Significant Species Management Plan 3 Egernia rugosa (Yakka Skink)

Egernia rugosa (Photo Craig Eddie) Egernia rugosa Occurrence Records Map (Atlas of Living Australia, 2015)

EPBC Act Conservation Status Vulnerable NC Act Conservation Status Vulnerable Known Distribution The Yakka Skink is distributed from Cape York Peninsula in the north, to central southern Queensland, as far south as the St. George area. Much of its southern distribution lies within the Brigalow Belt Biogeographic Region (Wilson and Knowles 1988; Cogger 2000). Recent surveys have extended the range further south to the NSW border (TSN 2008). This Yakka Skink distribution and records in relation to the Anya project area are shown in Figure 1. Occurrence within Anya Block There are currently no available records of the Yakka Skink from within the Anya block however mapping indicates the species distribution may extend over the area. Atlas of Living Australia (2015) shows the closest record to Anya as being 58kms North West near the Condamine State Forest. However, QGC has found the Yakka Skink within the southern portion of the Braemar State Forest during Surat Basin gas field development, approximately 11km South West from Anya. The Land Zones (LZ) and dominant tree species within Anya may provide suitable habitat for the species (refer to Preferred Habitat and Microhabitat). Potential habitat for the species within the Anya project area has been mapped using RE associations and is shown in Figure 2. Description and Relevant Characteristics The Yakka Skink is a large, robust skink to 40cm long (DoE 2015). It is a little smaller than a Blue- tongued Lizard (Tiliqua scincoides). The Yakka Skink has a light brown body with a darker brown back and usually a straw-coloured line along each side (DoE 2015). Biology and Reproduction The Yakka Skink, like other Egernia species, is highly gregarious, with populations occurring primarily as colonies or aggregations; these groups consist of both adults and juveniles of a wide variety of body sizes (Chapple 2003; Osterwalder et al. 2004). Colonies live in burrows under or around surface structures such as rocks or logs and they have been known to excavate deep burrow systems (DoE 2015 DSITIA

2014). They tend to be active during cooler parts of the day, dusk and sometimes at night. The Yakka Skink is an omnivorous species (consumes plant and animal matter) ambushing arthropods and small vertebrates that venture near the burrow entrance. The species produces live young, with around six per litter (TSN 2008). The breeding season has not been recorded. Preferred Habitat and Microhabitat Yakka Skinks occur in a wide variety of vegetation types including Poplar Box (Eucalyptus populnea), Ironbark (Eucalyptus spp.), Brigalow (Acacia harpophylla), White Cypress Pine (Callitris spp.), Mulga (Acacia aneura), Bendee (Acacia catenulata) and Lancewood (Acacia spp.) woodland and open forest (TSN 2008) in QLD RE LZs 3, 4, 5, 7, 9 and 10. Of these LZs 3, 5 and 7 occur within Anya. Chapple (2003) suggests that this species is diurnal and secretive, preferring ecotonal forest in rainforest and wet / dry sclerophyll forest in the northern sections of its range. They use burrows as shelter that are dug under rocks, logs (especially very large logs, if available), old root tracts, bases of large trees or stumps, stick-raked piles and dense covering vegetation. They may also utilise old rabbit warrens, deep gullies and tunnel erosion and sinkholes (QMDC 2008). Like several related species, Yakka Skinks use communal defecation sites near permanent burrows (Ehmann 1992; Wilson and Knowles 1988). These sites help to identify burrows that are currently in use by a colony (DSITIA 2014). This species, and other similar skinks, often take refuge among dense ground vegetation, large hollow logs, and cavities in soil-bound root systems of fallen trees and beneath rocks (Wilson and Knowles 1988; Cogger 2000). Alternatively, this species may also excavate burrow systems among low vegetation or below logs (Ehmann 1992). In cleared habitat, this species can persist where shelter sites such as tunnel erosion, rabbit warrens and log piles exist (TSN 2008). This species is not generally found in trees or rocky habitats (Chapple 2003). The Yakka Skink may use several sites during the year with the occupied burrow identified by scat piles near the entrance (Ehmann 1992). General Threats The main threat to the Yakka Skink is habitat reduction and degradation. The Yakka Skink occurs in the Brigalow Belt Bioregion, an area of high human impact (Covacevich et al. 1998). Much of this land has been modified through agricultural and urban development (Cogger et al. 1993; McDonald et al. 1991). In particular, Brigalow communities have been severely modified and are poorly reserved (Covacevich et al. 1998). Other threats impacting the Yakka Skink include inappropriate roadside management, removal of wood debris and rock microhabitat features, ripping of rabbit warrens and feral animals (TSN 2008). Inappropriate roadside management includes road widening and removal of microhabitat such as rocks, logs, dense leaf litter and fallen bark. Feral animal impacts include predation by Foxes (Vulpes vulpes) and Feral Cats (Felis catus). Inappropriate fire regimes and trampling of burrow systems by stock and feral pigs are also known to have adverse impacts. Potential Project Threats The Project specific threats for this species include: Development • Clearing resulting in the loss of habitat; • Soil or burrow degradation from clearing, use of heavy vehicles and machinery and increased access by stock • Reduced shelter availability and soil degradation from removal of microhabitat features; • Clearing activities causing injury or mortality; • Vehicle traffic resulting in injury or mortality; • Increased access to habitat by feral predators; • Increased likelihood of trampling of individuals or burrows by livestock due to increased access to habitat;

