (B.Sc. Zool. Cert. Env. Man.); Katherine Chuk (B. Sc. Zool. Hons.) assisted with report production.

The assessment on 12-14 July 2016 involved targeted surveys for Greater Bilby and Brush-tailed Mulgara at both Stage 2 and 3. Opportunistic fauna observations were made and the study area was systematically searched for evidence of the two species. This involved trained personnel walking transects spaced 200 m apart across the study area.

The 18-21 September 2017 site visit involved traversing as much of the project area as possible, including the nearby Ramsar site. This enabled environmental descriptions to be prepared and opportunistic observations on fauna to be made. Targeted searching was undertaken for several significant species known from the general area, in particular the Greater Bilby, Mulgara and significant waterbirds. In addition, one evening (night of 20th September) was spent listening for rare fauna (including the Night Parrot) and spotlighting for reptiles.

4.5.3.3 FAUNA HABITAT

Vegetation and Substrate Associations (VSAs) correspond with vegetation mapping (Figure 10 and Section 4.3.3.3). The Stage 3 area and the adjacent Ramsar site represent two very different environments that reflect two major components of the Dampierland Bioregion, and these have a rapid transition marked by a small fall in altitude but a great change in substrate. Broadly, the two areas may be described as follows.

The Stage 3 project area occurs within an area characterised by Pindan (red sandy) soils which support acacia and mixed species shrublands over spinifex grasslands. The area does not flood and is not seasonally wet, due to the high infiltration rates of the pindan soil. The Stage 3 project area provides habitat values for species which utilise the dry, sandy, shrubland environment such as Bilby and Mulgara.

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The Ramsar area to the north of the Stage 3 project, contains a mixture of grasslands and shrublands, as well as small salt pans on white to grey clayey soil. This area can be categorised as a coastal floodplain which is seasonally damp and floods infrequently for short periods after heavy prolonged rainfall. Its elevation is slightly lower in the landscape than the Stage 3 project area to the south. This area provides habitat values for grassland-dependent migratory waterbirds (Oriental Plover, Little Curlew and Oriental Pratincole) that can be expected to be regular migrants visiting the dry grasslands of the adjacent Ramsar site.

Much of the adjacent Ramsar site supports dense acacia and melaleuca thickets. This means that even when flooded, migratory waterbirds that rely on wetland environments would find only small areas of open, shallow wetlands in grasslands and salt pans. Water Technology (2017) conducted a flood study for the area which showed that flooding occurs locally approximately every 10 years. Localised flooding is short lived with some areas flooded for periods of 1 – 2 weeks whilst other areas are inundated for 3 – 5 weeks after heavy prolonged rainfall (Water Technology, 2017) – refer to Section 4.6.

By cross-referencing vegetation types (EnviroWorks Consulting, 2017a), with flood modelling conducted (Water Technology, 2017), within a 1 km buffer from the Stage 3 Development Envelope, there are 20.8 ha of salt pans/grasslands which would flood for 1 – 2 weeks and 12.6 ha of salt pans which would flood for 3-5 weeks. The abundance of waterbirds that use these short lived, ephemeral wetlands adjacent to the project is not expected to be high due to the small area of suitable habitat and infrequency of flooding (Bamford Consulting Ecologists, 2017).

The abundance of dry grassland-dependent waterbirds is also not expected to be high, as the area of dry grassland adjacent to the project is small, but such species are likely to occur regularly in the September to November period (pre-Wet season). Only three listed migratory birds are likely to occur regularly, and all are grassland-dependent species that forage (mostly on invertebrates) on dry grasslands. These are the Oriental Plover, Little Curlew and Oriental Pratincole (Bamford Consulting Ecologists, 2017).

Large but very rare aggregations of these dry grassland species are possible, but the likelihood of such aggregations meeting the Ramsar criterion for any of these species adjacent to Stage 3 is extremely low (Bamford Consulting Ecologists, 2017). The Eighty Mile Beach Ramsar Site is listed on the basis of large aggregations of migratory waterbirds on the coastal flats and beaches 4 km away from the Stage 3 project (Bamford Consulting Ecologists, 2017).

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4.5.3.4 TERRESTRIAL FAUNA ASSEMBLAGE

Bamford Consulting Ecologists (2017) identified 235 vertebrate fauna species as potentially occurring in the Stage 3 area and adjacent Ramsar site: 5 frogs, 44 reptiles, 148 birds and 38 mammals (Table 15). A full species list is provided in Appendix G. This assemblage is typical of a broad region of overlap between the Pilbara, Great Sandy Desert and Kimberley. The number of species present will vary greatly seasonally and annually such that many species are absent for periods of time (Bamford Consulting Ecologists, 2017).

Table 15. Composition of expected vertebrate fauna assemblage of the survey area

Taxon Number Number of species in each category of species Resident Regular Irregular Vagrant Locally expected visitor visitor extinct or migrant Frogs 5 4 1 Reptiles 44 42 2 Birds 148 41 39 19 49 1 Native 30 8 10 7 4 2 Mammals Introduced 8 3 4 1 Mammals

Total 235 95 50 19 56 3

4.5.3.5 CONSERVATION FAUNA

The expected vertebrate assemblage includes 37 species which are listed under legislation or regulatory lists as conservation significant. Of these species nine are expected to occur in Stage 3, twenty are expected to occur in the adjacent Ramsar site and a further 8 are expected to occur in both locations. These species are listed in Table 16 below. Five of these species were recorded on site. Most of the significant species are expected in the project area only as vagrants, and therefore the area is probably of low importance for them. No invertebrate species of conservation significance are expected in the survey area based on database searches. Notes on species that are considered to be at least irregular visitors are provided in Appendix G (Bamford Consulting Ecologists, 2017). Conservation significant fauna recorded from the Stage 3 vicinity are depicted in Figure 17.

Table 16. Conservation significant fauna species expected to occur in the project area.

CS Species Status Recorded Expected Expected Status Habitat REPTILES Airlie Island Ctenotus Ctenotus angusticeps V S3 No Resident S3, Ram Dampierland Plain Slider Lerista separanda P2 No Resident S3, Ram BIRDS Fork-tailed Swift Apus pacificus M S5 Recorded in Stage Migrant S3, Ram 3 and Ramsar Site Oriental Plover Charadrius veredus M S5 Recorded in Migrant Ram Ramsar Site Sharp-tailed Sandpiper Calidris acuminata M S5 No Vagrant Ram Broad-billed Sandpiper Calidris falcinellus M S5 No Vagrant Ram Curlew Sandpiper Calidris ferruginea Cr M No Vagrant Ram S3 S5 Pectoral Sandpiper Calidris melanotos M S5 No Vagrant Ram Red-necked Stint Calidris ruficollis M S5 No Vagrant Ram

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CS Species Status Recorded Expected Expected Status Habitat Swinhoe's Snipe Gallinago megala M S5 No Vagrant Ram Pin-tailed Snipe Gallinago stenura M S5 No Vagrant Ram Little Curlew Numenius minutus M S5 No Migrant Ram Wood Sandpiper Tringa glareola M S5 No Vagrant Ram Common Greenshank Tringa nebularia M S5 No Vagrant Ram Marsh Sandpiper Tringa stagnatilis M S5 No Vagrant Ram Australian Painted Snipe Rostratula australis E S2 No Vagrant Ram Oriental Pratincole Glareola maldivarum M S5 No Migrant Ram White-winged Black Tern Chlidonias leucopterus M S5 No Vagrant Ram Australian Gull-billed Gelochelidon M S5 No Vagrant Ram Tern macrotarsa Eastern Great Egret Ardea modesta S5 No Irregular Ram visitor Cattle Egret Ardea ibis S5 No Irregular Ram visitor Glossy Ibis Plegadis falcinellus M S5 No Vagrant Ram Osprey Pandion haliaetus M S5 No Vagrant Ram Peregrine Falcon Falco peregrinus S7 No Irregular S3 visitor Rainbow Bee-eater Merops ornatus S5 Recorded in Stage Resident S3 3 and Ramsar Site Grey Wagtail Motacilla cinerea M S5 No Vagrant S3, Ram Yellow Wagtail Motacilla flava M S5 No Vagrant S3, Ram Barn Swallow Hirundo rustica M S5 No Migrant S3, Ram MAMMALS Brush-tailed Mulgara Dasycercus blythi P4 Recorded in Regular S3 Stages 2 and 3 visitor Northern Quoll Dasyurus hallucatus E S2 No Vagrant S3 Greater Bilby Macrotis lagotis V S3 Recorded in Regular S3 Stages 2 and 3 visitor Northern Brushtail Trichosurus S3 No Irregular S3 Possum arnhemensis visitor Spectacled Hare- Lagorchestes P3 No Regular S3 Wallaby conspicillatus leichardti visitor Ghost Bat Macroderma gigas V S3 No Vagrant S3 Pilbara Leaf-nosed Bat Rhinonicteris aurantia V S3 No Vagrant S3 (Pilbara form) P4 Loria's Mastiff Bat Mormopterus loriae P1 No Vagrant S3, Ram Lakeland Downs Mouse Leggadina P4 No Irregular S3, Ram lakedownensis visitor Total Number of 37 5 Species: Table Note: EPBC Act listed species: V = Vulnerable, E = Endangered, C = Critically Endangered, Mig = Migratory, Mar = Marine. WC Act listed species: S1 – S7 = Schedule 1 - 7; DPaW Priority Species: P1 - P5 = Priority 1 – 5; S3 = Stage 3, Ram = Ramsar area.

