Appendix A Submissions Register - Metro Mining...Fly in Fly out (FiFo). In the EIS teleconference...

1

Appendix A – Submissions Register

This submissions register identifies the submitter number, the submission reference number, the

relevant section of the EIS that the issue relates to, if applicable, details of the issue and Metro

Mining’s response or cross-reference location to the response within the Supplementary Report.

Bauxite Hills Project Supplementary Report to the Environmental Impact Statement

2

Submissions Register

Submitter

No.

Submission

Reference No.

Relevant EIS

Section Issue Detail Metro Mining Response/Cross-reference Location

1 1.1 Sport and Recreation Services has no concerns with this

project. Noted. No further response to this comment is required.

2 2.1 18 The EIS addresses HICB concerns that were identified in our

comments on the TOR for the EIS. Noted. No further response to this comment is required.

2 2.2 18

The EIS (in section 18) provides detailed information about

the hazardous chemicals and associated risk and risk

controls to be employed on/at the project.

Noted. No further response to this comment is required.

2 2.3 18 Risk associated with natural hazards and hazardous

chemicals are comprehensively addressed. Noted. No further response to this comment is required.

2 2.4 18 Emergency planning has been addressed. Noted. No further response to this comment is required.

2 2.5 18 Off-site risk and impacts on sensitive receptors (from a land

use safety planning perspective) have been addressed. Noted. No further response to this comment is required.

2 2.6 18

Due to the quantities of hazardous chemicals that will be

required to be kept at the project site, a Form 73 (Manifest

Quantity Workplace Notification) to Work Health and

safety Queensland will be required once keeping of the

hazardous chemicals commences.

Noted. Metro Mining notes the need to submit / keep Form 73

(Manifest Quantity Workplace Notification) onsite once the keeping

of hazardous chemicals commences.

2 2.7

HICB would like to thank the proponent for providing clear

and detailed information within the EIS. From our

perspective the information was easy to locate and review.

This EIS is one of the best presented that HICB has

reviewed.


3 3.1

CYSF SUPPORTS the Bauxite Hills Project proposed by

Metro Mining Limited which is currently the subject of

Environmental Impact Statement Public Consultation.


4 4.1

On the basis of my own knowledge and the facts I have

before me, I wholeheartedly support Metro Mining and its

Bauxite Hills Project and wish the company well in its

endeavours.


5 5.1

I am pleased to support Metro Mining and its Bauxite Hills

Project, which offers substantial opportunities and benefits

to the Cook electorate and far North Queensland.



3

Submitter

No.

Submission

Reference No.

Relevant EIS


6 6.1

The Environmental Impact Statement (EIS) document is

predominately focused on environmental impact and

management, with no detailed comment outlining

strategies in place to manage an incident involving workers

with acute and possibly time critical medical conditions.

Refer to Section 18.2 of the Supplementary Report.

6 6.2

Due to the remote location of the Bauxite Hills Project, the

EIS document states that access to the project will be 100%

Fly in Fly out (FiFo). In the EIS teleconference attended on

31 May 2016, information presented to the attendees was

that no road access was available from the PDR to the

project site, which limits the option of a road response to

an incident, limiting a response to either rotary or fixed

wing aircraft.


6 6.3 2.7.8.2 and

18.8.3.4

The EIS document (2.7.8.2 and 18.8.3.4) refers to the

Bauxite Hills Project as developing an 'Emergency Response

Plan'. The QAS requests that a copy of this document be

provided to the QAS so that the access strategies and on-

site medical capacity of the project can be reviewed.


6 6.4

The QAS would like to be formally notified and engaged

regarding the actions proposed by the Department of

Environment and Heritage Protection to mitigate the risks

identified by the QAS. Contact officers to be notified are Mr

Warren Martin, Executive Manager, Torres and Cape Local

Ambulance Service Network on email

[email protected] or telephone 4032

8627 and Ms Rachael Harmston, Town Planner,

Infrastructure and Procurement Branch on email

[email protected] or telephone

3635 3887.

This comment appears to be requesting direct action from EHP to

notify and engage with QAS regarding their proposed actions. As

such, Metro Mining is not able to respond on EHP’s behalf.

However, as noted in Section 18.2 of the Supplementary Report,

Metro Mining will formally notify and engage QAS regarding the

development of the ERP (as discussed in Section 18.8.3.4 of the EIS).

Given the commitment by Metro Mining to consult with QAS no

update to the information included in the EIS is proposed.

7 7.1 The Cairns Chamber of Commerce has pleasure in offering

its support to this very important project. Noted. No further response to this comment is required.


4

Submitter

No.

Submission

Reference No.

Relevant EIS


8 8.1 16

To ensure local suppliers have full, fair and reasonable

opportunities to tender for procurements (throughout the

life of the project), separate strategies should be developed

to differentiate the project's 'operational' and

'construction' phases.


8 8.2 16

Further clarification of workforce management, including

local/regional recruitment and employment strategy, is

required.


8 8.3 16.8.2.1

Further clarification of workforce management, including

recruitment and employment strategies for targeted equal

employment opportunity groups (e.g. women; Aboriginal

and Torres Strait Islander people; people with a disability),

is required. It is noted the proponent has indicated a

commitment to maximising opportunities for the groups

mentioned above; however, the Department of State

Development is seeking some measure to have this

position strengthened, particularly as is provides reference

(under section 16.8.2.1) to other projects in the region that

have strategies promoting an inclusive workforce.


8 8.4 16.9.1.2,

16.9.1.3

Section 16.9.1.2 states recruitment and management of the

workforce during all phases of the project will largely be

the responsibility of contractors and subcontractors, but in

section 16.9.1.3 it is identified the proponent will advertise

for goods and services in the region.

Refer to Section 16.2 and Section 16.3 of the Supplementary Report.

8 8.5 16

Further clarification is required for the structure and

frequency of performance reporting on social impact

mitigation strategies, including: management

arrangements; commitments; local agreements; and

outcomes achieved.


9 9.1 1.3.6, Table 1-

11

Project environmental approval requirements, no mention

of waterway barrier works approvals. Refer to Section 3.1 of the Supplementary Report.


5

Submitter

No.

Submission

Reference No.

Relevant EIS


9 9.2 2.6.1 p

Shared port infrastructure with Gulf Alumina: It is noted

that discussions are underway for an option of Metro

Mining and Gulf Alumina to share the port infrastructure

and haulage roads. In consideration of a least impact

option to high value marine plants in this area, it is

Fisheries QLD preference for the existing port

infrastructure and haulage roads to be upgraded and used

by Metro Mining.

The acquisition of Gulf Alumina enables the shared use of the

existing and approved SRBP infrastructure. Section 4 of the SEIS

describes the amended Bauxite Hills Project and how the SRBP

infrastructure will be used to service the Bauxite Hills project.

9 9.3 2.7.6.2

The EIS notes: It is not anticipated that forestry materials

will be required by the project. The exact location and

suitability of the on-site deposits is yet to be determined,

although it is expected that suitable materials can be

sourced from within the project area given the presence of

existing borrow-pits associated with the previous kaolin

mine.

The issue is: While the required extractive materials are

expected to be found within the project area, DAF

(Forestry) notes that the actual location/s of suitable

resources has not been determined. If extractive materials

do have to be sourced from outside the project area then

DAF (Forestry) should be consulted for advice on any

authority that might be required under the Forestry Act

1959.

Refer to Sections 4.3.2 and 4.5.3 of the Supplementary Report.


6

9 9.4 4.5.1.4, 4.5.1.7

Capacity of the soil to support agricultural use.

The findings of the soils assessment indicate that the land

subject to the proposed activity might have limited ability

to be used for cropping and or other agricultural use. If the

Agricultural Land Classification B Class land classification is

incorrect, it is recommended that the proponent provide its

findings to the Department of Science, Information

Technology and Innovation (DSITI) to update the State's

soils data and soils mapping. However, if the Agricultural

Land Classification is correct, DAF's key concern is that

there should be no net loss of the availability or utility of

land for agricultural uses resulting from the project. Land

within the project area likely to be directly impacted

includes 1,422 ha of land identified as Agricultural

Classification B Class land. The availability and utility of this

land to undertake agricultural land uses will be impacted by

the project. This land is classed as being highly suitable for

pastures and may be suitable for cropping with engineering

and/or agronomic improvements. DAF recommends that

the proposed mitigate the impacts on agricultural land

availability.

It is recommended that the proponent be required to:

1. Secure equivalent land for permanently impacted

agricultural land (e.g. final void areas, any contaminated

land, and areas of steep slopes post rehabilitation) for

ensuring that there is no permanent net loss of land

available for agricultural production as a result of the

proposed resource activity, in perpetuity; and

2. Ensure that there is no temporary reduction in land

available for highest order agricultural production as a

result of the proposed resource activity by:

Securing equivalent land for temporarily impacted land

for the purpose of highest-order agricultural production

during the term of the project (i.e. 1,375ha)

Providing an 'uplift measure' to ensure the

development of land for agricultural use in the region.

Metro Mining does not propose to revise the EIS to reflect these

proposed recommendations due to the land not being mapped as an

area of regional interest or as a priority agricultural area; that it is

not a strategic cropping area and therefore the Regional Planning

Interests Act 2014 would not apply to the Project. Given the general

limited depth of topsoil recorded across the site, low nutrient

content of the soils, need for excessive amounts of fertilisers,

variable climatic conditions, provision of irrigation and high

transportation costs given the distance to markets, agricultural uses

of the land are extremely limited and generally not feasible.

Furthermore, the proposed post-mining land use, once

rehabilitation is complete, is to return the land to pre-existing native

vegetation communities.


7

Approval conditioning:

1. It is recommended that if an approval is made, it be

subject to the proponent ensuring that the equivalent land

for permanently impacted land be maintained as land used

for the highest-order agricultural land use in perpetuity.

The equivalent land for permanently impacted land must

be legally secured by registration of a covenant on the title

of the equivalent land, and evidence of the same proved to

the Chief Executive of the Department of Environment and

Heritage Protection (the Chief Executive) prior to the

commencement of the project. It is recommended that if

an approval is made, it be subject to the proponent

submitting a report annually to the Chief Executive which

details:

yield quantity from the equivalent land

yield quality from the equivalent land

inputs (e.g. water, fertiliser, machinery) to the

equivalent land

any events, whether natural or not, which have

influenced the productive capacity of the equivalent

land.


subject to the proponent ensuring that the equivalent land

for temporarily impacted land be maintained for land used

for the highest-order agricultural land use for the term of

the project. The equivalent land for temporarily impacted

land must be legally secured by registration of a covenant

on the title of the equivalent land, and evidence of the

same proved to the Chief Executive prior to the

commencement of the activity. It is recommended that if

an approval is made, it be subject to the proponent

submitting a report annually to the Chief Executive which

details:

yield quantity from the equivalent land

yield quality from the equivalent land


8

Submitter

No.

Submission

Reference No.

Relevant EIS


inputs (e.g. water, fertiliser, machinery) to the

equivalent land

any events, whether natural or not, which have

influenced the productive capacity of the equivalent

land.


subject to the proponent providing an uplift measure to

ensure the development of land suitable to undertake

agriculture on occurs in the region. DAF recommends that

the proponent detail the strategy including the sequence of

actions to ensure that this happens, including proposed

farming arrangements and back up options in case first

instance arrangements fail.

9 9.5 5.10.7.2, Table

5-19

Queensland Offset requirements - direct benefit

management plans, potential offset actions, mangroves: It

has been proposed that mangrove and saltpan disturbance

is to be offset through the funding of sea turtle

conversation. Funding to protect marine turtles is not an

acceptable offset as it does not have a direct benefit to

fisheries resources and habitats which are the subject of

the offset.

Metro Mining commits to further consultation with EHP and DAF as

part of finalising the offsets package for the Project. Refer to Section

6.12 of the Supplementary Report for further details on the

predicted and reduced clearance footprint for environmentally

significant vegetation, taking into account the use of the approved

SRBP MIA, BLF and existing SRBP main haul road, in addition to the

use of the SRBP accommodation and associated facilities.

9 9.6 5.13, Table 5-

21

Commitments terrestrial and aquatic ecology.

All waterway crossings are to be designed with regard to

the State development assessment provisions to maintain

fish passage.


9 9.7 6.2.5

Fisheries Act 1994 also protects waterways providing for

fish passage. The Fisheries Act 1994 protects waterways

providing for fish passage, waterway barrier works may be

applicable for waterway crossings outside of the mining

lease area to ensure fish passage and connectivity within

waterways.

Metro Mining acknowledges this observation. Refer to Section 3.1.1


9

Submitter

No.

Submission

Reference No.

Relevant EIS


9 9.8 6.6.1.4

Hydrological Connectivity - omission of the importance of

hydrological connectivity for fish species and fisheries

resources. Hydrological connectivity is important for a wide

range of commercial, recreations and native fish species to

access feeding, spawning and refuge areas. Waterway

barriers that restrict fish movement can significantly reduce

the long term viability of many Australian native fish

populations. Waterway crossings should be designed with

regards to the state development assessment provisions to

maintain fish passage at all flow regimes. Where waterway

crossing falls outside of the mining lease area a

development approval may be applicable.

Metro Mining will utilise the existing SRBP mail haul road to access

the SRBP MIA. As such the north south haul road proposed for the

Bauxite Hills Project is no longer required.

The relocation of the east-west haul road crosses two un-named

creek lines. These crossings will incorporate culverts that will allow

fish passage upstream and downstream of the crossings as outlined

in Section 3.1.1 of the Supplementary Report.

9 9.9 6.6.2

Marine Species-no recognition that marine plants and fish

species may be affected by the proposed development.

Mangroves and associated marine plants provide important

feeding and nursery habitats for many marine species and

fauna including crustaceans and fish.

Impacts to terrestrial, freshwater and marine ecology are discussed

in Chapter 6, 7 and 8 of the EIS and updates are provided Section 6,

7 and 8 of the Supplementary Report.

9 9.10 6.6.4

Fisheries - commercial and recreational fishing

displacement. Note that any displacement to commercial

or recreational fisheries needs to be considered, and

compensation may be applicable for commercial fisheries

in this area. The Guideline on fisheries adjustment provides

advice for proponents on relevant fisheries adjustment

processes and is available by request from the Department

of Agriculture and Fisheries.

The Project is not considered likely to impact commercial or

recreational fishing activity in the Skardon River and adjacent

waters. Refer to Section 6.5.5 of the EIS which discusses potential

impacts to the various commercial fisheries and recreational fishing

activities in the Skardon River area.


10

Submitter

No.

Submission

Reference No.

Relevant EIS


9 9.11 6.6.5

Summary of impact to marine ecology - no recognition of

marine plants playing a vital role in Qld's fisheries and the

potential impacts of the project on this aspect of the

development. Clearing of 20.5 ha of mangrove, 0.25 ha of

saltmarsh vegetation and 0.4ha of seagrass has the

potential to impact on Queensland fisheries as an economic

driver. These marine plants provide vital shelter, food and

nursery areas to about 75% of fish species caught in

Queensland, and play an integral role in Queensland's

commercial, recreational and indigenous fisheries.

The use of the existing SRBP MIA, BLF and main haul road, in

addition to the relocation of the east –west BH1 haul road has

removed all of the direct impacts on estuarine wetlands (including

areas of seagrass and mangrove habitat) that were previously

identified in the EIS. It is considered unlikely that the economic

driver of Queensland Fisheries will be impacted. Refer to Section

6.5.5 of the EIS which details the existing commercial and

recreational fishing activities within the Skardon River area. Also

refer to Section 6, 7 and 8 and Appendix D of the Supplementary

Report for updated information on terrestrial and marine ecology.

9 9.12 6.8.2.1, Table

6-15

Assessment against significant impact criteria: three

sawfish species and Speartooth Shark: Fragment an existing

population into two or more populations -does not

recognise that waterway crossings may act to fragment this

population. Waterway crossings to be designed in

consideration of the species present in this location, and

allow for fish passage of the entire range of species,

including sawfish and speartooth shark species. This will

allow for movement of these species between nursery and

feeding areas and reduce the likelihood of the population

becoming fragmented.