• Creation of barriers to movement; • Trenches and other excavations acting as traps resulting in injury or mortality; • Provision of shelter resources (open pipes and under stored equipment/building materials) resulting in subsequent mortality; and • Increased likelihood of weed invasion leading to degradation of habitat. Operation • Vehicle traffic resulting in injury or mortality; • Increased likelihood of weed invasion from disturbed areas leading to degraded habitat; • Increased predation due to increased access to habitat by feral species; and • Increased predation by fauna which may benefit from the disturbance. Decommissioning • Vehicle traffic resulting in injury or mortality; • Altered fire regimes; and • Increased likelihood of weed invasion from disturbed areas leading to degradation of habitat. Management Strategies As the Yakka Skink has not been identified as occurring in the Anya project area, the primary management strategy is to focus on the identification, avoidance and protection of individuals, populations, habitat and breeding areas. Planning and placement of infrastructure During the planning phase proposed infrastructure locations will be placed following QGCs Constraints Planning and Field Development Protocol (The Protocol). The primary aim of the protocol is to avoid placing infrastructure within areas of significant environmental value, including MNES, by ranking constraints as Low, Moderate, High, Very High or No Go according to infrastructure type. In accordance with the Protocol, MNES, including the Yakka Skink are designated as either ‘very high’ or ‘no go’ constraints in the mapping depending on infrastructure type (e.g. static or linear). Buffers are applied to these areas for linear and static infrastructure and these buffers are assigned the same constraint ranking as the MNES. Where the constraint is ‘no go’, QGC will not conduct activities in the area containing MNES unless: • ground truthing and field ecological surveys demonstrate that siting infrastructure in that location will cause minimal adverse impact on MNES or ESAs, including habitat for listed species and/or MNES/habitat is recoverable; • it would be within disturbance limits; and • other constraints preclude any alternative location; or • QGC obtains the relevant permits and/or approvals for the activity to commence e.g. EA Amendments or Clearing Permits.

Where the constraint is ‘very high’ QGC will seek alternative locations for proposed infrastructure in that location. Very high is generally assigned to environmental constraints when planning for linear infrastructure as it is not always possible to avoid these constraints.

From a mapping and desktop assessment perspective, Yakka Skink habitat may be widespread throughout the area as assessment stops at the RE level. Further validations will aim to further refine these areas to a more accurate representation of habitat on a finer scale. This will allow infrastructure to be proposed within areas that are less likely to provide suitable habitat or that offer lower quality habitat. Burrows and Burrow systems (particularly active sites/those with latrines) will be ranked as No Go as these are likely to be discrete locations that can be avoided. Alternative locations may be recommended by QGC’s environment advisers based on desktop analysis of environmental and other constraints, or the DoE approved ecologist conducting pre-clearance surveys in the field. The approval process for determining the final location of infrastructure is described in Section 3.0 of the Protocol. This requires all proposed infrastructure locations to be approved by various disciplines within QGC.