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POTENTIAL IMPACTS

Activities that may impact upon terrestrial fauna include:

 Clearing of terrestrial fauna habitat (for pivot irrigation areas and related infrastructure);  Installation of equipment on site (generators, pipelines and irrigation equipment);  Crop establishment;  Fertiliser storage and use;  Irrigation and changes to drainage patterns;  Operational activities (e.g. vehicle movement); and  Storage and handling of contaminants (hydrocarbons) – note no chemicals or pesticides are used on site.

Potential impacts to terrestrial fauna include:

 Habitat loss as a result of vegetation clearing  Water run-off from irrigation creating an altered vegetation structure in the surrounding environment resulting in an artificial ecosystem, affecting fauna behaviour and assemblages.  Habitat fragmentation due to fencing and pivots creating a barrier  Loss and injury of fauna as a result of vehicle and/or equipment strikes  Loss of fauna and habitat due to altered fire regimes  Fauna entrapment in excavated trenches and behind fences  Exposure of fauna to toxicants and contamination through: o Disturbance of acid sulphate soils o Hydrocarbon spills from generators, earthmoving and harvesting equipment o Spills of fertiliser o Inappropriate waste disposal  Noise, lighting, access to water and food waste causing fauna behaviour changes including changes to predator/prey relationships  Increase in feral fauna species, particularly cats and foxes, as a result of increased accessibility and use of linear infrastructure (e.g. impacts of increased predation and competition)  Increased potential habitat for cane toads.

4.5.4.1 DIRECT LOSS OF HABITAT

As discussed in Section 4.3.4.1, the disturbance footprint required for the Stage 3 irrigation project is 280 ha (266 ha for the 6 pivots and 14 ha for support infrastructure). This direct loss of habitat will occur within the acacia and mixed shrubland habitat types on red sandy (pindan soil).

No direct loss of habitat will occur within the Ramsar wetland area. It should be noted that a project development buffer of 100 m is proposed from the adjacent Ramsar wetland boundary.

4.5.4.2 INDIRECT IMPACTS TO FAUNA

Indirect impacts to fauna and habitat such as water/nutrient run-off, habitat fragmentation, mortality from vehicle/equipment strike, fire, entrapment, toxicants from contamination, behavioural changes and increases in feral species will be avoided as described in Section 4.6, 4.7 and Appendix A – Environmental Management Plan.

As described in Section 4.3.4.2, there may still be some localised areas of indirect impact to fauna habitat which are unavoidable due to increased trampling of cattle around the pivots. For the purposes of the impact assessment, the entire 88 ha of native vegetation surrounding the pivots within the fenced areas is assumed

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to be impacted by trampling. There will be no additional trampling or grazing by cattle outside the fenced Development Envelope as cattle movement frequency and density is unlikely to change in these areas (cattle already move and graze freely within the local area as part of normal station activities regulated under the pastoral lease and installation of the pivots will not change this). Cattle will be herded into the Stage 3 Development Envelope via a fenced track from existing cattle station holding yards to the south east – this fenced track will be installed as part of normal cattle station activities under the conditions of the pastoral lease.

4.5.4.3 QUANTIFICATION OF IMPACTS

Quantification of impacts to fauna habitat within a 15 km buffer (Environmental Protection Authority, 2016l) is detailed in Table 17 below.

Table 17: Predicted proportional cumulative loss of fauna habitat within a 15 km buffer of Stage 1, 2 and 3

Land System Direct and Direct and Direct and Total Nita Land % of land Indirect Indirect Indirect Loss System in system in Loss Stage Loss Stage Loss Stage (ha) 15 km 15 km 1 (ha) 2 (ha) 3 (ha) buffer buffer Nita Land System: Sandplains 270 400 368 1038 61,143 1.7% supporting shrubby spinifex grasslands with occasional trees

ASSESSMENT OF IMPACTS

The area of habitat loss across the largely intact landscape is proportionately small, and therefore the impact upon fauna biodiversity from habitat loss is predicted to be negligible. The 1028 ha of disturbance/impact from Stages 1, 2 and 3 at Pardoo represents 1.7% of the 61,143 ha of native vegetation from the Nita Land System the within a 15km buffer around the three project areas (Figure 18).

Highly significant fauna habitat for waterbirds, shorebirds and migratory birds within the adjacent Ramsar wetland does not occur in close proximity to the proposal. The closest coastal beaches and mudflats which meet the criteria for Ramsar listing in terms of numbers of migratory waterbirds are approximately 4 km away from the Stage 3 project. Indirect impacts to the migratory birds at the coastal beaches and mudflats are highly unlikely due to their distance from the project.

A buffer of 100 m is proposed for the Stage 3 project, from the Ramsar wetland boundary. Indirect impacts to habitat and fauna within the adjacent Ramsar wetland will be avoided as described in Sections 4.3, 4.4, 4.6 and 4.7 of this EPA referral document as well as Appendix A – Environmental Managemental Plan.

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MITIGATION

The mitigation hierarchy has been applied as described below:

 Avoid: o Direct disturbance of habitat will be avoided outside the Stage 3 Development Envelope, by fencing the Development Envelope to contain cattle within it. o A buffer of 100 m is proposed from the adjacent Ramsar wetland. o Indirect impacts from water/nutrient run-off, mortality from vehicle/equipment strike, fire, entrapment, toxicants from contamination and increases in feral species will be avoided as described in Appendix A – Environmental Management Plan.  Minimise: o Impacts to regional habitat types have been minimised by impacting only 1.7% of the 61,143 ha of native vegetation from the Nita Land System within a 15km buffer around the Stage 1, 2 and 3 project areas. o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan.

Further detail on mitigation of impacts is discussed in Appendix A – Environmental Management Plan.

With successful implementation of the above management measures, any residual impacts should be minor. Therefore, PBC have not proposed any offsets in relation to Terrestrial Fauna.

PREDICTED OUTCOME

As stated above, any residual impacts should be minor. Given the Project will avoid or minimise direct and indirect impacts on terrestrial fauna, it is concluded that the EPA objective can be met.

HYDROLOGICAL PROCESSES

This Section describes the hydrological processes within and surrounding the Proposal area. It identifies Proposal activities that may impact (directly or indirectly) upon hydrological processes, assesses the potential impacts, and follows the mitigation hierarchy to ensure that the Proposal meets the EPA’s objectives for this factor.

EPA OBJECTIVE

To maintain the hydrological regimes of groundwater and surface water so that environmental values are protected.

POLICY AND GUIDANCE

EPA:  Environmental Factor Guideline: Hydrological Processes (Environmental Protection Authority, 2016e).  Australian groundwater modelling guidelines (Waterlines Report Series No. 82) (Barnett, et al., 2012). Other:  Operational Policy 5.12 - Hydrogeological reporting associated with a groundwater well licence (Department of Water, 2009).  Rights in Water and Irrigation Act 1914.