The assessments of the impacts to Speartooth shark and Sawfish

spp. are discussed in Sections 8.4.1 and 8.4.2 of the Supplementary

Report.

9 9.13 8.8 References to the Land and Sea "Ranges" is incorrect. The online version of the EIS will be updated to reflect these

amendments.


11

Submitter

No.

Submission

Reference No.

Relevant EIS


9 9.14 8.8.1.1

Section refers to the Cook Shire Council Pest Management

Plan 2012-16. The proponent should note that the existing

plan is currently being reviewed and will be replaced by the

Cook Shire Biosecurity Plan 2016-2020 in the second half of

2016. Reference should be made to the new plan which will

be written under the new legislation (i.e. Biosecurity Act

2014). The proponent is advised to also refer to the

Regional Biosecurity Strategy for Cape York Peninsula 2016-

20 (out for consultation). The Strategy provides valuable

information including detailed maps and strategic

management for priority species. Suggest that proponent

checks for alignment with the priorities of this Strategy.

The revised Cook Shire Biosecurity Plan 2016-2020 is not yet publicly

available on the Cook Shire Council website

(http://www.cook.qld.gov.au/biosecurity). The Regional Biosecurity

Strategy for Cape York Peninsula 2016-2020 is also not available on

the Cape York Natural Resource Management website

(http://www.capeyorknrm.com.au/project/1657).

These documents will be reviewed and considered by Metro Mining

when available.

10 10.1

Substantial community support exists for the Bauxite Hills

Project. Accordingly, we have pleasure in encouraging all

concerned to facilitate the necessary approvals enabling it

to proceed, so long as Metro meets all necessary

environmental standards. We wish Metro well in its

endeavours and look forward to a long-standing, mutually

beneficial relationship.



12

Submitter

No.

Submission

Reference No.

Relevant EIS


11 11.1 17.2.4.12,

Figure 17.1

The proponent is proposing to conduct its shipping

operations (barging loading area) outside of the Skardon

River port limits and there is currently no approval for an

extension to the existing port limits or permission to carry

out port activities outside of the port limits.

The proponent should consult closely with Ports North with

regard to use of the Skardon River port, to either:

(a) seek an extension of the Skardon River Port limits in

consultation with Ports North. (Under s274 of Transport

Infrastructure Act 1994, a regulation may define or amend

the limits of a port.

Extension of the Skardon River Port limit would require an

amendment to the Transport Infrastructure (Ports)

Regulation. (This is the Department of Transport and Main

Roads' preferred course of action) or

(b) seek an approval to carry out port activities outside the

current Skardon River port limits under s274 of the

Transport Infrastructure Act 1994. (The Governor-in-

Council may decide that port activities of a substantial

nature may be carried on at a place that is not a port

managed by a port authority, the State or a local

government).

The EIS should clearly indicate which approach the

proponent wishes to take and consult closely and regularly

with Ports North to progress this issue.

There is no longer a requirement to extend the port limits given the

relocation of the port area. Refer to 3.1.5 and 17.2 of the

Supplementary Report.

11 11.2 17.6.3.3

In the second paragraph "Navigational Aids", it states that

"the navigational channel will be charted by MSQ and the

RHM and checked regularly, particularly following the wet

season and extreme weather events".



13

Submitter

No.

Submission

Reference No.

Relevant EIS


11 11.3 17.9, Table 17-

16

The 11th item states that "Navigation channel will be

charted and checked regularly, particularly following the

wet season and extreme weather events". To clarify

responsibility for surveying the channel, this commitment

should more clearly state annual surveying will take place,

at the proponent's expense, e.g. "the channel offshore of

the mouth of Skardon River will be hydrographically

surveyed by MSQ at the end of each wet season at the

proponent's expense "


11 11.4 Appendix M

"the channel offshore of the mouth of Skardon River should

be hydrographically surveyed (at the end of the wet

season)." To clarify responsibility for surveying the channel,

this commitment should more clearly state annual

surveying will take place, at the proponent's expense, e.g.

"the channel offshore of the mouth of Skardon River will be

hydrographically surveyed by MSQ at the end of each wet

season at the proponent's expense "


12 12.1

Recently draft guidance material for Bushfire hazard has

been developed in support of the State Planning Policy in

the form of a draft model code (attached). The draft model

code has been developed to meet QFES operational needs

and adopt key recommendations for bushfire mitigation.

The code is currently in consultation with peak bodies and

key industry groups. In support of this process, please

consider relevant sections of the draft model code as a

guide to address SPP requirements for bushfire hazard.



14

Submitter

No.

Submission

Reference No.

Relevant EIS


12 12.2

Although the mining component is exempt from the State

Planning Policy the proponent should consider relevant

sections of the draft model code to assist in mitigating

against the adverse effects of bushfire. A number of

management and mitigation measures that are identified

by the EIS are addressed in the draft model code such as

firebreaks, design and siting of buildings, access, and water

supply. In particular mitigation measures should be

implemented in the development of the accommodation

camp. PSBA advises that a bushfire site assessment should

be conducted to determine the level of bushfire affecting

the site and this in turn will guide adherence requirements

against the draft model code.


13 13.1 2.2.3, 6.6.1,

7.6.2

Listed threatened marine species - Please provide further

evidence to support the conclusion that the proposed 1:10

year sediment pond design will be sufficient to avoid

sediment-laden runoff entering the Skardon River from the

Mine Infrastructure Area (MIA).

The Department notes the sediment ponds in the MIA are

within 100 m of the Skardon River and the EIS notes the

sediment ponds are expected to overflow. The Department

also notes that the mine site will not be operational during

the wet season and will be effectively understaffed during

this time.

Since the release of the EIS, Metro Mining has completed a

successful takeover of Gulf Alumina’s assets, including the existing

and proposed infrastructure for the SRBP, and proposed

operations. The MIA and sediment ponds originally proposed for the

Project are no longer required, and the comments relating to this

area are no longer relevant.

The acquisition of the SRBP enables the use of the approved

infrastructure at the port area. The sediment ponds approved for

the SRBP will be used for the MIA.


15

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.2

6.5.2, 7.6.3,

7.13.2,

Appendix B3

(Section 3.3)

Seagrass - Dugong - Please calculate the amount of

seagrass habitats (in hectares) that have the potential to be

impacted by the construction and operation of the Barge

Loading Facility (BLF) and vessel activities on the Skardon

River.

Please update the relevant sections of Chapter 7 to identify

the potential impact to seagrass habitats from the

proposed action.

The Department notes there have been seven benthic

habitat surveys undertaken from the Skardon River (Table

6-3, Table 7-6 and Appendix B3) and the EIS discusses the

results of these surveys. The EIS also includes Figure 6-4

and Figure 7-10 which highlights seagrass habitats near the

proposed BLF. The Department considers seagrass habitats

are important habitat for the migratory Dugong which is

known to occur in the Skardon River.

However, the Department notes that Table 7-47

acknowledges the area of direct estimated disturbance on

seagrass communities is yet to be confirmed as “Detailed

surveys for the presence of seagrass within the proposed

footprint will be undertaken during the final design phase.”

Hence, the EIS does not provide an estimated amount of

seagrass habitat to be potentially impacted.

The Department notes that Appendix B3 contains mapping

of seagrass habitats in the Skardon River dated March 2015

(Figure 3.2). The Department considers this map would be

useful to include in the EIS and assist in the calculation of

the amount of seagrass habitats that have the potential to

be impacted by the proposed action.

The Supplementary Report includes the new information obtained

during the seagrass surveys undertaken in the Skardon River (refer

to Figure 7-1) in the vicinity of the infrastructure disturbance

footprint of the cyclone mooring area and the originally proposed

BLF and RoRo - refer Section 7.3. Table 7-47 and Table 5-18 of the

EIS identifies the significant residual impacts from the Project

requiring offsets, which have been significantly reduced. This table

has been updated and is provided in Section 6.12 refer specifically to

Table 6-11) of the Supplementary Report.


16

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.3 7.8.1

Water Mouse - Please amend Table 7-15 to note the Water

Mouse as having the ‘Potential’ to occur. The EIS notes that

surveys for the Water Mouse were not carried out.

However, suitable mangrove and saltpan habitat occurs on

the margins of the Project Area. The EIS states 20.5 ha of

mangrove and 0.25 ha of saltpan vegetation will be cleared

for the barge loading area. Please provide an assessment of

the likely impacts to the Water Mouse, its habitat and the

proposed management and mitigation measures to

minimise the impact to this species.

Under the system Metro Mining has adopted (as with most EIS

assessments), species considered with 'potential' to occur are not

considered under the significant impact guidelines. Metro Mining

also notes comment 13.7 from the Department itself which states

'The Department considers species assessed against the significant

impact criteria should be categorised as no less than ‘Likely’ to

occur.'

Recent surveys for Water Mouse have been carried out in mangrove

areas proposed to be impacted by the Project.

Refer to Section 8.2.5 of the Supplementary Report for the results of

the targeted Water Mouse surveys.

Following the collocation of the BLF and RoRo to the approved SRBP

port area and the use of the existing SRBP main haul road to service

the Bauxite Hills Project, no mangrove habitat is anticipated to be

disturbed in addition to that already approved for the SRBP.

13 13.4 7.8.1, 7.12

Northern Quoll - Please provide further discussion to

support the conclusion that the Northern Quoll only has

the ‘Potential’ to occur in the Project Area. The Department

considers the Northern Quoll is ‘Likely’ to occur as the EIS

notes that foraging habitat (eucalypt woodlands) for the

Northern Quoll occurs on the project site and the species

has a large foraging range.

Refer to Section 8.2.3 of the Supplementary Report.


17

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.5 7.8.1, 7.13.2,

7.16

Red Goshawk, Masked Owl and Bare-rumped Sheathtail bat

- Please provide hollow-bearing tree habitat mapping for

the Project Area and calculate the amount of hollow-

bearing tree habitat (in ha) to be directly impacted by the

project. Please discuss and provide case studies (where

relevant) to demonstrate the effectiveness of selectively

felling hollow-bearing trees prior to general clearing for use

within rehabilitation areas as a mitigation measure. Please

update the relevant sections of Chapter 7 to identify the

potential direct impact of the project to hollow-bearing

tree habitat from project activities. Please update the

Commitments Table (Table 7-50) to include a commitment

to monitor and assess this mitigation measure throughout

the rehabilitation lifetime.

The Department notes that hollow-bearing trees are

important habitat for several listed threatened species,

particularly the Red Goshawk (for prey species), Masked

Owl (for nesting) and the Bare-rumped Sheathtail Bat (for

nesting). The EIS notes the commitment to selectively fell

large, hollow-bearing trees prior to general clearing for use

within rehabilitation areas to provide immediate breeding

and nesting habitat. The Department considers the

monitoring and assessment of this mitigation measure

would be useful to determine its effectiveness for use in

other mining rehabilitation actions in the area.

Further detail of the likelihood of the species occurring in the Project

area is presented in Sections 8.2.1, 8.2.2 and 8.2.4 of the

Supplementary Report. This updated assessment reaffirms the

position that these three species are not known or likely to occur at

the site. Consequently, Metro Mining does not propose to

undertake hollow bearing tree mapping.

Notwithstanding, Metro Mining will still undertake selective clearing

of hollow bearing trees for rehabilitation use.


18

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.6 7.8.1 and 7.12

Chocolate Tea Tree Orchid, Black-footed Tree-Rat (north

Queensland) - Please provide suitable habitat mapping for

the species identified (known and likely to occur) in the

Project Area. These maps should include an overlay of the

proposed mining infrastructure layout to illustrate where

there will be an impact on suitable habitat. Please provide

the total amounts of suitable habitat (in ha) for the Black-

footed Tree-rat:

o in the entire Project Area; and

o to be directly and indirectly impacted by the project.

Please update Chapter 7 to assist in the assessment of

impacts of the project on the species and the identification

of potential offsets.

The EIS states that the Black-footed Tree-rat is ‘Known’ to

occur in the Project Area. The Black-footed Tree-rat was

listed at the time of the referral decision and therefore an

offset may be required for habitat clearance.

The information for the Black-Footed Tree Rat is included in Section

8.4.4.3 of the Supplementary Report. The Project requires the

clearing 1,507 ha of Darwin Stringybark woodland (RE3.5.2). This

habitat remains widespread in the surrounding region with a further

44,280 ha located within a 20 km radius of the Project area. Given

the general lack of records and the abundance of this habitat in the

wider landscape no significant residual impacts have been predicted

for this species and therefore no offsets are required. The species

will be part of the Project-specific Significant Species Management

Plan (refer Section 8.4.3.3 of the Supplementary Report).

Updated discussion on the Chocolate Tea Tree Orchid is provided in

Section 8.4.3.1 of the Supplementary Report.

13 13.7

6.5.4, 7.8.2,

Appendix B3

(Section 4.2.2)

Migratory Species - Please review the consistency of the

‘Likelihood of occurrence’ of all migratory species in

individual EIS chapters, between EIS chapters and EIS

appendices. The Department considers species assessed

against the significant impact criteria should be categorised

as no less than ‘Likely’ to occur (Table 7-19). For example,

the Loggerhead Turtle, Dugong and Giant Manta Ray.

In the EIS, Dugong was listed as being ‘likely’ to occur this has since

been updated to 'known’ based on a single record in the Skardon

River (refer to Section 7.6.4.2, 7.8.1, 8.4.3.7 and 8.6.2.1 of the

Supplementary Report).

Giant Manta Ray remains 'unlikely to occur.' Metro Mining has

assumed DotEE were referring to Coastal Manta Ray as this species

was assessed under the significant impact guidelines as per Table 6-

20 and Table 7-43 of the EIS. This species was previously assessed as

potential to occur and has been elevated to ‘likely to occur’, albeit as

a transient species through the offshore transhipment area.

Loggerhead Turtle remains at 'potential to occur' and the significant

impact assessment for this species included at Table 7-19 of the EIS

may be ignored in accordance with DotEE’s comment that species

assessed against the significant impact criteria should be categorised

as no less than ‘likely’ to occur.


19

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.8 6, 7, Appendix

B3

Pristis pristis - Please update Chapter 6 and Chapter 7 to

ensure consistency in the naming of Pristis pristis:

o Section 6.5.4 (Table 6-5) and Section 6.8.2 of the EIS

notes the common name of species as the Largetooth

Sawfish.

o Section 7.8.2 of the EIS notes the common name of the

species as both the Freshwater Sawfish and Largetooth

Sawfish.

o Section 4.2.2 (Table 4.2) and Section 4.3.3 of Appendix

B3 notes the common name of the species as the

Largetooth Sawfish.

It is noted that both common names are used on the species

webpage on DotEE's own Species Profile and Threats Database.

Metro Mining have adopted Largetooth Sawfish for use in the

Supplementary Report as on the approved Conservation Advice for

the species.

13 13.9 7.9.1

Palm Cockatoo - Please remove the impact assessment for

the Palm Cockatoo.

The Department notes the Palm Cockatoo was listed as

‘Vulnerable’ under the EPBC Act on 31 October 2015. The

Controlled Action decision for this project was 18

September 2016. The Department notes that the EIS makes

reference to this and that the ‘species is not required to be

assessed’.

The significant impact assessment for Palm Cockatoo included in

Section 7.9.1 of the EIS may be ignored in line with DotEE’s

comment that “the Palm Cockatoo was listed as ‘Vulnerable’ under

the EPBC Act on 31 October 2015. The Controlled Action decision for

this project was 18 September 2016. The Department notes that the

EIS makes reference to this and that the ‘species is not required to

be assessed’.

13 13.10 7.9.2

Whimbrel and Common Sandpiper - Please update Chapter

7 to consider EPBC Act Policy Statement 3.2.1 – Industry

guidelines for avoiding, assessing and mitigating impacts on

EPBC Act listed migratory shorebird species (2015) and how

the proposed action is not inconsistent with actions

outlined this document. The Department notes this

document applies to two shorebird species identified in the

EIS:

o Whimbrel (Numenius phaeopus)

o Common Sandpiper (Actitis hypoleucos)

The EPBC Act Policy Statement can be found on the

Department’s website at:

www.environment.gov.au/epbc/publications/shorebirds-

guidelines.