Pegging Party Surveys All proposed infrastructure locations will be surveyed by a multi-functional group to determine the best location for each piece of infrastructure that takes into account all validated constraints (referred to as a pegging party). An ecological survey by a DoE approved ecologist forms part of the pegging party. The Yakka Skink is unlikely to be identified in the field during pegging parties due to its cryptic nature. However, during these surveys ecologists will assess the area in terms of habitat suitability for the species by identifying and recording key habitat and microhabitat features. This will indicate if a targeted fauna survey should be undertaken for the species. Within areas of potential habitat the following attributes will be recorded: • Regional ecosystem • The presence of fallen woody material o large fallen trees o numerous logs and branches o scattered logs and branches o bulldozed windrows (stick-raked) • Presence of burrows and latrine sites Initial locations of infrastructure determined during the pegging party will avoid habitat and micro-habitat as far as possible. Targeted surveys If the pegging party determines that there is potential for Yakka Skink habitat to occur within proposed disturbance areas, targeted surveys will be undertaken in order to confirm the presence/absence of species. These surveys will be undertaken prior to final internal approval of proposed infrastructure locations. Where appropriate and practicable, and in accordance with the Draft EPBC referral guidelines for the nationally listed Brigalow Belt reptiles (2011) and the EPBC Survey guidelines for Australia’s threatened reptiles (DoE 2011), the targeted surveys will be undertaken during summer. The potential survey methods for the species (in accordance with the relevant guidelines) are summarised below. These survey methodologies will be implemented where appropriate and practicable:

• Transect searches for evidence of the species and suitable microhabitat. Transects (number and size of areas sampled) should be strategically designed/positioned in large habitat patches (>10ha) to adequately sample representative microhabitats in each habitat type; • Assessment of potential burrow sites to confirm presence of the species, which may include scat identification, distant observation with binoculars or spotting scope, viewing into burrows with torches or videoscopes/borescopes; and • Placement of Elliot traps (15.5cm x 15cm x 46cm) as close as possible to burrow entrances and checked every morning and evening over four days. Realignment of infrastructure Where the species or its habitat has been confirmed, the proposed infrastructure locations will be reconsidered. Where possible infrastructure will be pegged in areas with no or low habitat quality and proposed impacts reduced as far as possible, with burrows avoided. Should the species or its habitat be identified, and impacts confirmed, the mitigation strategies outlined in the following section will be implemented. Mitigation Measures Where the species or its habitat is known or likely to occur and impacts are unavoidable, mitigation measures will be implemented to minimise the project impacts on the species. For the Yakka skink this includes: Clearing • Pre-clearance surveys to be undertaken by suitably qualified, experienced and licenced fauna spotter catcher(s) (FSC) prior to any clearing activities being undertaken. FSCs shall subject areas of potential habitat to disturbance prior to clearing to encourage the natural relocation of resident reptiles; • Prior to clearing, limits of clearing delineating actual Yakka Skink habitat identified during pre- clearance surveys will be clearly marked out with appropriate flagging material and/or barricade