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 A Directory of Important Wetlands in Australia (Australian Nature Conservation Agency, 1993).  WA Environmental Offsets Guidelines (Government of Western Australia, 2014)

RECEIVING ENVIRONMENT

4.6.3.1 REGIONAL CONTEXT

SURFACE WATER

The Stage 3 project is situated approximately 4 km from the Indian Ocean within an un-named sub-catchment (which is 28,900,000 ha) within the Sandy Desert Lake Dora catchment (which is 29,360,000 ha) – Figure 19. There is no major river system within the Sandy Desert, just low-lying lake systems, sand dunes and a very long uninterrupted beach front (Water Technology, 2017).

GROUNDWATER

Pardoo Station is located in the north-western corner of the Canning Basin (the largest sedimentary basin in Western Australia, covering about 550,000 km2). The project area is located within the West Canning Basin Pardoo groundwater sub-area (Figure 20) on the Lambert Shelf, where the Wallal Sandstone overlies shallow Archaean basement (Groundwater Consulting Services, 2017a). The groundwater resources of the western Canning Basin have been relatively well understood since the groundwater exploration work carried out by the Geological Survey of Western Australia in the late 1970s across Pardoo Station and the western part of Wallal Downs Station (Leech, 1979).

4.6.3.2 STUDY METHODS

SURFACE WATER

A hydrological assessment of surface water conditions was conducted by Water Technology (2017) – Appendix E. The assessment included:

 A review of meteorological, terrain, satellite imagery and soil mapping data available within the catchment.  Characterisation of the catchment soils and hydrology.  Preparation of a hydraulic model to determine the extent, duration and frequency of local flooding.

GROUNDWATER

Extensive groundwater investigations have been ongoing on Pardoo Station since 2008 as part of the process of obtaining groundwater licences to abstract groundwater for irrigation purposes for the Pardoo Irrigation Project Stages 1, 2 and 3 as listed below:

 Desktop hydrogeological assessment (Groundwater Consulting Services, 2008).  Groundwater operating and monitoring strategy for Stage 1 (Groundwater Consulting Services, 2009).  Staged development plan for groundwater resources at Pardoo (Groundwater Consulting Services, 2011).  Annual groundwater monitoring reviews have been submitted to the regulator from 2012 – 2017 (Groundwater Consulting Services, 2013; 2014a; 2015; 2016a; Groundwater Consulting Services, 2017a).  An impact assessment was undertaken regarding the Stage 1 project (Groundwater Consulting Services, 2014b)  Groundwater operating strategy for Stages 1 and 2 (Groundwater Consulting Services, 2016b).

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 The development of a regional numerical groundwater model for the West Canning Basin using groundwater level/pressure response to the last three years of irrigation. The model has been used to run predictive scenarios to determine the potential impact of increased groundwater abstraction for irrigation at Pardoo Station and Wallal Downs Station (Cymod Systems, 2016).  Groundwater operating strategy for Stages 1, 2 and 3 (Groundwater Consulting Services, 2017b).

A groundwater licence is in place for water abstraction for Stages 1, 2 and 3 (including this proposal) (Groundwater Well Licence 158616(16) issued on 25 January 2017 for 14,822,250 kL or 14.8 GL per annum).

A report describing groundwater monitoring results conducted to date is contained in Appendix H (Groundwater Consulting Services, 2017a).

4.6.3.3 SURFACE WATER HYDROLOGICAL PROCESSES

HYDROLOGY AND SOILS

As described in Section 4.4.3.3, the soils along the coastal strip of Pardoo Station can be divided into two key categories (Figure 14):

The Stage 3 project area sits on top of sandy red Pindan soils at approximately 7-8 m AHD. The adjacent low lying Ramsar area is comprised of grey silty clay soils and sits at approximately 4 – 6 m AHD.

A sub-regional catchment of 250,000 ha (2,500 km2) was defined by Water Technology utilising best available topography data (Figure 19). The inland portion this sub-regional catchment (including the Stage 3 project area) is characterised by red sandy ‘Pindan’ soils (Figure 14) with high infiltration rates (refer to Section 4.4.3.5). The relatively flat nature of the terrain coupled with the high soil permeability means that runoff is negligible (as is typical of desert catchments). Streamlines are not well defined and there are no signs of concentrated flow. This is demonstrated by the lack of waterway infrastructure under the Great Northern Highway, with a 2,500 km2 catchment draining to just two small box culverts, which are likely fed by road runoff rather than catchment runoff. The depth to groundwater in the vicinity of the Stage 3 project is in excess of 3 m (Groundwater Consulting Services, 2017a), hence with an average annual rainfall of approximately 320 mm, the land is unlikely to become saturated (Water Technology, 2017).

A small strip of coastal floodplain occurs within the sub-regional catchment, coinciding with the Ramsar listed wetland area, characterised by grey clayey/silty soils (Figure 14). Again, this area is very flat, with few signs of formed drainage lines. These soils have much lower infiltration rates (refer to Section 4.4.3.5). Water is likely to pond in the lower parts of coastal floodplain after heavy, prolonged rainfall, with runoff being generated from the slightly raised areas. Average daily recorded evaporation within the region (at Port Hedland) is approximately 0.009 m/day (9 mm/day), hence a significant amount of water will evaporate from the ponded areas (Water Technology, 2017).

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EXTENT, DURATION AND FREQUENCY OF FLOODING

An initial hydraulic model, utilising 30 m resolution grid, was prepared by Water Technology (2017) covering the 2,500 km2 sub-regional catchment. At this grid size small floodplain features, such as creeks and roads, are not well represented. However, there is only one major road within the catchment and no major creek systems, just wide, flat surface depressions. Hence, the initial grid size allowed for adequate modelling of the dominant features of the site whilst maintaining manageable model run times.

Following the initial model testing and analysis, a revised smaller model extent (of 19,500 ha) was established covering the low lying Ramsar listed areas, the Stage 3 site, and extending to just upstream of the Great Northern Highway (Figure 21). This smaller model size was selected because it was identified to be the key area that determined flooding of the coastal floodplain adjacent to the Stage 3 project (Water Technology, 2017).

The hydraulic model was run for the three historical rainfall events from March 2007, February 2013 and January-February 1982. The March 2007 event had very good satellite imagery for the weeks after the rainfall event, hence it was used to verify the modelling assumptions. The modelled flooding areas matched the aerial photography of actual flooding well. Modelling shows that no significant surface flows occur across the proposed Stage 3 area due to the high infiltration rates of the Pindan soils. Ponding occurs across parts of the adjacent Ramsar wetland due to the presence of the more clayey soils, however there is no obvious interaction between the two areas (Water Technology, 2017).

An analysis of historical rainfall patterns indicates that historically prolonged heavy rainfall events sufficient to produce flooding of the Ramsar wetland adjacent to the Stage 3 project area occur approximately every 10 years. Climate change predictions for the area indicate that such rainfall events may become more frequent in the region in the future and could possibly occur every 5 years by the year 2090 (Ball, et al., 2016).

The 2007 event is the largest monthly rainfall record available and provides a good basis for estimating flood extents and duration. Based on this event, within the modelled area (of 19,500 ha) when flooded, it is estimated that approximately 1,100 ha of open shallow ponds occur which are flooded for periods of 1 – 2 weeks and approximately 350 ha of open shallow ponds occur which are flooded for periods of 3 – 5 weeks (Figure 21).

Within a 1 km buffer from the Stage 3 Development Envelope, there is 20.8 ha of salt pans/grasslands which would flood for 1 – 2 weeks and 12.6 ha of salt pans which would flood for 3-5 weeks (Water Technology, 2017).

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4.6.3.4 GROUNDWATER HYDROLOGICAL PROCESSES

SEDIMENTOLOGY AND GROUNDWATER AQUIFERS

Locally within Pardoo, the West Canning Basin is comprised of the following sediments which create the local groundwater characteristics (Figure 22):

 At the surface red sandy pindan soils occur within the inland areas, while grey silty clayey soils and a layer of paleo-tidal clay occurs within the coastal plains.  The next layer is the Broome Sandstone, a cross-bedded sandstone, siltstone and conglomerate (its approximate thickness ranges from 30 – 70 m).  The next layer is the Jarlernai siltstone a light-grey to black, puggy, silty clay (its approximate thickness ranges from 50 – 100 m).  The following layer is the Alexander Formation a fine to medium grained sandstone and interbedded mudstone, considered a transitional unit between Wallal Sandstone and Jarlemai Siltstone (its approximate thickness ranges from 10 – 50 m).  The following layer is the Wallal Sandstone a poorly consolidated coarse to fine grained, fawn to light grey sandstone with rare siltstone and conglomerate interbeds (its approximate thickness ranges from 50 – 150 m) (Groundwater Consulting Services, 2017a).