Refer to Section 8.3.1.1 of the Supplementary Report.


20

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.11 7.10.2

Listed threatened marine turtle species - Please update

Chapter 7 to include a discussion on how the proposed

measures to avoid, mitigate and manage impacts on listed

threatened marine turtles are consistent with recovery

actions in the National Recovery Plan for Marine Turtles

(2003). The Department notes the EIS mentions the

recovery plan for marine turtles in Australia, however, the

EIS Terms of Reference states “The Assessment

Documentation must discuss how the proposed action is

not inconsistent with any relevant recovery plan for listed

threatened species and communities.”


13 13.12

7.10.2, 7.16,

Appendix B3

(Section 4.3.1)

Flatback Turtle, Hawksbill Turtle, Olive Ridley Turtle - Please

identify and discuss the proposed measures to avoid,

mitigate and manage consequential impacts on marine

turtle nesting beaches during critical nesting and hatching

periods. Please make reference in this discussion as to how

additional measures are consistent with recovery actions in

the National Recovery Plan for Marine Turtles (2003).

Please update the Commitments Table (Table 7-50) to

demonstrate how consequential impacts on marine turtle

nesting beaches during critical nesting and hatching periods

will be avoided, mitigated and managed. Appendix B3

states that there is listed threatened marine turtle nesting

beaches located approximately 10 km downstream of the

proposed action. The Department notes that the beaches

will not be traversed during construction or operation of

the mine. However, the Department considers that there

are likely to be consequential impacts of the proposed

action on turtle nesting beaches as a result of the work

force visiting the area for recreation.

The Project itself will have no impact on the beach to the west of the

Project area. Metro Mining will communicate the importance of the

turtle nesting areas and critical nesting times to its workforce and

establish educational and operational measures (i.e. no 4WD on the

beach) to protect the values of the beach.

An assessment of the Project’s potential impacts to turtles against

the recovery plan is included at Section 8.4.2.1 of the


In addition, as part of the Project offsets strategy investigations into

supporting Mapoon Land and Sea Rangers are being carried out.

This includes supporting activities such as removing/cleaning up

marine debris known to endanger marine species such as marine

turtles (e.g. discarded fishnets) and feral animal control, particularly

feral pigs which are well known to predate marine turtle nests.


21

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.13 7.10.2

Sawfish species and Speartooth Shark - Please update

Chapter 7 to consider the recovery actions contained in the

Sawfish and River Sharks Multispecies Recovery Plan (2015)

and how the proposed action is not inconsistent with these

actions.

The Recovery Plan was approved by the Minister and

applies to the following species:

o Largetooth Sawfish (Pristis pristis)

o Green Sawfish (Pristis zijsron)

o Dwarf Sawfish (Pristis clavata)

o Speartooth Shark (Glyphis glyphis)

o Northern River Shark (Glyphis garricki)


13 13.14

7.10.2,

Appendix B3

(Section 4.4.1)

Speartooth Shark - Please complete a separate impact

assessment for the Speartooth Shark against the ‘Critically

Endangered’ significant impact criteria in the Significant

impact guidelines 1.1 Environment Protection and

Biodiversity Conservation Act 1999.


13 13.15 6.11, 7.10.1,

7.14, 7.16

Listed Threatened and Migratory Species - Please confirm

the distance of the safety exclusion zone around the pile

driving works during the construction of the Barge Loading

Facility. The Department notes inconsistencies in the

distance quoted in the EIS:

o Table 6-22 quotes a commitment to employ a 500 m

safety exclusion zone.

o Section 7.10.1 quotes a 1000 m safety exclusion zone

will be established.

o Table 7-49 quotes a safety zone will be established at

1000 m prior to piling activity.

o Table 7-50 quotes a commitment to employ a 500 m

safety exclusion zone.

The use of the approved SRBP MIA and BLF removes the need for pile driving activities associated with the originally proposed Bauxite Hills BLF. No additional piles will be required for the BLF to those already approved for the SRBP.

Pile driving will still be necessary to construct the cyclone moorings.

A 500 m safety exclusion zone will be implemented during the

placement of these piles. Refer to Section 7.2.1 of the



22

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.16 7.11

Cumulative Impacts MNES - Please provide a discussion on

how cumulative impacts on matters of national

environmental significance can be avoided, mitigated and

managed, in cooperation with other project proponents.

The Department expects this discussion to include, but not

limited to, the following:

o a cooperative management strategy to prevent

fragmentation of critical habitats;

o consultation and cooperation with Gulf Alumina on

water management and water monitoring;

o the publication and sharing of data and other

information;

o sharing infrastructure where commercially viable; and

o adaptive management approaches, including:

maintaining biodiversity corridors, offsets (if required)

and other habitat areas;

management of port infrastructure and vessel traffic;

and

rehabilitation of disturbed areas post-mining.


demonstrate how cumulative impacts on matters of

national environmental significance will be avoided,

mitigated and managed, in cooperation with other project

proponents.

The Department notes that many of the identified

cumulative impacts on the Skardon River and adjacent

proposed Skardon River project (SRBP) can be managed

through the implementation of project specific mitigation

and management programs. The conclusion of the MNES

chapter states that no project impacts are considered

significant with the proposed mitigation measures and in

partnership with SRBP. However, no details of this

partnership are discussed in the MNES chapter.

With the acquisition of Gulf Alumina and as the owner of the SRPB,

Metro Mining will effectively be the responsible party for both the

Bauxite Hills Project EA and the SRBP EA. This means that areas

identified for cooperative management and/or consultation and

cooperation with Gulf Alumina will now occur seamlessly as part of

an amalgamated Project.

Given the acquisition potential impacts have been minimised where

possible by using existing and approved infrastructure as per SRBP’s

EA, including the MIA, BLF and accommodation camp.

Metro Mining will be responsible for establishing and implementing

operational arrangements aimed at minimising potential impacts

both cumulatively and individually as a result of the two projects.

Refer to Section 1.1 of the Supplementary Report regarding

discussion on the acquisition.


23

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.17 7.16


ensure that all proposed plans and management strategies,

noted in Chapter 7 and proposed to be implemented, have

been included.

A review has been carried out and the commitments table has been

updated. Refer to Appendix J of the Supplementary Report. Note

that the commitments in Appendix J are specific to the Bauxite Hills

Project. Metro Mining will look to consolidating the commitments

for both projects into a single consistent approach that will be

applied across the Bauxite Hills and SRBP projects.

13 13.18 7

Please review the section numbering of the MNES chapter

to ensure it is in numerical order as there are some

inconsistencies. For example, Section 7.10 MNES Impact

Assessment – Marine Species.

This will be updated in the online version of the EIS.

13 13.19 7

Listed Threatened and Migratory Species - Please update

Chapter 7 to take account of all relevant approved

Conservation Advices for listed threatened and migratory

species. When considering whether or not to approve a

proposed action, the Minister must have regard to relevant

approved conservation advices. The Department notes

where there is no recovery plan for a species, the

conservation advice for the species provides sufficient

direction to implement priority actions and mitigate against

key threats.



24

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.20 7

Listed Threatened and Migratory Species - Please update

Chapter 7 to include an assessment of how the proposed

action is not inconsistent with the actions contained in all

relevant Threat Abatement Plans for the following species:

o Black-footed Tree-rat

o Listed marine turtle species

o Dugong

When considering whether or not to approve a proposed

action, the Minister must consider the proposed action, its

impacts and mitigation measures and whether the

proposed project would be inconsistent with any applicable

threat abatement plans.

Approved threat abatement plans can be found on the

Department’s website at:

www.environment.gov.au/biodiversity/threatened/threat-

abatement-plans/approved.

There is no threat abatement plan for Black-footed Tree-rat. Refer

to Section 8.4.3 of the Supplementary Report which discusses

relevant threat abatement plans.

13 13.21 6,7

Impact Assessments - Listed Threatened Species - The

Department notes that significant impact assessments have

not been undertaken for several listed threatened species

which are dependent on hollow-bearing trees of Darwin

Stringybark woodland that dominates the project site. The

Department considers there is insufficient evidence to

conclude that there is an acceptable impact to this habitat

without further detailed investigation (see comment 5).

Comment 13.5 refers to the potential occurrence of Red Goshawk,

Northern Quoll, Masked Owl and the Bare-rumped Sheathtail Bat.

The occurrence assessment confirms that these species are not

known or likely to occur in the Project area, which is consistent with

Gulf Alumina's assessment in their EIS.

Metro Mining has provided a response to the occurrence of these

species in Section 8.2 of the Supplementary Report.


25

Submitter

No.

Submission

Reference No.

Relevant EIS


13 13.22 7

Residual significant impacts to MNES - The Department

notes the conclusion in the EIS that significant impacts on

matters of national environmental significance will not

occur. No offsets are therefore proposed under the EPBC

Act. Please note that following completion of the

assessment of impacts under the bilateral agreement with

Queensland, a decision will be made as to the acceptability

of impacts on MNES and whether residual significant

impacts are likely and offsets are therefore required to

compensate for these impacts.

Section 5.12 of the EIS summarises the Project's approach to

offsetting. The Project Offsets Strategy is located in Appendix C of

the EIS.

The area required for offsets has been updated since the EIS to

reflect the use of the SRBP infrastructure and the relocation of the

east – west BH1 haul road and is detailed in Table 6-11 of the

Supplementary Report. The outcome is a significant reduction in the

originally identified offsetting requirements. The final offsetting

strategy for both Projects will be discussed and agreed with the

relevant departments, including EHP and DAF.

14 14.1

Infrastructure Duplication - For the Skardon River Bauxite

Project, Gulf Alumina proposes to utilise existing

infrastructure and develop additional infrastructure in

areas predominantly disturbed by previous mining activities

on Gulf Alumina’s mining leases. This includes the Port

infrastructure area, wharf for loading barges, haul roads,

camp and airstrip. Gulf Alumina’s existing and proposed

infrastructure areas are located in areas that make optimal

use of topography to minimise impacts on wetland and

aquatic environments.

Metro Mining proposes duplication of much of this

infrastructure in areas previously undisturbed by mining or

other activities, including the proposed barge loading

facility (BLF), roll on roll off (RORO), haul roads and camp.

Much of the duplicated infrastructure is bordering, or in

sensitive environments such as wetlands and mangroves.

Gulf Alumina is supportive of sharing Gulf Alumina’s

existing and proposed infrastructure as this will reduce or

remove the environmental impacts of duplicated

infrastructure of the Bauxite Hills project. Gulf Alumina has

and will continue to seek cooperation on infrastructure

sharing subject to mutually agreed commercial

arrangements.

As detailed throughout the Supplementary Report, with Metro

Mining’s takeover of Gulf Alumina, the Bauxite Hills Project will

utilise the approved SRBP MIA and BLF rather than constructing

standalone MIA, BLF and RoRo infrastructure. The originally

proposed duplication of major infrastructure for the Project has

been completely avoided.

Further, Metro Mining will use the existing SRBP main haul road,

airstrip and accommodation facilities.

The use of the existing and proposed infrastructure as described

variously throughout the SEIS significantly reduces the project

specific and cumulative impacts.


26

Submitter

No.

Submission

Reference No.

Relevant EIS


14 14.2 1.7.2.5

Port of Skardon River - Far North Queensland Ports

Corporation Limited, trading as Ports North, is a company

Queensland Government Owned Corporation responsible

for the development and management of the declared Port

of Skardon River, as well as other ports in north

Queensland. The port limits for the Port of Skardon River

are shown in Figure 6-2. From this figure and similar spatial

data presented in the Skardon River Bauxite Project EIS it

appears that the proposed barge loading facility may not

be within Port limits and that the RORO is not within the

Port limits. As noted in Section 1.7.2.5 “The Port of Skardon

River is operated by Ports North and the subsequent Port

rules and the Project will apply to activities within the Port

limits”. It is therefore unclear how activities outside of the

Port limits will be regulated and controlled, especially those

activities directly upstream of Gulf Alumina’s proposed

wharf area.

Metro Mining will utilise the approved SRBP MIA and BLF to service

the Bauxite Hills Project. As such there is now no requirement to

extend the Port boundaries. Refer to Section 3.1.5 and Section 17.2

of the Supplementary Report.

14 14.3 2.6.1

Air Strip - There is one existing airstrip in the Skardon River

area, located on Gulf Alumina’s mining leases. Gulf Alumina

is supportive of shared infrastructure but notes that, as per

Section 2.6.1, Metro Mining is seeking approval for a

standalone project. Gulf Alumina therefore queries how

Metro Mining proposes to gain access to the Skardon River

area without an airstrip. It appears that Metro Mining

assumes it will use the existing airstrip. Therefore, the EIS is

not consistent in proposing duplication of some

infrastructure that could be shared, but not providing

duplication for the airstrip. If the Bauxite Hills project is a

standalone project, then the impacts associated with a

separate airstrip should be assessed as part of the EIS.

Metro Mining will utilise the approved SRBP airstrip and

accommodation facilities to service the Bauxite Hills Project. As such

there is now no requirement to build separate facilities.

Refer to Section 1.1 and 4.4 of the Supplementary Report.


27

Submitter

No.

Submission

Reference No.

Relevant EIS


14 14.4 2

Haul Roads on Gulf Alumina's Mining Leases - Gulf Alumina

notes that the Metro Mining have applied for infrastructure

mining leases for various haul roads, mine infrastructure

area, BLF and RORO.

On various maps (e.g. Fig 2-5), Metro Mining’s EIS shows

haul roads crossing Gulf Alumina’s mining leases. These

haul road crossings are not subject to any mining lease

applications. Whilst Gulf Alumina is supportive of

infrastructure sharing, haul road crossings of Gulf Alumina’s

mining leases are not required for Gulf Alumina’s project

(i.e. they are not shared infrastructure) and are located in

areas proposed for mining by Gulf Alumina.

The bauxite resources within Metro Mining’s mining lease

application 20689 (BH6 West) cannot be transported to

Metro Mining’s proposed barge loading facility without

crossing Gulf Alumina’s mining leases (ML 6025, ML 40069

and ML 40082) at some point. Therefore, if the Bauxite Hills

project is a standalone project, Gulf Alumina queries how

Metro Mining proposes to transfer bauxite from MLA

20689 (BH6 West) to the barge loading facility. If there is

some alternate route or means to transport bauxite from

MLA 20689 (BH6 West), the impacts of this should be

assessed in the EIS.

Refer to Section 1.1 of the Supplementary Report regarding the

acquisition of the SRBP. This negates the issue of requiring s316

Mining Leases across the SRBP.


28

Submitter

No.

Submission

Reference No.

Relevant EIS


14 14.5 2.8.5

Vessel Operations - Gulf Alumina notes that cooperation

with Metro Mining will be required, in conjunction with

Ports North and Maritime Safety Queensland, to ensure

safe and efficient operation of multiple barges and tugs

within the Skardon River and defined Port of Skardon River

limits. Whilst Gulf Alumina proposes 2 barges each

operating on 12 hour cycles, Metro Mining propose 6

barges, 5 tugs and floating cranes for transshipment of

bauxite (Section 2.8.5).

Gulf Alumina notes that the proposed tug and barge route

shown on Figure 19-29 intersects the proposed wharf

location for Gulf Alumina’s Skardon River Bauxite Project.

In the absence of an alternative tug and barge route for

Metro Mining’s Project, congestion is likely to inhibit both

Gulf and Metro operations.


acquisition of the SRBP.

14 14.6 2.8.6, 17.6.3

Skardon River Depth at Barge Loading Facility - Section

2.8.6 states that the barge draft will be 3.5m. Section

17.6.3 recommends an under keel clearance of 0.5m.

Therefore, the proposed barge draft plus under keel

clearance is 4m. In addition, the draft of tug boats for the

barges is not stated so these may be more or less than 4m

with under keel clearance. With 6 barges taking 4 hours

each, over a 24 hour cycle, to load 6000t on average, there

will be at least 3 barges berthed at the barge loading facility

during periods of low tide.