webbing as determined by the site Environment Representative. • If the species is found prior to or during clearing activities, it will be relocated from the clearing area to a suitable location by a licenced FSC. Appropriate permits for fauna relocation must be held by the FSC. Any injured fauna will be transported to a veterinarian or recognised wildlife carer immediately for treatment; • Where possible, clearing areas should be reduced to avoid specific high risk micro-habitat areas identified by FSCs; • Clearing will be carried out in a sequential manner and in a way that directs escaping wildlife away from clearing and into adjacent native vegetation or natural areas; • Habitat features including suitable cleared trees, logs or other shelter sites will be stockpiled separately (not mulched) and used for rehabilitation post construction; and • Clearing and FSC activities will be undertaken as per QGCs Fauna Management Procedures. Soil • Prior to works commencing a soil assessment will be undertaken to determine appropriate soil management requirements; • The depth of topsoil strip will be assessed and confirmed on site with a QGC FEO to ensure protection of topsoil for rehabilitation purposes; and • Prior to works a site specific drainage, erosion and sediment control plan will be developed by the contractor. The plan must be approved by a QGC Field Environment Officer and Queensland Parks and Wildlife Service (QPWS). Habitat Loss and Connectivity • Infrastructure will be located to maximise the use of areas of pre-existing disturbance; • Infrastructure locations will aim to avoid fragmentation of habitat; • The total disturbance proposed for the Anya project will not exceed 5% of the total Anya Project Area and disturbances will be spread throughout the area due to well spacing requirements. This means each site disturbance will be small compared to the surrounding vegetated area and disturbance at each site will be minimal; • Rehabilitation, including filling of trenches, will be undertaken as soon as possible after construction and will include reinstatement of debris and shelter sites to allow for Yakka Skink movement across, and utilisation of, the sites; and • The Anya project area is wholly within a State Forest and fauna will be able to move into surrounding undisturbed areas. Entrapment • In areas where the species has been identified or its habitat is present, a FSC must inspect and remove any fauna from gathering lines trenches twice daily (early morning and late afternoon) every day while the trenches are open, and have access to the site in all weather. In all other areas FSC shall inspect trenches at least once daily; • For each site, the contractor will prepare a Site Based Environmental Management Plan and submit to a QGC FEO for approval prior to works commencing. The plan will detail additional measures in relation to trenches and preventing fauna entrapment, including providing exit ramps for fauna and shelter such as hessian sacks soaked in water; • Gas well-head cellars, well site troughs and similar will be covered to prevent reptiles from falling in and becoming trapped; and • Prior to backfilling of the trench site personnel will check the open trench for trapped fauna, and where required a FSC will be called to move any fauna to a safe location away from the trench. Breeding Place • Yakka Skinks give birth to live young so burrows will be treated as breeding places; • Should a Yakka Skink breeding place be identified it will be avoided. Breeding places may be avoided through placement of infrastructure, particularly if identified prior to internal approval of final infrastructure locations, or if on the edge of proposed disturbance areas. They may also be avoided through timing of works, by delaying clearing until after the breeding cycle has completed and the young have left the area; or • If it is determined that disturbance or tampering to the breeding site is unavoidable a FSC will determine the appropriate response in line with their permit, which may include the removal of individuals from the burrow and relocation, or placement with a wildlife carer or facility if required. Vehicles • After clearing, vehicle activities will be restricted to roads, access tracks and hardened surfaces (once these are constructed) to reduce potential impacts to the species.

Weeds • Weeds will be identified and recorded by an ecologist during pegging parties; • For each site the contractor will develop a weed strategy that includes management of weeds that may contribute to habitat degradation for the species and submit to an FEO for approval; and • Throughout all site activities crews will implement the QGC Weed and Pest Management Plan and procedure for weed hygiene for Vehicle and Machinery. These documents specify requirements for weed hygiene, including ensuring all vehicles and machinery are certified weed free before commencing work on site and regular weed wash-downs to minimise introduction and spread of weeds. Fire • QGC has no fire regime, fire management in the area may be undertaken by the Land manager, in this case Queensland Parks and Wildlife Service (QPWS) as per their usual management strategies; • Staff and contractors will be made aware of fire risk levels and will use increased caution during high fire risk period; • All combustible liquids onsite must be stored appropriately and in line with the relevant Australian standard where available. Storage of combustible liquids will be minimised during times of high fire risk; • On site fire management practices shall be in accordance with Contractor HSSE requirements, relevant construction permits and method statements and appropriate dedicated firefighting equipment will be available at high risk construction sites to manage any fires that may start up and to avoid wildfires breaking out; • Cleared work areas around QGC infrastructure and activities will act as fire breaks that prevent or reduce the potential of any fire started from QGC works from spreading; and • Cleared vegetation will be removed from or limited in fire break areas with preference for storing these materials toward the edges of cleared areas. For example, fire breaks of 15m will be maintained around well heads and vegetation placement for storage or progressive rehab will not occur within these areas (progressive rehabilitation will occur in other parts of the 1ha well pad area). Injuries • All FSCs must be appropriately prepared for fauna injuries. They must have a rescue and first aid kit and response plan, including nearby wildlife carer contacts, to ensure all injured fauna are given appropriate care; • Any injured fauna shall be transported to a veterinarian or recognised wildlife carer immediately for treatment. QGCs Fauna Emergency Response and Care Centre (FERCC) is available to all staff and contractors for the treatment and care of injured fauna. Stock • Any grazing in the State Forest will be the activity of a Lessee and would be managed as per an agreement with QPWS; and • Habitat features including suitable cleared trees, logs or other shelter sites used for progressive and/or final rehabilitation will provide shelter sites for protection against trampling by stock. Predation • Habitat features including suitable cleared trees, logs or other shelter sites used for progressive and/or final rehabilitation will provide shelter sites for protection against predators Awareness • Signage will be erected to increase the general awareness amongst work crews of the species presence and its habitat in the area; • Nearby habitat areas that are to be avoided will be signed and flagged as No Go areas to ensure they are not disturbed; and • The presence of the species and habitat areas will be discussed by crews during tool box talks. Reporting and compliance • All recorded sightings and relocation of the species will be recorded, and will also be reported to the relevant administering authority where required; and • Should non-compliance with the mitigation measures or management strategies outlined in this SSMP occur on site, an investigation shall be undertaken by all responsible parties followed by

corrective action procedures if required. Work in the area will cease at the time of the non- compliance if the incident is deemed significant by the site Environment Representative.