The Wallal aquifer occurs within the Wallal Sandstone and Alexander Formation and is the preferred groundwater source in the West Canning Basin. It supports tourism related activities on Pardoo Station and provides nearly all stock water requirements on Pardoo Station and Wallal Downs Station to the east. Pardoo Station sources water from the artesian groundwater resources of the Wallal aquifer authorised under the terms and conditions of Groundwater Well Licence 158616(16).

The Wallal aquifer is artesian near the coast, and its utility improves to the east on Pardoo Station with higher groundwater pressure, transmissivity and lower groundwater salinity. The Wallal aquifer thins to the south and the groundwater pressure above ground level diminishes and the aquifer becomes non-artesian inland.

The Jarlemai Siltstone forms the confining layer for the Wallal aquifer, and hydraulically separates the Wallal aquifer from the overlying, unconfined Broome aquifer system across most of Pardoo Station. Pardoo Station does not currently use groundwater from the Broome aquifer for commercial purposes. The Broome aquifer is the receiving aquifer for rainfall and irrigation surface water which infiltrates from the Stage 3 project (Groundwater Consulting Services, 2017b).

GROUNDWATER DEPTH AND FLOWS

Groundwater contours have been prepared by Groundwater Consulting Services based on available water level readings from surrounding bores (Figure 23).

Surficial (Broome Aquifer) groundwater depth beneath the project area is estimated to be greater than 3 m below the surface. Surficial groundwater flows in a northerly direction towards the coast (Figure 23)

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Gamma Log Pardoo PB5 Scale projected from 2km north strat. intercepts shown

0 100 200 Gamma (cps)

Broome Aquifer 1977 Water Level (mAHD) 2015 Water Level (mAHD) Wallal Aquifer 1977 Head (mAHD) 2015 Head (mAHD) 525 Salinity (mg/L TDS) converted from field EC * Salinity from Leech (1979a,b)

Pardoo Station Cross section location

FROM LEECH (1979) LEECH FROM Basin/sub-basin boundary Edge of Jarmelai siltstone

0km 5km 10km

Figure 22

GROUNDWATER DEPENDENT ECOSYSTEMS

Within the Stage 3 project area itself, the predominant vegetation types (Acacia and Mixed Species Pindan Shrublands) are not groundwater dependent. However, the adjacent Ramsar area has some species which may access saturated surface soils or the shallow groundwater ephemerally (EnviroWorks Consulting, 2017a). Any groundwater accessed by the above vegetation is from either saturated surface soil or the surficial Broome aquifer, not the deeper artesian Wallal aquifer.

Within the Mandora Salt Marsh located approximately 120 km to the east of the Stage 3 project, the following groundwater dependent ecosystems exist (Figure 24):

 Salt Creek – a permanent wetland which is ground water fed and flows from east to west into Walyarta Lake after heavy rain. However, during other times, Salt Creek exists as a series of isolated pools, with water “disappearing into the sands to the east of Walyarta”. It is thought that it may be connected to the coast via an aquifer.  To the south of Walyarta are a number of freshwater mound springs, including Eil Eil (formally known as Mandora Spring), Saunders and Fern Springs. These are mostly classical raised peat bogs consisting of a central mound of saturated peat 2 – 3 m in elevation. The springs vary in size from approximately 0.1ha to several hectares. The mound is typically surrounded by an inundated moat, which may contain aquatic or emergent vegetation. There are both freshwater and saline springs, which support paperbarks and mangroves respectively (Hale & Butcher, 2009).

In addition, there are several springs located to the south west of the Stage 3 project (west of Cape Keraudren), thought to be supported by the Wallal aquifer discharging through a clayey portion of the Broome aquifer as follows (refer to Figure 24):

 Myadee Spring (located approximately 20 km to the south west)  Banningarra Spring (located approximately 25 km to the west)  Pardoo Spring (located approximately 45 km to the south west) (Groundwater Consulting Services, 2017b).

Due to distance of the Stage 3 project from the above groundwater dependent ecosystems impacts to them are unlikely. There are no known groundwater dependent ecosystems close to the Stage 3 project.

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POTENTIAL IMPACTS

Activities that may impact upon the receiving environment include:

 Clearing and earthworks to create pivots, roads, fencing and pipelines; and  Irrigation of the pivots.

Note: No additional groundwater abstraction is proposed for the Stage 3 project – all groundwater abstraction is already approved.

Potential impacts upon hydrological processes include:

 Changes in surface water flows or infiltration as a result of clearing, earthworks or irrigation and consequential impacts such as: o Changes to terrestrial ecosystems (creation of an artificial ecosystem or water starving of ecosystems) o Changes to flooding in the adjacent Ramsar site o Erosion of soils o Increase in groundwater recharge due to irrigation.

4.6.4.1 SURFACE WATER FLOWS AND GROUNDWATER INFILTRATION

Clearing and earthworks will affect approximately 280 ha of land, within the Pindan red sandy soil type. Irrigation will be carried out on 266 ha of the Pindan red sandy soil type. Water Technology (2017) found that:

 The Pindan red sandy soil type has a very high infiltration rate of around 155 mm/hour (Section 4.4.3.5). After clearing, earthworks and crop establishment, it is expected that the infiltration rate in these areas will not change significantly, because the soil will remain in situ.  The site experiences an average annual rainfall of approximately 320 mm per m2.  Irrigation is expected to add 4.123 GL annually to the pivots over the 266 ha irrigation area. This equates to 1550 mm of water applied annually per m2.  The combination of annual rainfall and irrigation on the pivot areas results in 1,870 mm of water falling on the pivot areas annually (320 mm of rainfall and 1550 mm of irrigation water).  Evapotranspiration can be estimated using the areas potential evapotranspiration rate (APER). Assuming a crop factor for grazed pasture up to 300 mm is 0.85 – 1.0, the APER for the site is around 1,755 mm/yr.  The results indicate that the annual 1,550 mm/m2 of irrigation water being applied to the crops will be used by the plants and lost to the atmosphere via evapotranspiration.  It is unlikely that irrigation water will infiltrate to groundwater as it will be captured in the plant root zone and utilised in evapotranspiration.

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On this basis, the clearing, earthworks and irrigation will not result in any changes to surface flows. There are no pre-development surface flows existing at the project area (due to the high infiltration rate of the soil). No post-development surface flows will be generated by the project because irrigation water will infiltrate to the plant root zone and will not create surface flow. Therefore, there will be no erosion due to surface water flows and no surface run-off related changes to flooding in the adjacent Ramsar wetland. The contours of the land will not be altered, therefore erosion and drainage lines will not be created. There will also not be an artificial ecosystem created outside the project boundary as surface flows will not exist to sustain such an ecosystem.

Similarly, there will be no significant changes in groundwater recharge or flows beneath the project due to surface irrigation. Irrigation application of water will be minimal (and timed to occur during periods of no rainfall). Irrigation water will infiltrate to the plant root zone. Very little (or none) of the irrigation water will infiltrate to groundwater as it will instead be utilised by the crop plants for evapotranspiration. Heavy rainfall will still infiltrate through the crop root zone to the groundwater (as is the case naturally within the Pindan soils prior to crop establishment). Therefore, the pivot irrigation is unlikely to have a significant impact on groundwater hydrological processes.

4.6.4.2 GROUNDWATER ABSTRACTION

Groundwater abstraction for the proposed Stage 3 project is up to 4.123 GL per annum. This groundwater abstraction has already been approved by the Department of Water (DoW) now Department of Water and Environment Regulation (DWER). Groundwater Well Licence 158616(16) was issued by DoW on 25 January 2017 for 14,822,250 kL or 14.8 GL per annum covering all the water needs for Pardoo Station including the Stage 3 irrigation project which requires up to 4.123 GL per annum.