Figure 2-16 shows the bathymetry at the barge loading

facility. The upstream corner of the BLF is shown in water

ranging from 3m to 4m below LAT. As the barges require

depths of up to 4m, Gulf Alumina queries whether this

corner of the BLF will require bed levelling or dredging. If

required, then Metro Mining should provide an assessment

of environmental impacts from any required bed levelling

or dredging.




29

Submitter

No.

Submission

Reference No.

Relevant EIS


14 14.7 2

Downstream Moorings - Metro Mining have proposed tug

and boat moorings and floating crane moorings

downstream of the existing Port infrastructure and Gulf

Alumina’s proposed wharf (refer to Figure 2-3). Information

is not provided as to whether these moorings, barges

alongside moorings or barges manoeuvring to access these

moorings will interfere with Gulf Alumina’s proposed

barging operations in the Skardon River.



14 14.8 17.6.6.7

Maritime Safety Queensland - The final terms of reference

for the Bauxite Hills project require details of the adopted

assessment methodology for impacts on maritime

operations in accordance with the Maritime Safety

Queensland (MSQ) Guidelines for major development

proposals.

Section 17.6.6.7 provides a commitment to prepare the

management plans required by MSQ but does not present

any draft or finalised plans. As cooperation is required on

vessel traffic management, aids to navigation and ship

sourced pollution prevention, Gulf Alumina considers that

the plans required by the MSQ Guideline should be

prepared as part of the EIS process.



Metro Mining is in the process of finalising the marine management

plans in consultation with the RHM and Ports North, and in

accordance with the MSQ guidelines for major development

proposals. With the acquisition of Gulf Alumina and as the owner of

the SRPB, Metro Mining will effectively be the sole responsible party

for relevant management plans within the Skardon River. Additional

discussion regarding the preparation of management plans is

included in Section 17.5 and Section 21 of the Supplementary

Report.


30

Submitter

No.

Submission

Reference No.

Relevant EIS


14 14.9

6.7.1.1, 6.6.1,

Appendix B3

(Fig 2-60 and

2-61)

Mangrove and Seagrass Impacts - Section 6.7.1.1 states

that “Based on Metro Mining’s base case, the addition of

the SRBP presents a 30% increase in mangrove distribution

(0.2ha) due to mangrove clearing to facilitate the

construction of marine facilities”. These numbers appear to

be incorrect. The Skardon River Bauxite Project will clear

approximately 300 m2 (0.03 ha) of mangroves. The Bauxite

Hills Project will clear approximately 20 ha of mangroves.

Therefore, the addition of the Skardon River Bauxite

Project presents an increase in mangrove clearing of 0.15%.

Section 6.6.1, describing potential impacts on marine

habitats, does not present information on potential

propeller wash impact to seagrass beds shown in Fig 6-4, as

identified in Fig 2-60 and Fig 2-61 of Appendix B3.

The removal of the requirement for duplicated Project infrastructure

(i.e. BLF, RoRo and east-west haul roads) and use of the existing

north-south haul road has eliminated the original requirement to

clear areas of mangroves, saltmarsh and wetland habitats.

Therefore, it is not anticipated that there will be any significant

impacts to MNES fauna potentially associated with this habitat.

The potential impact of propeller wash on seagrass beds is based on

recent wave wake modelling carried out for the Project (see

Appendix E of the Supplementary Report) and is summarised in

Section 7.3.2 and Section 19.4 of the Supplementary Report.

Appendix E of the Supplementary Report is only relevant to the

small patch of seagrass associated with the cyclone moorings as the

originally proposed BLF and RoRo are now incorporated into the

approved SRBP port area.

In terms of cumulative impacts, the concurrent operation of the

SRBP and this Project was assessed as doubling the incidence of

propeller wash in the Skardon River. With the future amalgamation

of the two projects, with individual production targets of 5 Mtpa, it

is considered the combined annual shipping tonnage of 10 Mtpa is

unlikely to be sough or achieved, thereby decreasing the extent of

vessel traffic and potential shipping impacts. Cumulative impacts to

seagrass are discussed in Sections 7.8.1 and 7.8.2 of the



31

Submitter

No.

Submission

Reference No.

Relevant EIS


14 14.10 2.8.4

Product Stockpile - Section 2.8.4 describes that the area of

the two product stockpile areas is 120 m x 150 m = 18000

m2, with a maximum height of 18m and maximum storage

of 250,000 t (approximately 300,000 m3).

Based on Figure 2-4, the area of ‘product area 1’ is about

4000 m2 and the area of ‘product area 2’ is about 5000 m2,

providing a combined area of 9000 m2. With a stockpile

volume of 300,000 m3, that would require a minimum

stockpile height of approximately 35 m, and potentially

much higher as bauxite is not stockpiled in a cubic shape.

Gulf Alumina queries whether sufficient area has been

allocated for the bauxite stockpiles. If additional area is

required, then the impact of this additional area should be

assessed in the EIS. Gulf Alumina notes the MIA is located

between Gulf Alumina’s mining lease boundary and the

mangrove vegetation communities of the Skardon River

and therefore additional available area for the product

stockpile may be limited.


acquisition of the SRBP and Section 4.4 regarding the use of

approved SRBP infrastructure.

14 14.11 9.8.1

Buffer Zones - Section 9.8.1 states that buffer zones of

either 50m, 100m or 200m will be maintained around

watercourses for vegetation clearing. This does not appear

to be possible, given that the proposed mine infrastructure

area and haul roads are all within these buffer zones, as

indicated by the scale in Figure 2.4.

No mining will be carried out within the nominated buffers.

Metro Mining has been able to significantly expand the proposed

buffer zones through the utilisation of the approved SRBP

infrastructure and also through the relocation of the east-west BH1

haul road away from the sensitive wetland areas.

Where impact to buffer areas is unavoidable, these areas will be

subject to environmental offsets as per the Qld Environmental

Offsets Policy. Refer to Sections 7.7 and 8.5 of the Supplementary

Report.


32

Submitter

No.

Submission

Reference No.

Relevant EIS


15 15.1 10.7.3

Reference is made to the water being drawn from "the GAB

(Great Artesian Basin) aquifer" without providing a

description as to which aquifer of the GAB water is

proposed to be sourced to provide the main water supply

for mining purposes, which would enable accurate

consideration of extraction impacts on any potential town

water supplies in the area.


15 15.2 10.8.3

Reference is made to the Bulimba aquifer being present;

however it appears as though the Bulimba aquifer (a GAB

aquifer) is not present in this area as described by the

Great Artesian Basin Water Resource Plan. Department of

Natural Resources and Mines (NRM) is the administering

agency for the GAB Water Resource Plan and may have

requirements in this area, however a clear assessment of

the potential impacts for any town water supplies in the

area is desired by DEWS.

The Bulimba aquifer is present but does not form part of the GAB as

detailed in Section 10.2 and Section 4.3.4 of the Supplementary

Report.

16 16.1 10, Appendix

E1

There is inconsistency between the volumes of water

required for the project detailed in the EIS and the volumes

of water in the applications made to DNRM under the

Water Act 2000.

Refer to Section 4.3.6 of the Supplementary Report. Note that there

may be further changes in the required volume of water

commensurate with the utilisation of the SRBP infrastructure to

service the Bauxite Hills Project and the final design of the project

infrastructure.


33

Submitter

No.

Submission

Reference No.

Relevant EIS



E1

The EIS has not provided sufficient information to

demonstrate how the proposal’s required take and use of

water meets the requirements of the Water Resource

(Great Artesian Basin) Plan 2006 and Resource Operations

Plan including:

a) How the project will ensure: protection of spring flows

and baseflow; the continued use of existing entitlements;

intergenerational equity; ensuring a reliable water supply

from the plan area; water availability for new users;

artesian water pressure and sub-artesian water levels;

addressing the availability of alternative water supply; and

addressing the efficiency of water use.

b) The location or alternative location of the proposed

bores.

c) A bore monitoring program.

d) The volume proposed to be taken (either 378 or 600

megalitres) is not in accordance with the spring factor rules

(Chapter 3 of the Resource Operations Plan). Grant of this

water would result in the cumulative spring factors

exceeding 400 mm for the Cockatoo Creek and Dulhunty

River watercourse springs. A volume of approximately 188

megalitres from the current proposed bore location would

be in accordance with the spring factors.

e) The volume proposed to be taken (either 378 or 600

megalitres) is not in accordance with the criteria for

protection of existing entitlements (Chapter 4 of the

Resource Operations Plan).

a) Refer to Section 10.2 of the Supplementary Report. Metro Mining

has not been able to ascertain how the referenced spring factors

have been calculated but based on the existing model for the GAB

no significant impacts were identified based on a much higher

extraction rate than what is being proposed.

b) and c) Refer to Appendix I of the Supplementary Report for the

proposed groundwater monitoring bore locations.

d) Refer to Sections 10.2 and 10.4 of the Supplementary Report.

Metro Mining has not been able to ascertain how the referenced

spring factors have been calculated but based on the existing model

for the GAB no significant impacts were identified based on a much

higher extraction rate than what is being proposed.

e) Refer to Section 10.2 of the Supplementary Report in regard to

the permit application to extract 400 ML annually from either the

shallow or GAB aquifers. Refer to Section 6.1.4.6 of the

Supplementary Report in regard to groundwater monitoring and

management.


34

Submitter

No.

Submission

Reference No.

Relevant EIS



E1

Insufficient information is provided to assess the

requirements for underground water from the shallow

aquifer (Greater Western Declared Subartesian Area –

currently under moratorium for Cape York Water Plan

development).

Metro Mining has submitted a temporary water permit application

pursuant to s237 of the Water Act 2000 to DNRM for while the

moratorium is in place. Information required to assess this

application has been submitted through a separate approval process

to DNRM. Refer to Section 4.3.4 of the Supplementary Report in

regard to the application process.

Refer to Sections 10.6.5 and 10.7.2 of the EIS in regard to the

modelling and identification of potential impacts to the shallow

aquifer.

16 16.4 1

Two proposed east west linkage hauls roads are not

included within the mining lease application area. The

roads overlap the adjacent mining tenement however

consent from the adjacent mining tenement lessee for the

haul roads has not been demonstrated. Under the

Queensland Vegetation Management Framework, the

Sustainable Planning Regulation 2009, Schedule 24, Part 1,

Item 6 resource activity exemption is not satisfied. These

haul roads include assessable vegetation.

Given the acquisition of Gulf Alumina by Metro Mining, consent can

now be assured across the tenements as they will be operated by

the same operator as an amalgamated operation.



16 16.5 1

In the event that works proposed to be undertaken in tidal

waters of the Skardon River are assessable under the

Sustainable Planning Act 2009, owners consent will be

required for a properly made application.

Metro Mining is applying for State Owned Land consent for the

cyclone moorings and tidal gauge. Note that this is only required for

land outside of the Mining Lease. Refer to Section 3.1.1 and Section

3.1.6 of the Supplementary Report.


35

Submitter

No.

Submission

Reference No.

Relevant EIS


16 16.6 5, Appendix E1

The Guideline for the Environmental Assessment of

Subterranean Aquatic Fauna recommends a desktop review

for projects, and where the presence of subterranean

aquatic fauna (stygofauna) is likely, a pilot survey must be

carried out to determine the local presence or absence of

stygofauna.

The proponent has assumed that the groundwater

environment between the Skardon River Project and the

Bauxite Hills Project is similar. However the underground

environment in coastal areas can be highly variable over

short distances and it is possible that the distribution of

stygofauna species is quite different between the two

project areas.

Refer to Section 6.1.4 of the Supplementary Report describing the

results of stygofauna surveys for the SRBP EIS, part of which

included sites within the Bauxite Hills Project area.

16 16.7 Appendix E1

The proponent has identified Great Artesian Basin (GAB)

springs more than 30km east of the project area, but has

not described the potential for a cumulative impact at the

GAB springs from the proponents’ GAB take (400ML, p3-3),

and the cumulative take for other projects, of water from

the GAB.

Impacts to the GAB springs are discussed in Sections 10.2 and 10.5

of the Supplementary Report and Section 3.4.2 of Appendix E1 of

the EIS with specific reference to the modelling study undertaken by

(DSITIA 2014).

16 16.8 Appendix E1

The proponent has not identified all Groundwater

Dependent Ecosystems (GDEs) in the project area (see

comments below).

Refer to Section 10.3 of the Supplementary Report and Section

10.6.3.5 of the EIS.

16 16.9 Appendix E1

Table 3-4 (p38) contains statements that effects are

negligible therefore impacts are unlikely.

Disturbing existing ecological equilibria even by small

amounts may impact an ecosystem. Without knowledge of

system processes and thresholds, assumptions that impacts

are unlikely cannot be made.


10.6.3.5 of the EIS.

16 16.10 Appendix E1

Figure 2-22, Groundwater Dependent Ecosystems, only

displays GDEs reliant on surface expression of groundwater

(Type 2 GDE). The GDE mapping should also identify Type 3

GDEs, as this mapping is also available from the GDE Atlas.

Type 1 GDE mapping has not been carried out for the Atlas,

so is not available except from other sources (see below).


10.6.3.5 of the EIS in regard to GDEs. Refer to Section 6.1.4 of the

Supplementary Report in regard to stygofauna.


36

16 16.11 5, Appendix E1

The following sentence in the groundwater technical report

is ambiguous:

‘These is not unexpected as the Type 1 aquifer and cave

ecosystems where groundwater-inhabiting ecosystems

reside were not identified within the project area.’

The GDE Atlas has indicated there is no data on Type 1

GDEs available in the project area; however other sources

of data are available.

Please note, Type 1 GDEs (p6 GDE toolbox part 1,

Australian Government, 2011) are typically found in karst

and fractured rock ecosystems as well as saturated

(consolidated and unconsolidated) sedimentary

environments, including the hyporheic zones of rivers,

floodplains and coastal environments, i.e. alluvium:

Figure 2-4 (Surface Geology) identifies Quaternary

alluvium as porous. Additionally the report identifies

other porous formations (kaolinite, bauxite, ironstone,

siltstone, valley fill sands). These formations should all

be identified and discussed as potentially providing an

environment for Type 1 GDEs.

Please also note, Regional Ecosystem mapping has

identified ecosystems developed on Landzone 3 (see

table below). This landzone is broadly described as

‘recent Quaternary alluvial systems’.

Regional Ecosystem Mapping of Landzone 3 (from section

5.5.4 of the Terrestrial Freshwater ecology report, p5-27):

3.3.9 Lophostemon suaveolens open forest on streamlines,

swamps and alluvial terraces

3.3.12 Melaleuca quinquenervia open forest associated

with scattered coastal swamps

3.3.14a Melaleuca saligna +/- M. viridiflora, Lophostemon

suaveolens woodland on drainage swamps

3.3.22a Corymbia clarksoniana or C. novoguinensis

woodland on alluvial plains

3.3.49b Melaleuca viridiflora low open woodland on low

plains


10.6.3.5 of the EIS in regard to GDEs.

Refer to Section 6.1.4 of the Supplementary Report in regard to

stygofauna.


37

Submitter

No.

Submission

Reference No.

Relevant EIS


3.3.60a Themeda arguens, Dichanthium sericeum closed

tussock grassland on marine plains

3.3.64 Baloskion tetraphyllum subsp. meiostachyum open

sedgeland in drainage swamps in dune fields

17 17.1

As stated in our review of the Terms of Reference for the

project in January/February 2016, the project is not located

near any NPSR interests, and therefore NPSR has nil

comment to make.

No response to this comment is required.

18 18.1 15.2.2

For the purpose of supporting future Cultural Heritage

assessments and management within the Bauxite Hills

Project area, in particular the areas adjacent to Mining

Lease 7024, we wish to provide the below information on

the generalised cultural heritage landscape encountered

through previous cultural heritage work undertaken on the

ML 7024 area.

Metro Mining appreciates the additional information that has been

provided to better understand the cultural heritage values in the

region. No further response to this comment is required.

18 18.2 15.2.2

Previous cultural heritage work has identified the following

cultural heritage sites in areas adjacent to the Bauxite Hills

Project area:

The areas surrounding the branches of the Skardon

River contain numerous stone artefact and culturally

modified tree sites

The areas surrounding the branches of Namaletta Creek

contain a number of shell midden sites, historic landing

areas, stone artefacts, and culturally

modified tree sites.