Rehabilitation and Recovery Rehabilitation will be undertaken to support recovery of the species. This will include: • Post construction rehabilitation will include distribution of mulched vegetation across cleared areas and stick raking or placement of non-mulched vegetation to assist with habitat recovery, this is also a QPWS requirement. Natural revegetation of areas will then be allowed to occur; • Fauna habitat to be created as part of rehabilitation of cleared areas, where the Yakka Skink has been identified. This is to include replacement of habitat logs, rocks and other natural features; • Rehabilitation will be progressively undertaken during construction following backfilling and completion of infrastructure establishment; and • As per QPWS requirements, rehabilitation will initially include seeding with a cover crop of annual millet grass to stabilise the area and prevent erosion while natural regeneration takes place and fertiliser application as per their specified rates.

Residual Impact Once the above mitigation and rehabilitation measures have been undertaken there is considered to be no or low residual impact to the species as it is not reliant on mature tree cover or remnant vegetation. Soil characteristics and shelter/burrow sites are important habitat characteristics for the species and these can be recovered relatively quickly after construction and decommissioning. Soil and shelter sites will be reinstated as part of progressive and final rehabilitation and disturbed areas will be seeded as per QPWS requirements. Therefore, within a few months of progressive or final rehabilitation grasses will have regenerated and all important habitat characteristics for the species will have been reinstated allowing them to construct burrows and utilise the area. Performance Measures Performance measures for this species includes: • A pegging party survey will be undertaken to identify the presence/absence of the species, its habitat and micro-habitat features. If these are confirmed and the area cannot be avoided, a second targeted survey will be undertaken in accordance with DoE Survey guidelines for Australia’s threatened Reptile species; • Gathering line trenches will be inspected twice daily to detect entrapped reptiles; and • Should impacts to the species occur, offset sites will potentially be established for unavoidable impacts to significant species habitat, where required; and • All progressive rehabilitation will occur within three months of construction. Monitoring Monitoring requirements for this species includes: • Monitoring is not currently required as the species has not been identified as being present within the Anya project area; • If the species is located DoE will be notified; • An appropriate monitoring program may be required if impact to the species or its habitat is identified and quantified. If required, this will be established with the relevant authority; • In areas where this species is likely to be present, FSC must monitor gathering line trenches twice daily (early morning and late afternoon) every day while the trenches are open and have access to the site in all weather. In all other areas FSC shall monitor trenches at least once daily; • Monitoring of vegetation structure and species composition, including abundance, and fauna habitat features of areas being rehabilitated back to remnant native vegetation will be undertaken to assess success of rehabilitation; and • Monitoring of rehabilitation areas will be undertaken as per requirements in the relevant Environmental Authority and QPWS. . References Apan, A, Phinn, S, McAlpine, C & Kath, J 2010, ‘Predictive habitat mapping of threatened reptiles in the Southern Brigalow Belt, Australia using GIS based weights-of-evidence modelling’, USQ Unpublished report.