Therefore, no additional groundwater abstraction impacts will occur as a result of this project.

4.6.4.3 MONITORING

A detailed groundwater monitoring program is in place under the Operating Strategy required by Groundwater Well Licence 158616(16).

Table 18 below provides a summary of this monitoring program and Figure 25 shows the groundwater monitoring network.

To date there are no trends evident of unacceptable groundwater impacts in the Wallal aquifer or changes to hydrological processes within the Broome aquifer resulting from Stages 1 and 2 of the Pardoo Irrigation Project (refer to Appendix H - Groundwater Consulting Services, 2017) with monitoring ongoing since 2011.

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Table 18: Summary of Proposed Groundwater Monitoring Program (Groundwater Consulting Services, 2017b)

CATEGORY PARAMETERS MONITORING SITE FREQUENCY Rainfall Rainfall Pardoo Homestead Daily Water Use Manual flowmeter reading Irrigation bores Monthly (irrigation bores) Pardoo PB1 to PB10. Quarterly (PB1 to PB10)

Automated flow volume Irrigation bores Minimum hourly counter Pardoo PB1 to PB10. Manual flowmeter reading Stock and other use bores, Homestead bore, Chower bore, Atlas PB1, Pardoo PB1 (stock flowmeter), Quarterly Stockyard Bore, Telegram Bore, WCB04B, WCB08C, WCB09E, WCB10B, WCB11Y, WCB14A. Barometric Pressure Barometric logger installed at Pardoo BMB2. Minimum hourly Pressure (logger data) Groundwater Pressure Wallal aquifer: Pardoo PB1 to Pardoo PB10, WMB1, Atlas MB3, Chower bore, WCB09E, WCB16C, Minimum hourly Pressure / (logger data) WCB17C Level Broome aquifer: Pardoo BMB2 Pressure Wallal aquifer: Pardoo PB1 to Pardoo PB10, WMB1, Atlas MB3, Cape Keraudren bore, Chower bore, Quarterly (pressure gauge reading) WCB04B, WCB08C, WCB09E, WCB10B, WCB11Y, WCB17C., Depth to water Wallal aquifer: WCB05YR, WCB06A, WCB07A, WCB15Y, WCB16C, WCB19Y, WCB20Y Quarterly (water level indicator) Broome aquifer: Pardoo BMB1 to BMB8 inclusive, WCB16B, WCB17B, WCB20Z, WCB03C/12 (refer footnote) Groundwater Electrical conductivity (field) Wallal aquifer: Pardoo PB1 to Pardoo PB10, WMB1, Homestead bore, Cape Keraudren Bore, Chower Quarterly Salinity bore, Atlas PB1, Stockyard Bore, Telegram Bore, WCB04B, WCB08C, WCB09E, WCB10B, WCB11Y, WCB14A, WCB16C. Broome aquifer: Pardoo BMB1 to BMB8 inclusive Groundwater Laboratory analysis of major Wallal aquifer: Pardoo PB1 to Pardoo PB10, WMB1, Atlas PB1, Cape Keraudren bore, Chower bore, Annual Quality ions, physio-chemical Homestead bore, WCB04B, WCB17C parameters and nutrients. Broome aquifer: Pardoo BMB1 to BMB8 inclusive Table Notes:  Any additional irrigation bores installed on Pardoo Station will be monitored in the same manner as the existing irrigation bores once commissioned. Loggers downloaded during quarterly site visits.  Stock bores listed that require a flowmeter will be incorporated in the monitoring programme for water use when the flowmeter is fitted.  Inclusion of the Cape Keraudren bore is subject to the on-going permission of the Shire of East Pilbara and access being maintained after installation of a reverse osmosis plant by the Shire.  WCB16A is non-artesian and a representative groundwater sample is only available if the bore is in use for stock watering.  WC03C/12 is blocked with tree roots and not available for water level monitoring. It will be included in the quarterly water level monitoring programme if it is rehabilitated. There is no access to WCB06C or WCB14A for measurement of water levels.  Timing of December/January and March/April site visit subject to cyclonic activity and site access.

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4.6.4.4 QUANTIFICATION OF IMPACTS

No significant changes to surface water flows or infiltration are predicted as follows:

 No surface flows currently exist and none are expected to be created by the project due to the very high infiltration rates of the soils.  Evapotranspiration can be estimated using the areas potential evapotranspiration rate (APER). Assuming a crop factor for grazed pasture up to 300 mm is 0.85 – 1.0, the APER for the site is around 1,755 mm/yr.  This indicates that the annual 1,550 mm/m2 of irrigation water being applied to the crops will be used by the plants and lost to the atmosphere via evapotranspiration.  Therefore, it is unlikely that irrigation water will infiltrate to groundwater or cause shallow water table rise, as it will be captured in the plant root zone and utilised in evapotranspiration.

ASSESSMENT OF IMPACTS

The scale of impact due to surface irrigation is considered insignificant because:

 There will be no changes to surface flows  Very little (or none) of the irrigation water will infiltrate to groundwater.  Heavy rainfall will still infiltrate through the crop root zone to the groundwater (as is the case naturally within the Pindan soils prior to crop establishment).

MITIGATION

The mitigation hierarchy has been applied as described below:

 Avoid: o Impacts to surface water flows have been avoided given no pre-development surface flows exist in the project area and none will be created post-development. o Impacts on groundwater dependent springs and wetlands (located 20 – 120 km away) have been avoided by their distance from the project.  Minimise: o Impacts to infiltration of surface water have been minimised by only irrigating with minimal water required for plant growth. As a result, very little (or none) of the irrigation water will infiltrate to groundwater. Heavy rainfall will still infiltrate through the crop root zone to the groundwater (as is the case naturally within the Pindan soils prior to crop establishment). o A detailed groundwater monitoring program is in place under the Operating Strategy required by Groundwater Well Licence 158616(16). o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan.

PREDICTED OUTCOME

With successful implementation of the above management measures, any residual impacts should be minor. Given the Project will avoid or minimise direct and indirect impacts on hydrological processes, it is concluded that the EPA objective can be met.

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INLAND WATERS ENVIRONMENTAL QUALITY

This Section describes inland water environmental quality within and surrounding the Proposal area. It identifies Proposal activities that may impact (directly or indirectly) upon inland water quality, assesses the potential impacts, and follows the mitigation hierarchy to ensure that the Proposal meets the EPA’s objectives for this factor.

EPA OBJECTIVE

To maintain the quality of groundwater and surface water so that environmental values are protected.

POLICY AND GUIDANCE

EPA:  Environmental Factor Guideline: Inland Waters Environmental Quality (Environmental Protection Authority, 2016f)

Other:  Australian and New Zealand Guidelines for Fresh and Marine Water Quality (Australian and New Zealand Environment and Conservation Council & Agriculture and Resource Management Council of Australia and New Zealand, 2000).  Australian groundwater modelling guidelines (Waterlines Report Series No. 82) (Barnett, et al., 2012).  Rights in Water and Irrigation Act 1914.  State Water Quality Management Strategy No. 6: Implementation Framework for Western Australia for the Australian and New Zealand Guidelines for Fresh and Marine Water Quality and Water Quality Monitoring and Reporting (Guidelines Nos. 4 & 7: National Water Quality Management Strategy) (Report No. SWQ 6) (Government of Western Australia, 2004).  A Directory of Important Wetlands in Australia (Environment Australia, 2001).  “Appendix B: Potentially contaminating industries, activities and land uses” in Assessment and management of contaminated sites: Contaminated sites guidelines (Department of Environmental Regulation, 2014).

RECEIVING ENVIRONMENT

4.7.3.1 REGIONAL CONTEXT

Surface water quality in the coastal plain areas south west of Broome is not well documented with limited data available. Groundwater quality in the Canning Basin is variable. The shallow Broome Sandstone aquifer of the Canning Basin is relatively fresh, though saltwater intrusion occurs near the coast. Deeper aquifers, including the Canning-Wallal, are brackish in some locations. The level of knowledge of groundwater varies across the region, and is largely drawn from investigations completed to support urban and development pressures (Department of Water, 2014).

4.7.3.2 STUDY METHODS

Refer to Section 4.6.3.2.