38

Submitter

No.

Submission

Reference No.

Relevant EIS


18 18.3 15.2.2

Previous cultural heritage surveys have facilitated the

development of the below predictive statements in regards

to the cultural heritage landscape:

A moderate density of culturally modified trees from

the collection of native honey (sugar bag) are likely to

occur - predominately located within 1 km of existent

or remnant waterways.

A moderate to high density of stone artefacts (n=50-

500) are likely adjacent to rivers, creek lines,

waterholes, and swamps. These will typically occur on

raised gravel ridges.

A very low density of isolate artefacts or low density

scatters {n= <5) may occur on the bauxite plateau.

Historic remains from early mining exploration and the

cattle industry are likely to occur on prominent access

ways.

A low to moderate density of shell midden sites may

occur within coastal zones.

Metro Mining appreciates this information being provided and

highlighting potential areas of cultural significance.

The utilisation of the approved SRBP infrastructure to service the

service the Bauxite Hills Project significantly reduces the risk of

disturbance to cultural heritage in the vicinity of the Skardon River.

Given Metro Mining has an executed CHMA in place with the

relevant Aboriginal parties that include protocols for undertaking

surveys and managing Indigenous Cultural Heritage no update to the

information included in the EIS is proposed.

19 19.1

A summary of some key concerns raised in Part A:

The EIS provides general information on the location

and construction of various infrastructure but does not

confirm its final preferred design and location

Duplication of infrastructure

Impacts on High Ecological Significance (HES) wetlands

The EIS proposes local water quality guidelines and

limits in the draft EA that have not been derived in

accordance with national and state water quality

guidelines (DEHP 2013; ANZECC 2000)

The offsets strategy requires further discussion to give

EHP confidence that a conservation outcome can be

achieved for the impacted matters

Metro Mining notes the key concerns that have been raised. These

concerns are addressed in our responses below.


39

19 19.2 1.6.1, Table 1-

11, Table 1-14

A granted EA for the proposed project would allow the

proponent to mine bauxite under schedule 2A (ERA 11,

particular resource activities) of the Environmental

Protection Regulation 2008 (EP Regulation). The EA would

also cover the following activities that are directly

associated with, or facilitate or support the mining

activities, and which would otherwise require approval

under the EP Act as ‘prescribed environmental relevant

activities (ERAs)’ listed under schedule 2 of the EP

Regulation.

Whilst the EP Regulation notes some ERAs exclude

resource projects, the activity must still be considered by

EHP and listed as an authorised ERA on the EA if the activity

is to occur on the lease. If these are not listed on the EA,

the proponent would not be able to conduct the activity

lawfully. For example, as the mining activity is a commercial

activity, any ancillary activities to this are also classed as

commercial. As such, any maintenance and repair of boats

(barges) on site would be classed as commercial boat

maintenance and repair.

Based on the information provided in Table 1-11 and Table

1-14 of the EIS, some of the prescribed ERAs and some of

the notifiable activities have not been included. For

completeness, the following ERAs would need to be

considered in the EA for the proposed project:

ERA 8(3) – Chemical storage - storing 500 m3 or more of

chemicals of class C1 or C2 combustible liquids under

AS 1940 or dangerous goods class 3

ERA 33 – Crushing, milling, grinding or screening more

than 5000t of material in a year

ERA 49 - Boat maintenance and repair – Operating, on a

commercial basis, a boat maintenance or repair facility

for maintaining or repairing hulls, superstructure or

mechanical components of boats or seaplanes.

ERA 50(1)(a) – Loading or unloading 100t or more of

minerals in a day or stockpiling 50,000t or more of



The removal of the BLF, RoRo and MIA for the Project, and

utilisation of the SRBP infrastructure, has significantly changed the

activities that will be undertaken as part of the Project, and

therefore changed the ERA approvals being sought.

Section 3.1.2 of the Supplementary Report discusses the ERA’s

associated with the Bauxite Hills Project and the SRBP. Notifiable

Activities are discussed at Section 3.1.3.


40

Submitter

No.

Submission

Reference No.

Relevant EIS


minerals within 5km of the highest astronomical tide or

1km of a watercourse

ERA 50(2) – Loading or unloading 100t or more of bulk

materials in a day or stockpiling bulk materials

ERA 63(1)(b) – Sewage treatment or operating a sewage

pumping station with a total design capacity of more

than 40 kL in an hour (100 to 1,500 equivalent persons

with treated effluent discharged through an irrigation

scheme)

For completeness the following notifiable activities,

prescribed under schedule 3 of the EP Act, would also need

to be authorised under the EA as part of the proposed

project:

notifiable activity 1 – abrasive blasting

notifiable activity 7 – chemical storage

notifiable activity 20 – landfill

notifiable activity 23 – metal treatment or coating

notifiable activity 27 – pest control

notifiable activity 29 – petroleum product or oil storage

notifiable activity 37 –waste storage.


41

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.3 1.6.1, 1.7.3.2,

Table 1-11

Section 1.6.1, 1.7.3.2 and Table 1-11, do not identify the

need for the applicant to acquire an operation works (tidal

works) approval for the installation of cyclone moorings

under the Sustainable Planning Act 2009 (SPA). If any

moorings or other proposed tidal works are proposed in

Queensland State waters outside the mining lease area, the

EIS should outline the development approval requirements

in accordance with the SPA.

The relevant assessment trigger is:

Operational work made assessable under schedule 3, part

1, table 4, item 5, other than—

(a) prescribed tidal work in a canal; or

(b) work that is for the installation, maintenance or repair

of overhead cables or lines that extend over tidal water; or

(c) work that is for the construction, installation,

maintenance or repair of pipelines, cables or lines under

tidal water.

Note: Schedule 3 Part 1 Table 4 Item 5 – For tidal works or

works within a coastal management district

Operational work (other than excluded work, work that is

self-assessable development, PDA-related development or

work carried out on a premises to which structure plan

arrangements apply) that is-

(a) tidal works

(b) any of the following carried out completely or partly

within a CMD

a. interfering with quarry material on State coastal land

above the high water mark

b. disposing of dredge spoil or other solid waste material in

tidal water

c. constructing an artificial waterway

d. removing or interfering with coastal dunes on land other

than State coastal land that is in an erosion prone area



42

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.4 2.1

The EIS indicated that operations would be undertaken by a

contractor and not necessarily by Metro Mining itself.

Contractors are not included as part of the EIS process

when important commitments are made. It is important

that the proponent ensures that contractors would

implement the commitments.

The draft EMP at Appendix K of the EIS, specifically Table 3-1,

outlines the roles and responsibilities of site personnel. Metro

Mining will ensure contractors will implement commitments

outlined in the EA for the Project.

19 19.5

The EIS provides general comments on location and

construction of various infrastructure, however does not

provide final details on the preferred design and location of

the infrastructure at the project site (e.g. accommodation

camp, sewage treatment plant (STP), irrigation area,

composting area, bioremediation pad/land farm, borrow

pits, sediment basins, power transmission lines, water

wells). This information is important to inform EHP of the

location of proposed infrastructure and proximity to and

potential impact on EVs. Sufficient information needs to be

provided in the EIS for EHP to finalise EA conditions for the

proposed project.



The updated project description is discussed at Section 4 of the


19 19.6 2.2.4

Section 2.2.4 refers to Figure 2-5 (Mining lease tenements

and cadastre) for general arrangement of mine area,

including location of port area. However it does not

reference Figures 2-3 (Project infrastructure) and Figure 2-4

(Mine infrastructure area layout) that show the proposed

disturbance areas for mine pits and infrastructure (e.g.

accommodation camp, STP and associated irrigation area).




43

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.7 2.3.1, 2.3.2,

2.6.1

The EIS states that the proponent is seeking approval for a

standalone project, however some primary options for the

project (haul road construction/operation and airstrip

utilisation for access) depend on agreements with Gulf

Alumina Limited (Gulf Alumina). The EIS does not provide

details of alternative options that may form part of the

projects approval footprint, if agreements with Gulf

Alumina are not reached. Where there is uncertainty

around key project details, alternative options should be

proposed and presented as a backup to the primary option.

The EIS states that the agreement with Gulf Alumina to

construct two haul roads to connect BH6 West mining

areas to the projects main haul road on MLA100047 are not

essential to the project, however no alternative options

have been proposed. The haul roads planned and

illustrated in Figure 2-5 would intersect Gulf Alumina

mining areas and/or rehabilitation areas depending on the

timing of haul road construction.

The EIS states that the primary site access option for

contractors and staff is to use the Gulf Alumina airstrip,

however this is based on achieving an agreement with Gulf

Alumina. A secondary option of transport via sea is briefly

mentioned; however there are no details about how this

would affect the project if this option is were used.



Given the acquisition of Gulf Alumina by Metro Mining, consent can

now be assured across the tenements and for all operational

requirements as they will be operated by the same company as an

amalgamated operation.




44

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.8 2.6.1.1

The infrastructure identified in Section 2.6.1.1 does not

align with the information provided in Figure 2-4 (Mine

infrastructure area layout) which notes that the MIA would

also include:

fuel farm

sediment traps grill/grate

RoRo facility

recycling storage

sediment trap

laydown

waste storage

material laydown area

product area 1 and 2

hopper

conveyor.

In addition, section 2.6.1.1 indicates that there would be

multiple workshops however Figure 2-4 only indicates

there would be one. It is possible that some of the

infrastructure noted in section 2.6.1.1 and Figure 2-4 are

the same, but with different names. However, this is not

clear. It is assumed that the following infrastructure not

described in 2.6.1.1 or Figure 2.4 may also be required for

the project:

truck/vehicle wash down facilities

hazardous material/chemical storage area.


acquisition of the SRBP. As detailed throughout the Supplementary

Report, with Metro Mining’s takeover of Gulf Alumina, the Bauxite

Hills Project will utilise the approved SRBP MIA and BLF rather than

constructing standalone MIA, BLF and RoRo infrastructure. The

originally proposed duplication of major infrastructure for the

Project has been completely avoided.




45

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.9 2.6.1.2

The Skardon River is a high environmental values (HEV)

environment, with the fuel farm proposed to be located in

very close proximity to the river. Due to the isolation of the

site and the potential to impact on HEVs identified in

Skardon River, the EIS should include a commitment that

the proponent would act as first responder to an incident.

The EIS should make a specific commitment that would

ensure that the fuel farm and storage facility is specifically

noted as a risk in emergency response plans, oil spill

contingency plans and first-strike oil spill response plans.

These plans are to be developed in discussion with officers

from Maritime Safety Queensland to ensure that the first

response adequately addresses any potential impacts on

environmental values. The response should include vessel

operation and accidental releases of storage as a credible

spill scenario and should include 1 ML of spill in one

scenario.




Hills Project will utilise the approved SRBP MIA (including the fuel

farm) and BLF rather than constructing standalone MIA, BLF and

RoRo infrastructure. The originally proposed duplication of major

infrastructure for the Project has been completely avoided.



Ports North is responsible for ensuring that an adequate first-strike

oil spill response capability is maintained within the Port of Skardon

River. MSQ is designated as both the Statutory and Combat Agency

for spills that may affect Queensland coastal waters but are outside

of the Port of Skardon River waters.

Notwithstanding the above, Metro Mining will be adequately

prepared to immediately respond to spills.


46

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.10 2.6.1.2

All fuels and chemicals should be stored in a containment

system and managed in a way that prevents release of such

fuels and chemicals to land or waters. All containment

systems for fuels and chemicals should be constructed and

maintained so as to be sufficiently impervious to:

allow retention and recovery of any materials being

stored within the system

prevent contamination of soil or any waters.

Further information is required to clarify details about the

fuel farm/storage area proposed in the MIA.





farm and hazardous material storage area) and BLF rather than






19 19.11 2.6.1.2

Bulk hazardous fuel should be sited outside of the 100 year

average recurrence interval (ARI) flood event to limit the

risk of fuel spillage and releases during flooding. The EIS

does not indicate that this would be the case.












47

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.12 2.6.3

Section 2.6.3 of the EIS outlines construction methods for

the RoRo facility. However, it is unclear whether the ramp

would need to be constructed in the dry season and

whether the impacts of creating this dry area, including

impacts to intertidal benthos and mangroves by excavators

and dozers, are included in the calculations of impacts in

later chapters.











19 19.13 2.7.4.1

It is unclear if the EIS includes impacts likely to arise from

construction methods, such as the use of a self-elevating

platform (SEP) (for example direct impacts to the benthos

or indirect impacts from shading), taking into account the

need for the SEP to be relocated during construction to

service several locations.












48

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.14 2.6.1.3

The EIS proposes the construction of borrow pits to supply

material for the haul roads and have proposed the location

of the borrow pits to be adjacent to the haul roads on

MLA100047 and MLA100048. It is assumed that borrow

pits would be required on Gulf Alumina’s MLs for haul

roads to BH6 West. Figure 2-15 and Table 2-6 do not

accommodate the requirement for borrow pits. There

appears to be limited area for borrow pits adjacent to the

haul roads and the feasibility of the construction of borrow

pits adjacent to the haul roads has not been adequately

explained or justified.

Erosion and sediment controls would be required to

manage these pits and they should be located outside of

High Ecological Significant (HES) wetlands.

Metro Mining will utilise the existing borrow pits associated with the

SRBP.

Where additional borrow pits are required they will be positioned as

close as practicable to the construction activities and within

identified haul road corridors. Metro Mining does not propose to

update Table 2-6 as this relates to road design.

Metro Mining commits to implementing ESC measures consistent

with IECA Guidelines.

19 19.15 2.6.1.3

The proponent has proposed construction of haul roads

between active mining areas and the MIA. There is

potential for flooding during heavy rainfall events and it is

not clear in the EIS how flooding of the haul roads and the

potential environmental impacts of this would be managed.

The haul road between BH1 and BH6 is also noted to cross

three creek systems. Insufficient information has been

provided on how the haul road would be constructed

across these creek systems and how the road would be

constructed to minimise impacts to water flow and release

of contaminants to waters.

Metro Mining will utilise the existing SRBP main haul road to access

the SRBP MIA and thereby avoiding the need to construct the

originally proposed north – south haul road.

Metro Mining has also relocated the east – west BH1 haul roads to

avoid the HES wetlands.

Sections 11.3 to 11.7 of the Supplementary Report discuss potential

impacts to haul roads associated with flooding.


49

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.16 2.6.3

There is an inconsistency between the commentary and the

site plan about whether the mangroves around the RoRo

facility would be trimmed or cleared. The EIS states: “There

is a requirement to clear mangroves to provide

construction clearance width of 15m to allow for a ramp

width of 7.2m”. The plan states “mangroves in this area to

be trimmed”. Clearing of the mangroves, rather than

trimming, would expose mangrove mud and could be a

source of sediment and potentially PASS material which

would need to be managed.

Metro Mining no longer proposes to construct the standalone RoRo

as it will be utilising the approved SRBP BLF and MIA to service the

Bauxite Hills Project. As detailed throughout the Supplementary







19 19.17 2.6.6.2

The EIS proposes to pump water from shallow and/or deep

aquifer bores for water supply, and store the water in

tanks. No information has been provided in the EIS on the

location of water supply bores, amount of water expected

to be pumped from each bore and location of water

storage tanks (for both mining activities and potable water

supply).


19 19.18 2.7.1

Raw water storage at the MIA and water storage dam have

been mentioned in the list of mine infrastructure. Raw

water storages have been indicated on Figure 2.21, but

have not been described in the EIS not in section 2.6.1.1 –

Mine Infrastructure.

Refer to Section 4.3.6 of the Supplementary Report..


50

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.19 2.7.6.2

This section notes that construction materials available at

the site is assumed to be suitable as it is the same material

used previously on site for the construction of the existing

haul road and existing air strip.

The Bauxite Hills Project is a proposed greenfield site

project with no existing infrastructure currently on site. If

the above description is referring to the Skardon River

Bauxite Project’s existing infrastructure then this should be

made clear, as it could be interpreted that there is existing

infrastructure already located at the Bauxite Hills project

site. Also, the existing haul road and airstrip at Skardon

River are made from high grade bauxite built during kaolin

mine operations – and are proposed to be mined during

the Skardon River Bauxite Project operations.