Atlas of Living Australia 2015, Egernia rugosa De Vis, 1888, viewed July 8 2015, http://bie.ala.org.au/species/Egernia+rugosa. Chapple, D 2003, ‘Ecology, Life-History, and Behaviour in the Australian Scincid Genus Egernia, with Comments on the Evolution of Complex Sociality in Lizards’, Herpetological Monographs, vol. 17, pp. 145-180. Cogger, H 2000, Reptiles and Amphibians of Australia, 6th edn, Reed New Holland, Sydney, NSW. Covacevich, J, Couper, P & McDonald, K 1998, ‘Reptile diversity at risk in the Brigalow Belt, Queensland’, Memoirs of the Queensland Museum, vol 42, no. 2, pp 475-486. Department of the Environment and Heritage Protection (DEHP) 2013, Wildlife Online Extract, viewed July 2015, http://www.ehp.qld.gov.au/wildlife/wildlife-online/index.html. Department of the Environment (DoE) 2015, Egernia rugosa in Species Profile and Threats Database, viewed 8 July 2015, http://www.environment.gov.au/cgi-bin/sprat/public/publicspecies.pl?taxon_id=1420. Department of Science, Information Technology, Innovation and the Arts (DSITIA) 2014, Targeted species survey guidelines, Yakka Skink Egernia rugosa, viewed 8 July 2015, https://www.qld.gov.au/environment/assets/documents/plants-animals/biodiversity/yakka-skink.pdf. Ehmann, H 1992, Reptiles. In: Strahan, R., ed. Encyclopaedia of Australian Animals. Sydney: Angus and Robertson. McDonald, K, Covacevich, J, Ingram, G and Couper, P 1991, The status of frogs and reptiles. In: Ingram, G and R Raven, Eds. An Atlas of Queensland's Frogs, Reptiles, Birds and Mammals, pp. 338-345. Queensland Museum, Brisbane. Osterwalder, K, Klingenbock, A & Shine, R 2004, ‘Field studies on a social lizard: Home range and social organization in an Australian skink, Egernia major’, Austral Ecology, vol. 29, pp 241-249. Queensland Murray Darling Committee (QMDC) 2008, Yakka skink, World Wildlife Fund, Sydney, viewed 8 July 2015, www.qmdc.org.au/publications/download/47/fact-sheets-case-studies/reptile-recovery/yakka- skink.pdf. Richardson, R 2008, Queensland Brigalow Belt Reptile Recovery Plan, Queensland Murray Darling Committee, Brisbane, viewed 8 July 2015, http://www.qmdc.org.au/publications/download/52/fact-sheets- case-studies/reptile-recovery/draft-reptile-recovery-plan.pdf. Wilson, S & Knowles, D 1988, Australia's Reptiles: A Photographic Reference to the Terrestrial Reptiles of Australia, Collins Publishers, Australia. Threatened Species Network (TSN) 2008, Yakka Skink; Egernia rugosa; National Threatened Species Day Information Sheet, World Wildlife Fund, viewed 21 July 2015, http://guides.is.uwa.edu.au/content.php?pid=43218&sid=318559 [8 July 2008] Threatened Species Scientific Committee (TSSC) 2001, Commonwealth Listing Advice on Egernia rugosa (Yakka Skink), viewed 8 July 2015, http://www.environment.gov.au/cgi- bin/sprat/public/publicspecies.pl?taxon_id=1420.

Figure 1 Yakka Skink Distribution

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NOTE: Whilst care has been taken to prepare this map, QGC (and associated data custodians) make no guarantees about its accuracy, reliability or completeness and cannot accept responsibility of any kind for any expenses, losses, damages and/or costs(including indirect or ATP 1188 consequential damage) which are incurred by any party as a result of this product. "Based on or contains data provided by the State of Queensland (Department of Environment and Resource Management) 2015. In consideration of the State permitting use of this data you acknowledge and agree that the State gives no warranty in relation to the data (including accuracy, reliability, completeness, currency or suitability) and accepts no liability (including without limitation, liability in negligence) for any loss, damage or costs (including consequential damage) relating to any use of the data. Data must not be used for direct marketing or be used in breach of the privacy laws."

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Figure 2 Yakka Skink Potential Habitat

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Meters 11.3.14 Map Projection: GDA 94 SCALE: 1:20,000 (A3) 11.3.14 11.5.1 11.5.1 DATA SOURCE: DCDB, Railways - DERM | Roads, Towns - GA Infrastructure - QGC

NOTE: Whilst care has been taken to prepare this map, QGC (and associated data custodians) make no guarantees about its accuracy, reliability or completeness and cannot accept responsibility of any kind for any expenses, losses, damages and/or costs(including indirect or consequential damage) which are incurred by any party as a result of this product. "Based on or contains data provided by the State of Queensland (Department of Environment and Resource Management) 2015. In consideration of the State permitting use of this data you acknowledge and agree that the State gives no warranty in relation to the data (including accuracy, reliability, completeness, currency or suitability) and accepts no liability (including without limitation, liability in negligence) for any loss, damage or costs (including consequential damage) relating to any use of the data. Data must not be used for direct marketing or be used in breach of the privacy laws." RubyJo Isabella PL 275