4.7.3.3 SURFACE WATER

There is no surface water within the project area, given all rainfall infiltrates quickly in the sandy pindan soils and reports to groundwater.

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Surface water quality within the ephemeral water bodies that occur after heavy prolonged rainfall within the coastal plain and Ramsar area adjacent to the project has not been studied. However, vegetation in this area is indicative of brackish water quality which may occur due to build-up of salts during evaporative processes. A number of saltbushes and saltmarsh succulent plants occur and one of the common grasses is marine couch (EnviroWorks Consulting, 2017a).

Some information exists on water quality in the Mandora Salt marsh 120 km to the east of the project. Walyarta is a seasonal water body within the Mandora Salt march, which is inundated in by direct precipitation and local runoff following heavy rainfall (Figure 24). When full, Walayarta is fresh, but alkaline. As water evaporates salts concentrate until eventually only a dry saltpan remains. Only a limited set of variables was measured at a single site in Walyarta in October 1999 after the extensive flooding event earlier that year. The water was brackish to saline (salinity = 27 parts per thousand, ppt) and alkaline (pH = 8.8). Daytime water temperature was high (34 °C) and despite the high temperature (which reduces the amount of oxygen that can be held in solution) the water was supersaturated with oxygen (dissolved oxygen = 108 % saturation). This is indicative of high primary productivity within the water column. As this sampling followed the extensive flooding event in early 1999 it is difficult to determine if the results are typical of the site and it would be expected that water quality during drier years may be substantially different (Hale & Butcher, 2009). Given Walyarta is a great distance from the project area, and limited data is available, this water quality record may only be somewhat indicative of water quality in the localised water bodies that occur north east of the project area after flooding as described in Section 4.6.3.3.

4.7.3.4 GROUNDWATER

Groundwater quality has been monitored in the vicinity of the project since 2011, at production and monitoring bores for the existing Stage 1 irrigation project located approximately 2 km to the east of the proposed Stage 3 (Figure 25). The results are summarised in Table 19 below with the most recent monitoring report included as Appendix H (Groundwater Consulting Services, 2017a).

The results indicate that locally:

 The Wallal aquifer contains hard, but fresh water ranging from slightly acidic to slightly alkaline pH.  The Broome aquifer can contain soft or hard water, which is marginally fresh or slightly brackish and slightly alkaline.  There are no trends evident of increasing nutrient or salt levels in either the Broome or Wallal aquifers since the commencement of irrigation of the Pardoo Stage 1 and 2 Pivots (Groundwater Consulting Services, 2017a).

In terms of nutrient levels:

 Nitrate levels in the Wallal aquifer are very low (in most cases below detection).  Nitrate levels are naturally elevated in the Broome aquifer (with nitrate readings actually decreasing since irrigation commenced – likely to be due to natural variation due to rainfall recharge).  Total phosphorous in the Wallal aquifer varies with most readings being low (below 0.01 mg/L) and a single reading of 0.2 mg/L.  The Broome aquifer had slightly higher readings of total phosphorous, mostly ranging from 0.01 – 0.03 mg/L, with two higher readings of 0.08 and 0.13 mg/L.  There are no trends evident of increasing nutrient or salt levels in either the Broome or Wallal aquifers since the commencement of irrigation of the Pardoo Stage 1 and 2 Pivots (Groundwater Consulting Services, 2017a).

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Table 19: Summary of groundwater quality monitoring data selected local bores

Analyte Wallal Aquifer (Bores PB1, PB2, Broome Aquifer (Bores PB3, PB4 and WCB17C) BMB2 and BMB3) pH 6.52 – 7.5 7.6 – 8.1 Electrical Conductivity (µS/cm) 910 – 1270 1560 - 2560 Total Dissolved Solids (mg/L) 500 - 680 1000 - 1600

Hardness (mg CaCO3/L) 80 - 180 20 - 100

Nitrate (NO3) (mg/L) <0.01 – 0.09 0.9 - 22 Nitrate (N) (mg/L) <0.002 – 0.5 0.2 – 4.9 Total Nitrogen (N) (mg/L) <0.1 – 0.5 0.4 - 5.3 Phosphate (mg/L) <0.005 – 0.02 <0.01 – 0.09 Total Phosphorus (P) (mg/L) <0.01 – 0.2 0.01 – 0.13

POTENTIAL IMPACTS

Activities that may impact upon the receiving environment include:

 Clearing and earthworks to create pivots, roads, fencing and pipelines;  Irrigation of the pivots;  Application of fertiliser to crops;  Storage, use and disposal of hydrocarbons; and  Waste generation and disposal.

Note:  No additional groundwater abstraction is proposed for the Stage 3 project – all groundwater abstraction is already approved. Therefore no additional impacts will be caused due to groundwater abstraction.  Only fertiliser and fuel (diesel) are stored and used on site (no other chemicals or hydrocarbons are in use).

Potential impacts of the project which may cause deterioration in the quality of surface water or groundwater include:

 Over irrigation causing the shallow ground water table to rise and resulting in the mobilisation of salts as the water comes into contact with salts entrained in local sediments  Over application of fertilisers causing nutrient leaching into surface water or groundwater  Erosion causing sedimentation of surface water  Contamination of surface water or groundwater through: o Disturbance of acid sulphate soils o Hydrocarbon spills from generators, earthmoving and harvesting equipment o Spills of fertiliser o Inappropriate waste disposal

4.7.4.1 IRRIGATION AND FERTIGATION

As described in Section 4.6, very little (or none) of the irrigation water applied to the project will infiltrate to the groundwater. Therefore, over irrigation causing the shallow ground water table to rise and resulting in the mobilisation of salts will not occur.

With regards fertigation (application of fertilisers) Water Technology (2017) conducted a nutrient impact assessment. The methodology used to assess the risk of nutrient leeching to the Broome aquifer from fertiliser

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application was based on the increased nutrient level present within the existing pivot area soils (Appendix F), compared with background groundwater nutrient level present naturally at the Stage 3 area.

Phosphorus is relatively immobile, and adsorption will occur mainly within the root zone, especially given the low Phosphorous Buffering Index (PBI) results of soils testing which makes the phosphorus available for plant uptake in the root zone. Therefore, the nutrient impact assessment focussed on nitrogen which is considered a greater risk.

The highest level of nitrogen present of 5 mg/Kg in soil sample P05 taken within the operational Stage 1 pivot number 3 (Appendix F, Figure 14) was applied. Using this level of nitrogen is a coarse approximation, because the soil samples were taken at the surface, however the nutrient levels below the root zone would be considerably less, given much of the nutrients would be taken up by the plants themselves. Therefore, a factor of 50% was applied which conservatively assumes 50% of the nitrogen applied would be taken up by crop plants and 50% would leach to the groundwater during heavy rainfall (however it is likely that more nitrogen would be taken up by the plants than this).

It was assumed therefore that 2.5 mg/Kg of Nitrates would be transported to groundwater via heavy rainfall. Based on an application rate of 700 kg/ha/year over an area of 266 ha (186 t per annum) (Table 4), up to 466 kg/year would leach into the aquifer over the entire Stage 3 irrigation area.

Groundwater Consulting Services (pers. comm, 2017) estimated groundwater through-flow in the Broome aquifer using Darcy’s Law, which describes water flow through porous media based on knowledge of the aquifer locally (Groundwater Consulting Services, 2017a; 2017b). The calculated annual groundwater through- flow is the product of the aquifer cross-sectional area, hydraulic conductivity and hydraulic gradient and is 890,000 kL/annum.

In terms of the concentration of nitrates in the aquifer, based on an annual groundwater through-flow of 890,000 kL, approximately 0.0005 mg/L would be present from fertilisation of Stage 3 pivots in the waters down gradient of the irrigation site. This is an insignificant amount of nitrate in the context of the naturally occurring nitrate levels in the Broome aquifer which range from 0.2 to 4.9 mg/L (Table 19).

Similar contributions of nitrogen to groundwater are likely to occur from Pivot Stages 1 and 2 which each will have similar flows of Broome Aquifer groundwater beneath them based on their width and the groundwater flow direction (Figure 23). Cumulatively the three stages are not likely to increase nitrates in groundwater significantly, given the large flow of groundwater beneath the sites (due to annual aquifer replenishment from rainfall) and the modest amounts of fertiliser application which as demonstrated above for Stage 3, is unlikely to raise nutrient levels above natural background (Water Technology, 2017).