Hence, it is not clear if the bauxite resource would be used

to build haul roads. The description does not provide a

contingency in the event that the material is not suitable

for use in the haul road construction.

The Project Description (Chapter 2) and each following chapter of

the EIS states that the Project is a greenfield project. This has now

changed as a result of the acquisition of Gulf Alumina by Metro

Mining and the utilisation of approved SRBP infrastructure to service

the Bauxite Hills Project. Refer to Section 1.1 of the Supplementary

Report regarding the acquisition of Gulf Alumina.

Metro Mining will now utilise the existing SRBP borrow pits to

support the construction of the east – west BH1 haul road. This

material has been used extensively across the SRBP area for the

construction of the haul roads and airstrip.

19 19.20 4.8

The final rehabilitated landform for each of the three

mining pit areas is shown in Figure 4-20 to 4-23.

A final land use plan/map/illustration has not been

provided to address the rehabilitation and

decommissioning requirements of the project.

Reference sites need to be identified, mapped and justified

as to why they are suitable to assist the rehabilitation

completion criteria in Table 4.17.

The proposed rehabilitation approach is to progressively restore the

site with the pre-existing vegetation communities. Hence, the final

land use will be native vegetation. A conceptual illustration of the

proposed rehabilitation is provided in Figure 4-16 of the EIS.

Final predicted landforms following mining and rehabilitation are

already presented for each mining area in Figures 4-18 to Figure 4-

23 of the EIS. Refer to Section 4.8.4 of the EIS which discusses the

proposed decommissioning approach for the Project.

19 19.21 4.8.1.4

It is possible that some on land treatment of ASS would be

required given the possible disturbance of ASS during

causeway and construction of the RoRo facility. However,

the location of ASS treatment areas for ASS disturbed on

land is not indicated on any mapping.

The utilisation of the approved SRBP MIA, BLF and existing haul road

to access the MIA, in addition to the relocation of the east – west

BH1 haul road has significantly reduced the likelihood of impacts

from ASS.

Refer to Sections 5.5 and 5.6 of the Supplementary Report.


51

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.22 4.8.3.3 The proposed location of the topsoil or overburden

stockpiles is not presented in the EIS.

Apart from very first cut, topsoil and overburden stockpiles will be

retained in pit. Topsoil for other disturbance areas e.g. east – west

BH1 haul road will be retained on the perimeter of the indicated

disturbance areas. Appropriate management has been described in

Sections 4.8.3 and 4.8.4 of the EIS. Refer to Appendix A3 of the EIS

for ESC measures proposed for the Project during the construction

phase.

19 19.23 4.5.1.5,

4.6.1.3, 4.8.1.4

The EIS provides details including indicative potential acid

sulfate soils (PASS) mapping, current design plans and ASS

laboratory results. Based on that information it is possible

to estimate the potential area and/or volume of ASS that

would be disturbed in order to inform management

measures and the subsequent impact assessment. The haul

road, MIA and port infrastructure are located on the border

or within marine sediments that are highly likely to be ASS.

Disturbing ASS is considered a high risk activity and

therefore the impact assessment should be more definitive

in terms of clarifying the likely areas of ASS, potential

impacts and management measures. The land chapter

states that small areas of the project may disturb ASS;

however the EIS has not provided any estimation of the

potential areas of ASS that would be disturbed based on

indicative PASS mapping, current design plans and ASS

laboratory results.

Given the size and configuration of mining leases

(ML100051 & ML100048), there appears little opportunity

for the haul road, MIA, BLF and RoRo facility to avoid or

minimise disturbance of ASS. The mitigation measures

proposed are brief, overarching and not focused on the

likely impacts the project poses on the environment.




from ASS.



52

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.24 4.6.1.2

Soil surveys and testing have confirmed that significant

differences in the erosion potential exist between various

soil units. An accurate erosion hazard assessment therefore

should include different soil erodibility factors that reflect

the soil unit’s actual risk of erosion. It appears that the soil

erosion assessment that has informed the conceptual

Erosion and Sediment Control Plan (ESCP) has used the

same soil erodibility factors across all sub catchments,

despite the soil testing and survey work identifying

significant differences between the various soil units.

The number 0.036 used in the RUSLE calculation is the worst case

scenario and includes a 20% safety factor. Emerson Class testing

identified the majority of the soils had a moderate (Emerson Class 4)

dispersive capacity with two samples showing slight (Emerson Class

5) and negligible (Emerson Class 6) dispersive capacities. Given the

worst case scenario was applied to the calculation across the site no

further change to the ESCP is proposed.

19 19.25 4.8.1.3

Important parts of the ESCP appear to be absent including:

wet season erosion and sediment control planning and

implementation;

mining pits are not included as a specific area for ESC

planning and is not considered a higher risk area.

Stockpiles are proposed to be relocated to pits prior to

the wet season posing a risk for sediment mobilisation;

the ESCP is mainly based on the erosion hazard

assessment and does not factor sensitive environments

into its sediment control planning. For example there is

no discussion around the sediment control

requirements around Big Footprint Swamp as a result of

mine extraction activities within close proximity.

Refer to Section 5.3 and 5.4 of the Supplementary Report and

Appendix E of Appendix C of the EIS. Appendix E specifically refers to

the ESC processes to be assessed prior to the commencement of

each wet season.


53

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.26 4.8.3.2

The EIS has undertaken a research review and have

referred to various case studies which indicate that a return

to pre-existing EVs is achievable. There is no explanation of

how these learnings would be applied to the project. The

outcomes specified in the research paper were a result of

specific rehabilitation methods or experiments. The

rehabilitation proposal for the Bauxite Hills project is

general and does not provide specific details about how

rehabilitation would be undertaken to achieve the results

stated in this section.

This is incorporated throughout the rehabilitation section, including

in the discussion around topsoil management (that was identified as

a major issue through Rio Tinto experience and the Gove report),

suitable species to use in rehabilitation, suitable seed mixes to be

used, also suitable fertiliser as required, the range of uses for

cleared vegetation to be used back within the rehabilitation areas -

rather than just windrowing and burning which is standard practice,

Metro Mining is planning to include non-standard, leading practice

methods (e.g. for re-standing a small number of large hollow bearing

trees, placing some cleared vegetation back over topsoiled areas for

immediate habitat and seed stores and the proposed use of

composted material to increase the naturally limited soil volumes in

the region). A commitment to monitoring the success of the

rehabilitation is also included and it is through this monitoring

regime that change based on success rates can be applied to the

rehabilitation program. Metro Mining will continue to consult with

other Cape York operators to ensure best practice rehabilitation in

undertaken at site. No amendment to the information already

included in the EIS is proposed.


54

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.27 4.8.3.2

The EIS did not consider a number of important indicators

in Table 4-17 that would constitute measurable and

quantifiable indicators of rehabilitated/reference

ecosystem condition and functionality. These include:

tree canopy height and cover

sub-canopy height and cover

proportion of large trees

shrub canopy cover

grass cover

course woody debris

shrub and grass species richness

non-native plant cover

nutrient cycling

soil quality, stability and infiltration

The QLD government has a bio-condition assessment

framework that can be referred to when considering

indicators of ecosystem condition. Furthermore landscape

functional analysis concepts can be referred when

considering indicators of ecosystem function.

Metro Mining has proposed rehabilitation criteria in the EIS that are

appropriate to meet the EHP guidelines for rehabilitation on mines

e.g. the four general rehabilitation goals require rehabilitation of

areas disturbed by mining to result in sites that are:

Safe to humans and wildlife;

Non-polluting;

Stable; and

Able to sustain an agreed post-mining land use.

Metro Mining believes the criteria that have been proposed meet

these requirements and are focussed on successful return of a

natural ecosystem approaching existing conditions e.g. greater than

50% of woody biomass (basal area) to be existing native dominant

tree sp. / stem densities and native species richness, natural seeding

and suckering. The environmental monitoring of rehabilitation areas

will incorporate tree heights etc., however, they are largely

irrelevant if the rehab is made of local native species, is not eroding,

is self-seeding, has a suitable native sp. richness and can be

maintained after fire. Similarly, the geotechnical stability

commitments ensure the stability of the rehabilitated land. Metro

Mining are rehabilitating a mine not doing a bio-condition

assessment. The criteria Metro Mining proposes are specifically

directed to show compliance with the necessary guidelines. No

update to the information provided in the EIS is proposed.

19 19.28 4.8.3.4

Topography maps of pre and post mining landscape

elevation are provided in this section however there are no

maps showing the difference in surface elevation pre and

post mining. Such mapping is beneficial at interpreting the

change in the landscapes hydrology.

Figures 4-18 to 4-23 of the EIS show the original topography to the

modelled mined topography and original topography to the

modelled (predicted) rehabilitated topography for each mine pit,

which together show the difference in surface elevation pre and

post mining. As no changes to the mine plan have occurred since the

release of the EIS no update to the information included in the EIS is

proposed.


55

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.29 4.8.3.4

The EIS predicts a 3m post mining lowering of the

landscape, on average, which means in some cases it would

be greater or lesser than 3m. As stated above, surface

elevation is a critical landform attribute that dictates the

hydrology and vegetation communities within the Skardon

River area. Surface elevation is therefore also critical at

dictating rehabilitation outcomes for the project.

Metro Mining has already addressed the issue of the lowering of the

land surface and potential for changes to vegetation in response to

this in the EIS. Metro Mining has also provided pre and post mining

landforms. The EHP comment is noted. No update to the

information provided in the EIS is proposed.

19 19.30 4.8.3.4

The EIS states that the mangrove vegetation will be allowed

to naturally recolonise the area and if necessary, the

proponent will commit to undertake appropriate mangrove

revegetation activities.

A reliance on natural re-colonisation of mangroves, rather

than committing to active rehabilitation of cleared

mangroves, is not considered best practice environmental

management and would constitute the minimum action

within the mining rehabilitation hierarchy.

Metro Mining will utilise the approved SRBP MIA, BLF and main haul

road to service the Bauxite Hills Project. In addition Metro Mining

has relocated the east – west BH1 haul road outside of HEV

wetlands and mangrove habitat. Consequently, no mangrove habitat

rehabilitation is anticipated to be required.


56

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.31 4.8.3.4

The project description states that all waste would be

shipped out from the project site but does not mention bio-

remediation pads as a proposed activity. Bio-remediation

pads can be a source of contaminated materials and a risk

to environmental values. Consideration of potential

impacts and management measures is required in the EIS.

Metro Mining will remove waste from the Bauxite Hills site as

proposed in the original EIS but will assess the opportunity to utilise

the approved SRBP landfill for inert waste. Should any change to the

existing landfill approval for the SRBP be required, this will follow

the required EHP approval process. Regulated waste will still be

removed from site as described in the EIS.

Metro Mining is not proposing specific bio-remediation pads, rather

any hydrocarbon contaminated soils will be managed in the

approved SRBP MIA.

A biosolids management area is no longer required as Metro Mining

will utilise the approved SRBP biosolids management area to service

the Bauxite Hills Project.

The waste composting area will be appropriately sized, the pad floor

will be lined or constructed with impermeable material and

appropriately bunded to prevent further contamination.


19 19.32 2.5.6.2

Section 2.5.6.2 of the EIS proposes to make arrangements

to share infrastructure as it would be advantageous for the

project. There are significant impacts proposed on the

Eucalyptus tetradonta woodland, HES wetlands, mangroves

and possibly seagrass beds associated with the project.

EHP is of the view that the impacts could be avoided or

significantly reduced if infrastructure is combined with the

adjoining project. EHP has had discussions with Gulf

Alumina and Metro Mining expressing such concerns. Given

these impacts are potentially avoidable; EHP considers that

they would not be acceptable impacts unless it can be

demonstrated that there is no other alternative available to

having the infrastructure in the proposed location.



utilise the approved SRBP accommodation camp, MIA (including the

fuel farm and hazardous material storage area) and BLF rather than




Refer to Sections 1.1 and 4 of the Supplementary Report.


57

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.33 5.4.5, of 5-19

The sampling of freshwater aquatic flora and fauna was

inadequate. Limited data creates uncertainty and is unable

to account for natural variation. Additional sampling is

required to adequately assess the seasonal variation in

aquatic communities.

Additional aquatic ecology sampling has been undertaken during

June 2016. An updated description of aquatic ecology values of the

area has been presented in Sections 6.2 and 6.3 of the

Supplementary Report. The Early Dry Season Aquatic Ecology

Technical Report is located in Appendix B of the Supplementary

Report.

19 19.34 5.7.1.15, 5.9

Haul Road crossing impacts on aquatic ecosystems have

not been adequately addressed in general. In particularly

there is no mention of the potential direct and indirect

impacts from the haul road linking BH6 and BH1.

Metro Mining will utilise the existing SRBP mail haul road to the MIA

and as such the originally proposed haul road between BH6 east and

the MIA is no longer required.

Additional aquatic ecology sampling has been undertaken during

June 2016. An updated description of aquatic ecology values of the

area has been presented in Section 6.2.2 and 6.2.3 of the

Supplementary Report. The Early Dry Season Aquatic Ecology

Technical Report is located in Appendix B of the Supplementary

Report. Potential impacts to aquatic ecology values are presented in

Section 5.8.1.16 of the EIS and updated where considered necessary

in Section 6.2 to Section 6.10 of the Supplementary Report. It is

important to note that Metro Mining has relocated the east – west

BH1 haul road outside of HEV wetland areas to further avoid

impacts to these sensitive wetland systems.

Further discussion around the design of creek crossings and flooding

is included in Section 11.4 to 11.7 of the Supplementary Report.


58

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.35 5.9.3 Road crossings of creeks potentially create barriers to the

movement of fish and should be considered in the EIS.

Metro Mining will utilise the existing SRBP mail haul road to the MIA

and as such the originally proposed haul road between BH6 east and

the MIA is no longer required.

The relocation of the east-west BH1 haul road crosses two un-

named creeks. These crossings will incorporate culverts that will

allow fish passage upstream and downstream of the crossings as

outlined in Section 6.3 of the Supplementary Report.

Updated information of the potential impact of the proposed

waterway crossings is provided in Section 6.3 of the Supplementary

Report. Haul road culvert design and drainage are discussed in

Section 11 of the EIS.

19 19.36 5

The current EIS discusses the need for buffers and proposes

a minimum 100m buffer around HES wetlands, however

the adequacy of the buffers to protect the HES wetlands is

not adequately addressed in the EIS, particularly given that

the current proposal requires the clearing of HES wetlands

to accommodate port infrastructure (BLF, causeway and

RoRo facility) and the siting of port infrastructure and haul

roads immediately adjacent or within HES wetlands (see

Chapter 2, Figure 2-4 and 2-14).

However, buffers alone are not sufficient to prevent

environmental harm to HES wetlands. The EIS has not

demonstrated sufficient information on EHP’s preferred

hierarchy for managing likely impacts: to avoid; to minimise

or mitigate; and if necessary, and if possible, to offset (refer

to section 2.5 of the terms of reference for the Bauxite Hills

Project). Instead the EIS proposed offsets without

demonstrating measures to avoid and minimise impacts on

the HES environment.

No mining will be carried out within the nominated buffers.

Metro Mining has been able to significantly expand the proposed

buffer zones through the utilisation of the approved SRBP

infrastructure and also through the relocation of the east-west BH1

haul road away from the sensitive wetland areas.

Where impact to buffer areas is unavoidable, these areas will be

subject to environmental offsets as per the Qld Environmental

Offsets Policy. Refer to Sections 7.7 and 8.5 of the Supplementary

Report.


59

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.37 5.9.2.2,

Appendix B2

The section in the chapter does not include sufficient detail

about the proposed REMP and particular proposals for

wetland monitoring. Monitoring should be undertaken for

all HES wetlands potentially impacted by the project, using

reference sites and measuring appropriate indicators.

Refer to Sections 6.9, 6.10, 9.7.3 and 9.7.4 of the Supplementary

Report.


60

19 19.38

5.8.1.2,

5.9.2.2,

Appendix E1

The proposed mining areas for the Bauxite Hills Project and

the Skardon River Bauxite Project have the potential to

impact HES wetlands (including the creek south of BH1), Big

Footprint Swamp, Lunette Swamp, Namaleta Creek and the

Skardon River. The individual and combined impact on

groundwater and surface water hydrology from both

projects should be more clearly defined in Section 5.8.1.2.

More information is required in section 5.9.2.2 to clearly

propose how the impacts on wetlands from the proposed

project would be monitored and managed and also how

any cumulative impacts would be managed between the

two operations should they be approved.

Mining on the project’s tenements and mining on Gulf

Alumina’s tenements will each have an impact on Big

Footprint Swamp separately and cumulatively. As both

projects could impact this wetland system, there is a need

to recognise the shared responsibility and not make

assumptions about management approaches.


road to service the Bauxite Hills Project. In addition, Metro Mining

has relocated the east-west BH1 haul road outside of the HES

wetlands. The potential for impacts to HEs wetlands has now been

significantly reduced – refer Section 6.5 of the Supplementary

Report.

Surface water and groundwater are discussed in detail in

Appendices E1 and E2 and variously through other EIS chapters such

as Chapter 10 and Chapter 11. The text from the EIS has been

updated to reflect this comment - refer Sections 6.5 to Section 6.10


Pre-impact surveys including aquatic ecology, ground water and

surface water sampling have already been carried out for the Project

as is described in Section 5.6.3.2 and Appendix B2 of the EIS. Further

surveys for aquatic ecology have been carried out since the

publishing in the EIS and updated information is provided in Sections

6.2.2 and 6.2.3 of the Supplementary Report. Further sampling for

water quality and proposed water quality monitoring are presented

in Sections 9.6 and 9.7 of the Supplementary Report.

Impacts to catchment hydrology from mining is discussed in Section

3.3 and cumulative impacts to catchment hydrology from mining is

discussed in Section 6.2.2 of Appendix E2 of the EIS.

It is noted that Lunette Swamp lies approximately 1.5 km southwest

of any proposed works for the Project which is well outside of the

predicted groundwater impact zone for Project operations

(Appendix E1 of the EIS) and lies directly adjacent to proposed

mining activity for the SRBP. Monitoring and management activity

for this Project will focus on Big Footprint Swamp which lies adjacent

to Project mining activity.

The REMP will include monitoring of wetlands and watercourses

reasonably assumed to potentially be impacted by the Project. Refer


61

Submitter

No.

Submission

Reference No.

Relevant EIS


to Sections 9.7 and 6.10 of the Supplementary Report for further

discussion regarding the REMP.

Refer to Section 1.1 of the Supplementary Report regarding

acquisition of Gulf Alumina.

19 19.39 5.6.3.1

The stygofauna information presented in Chapter 5 is

based on a survey carried out for the Skardon River Bauxite

Project. This survey does not cover the area that is

proposed to be affected within the BH1 mining lease

including the surface springs in close proximity to the BH1

Haul Road.


19 19.40 7.3, Appendix

B2

The Appendix to the EIS states that there were five regional

ecosystems (REs) not previously mapped but lists a total of

seven REs.

The reference provided by EHP is incorrect and Metro Mining

assumes EHP are referring to Appendix B1 Section 7.3 of the EIS.

Following the results of early dry season surveys (refer Appendix C)

Metro Mining confirmed a total of six new REs within the revised

mapping - RE 3.1.2, RE 3.3.32, RE 3.3.42, RE 3.3.51, RE 3.3.63 and RE

3.3.65 and two new REs for the entire Project area (3.1.2 and

3.3.63). Refer to Section 6.11.1 of the Supplementary Report.

19 19.41 7.4.4,

Appendix B2

Section 7.4.4 refers to special least concern flora however,

this status does not exist for flora under the Nature

Conservation Act 1992.

Special least concern plants are listed in schedule 3A of the Nature

Conservation (Wildlife Management) Regulation 2006 which is

administered under the NC Act. Table 5-9 of the EIS refers to fauna

and is correct in attributing the correct NC Act status level. The

wording in Section 7.4.4 of the EIS describes these species as

'regulated under the NC Act' which is correct. No updates to the EIS

are proposed.


62

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.42 Table 5-9,

Appendix B1

With the exception of bats, the EIS used the following four

categories to classify the likelihood of occurrence of

species: known (confirmed during field studies), likely

(suitable habitat & known distribution), potential

(possibility of suitable habitat but limited records within or

around the project site), Unlikely (no suitable habitat & not

known in the area).

Some of the species that meet the definition of likely have

been classified as potentially occurring, even though there

is suitable habitat and nearby records placing the project

site within the reasonable range of the species. The EIS only

considered species categorised as known or likely in the

impact assessment and the Offset Strategy in Appendix C.

Therefore some species have been not adequately

considered in the EIS and further information is required

for the red goshawk, northern quoll, masked owl and the

bare-rumped sheath tailed bat.

Where the project proposes to impact on nesting and

roosting habitat, it is likely there will be an impact on these

species.

The consideration of species that are only likely or known to occur is

a standard approach in EIS impact assessments. DotEE itself have

also stated 'The Department considers species assessed against the

significant impact criteria should be categorised as no less than

‘Likely’ to occur' (refer comment 13.7). The updated species

occurrence information is revised in Section 6.13 of the


Under State and Commonwealth legislation offsets are only required

where a 'significant residual impact' is predicted for those species

likely or known to occur. Significant impact assessments have

already been carried out in the EIS and have been updated in

Section 6.13 of the Supplementary Report.

19 19.43

Table 5-9,

Table 8-2,

Appendix B2

Appendix B2 states that there are no known records of the

red goshawk in close proximity to the project and that the

nearest record is approximately 100km SE of the project

site. EHP has information that there is an active nest

approximately 40km south of the project site which is

within foraging range for the red goshawk. This would may

the assessment possible or likely to occur. Also the red

goshawk has been recorded on the Steve Irwin Reserve

which is approximately 50km from the project site5.

Due to the potential presence of foraging and possibly

nesting habitat, and that the project will involve clearing

this habitat, EHP considers that there is the potential that

the project will impacts on this species.



63

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.44 Table 5-9,

Appendix B2

Appendix B2 states that if there are known records in

proximity to the project site and there is suitable habitat

then the species should be classed as likely to occur. The

northern quoll has been classed as possible to occur in

Table 8-2 in Chapter 5. EHP has recently become aware of

an additional record of the northern quoll in the Steve Irwin

Nature Reserve and other records are noted in the EIS in

nearby Mapoon and Scherger air base. Also, Appendix B2

notes that there is fallen timber with hollows in the

tetradonta woodlands which could provide denning

habitat.

Given these factors, there is a real chance or possibility for

the northern quoll to occur on the project site; especially

on BH6. Due to the potential presence of foraging and

possibly nesting habitat, and that the project will involve

clearing this habitat, EHP considers that there is the

potential that the project will impacts on this species.


19 19.45 6.6.1.2

Impacts of vessel movements on water quality are

discussed under the heading- “Surface Water Runoff”,

rather than vessel movements.

The online version of the EIS will be updated to address this

comment.

19 19.46 6.8

Sections 6.6.1.1 and 6.7.1.1 indicate that the project could

have indirect and cumulative impacts on seagrass. More

detail about the potential impacts is required and

management and mitigation measures need to be

proposed in section 6.8.


the Bauxite Hills Project. The utilisation of the approved SRBP

infrastructure reduced the potential indirect and cumulative impacts

on seagrass with likely impacts to be restricted to a small patch of

seagrass (<0.1 ha) associated with the cyclone moorings.

Given the lack of seagrass in the disturbance footprint and broader

area the Supplementary Report has been updated to reflect a lesser

impact than initially considered. Refer to Section 7.3 and Table 6-11



64

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.47 6.6.1.2

It is noted that Figure 2-21 in Chapter 2 shows a sediment

pond to capture runoff from the port stockpiles/conveyor.

It is also noted that this pond is expected to overflow in the

wet season. Insufficient detail on this source of water

discharge is included in the EIS. The impacts of this

overflow on marine water quality and the potential impacts

on marine ecology have not been adequately assessed.



infrastructure and proposed operations. The acquisition enables the

use of the approved infrastructure at the port area. The sediment

ponds approved for the SRBP will be used for the MIA.

19 19.48 6.6.2.3, 6.8.1.3

Wildlife can be significantly disrupted by changes in light.

Turtles, roosting birds and marine fauna are particularly

vulnerable. This effect is poorly assessed in the EIS. The

‘turtle friendly lighting’ referred to on page 6-45 had little

explanation however some mitigation measures have been

presented for turtles in 6.8.1.3. Commitments in Section

6.22 does not outline how risk areas/populations will be

identified, how monitoring for light impacts on wildlife will

be undertaken, and does not detail what the ‘turtle friendly

lighting’ solutions would be.


the Bauxite Hills Project. Refer to Section 4.4 of the Supplementary

Report. The use of turtle friendly lighting will be as per the approvals

for the SRBP project.

19 19.49 6.6.2.4

This section states that there would be no impact in the

marine environment from shading. However, it is unclear

which components of the project have been assessed and

whether this statement includes possible impacts of

shading from barges left moored for several months on the

cyclone moorings.


the Bauxite Hills Project. Impacts associated with shading from the

SRBP has been addressed through that project’s EIS.

Potential impacts associated with the cyclone moorings are

discussed in Section 7.3.2 and Appendix D of the Supplementary

Report.


65

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.50 6.6.5

Marine vegetation communities act as nurseries for

numerous species including those of recreational and

commercial value and help stabilise sediments against

scouring and erosion generally, thus contributing to water

quality and productivity. The section (and related parts of

the EIS) does not acknowledge the full range of impacts

that clearing 20.5ha of mangrove, 0.25 ha of saltmarsh and

0.4 ha of seagrass may result in.


road to service the Bauxite Hills Project. In addition Metro Mining

has relocated the east – west BH1 haul road outside of HEV

wetlands and mangrove habitat. Consequently, no mangrove habitat

rehabilitation is anticipated to be required.

The relocation of the east-west BH1 haul road avoid all areas

identified as saltmarsh.

As the originally proposed BLF and RoRo are not required, the

potential to impact marine vegetation, including mangroves and

seagrass, has been significantly reduced. It is now assessed that <0.1

ha of seagrass may be disturbed from activities associated with the

cyclone moorings.

19 19.51 6.7.1.3

Section 6.7.1.3 does not adequately assess the potential

cumulative impacts of sediment pond overflow on marine

water quality. The Skardon River Bauxite Project and this

project both propose the use of sediment ponds that may

overflow in the wet season, however, an assessment of the

cumulative impacts of the two sediment ponds overflowing

in the wet season on water quality and MNES is not

included.

Refer to Section 4.4.1. Since the release of the EIS, Metro Mining has

completed a successful takeover of Gulf Alumina’s assets, including

the existing infrastructure and proposed operations. The acquisition

enables the use of the approved infrastructure at the port area. The

sediment ponds approved for the SRBP will be used for the MIA.


66

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.52 6.6.1.1

The EIS does not provide a clear statement of predicted

impacts to marine communities and species. It is unclear in

the EIS what species are considered to be sensitive

receptors in the marine environment and which of them

are likely to be directly or indirectly impacted by project

activities. Detailed information outlining the zone within

which sensitive receptors would be impacted by project

activities is not clearly or adequately described.

Page 6-38 states that there would be potential indirect

impacts of project activities on seagrass. However, where

these impacts would occur and the area of seagrass likely

to be impacted is not clearly outlined in the EIS. Mapping is

planned to occur as a result of a pre-construction survey.

Describing exactly where seagrass beds are in the EIS would

better inform avoidance and mitigation measures to

minimize impacts on marine fauna likely to use the impact

zone.

As the originally proposed BLF and RoRo are not requiredthe

potential to impact marine vegetation, including mangroves and

seagrass, has been significantly reduced. It is now assessed that <0.1

ha of seagrass may be disturbed from activities associated with the

cyclone moorings.

Refer to Sections 7.3.1, 7.3.2, 7.5 and 7.6 of the Supplementary

Report in addition to Sections 6.5.4.1 and 6.5.4.2 of the EIS.

19 19.53 6.7.1

At present the impact assessment does not contain

sufficient information on the cumulative impacts on water

quality and shore erosion. The EIS should include a more

quantitative assessment of the potential impacts of the

Skardon River Bauxite Project and this project, particularly

impacts on water quality, shore erosion and MNES.

Sections 2.5, 7 and 8 of Appendix B3 of the EIS provides further

detail on the matters of concern.

Since the publication of the EIS, a detailed wave wake modelling

assessment for the Project has been carried out (refer to Appendix E

of the Supplementary Report). The assessment has been

summarised in Section 19.3 of the Supplementary Report and

includes impacts and mitigation measures. Note that the assessment

included the location of the originally proposed BLF and RoRo.

Whilst these are no longer relevant due to the utilisation of the

approved SRBP port area the assessment in relation to barge

movements from the river mouth to the BLF is still relevant.

Section 7.3.2 within the Supplementary Report describes the

predicted impacts to seagrass. MNES are discussed in Section 8 of

the Supplementary Report.


67

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.54 6.8

Potential impacts to marine habitats identified in Section

6.6.1, includes decreased water quality and disturbance of

PASS. However, the management and mitigation measures

in Section 6.8 do not address decreased water quality or

disturbance of PASS.




from ASS.


19 19.55 Table 6-21

Table 6-21 of the EIS states that “Trained marine fauna

observer to inspect area for 30 minutes prior to start”. EHP

is concerned that many species would not be visible from

the surface to make this an effective mitigation measure.

Surface monitoring will be undertaken for the presence of marine

turtles, dugongs and cetaceans.

Trained marine observers is only one of the measures proposed in

the Table 6-21 of the EIS and taken in conjunction, these

management measures are considered effective. Refer to Sections

7.2.1 and 7.2.2 of the Supplementary Report.

Note that with the utilisation of the approved SRBP BLF, the only

piling works proposed by Metro Mining for the Bauxite Hills Project

are associated with the cyclone moorings.

No additional monitoring methods are proposed during piling works.

19 19.56 Table 6-21

Table 6-21 of the EIS indicates that there would be “Soft

start-up of piling operations”, however, there is no

indication of the ramping time. Section 6.8.1.1 dot point 6

indicates some details about the intended soft start-up but

it is not clear whether it is consistent with the literature

which indicates a ramping up between 15 to 30 minutes

would be required to minimise impacts.

Refer to Section 7.2.2 of the Supplementary Report which

incorporates a 15 minute ramp up period for piling operations.


68

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.57 6.8.1.1

This section of the EIS does not provide sufficient

explanation of how the mitigation measures would be

implemented in relation to acoustic impact on species.

Different species have differing thresholds with respect to

the impact of noise levels on their behaviour or health. In

addition, and as raised in comments on Chapter 13 - Noise,

the reflectivity or absorption of noise levels has not been

considered in their effect on noise propagation and so the

true extent of impact is not known.

On page 6-53 of the EIS a 500m safety exclusion zone is

proposed to be established around piling work however it

is unclear whether this would be sufficient for the species

and the levels of noise and vibration generated. Also, it is

not clear how this would be implemented, particularly for

species that are not visible from the surface.


19 19.58 6.8.1.1

The underwater noise and vibration resulting from the

project may have biologically significant effects on

threatened marine species. These potential impacts were

not considered in the EIS for the following marine species:

speartooth shark (Glyphis glyphis) – listed as critically

endangered.

dwarf sawfish (Pristis clavata) – listed as vulnerable.

freshwater sawfish (Pritis pritis) – listed as vulnerable.

green sawfish (Pritis zijsron) – listed as vulnerable.

There is no scientific literature available to assess the impacts of

noise and vibrations on Speartooth Shark or Sawfish spp.

Section 4.4.3.1 of Appendix B3 of the EIS already provides a detailed

analysis of the known impacts of underwater noise on marine fauna.

Section 2.1.15 of Appendix I of the EIS provides an assessment of the

predicted underwater noise levels and impact on marine fauna

produce by large OGVs.