4.7.4.2 SEDIMENT CONTAMINATION OF SURFACE WATER

With regards to sedimentation of surface water bodies:

 There will be sedimentation caused by irrigation water (as no surface water will be generated, all irrigation water will be utilised by the plant root zone and heavy rainfall will continue to infiltrate to groundwater).  Erosion of soil (and resulting sedimentation of adjacent naturally occurring flood waters) by other activities (trampling, vehicle movement and wind) will be avoided by ensuring there is no surface water run-off from the project, containing cattle within fenced areas and by crop planting strategies which stabilise the soil (refer to Section 2.3.7).

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4.7.4.3 CONTAMINATION

Refer to Appendix A – Environmental Management Plan which discusses mitigation of contamination of surface water or groundwater.

4.7.4.4 MONITORING

A detailed groundwater monitoring program is in place under the Operating Strategy required by Groundwater Well Licence 158616(16) as detailed in Appendix A – Environmental Management Plan.

Table 18 provides a summary of this monitoring program and Figure 25 shows the groundwater monitoring network.

To date there are no trends evident of increasing salt or nutrient levels in either the Broome or Wallal aquifers since the commencement of irrigation of the Pardoo Stage 1 and 2 Pivots (refer to Appendix H - Groundwater Consulting Services, 2017) with monitoring ongoing since 2011.

4.7.4.5 QUANTIFICATION OF IMPACTS

Quantification of impacts to hydrological processes is detailed in Table 20 below. Quantification has focussed on nitrate leaching to groundwater given other impacts will be avoided as described above and in Appendix A – Environmental Management Plan.

Table 20: Predicted proportional infiltration of nutrients to the Broome Aquifer

Aquifer Average level of Estimated addition of % increase in nitrate1 (mg/L) nitrate (mg/L) nitrate Broome Aquifer 2.1 0.0005 0.02%

Table Note 1: Average nitrate level derived from the 2016 Monitoring Summary – Appendix H (Groundwater Consulting Services, 2017a).

ASSESSMENT OF IMPACTS

The scale of impacts is considered to be small, given nitrates are expected to increase by only 0.02% within the groundwater beneath the project.

MITIGATION

The mitigation hierarchy has been applied as described below:

 Avoid: o Impacts to surface water quality have been avoided given no pre-development surface flows exist in the project area and none will be created post-development. o Very little (or none) of the irrigation water applied to the project will infiltrate to the groundwater. Therefore, over irrigation causing the shallow ground water table to rise and resulting in the mobilisation of salts will not occur. o Impacts such as sedimentation and contamination will be avoided as described in Appendix A – Environmental Management Plan.  Minimise: o Nutrient increases in the Broome aquifer has been minimised by only applying the minimum fertiliser needed for plant growth.

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o A detailed groundwater monitoring program is in place under the Operating Strategy required by Groundwater Well Licence 158616(16). o Refer to Appendix A – Environmental Management Plan for other impact minimisation strategies.  Rehabilitate: o The pivots will be rehabilitated at the end of the project life – Refer to Appendix A – Environmental Management Plan.

PREDICTED OUTCOME

With successful implementation of the above management measures, any residual impacts should be minor. Given the Project will avoid or minimise impacts on inland waters environmental quality, it is concluded that the EPA objective can be met.

SOCIAL SURROUNDINGS

This Section describes the social surroundings recorded and potentially occurring within the Proposal area and surrounding area. It identifies Proposal activities that may impact (directly or indirectly) upon cultural and heritage areas, assesses the potential impacts, and follows the mitigation hierarchy to ensure that the Proposal meets the EPA’s objectives for this factor.

EPA OBJECTIVE

To protect social surroundings from significant harm.

POLICY AND GUIDANCE

EPA:  Environmental Factor Guideline: Social Surroundings (Environmental Protection Authority, 2016g)  Guidance Statement 41 – Assessment of Aboriginal Heritage (Environmental Protection Authority, 2004).

Other:  Aboriginal Heritage - Due Diligence Guidelines (Version 3.0) (Department of Aboriginal Affairs & Department of the Premier and Cabinet, 2013).  Aboriginal Heritage Act 1972.

RECEIVING ENVIRONMENT

4.8.3.1 STUDY METHODS

A desktop review of available datasets was conducted:

 Land tenure (for aboriginal reserves and communities)  Aboriginal and European heritage sites.

Discussions have also been ongoing with traditional owners.

Aboriginal heritage surveys are planned to be conducted prior to ground disturbance.

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4.8.3.2 ABORIGINAL RESERVES AND COMMUNITIES

There are no Aboriginal reserves or communities in the vicinity of the Land Tenure Envelope.

4.8.3.3 ABORIGINAL HERITAGE AND CULTURE

HERITAGE SITES

Aboriginal sites are places of importance and significance to Aboriginal people and to the cultural heritage of Western Australia. Aboriginal sites include:

 Archaeological – places where material remains associated with past Aboriginal land use.  Anthropological - places of spiritual importance and significance to Aboriginal people.

The WA Aboriginal Heritage Act 1972 protects places and objects that may be of importance and significance to Aboriginal people in Western Australia. The Department of Planning, Lands, and Heritage (DPLH) maintains a register of Aboriginal sites that are protected under the Aboriginal Heritage Act 1972. The Aboriginal Heritage Act 1972 states it is an offence under this legislation to “excavate, destroy, damage, conceal, or in any way alter any Aboriginal site, without prior authorisation of the Registrar of Aboriginal sites and/or consent of the Minister for Indigenous Affairs”.

An online search for relevant Aboriginal Heritage information was performed using the DPLH Aboriginal Heritage Inquiry System. The system incorporates both the Heritage Site Register and the Heritage Survey Database. The Heritage Site Register is held pursuant to Section 38 of the State's Aboriginal Heritage Act 1972 and contains information on over 22,000 Aboriginal sites throughout Western Australia. The Heritage Survey Database is a catalogue of the heritage survey reports held by the DPLH. It holds a description of each survey, its boundaries, proponent and participants.

The search revealed that there are four Aboriginal heritage sites within 5 km of the Stage 3 Project (Table 21, Figure 26).

Table 21: Aboriginal Heritage Sites

Name Legacy ID Status* Type KERAUDREN CAMP 1 K00821 Lodged Ceremonial, Mythological KERAUDREN CAMP 2 K00822 Lodged Ceremonial, Mythological COOTENBRAND FISH TRAPS K01887 Lodged Fish Trap CAPE KERAUDREN K00830 Lodged Grinding Patches / Grooves, Skeletal Material / Burial * Note: Lodged: Information has been received in relation to the place, but an assessment under meeting Section 5 of the Aboriginal Heritage Act 1972 has not been completed.

CULTURE

Discussions with the traditional owners have indicated there are any no significant associations with the physical or biological aspects of the environment, which may be impacted by the Stage 3 proposal. Refer to Appendix C which contains traditional owner consultation letters.

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4.8.3.4 EUROPEAN HERITAGE

The following databases were searched for features of European Heritage significance:

 World Heritage Sites;  National Heritage Sites;  Commonwealth Heritage Sites;  Register of the National Estate;  Heritage Council WA State Register; and  Municipal Inventories (WA) (SHO-005)

The National Heritage List and Commonwealth Heritage List are established under the EPBC Act and include natural, historic and Indigenous places of outstanding heritage value to the nation and the Commonwealth respectively. The State Register of Heritage Places was established under the Heritage of Western Australia Act 1990, and includes buildings, structures, gardens, cemeteries, memorials, landscapes and archaeological sites.

There are no heritage sites intersecting the Land Tenure Envelope. The closest site is Eighty Mile Beach, a natural heritage site on the Register of National Estate, which as of February 2012 is maintained on a non- statutory basis as a public archive.

POTENTIAL IMPACTS

Activities that may impact upon the receiving environment include:

 All land disturbance, excavation and construction activities.

Potential impacts as a result of implementing the proposal:

 Loss/disturbance to Aboriginal heritage sites.  Disturbance to cultural associations within the area.  Temporary and/or permanent constraint on traditional cultural activities.  Prevention or change of access to a site.  Alterations to hydrological processes.

ASSESSMENT OF IMPACTS

No known heritage sites occur within the Stage 3 Development Envelope.

Impacts to heritage sites are unlikely.

MITIGATION

PBC will meet its obligations under the Aboriginal Heritage Act 1972.

Heritage management measures are described in the Environmental Management Plan – Appendix A.

PREDICTED OUTCOME

With implementation of the above mitigation measures, it is considered that residual impacts should be acceptable and that the EPA objective can be met.

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5 OTHER ENVIRONMENTAL FACTORS OR MATTERS

PBC is aware that other environmental factors or matters may be identified during the course of the environmental review process and stakeholder engagement that were not apparent at the time that this referral was prepared. If this situation arises, PBC will consult with the EPA and DoEE to determine how (and to what extent) these factors and/or matters are to be addressed.

SUBTERRANEAN FAUNA

One other issue which has been considered by the Proponent for this project is subterranean fauna. Specifically, it was considered whether stygofauna could be impacted by the proposal. Whilst stygofauna may exist within the Broome Aquifer (the shallow aquifer beneath the proposal), it is considered unlikely they could be impacted by the proposal given:

 No groundwater abstraction will occur from the Broome Aquifer;  Recharge of the Broome aquifer is unlikely to be significant affected by the proposal; and  Contamination of the Broome aquifer is unlikely as management processes are in place to manage potential contaminants (fertilisers and hydrocarbons) – Refer to Appendix A - Environmental Management Plan.

Refer to Appendix I Stygofauna Habitat Assessment (Bennelongia Environmental Consultants, 2017).

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6 OFFSETS

The Project is aiming to avoid and minimise significant environmental impacts. Residual impacts are likely to be minor. Therefore, no offsets are proposed.

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7 HOLISTIC IMPACT ASSESSMENT

Direct disturbance of fauna habitat will be avoided outside the Stage 3 Development Envelope, by fencing the Development Envelope to contain cattle within it. Indirect impacts to fauna from water/nutrient run-off, mortality from vehicle/equipment strike, fire, entrapment, toxicants from contamination and increases in feral species will be avoided as described in Appendix A – Environmental Management Plan.

The portion of the Ramsar wetland adjacent to the proposed Stage 3 project is a coastal floodplain that only floods approximately every 10 years (Water Technology, 2017). Much of the adjacent Ramsar site supports dense acacia and melaleuca thickets. This means that even when flooded, migratory waterbirds that rely on wetland environments would find only small areas of open, shallow wetlands in grasslands. The abundance of waterbirds that use these short lived, ephemeral wetlands adjacent to the project is not expected to be high due to the small area of suitable habitat and infrequency of flooding (Bamford Consulting Ecologists, 2017). The abundance of grassland-dependent waterbirds is also not expected to be high, as the area of dry grassland adjacent to the project is small. It is concluded that the key values of the Eighty-Mile Beach wetland occur on the coastal flats and beaches 4 km away from the Stage 3 project (Bamford Consulting Ecologists, 2017). A buffer for Stage 3 Development Envelope of 100 m from the Ramsar Wetland boundary is proposed and management measures will be implemented to prevent impacts on the wetland related to hydrological processes and inland waters environmental quality. Therefore, it is concluded there will not be any significant impacts on the Ramsar or Nationally Important Wetland as a result of the Stage 3 project.

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Mitigation and management measures as outlined in Appendix A (Environmental Management Plan) will further reduce the risk of impact to environmental values.

Residual environmental impacts are not expected to be significant for any environmental factors. With implementation of the proposed mitigation and management measures, it is considered that the Proposal will meet the EPA’s objective for each environmental factor.

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8 REFERENCES

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Environmental Protection Authority. (2016j). Statement of Environmental Principles, Factors and Objectives. Perth: Environmental Protection Authority. Environmental Protection Authority. (2016k). Technical Guidance: Flora and Vegetation Surveys for Environmental Impact Assessment. Perth: Environmental Protection Authority. Environmental Protection Authority. (2016l). Technical Guidance: Sampling methods for terrestrial vertebrate fauna. Perth: Environmental Protection Authority. Environmental Protection Authority. (2016m). Technical Guidance: Sampling of short range endemic invertebrate fauna. Perth: Environmental Protection Authority. Environmental Protection Authority. (2016n). Technical Guidance: Terrestrial fauna surveys. Perth: Environmental Protection Authority. Environmental Protection Authority. (2017). Instructions on how to prepare an Environment Review Document. Perth: Environmental Protection Authority. EnviroWorks Consulting. (2016). Targeted Survey for Bonomia Oblongifolia at Wall Downs (Homestead). Perth: Unpublished Report Prepared For Warrawagine Cattle Co. EnviroWorks Consulting. (2017a). Flora and Vegetation Study Pardoo Station Pivot Irrigation Project Stage 3. Perth: Unpublished Report Prepared for PBC Pty Ltd. EnviroWorks Consulting. (2017b). Targeted Conservation Flora Survey at Anna Plains. Perth: Report for Anna Plains Cattle Co Pty Ltd. Geological Survey of WA. (2017). Surface Geology Mapping. Perth: GIS Data Files Accessed. Government of Western Australia. (2004). State Water Quality Management Strategy No. 6: Implementation Framework for Western Australia for the Australian and New Zealand Guidelines for Fresh and Marine Water Quality and Water Quality Monitoring and Reporting (Report No. SWQ 6). Perth: Government of Western Australia. Government of Western Australia. (2011). WA Environmental Offsets Policy. Perth: Government of Western Australia. Government of Western Australia. (2014). WA Environmental Offsets Guidelines. Perth: Government of Western Australia. Graham, G. (2003). Dampierland 2 (DL2 - Pindanland subregion). In J. E. May, & N. L. McKenzie (Eds.), A Biodiversity Audit of Western Australia’s 53 Biogeographical Subregions in 2002 (pp. 179-187). Perth: Department of Conservation and Land Management. Groundwater Consulting Services. (2008). Hydrogeological Assessment - Pardoo Station, Wallal Sandstone Aquifer, Cattle Feed. Perth: Unpublished Report Prepared for Pardoo Station. Groundwater Consulting Services. (2009). Operating and Monitoring Strategy Stage 1a/b. Wallal Sandstone Aquifer, Cattle Feed Irrigation, Pilbara Coast, WA. Perth: Unpublished Report Prepared for Pardoo Station. Groundwater Consulting Services. (2011). Staged Development Proposal, Wallal Sandstone Aquifer, Cattle Feed Irrigation, Pilbara Coast, WA. Perth: Unpublished Report Prepared for Pardoo Station. Groundwater Consulting Services. (2013). Groundwater monitoring summary 2012, Irrigation Project, Pardoo Station. Perth: Unpublished Report Prepared for Pardoo Station. Groundwater Consulting Services. (2014a). Groundwater monitoring summary 2013, Irrigation Project, Pardoo Station. Perth: Unpublished Report Prepared for Pardoo Station. Groundwater Consulting Services. (2014b). Impact Assessment - Stage 1b development. Irrigation Project, Pardoo Station. Perth: Unpublished Report Prepared for Pardoo Station. Groundwater Consulting Services. (2015). Groundwater Monitoring Summary 2014. Irrigation Project, Pardoo Station. Perth: Unpublished Report Prepared for Pardoo Station. Groundwater Consulting Services. (2016a). Groundwater Monitoring Review 2016. Irrigation Project, Pardoo Station. Perth: Unpublished Report Prepared for Pardoo Station. Groundwater Consulting Services. (2016b). Operating Strategy - Wallal Aquifer, Irrigated Agriculture Pastoral Lease 3114/46 - Pardoo Station. Perth: Unpublished Report Prepared for Pardoo Station. Groundwater Consulting Services. (2017a). Groundwater Monitoring Summary 2016: Irrigation Project Pastoral Lease 3114/46 - Pardoo Station. Perth: Groundwater Consulting Services. Groundwater Consulting Services. (2017b). 2017/2018 Operating Strategy - Wallal Aquifer: Irrigated Agriculure Pastoral Lease 3114/46 - Pardoo Station. Perth: Groundwater Consulting Services.

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