This assessment approach and the proposed mitigation measures

for potential impacts to marine species is consistent with Gulf

Alumina's approach in the SRBP SEIS in regard to the lack of

scientific data to these species.


69

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.59 6.8.2.1, 6.6.2

CSIRO considers that the sawfish species are likely to be in

the Skardon River and the speartooth shark may also be

there. The species are recorded in Port Musgrave and adult

speartooth sharks were recently caught there. Bauxite

mining in the area will result in a significant increase in

vessel traffic in the Skardon River and very little is known

about the ecology and occurrence of these species and

what their response to disturbance may be.

Section 6.6.2 lists potential impacts including fauna

avoiding an area because of disturbance and section states

that a behavioural response to disturbance may occur over

an area of many kilometres. As such, the EIS should provide

reasons why the proponent considers that the long-term

disturbance of the estuary by vessel traffic may not cause

marine fauna to avoid the area. The EIS contains

information about the transhipment area but does not

consider the significant increase in vessel traffic in the

estuary.



70

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.60 7.9.1.4

It is possible that offsets may be required for impacts to

MNES. The EIS notes that one vulnerable species (black-

footed tree-rat) was found in the Skardon River Bauxite

Project surveys. This species relies on hollows in eucalyptus

tetradonta woodlands and pandanus for habitat which

would be cleared for the project.

The EIS states that no black-footed tree-rat was found

during surveys at the Bauxite Hills Project area. However,

there were no targeted surveys undertaken on the site to

provide evidence that this species would not be present.

Given the species was confirmed in close proximity to the

project site, and suitable habitat occurs on the project site,

the EIS reflects that the species is “confirmed” for the

purposes of the assessment.

A significant impact assessment for the black-footed tree-

rat is included in Table 7-25. It concludes that no significant

impact would result for this species against any of the

criteria. EHP considers that the removal of hollow bearing

trees would indicate that a significant impact is likely to

result from the project.

The information for the Black-Footed Tree Rat is included in Section

8.4.3.3 of the Supplementary Report. The Project requires the

clearing 1,410 ha of Darwin Stringybark woodland (RE3.5.2). This

habitat remains widespread in the surrounding region with a further

44,280 ha located within a 20 km radius of the Project area. Given

the general lack of records and the abundance of this habitat in the

wider landscape no significant residual impacts have been predicted

for this species and therefore no offsets are required. The species

will be part of the Project-specific Significant Species Management

Plan (refer Section 8.4.3.3 of the Supplementary Report).

19 19.61 7, Table 5-9,

Appendix B1

Some of the species that meet the definition of likely have

been classified as potentially occurring, even though there

is suitable habitat and nearby records placing the project

site within the reasonable range of the species. The EIS only

considered species categorised as known or likely in the

impact assessment and the Offset Strategy in Appendix C.

Therefore some species have been not adequately

considered in the EIS and further information is required

for the red goshawk, northern quoll, masked owl and the

bare-rumped sheathtail bat.



71

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.62 7.14

The risk assessment does not include the removal of

marine plants (mangroves and saltmarsh), wetland area or

watercourse REs in the risk assessment within Table 7-49.

The removal of this habitat may potentially impact MNES

species.


road to service the Bauxite Hills Project, in addition Metro Mining

has relocated the east-west BH1 haul to avoid HES wetlands.

Consequently that will be no clearance of mangrove or saltmarsh

habitat.

19 19.63 4.8.3.2

The level of groundwater in the groundwater dependent

ecosystems (Big Footprint Swamp and Skardon River)

would provide an important measure of rehabilitation of

the site and whether further rehabilitation work is required

to maintain the water catchment values. This was not

included as a completion criteria in Table 4-17.

Maintenance of stable groundwater levels, within natural variations,

the groundwater dependent ecosystems (Big Footprint Swamp and

Skardon River) have been included as a completion criterion in Table

10-1 of the Supplementary Report.

19 19.64 4

ASS are present on the site and pose a potential hazard to

receiving waters. Figure 4-8 shows areas within the

mangrove and riparian habitats that have a high probability

to generate ASS. Preliminary lab results indicate the

presence of actual ASS in the project area. There is

potential that ASS would be disturbed or removed during

the construction of the MIA, RoRo facility, BLA and haul

roads; and the stockpiles and laydown areas within the MIA

would also be on PASS.

The potential impacts to water quality from the

disturbance, removal or onshore management of ASS are

not discussed in this Chapter. The MIA layout is not shown

on an adequately scaled map that allows the location of

infrastructure and the risk of PASS to be evaluated.




from ASS.


19 19.65 5.6.3.2

The water quality information presented in Chapter 5 does

not describe all aquatic habitats within the project area,

such as freshwater streams, swamps and surface springs.

The water quality is likely to vary between these habitats

and water quality data for these aquatic habitat types

should be provided in the EIS. Currently only in situ data at

3 sites sampled once is presented in Chapter 5. Additional

water quality sites are presented on Figure 5-4 and

information for these sites is presented in Chapter 9.

The aquatic ecology section has been updated with surface water

quality data collected for the Project and SRBP. Refer to Sections

6.2.2 and 6.2.3 of the Supplementary Report in reference to aquatic

ecology and Section 9 of the Supplementary Report more generally

for water quality.


72

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.66 9.5.2

It is not appropriate to define water quality objectives

(WQOs) for physico-chemical indicators using the 80th

percentile of background for high ecological value (HEV)

waters. In section 9.5.1 it was recognised that the waters

potentially impacted by the Project area are considered to

be ‘high ecological value’ (waters in which the biological

integrity of the water is effectively unmodified or highly

valued). In ANZECC & ARMCANZ (2000) and the

Queensland Water Quality Guidelines (DEHP, 2009) the

management intent for such waters is to ensure “no

change to existing condition” (refer to appendix D, Table D1

DEHP, 2009). For HEV areas, the principal of ‘no change to

existing condition’ applies to all parameters (including

physical and chemical, biological, toxicants, and habitat and

flow attributes).

It is also not appropriate to use slightly disturbed

ecosystem or livestock drinking water trigger values as

interim WQOs, as the waters within the Project area are

considered to be ‘high ecological value’ and livestock

drinking water is not considered an EV for the Project area.

The methodology used to report and interpret data at or

below the Limit of Reporting (LoR) was not clear and did

not appear to be applied consistently for all data sets

reported.

The water quality data presented in the tables (the data for

Pisolite Hills presented in Table 9-5) contains errors which if

included could affect interpretation of the data.

Since the submission of the EIS further site-specific samples have

been collected. Refer to Section 9 of the Supplementary Report.

19 19.67 9.5.3

The concentration of metal data for the Dulhunty River is

presented in Table 9-4. It is unclear whether this data is for

dissolved or total concentrations of metals.

Since the submission of the EIS further site-specific samples have

been collected. Refer to Section 9.4 of the Supplementary Report.

This excludes the Dulhunty River data as it is no longer required for

the purpose of developing site-specific WQOs.


73

19 19.68 9.5.4

There is a lack of adequate water quality data to define

background conditions and define locally relevant water

quality guidelines for the project area. Most sites have only

been sampled once. A single sample is not adequate to

define natural seasonal variations in water quality.

Between 8 and 18 samples over a 12 month period

(preferable 24 months) is required to determine reference-

based guidelines (Queensland Water Quality guidelines

(refer to Table 4.4.2 page 78 DEHP, 2013a)).

Using combined data from the Skardon River project to

define background conditions is appropriate as the Skardon

River project was collected within the same catchment and

is within similar ranges for most parameters. However,

combining data from sites with different water types and

varying characteristics is not appropriate to define

background conditions as each can have very different

water quality.

In addition to this, Table 9-9 notes that S6 and S9 were

used to collect surface water quality information. This is

not considered an appropriate surface water quality

collection site as both these locations are downstream of

an existing release point from the Skardon River Kaolin

mine water pits. As such, these are impacted sites and

would not reflect true background data for this creek

system.

S14 is also noted as an estuarine/marine surface water

quality sampling site. However, this is a designated release

point for a new sediment pond at the Skardon River bauxite

project. Therefore, it is unclear how this location is relevant

to the collection of such data.

These pages present what appears to be raw data for 5

different monitoring locations, referred to as WQ1 – WQ5.

However, these locations have not been referred to in the

water quality chapter (Chapter 9), therefore it is unknown

where these locations are and how these are relevant to

the project and the data collected. If these refer to a

With the addition of water quality data from three further sampling

events undertaken in May, June and July 2016 sufficient sampling

events (i.e. minimum of eight as outlined in the QWQG) to establish

‘interim guidelines’ for the majority of quality indicators were able

to be established based on the 20th, 50th and 80th percentiles.

Refer to Section 9 of the Supplementary Report for discussion on

water quality and Appendix I of the Supplementary Report for draft

EA conditions.

The requirement for consistency in terminology is noted.

The error in the calculations of means for physicohemical

parameters for WQ5 in January 2012 as presented in Appendix D is

noted.


74

Submitter

No.

Submission

Reference No.

Relevant EIS


monitoring location that has been listed in the EIS (EG: W1

– W5), clarification should be provided (preferably in the

water quality chapter) on which location this refers to and

why the reference name has changed. Naming convention

should always be consistent between chapters and

appendices, for ease of reference.

The time series data for WQ5 collected in January 2012,

and the calculated mean for each physiochemical

parameter, includes data collected from WQ1 (date 2/6/12,

time 10:47). As such, the data is skewed. Likewise, as this

data has not been included in the mean for WQ1, the mean

for this will also be incorrect.

19 19.69 9.5.4

Based on Figure 9-2 SW03 and AQ01 appear to be two

different monitoring sites, yet they have been grouped

together as the same site in Table 9-9.

Table 9-9 notes, that AQ02 is a large heavily disturbed

Melaleuca swamp system to the south of S10. Based on

Figure 9-2, AQ02 is based to the north west of S10, not the

south. In addition, it is not clear what is classed as

disturbed. This location is a greenfield site, therefore no

disturbance should be present at the site.

SW03 and AQ01 are different locations but represent sampling

locations within the same water body “Big Footprint Swamp” which

explains why they have been grouped together in Table 9-9 of the

EIS. Descriptions for each site are provided in Table 9-10 of the EIS.

AQ02 is located to the north of SRBP site S10 rather than to the

south as noted in the EIS. Section 9.6.1 of the Supplementary Report

describes the number of sites and samples used to establish

reference conditions and neither AQ02 or S10 (SRBP site) are used.

As mentioned in Table 4.6 of EIS Appendix B2 Large numbers of wild

pigs were observed during aquatic ecology surveys at the Project

site, watering and the open areas around the waterhole were

heavily disturbed from foraging by feral pigs.


75

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.70 9.5.4

Table 9-9 notes, that S6 and S9 were used to collect surface

water quality information. This is not considered an

appropriate surface water quality collection site as both

these locations are downstream of an existing release point

from the Skardon River Kaolin mine water pits. As such,

these are potentially impacted sites and may not reflect

true background data for this creek system.

In addition to this, S14 is noted as an estuarine/marine

surface water quality sampling site. However, this is a

designated release point for a new sediment pond at the

Skardon River bauxite project. Therefore, it is unclear how

this location is relevant to the collection of such data.

Data from sites S6, S9 and data from potentially impacted sites have

not been used in the revised assessments.

Data from site S14 post operation of the new SRBP sediment ponds

will not be used.

Refer to Section 9 of the Supplementary Report for updated water

quality discussions.

19 19.71 Figure 9-2

The location of water quality monitoring sites sampled for

the Bauxite Hills and the Skardon River Bauxite Projects and

the Dulhunty River gauging station are provided in Figure 9-

2. The water quality monitoring sites sampled for the

Amrun and Pisolite Hills Projects are not presented in the

EIS.

Water quality from the Amrun and Pisolite Hills Projects will not be

used to characterise the receiving water for the Bauxite Hills Project

with the relevant surface water monitoring points clarified in

Section 9 and in Appendix I of the Supplementary Report.


76

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.72 Table 9-2

The surface water and groundwater in this area are

naturally high in aluminium. Background concentration of

aluminium exceeds the ANZECC & ARMCANZ (2000) trigger

value for aluminium (pH>6.5) for both dissolved and total

aluminium at sampling locations within the project area.

The groundwater in the area is also naturally high in copper

and zinc. Background concentrations of copper and zinc in

the groundwater within the project area exceed the

ANZECC & ARMCANZ (2000) aquatic ecosystem toxicant

trigger value for the protection of 95% of species.

The QWQG (refer to Table 4.4.2 page 78) stipulate that to

derive interim or local water quality guidelines, a minimum

of 8 samples per site collected over 12 months (preferably

24 months). Based on the combined Bauxite Hills Project

and Skardon River Bauxite Project’s water quality data from

23 samples the 20th, 50th and 80th percentile for dissolved

aluminium is 23.8, 64 and 130 μg/L respectively. The

variation in water quality between sites, however, needs to

be evaluated before the combine water quality data for

both projects can be used to determine interim local water

quality guidelines. For example, some differences were

found between Skardon River data and the current project.

The EIS used an estuarine/marine WQO for aluminium of

0.5μg/L. According to recent guidelines, a figure of 2.1 μg/L

(for 99% species protection) total aluminium in estuarine

marine waters should be used (as published by Golding et

al., (2015)).





to be established based on the 20th, 50th and 80th percentiles. For

some parameters there remains insufficient data to establish interim

guidelines and for these, where possible, Metro Mining have

defaulted to the ANZECC / ARMCANZ 2000 guidelines for tropical

waters 99% species protection levels.

Refer to Section 9 of the Supplementary Report for water quality

and Appendix I of the Supplementary Report for revised EA

conditions.


77

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.73 Table 9-2

There is limited data to derive local freshwater and marine

water quality guidelines. The guidelines should be

considered as interim and be revised when further data

becomes available. Interim local guidelines should be

determined based on Comments 11, 13 and 15 above.












conditions.

19 19.74 9.3.2

The Environmental Protection Regulation 2008 (EP

Regulation) includes a performance outcome for wetlands

which is: “there will be no potential or actual adverse effect

on a wetland as part of carrying out the activity”. The

current performance outcome stated in the EIS for

wetlands is not consistent with those stated in the EP Reg.

The proposed performance criteria in the EIS reflects that there will

be impacts and these impacts will be prevented or minimised to the

extent possible. As such no amendment is proposed.

19 19.75 9.5.4

This section of the EIS refers to table 9-7 and table 9-9 for a

list of the surface water monitoring locations, and figure 9-

2 for a map of where these are located. However, not all

locations listed in this table are reflected in figure 9-2.

Specifically, the following locations are missing from figure

9-2:

S11

SW04

SW06

SP01a

S3

S8

S14

All monitoring locations should be listed for ease of

reference for the reader.

The proposed surface water and groundwater monitoring locations

have been updated as discussed in detail in Section 9 and Appendix I



78

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.76 9.5.6

The surface water quality results presented in Table 9-11

depict a very limited amount of data that is representative

of the various freshwater environments.

The freshwater stream water quality results in Table 9-11

come from the following freshwater environments that

should ideally be characterized separately;

SW01/AQ03 is a freshwater stream (Irish Creek);

SP01 was a wet season spring expression at ground

surface near Irish Creek;

AQ01/SW03 is Big Footprint Swamp, a freshwater

wetland; and

AQ02 is described as a large heavily disturbed

Melaleuca Swamp system.

Furthermore, the freshwater quality data provided in Table

9-11 ranges from 8 to 2 samples. Considering these

samples were taken across the various freshwater

environments described above (springs/swamps/creek),

they provide a limited reference data set capable of

characterising the various freshwater environments.

It is not clear how many samples have been taken within

the Irish Creek system that will be impacted by a haul road

and lays adjacent to the BH1 mining area. It is likely that

there is very limited data of this freshwater system. It

should be noted that the Skardon River Bauxite Project did

not monitoring this freshwater system. It would not be

appropriate to use the Skardon River Bauxite Project data

from Namaleta Creek in replacement of obtaining

reference condition data.










Whilst it is acknowledged that these sites represent systems that

may be classified differently, one-way ANOVA assessment of

variance in water quality between sites indicates sufficient similarity

for their use in this instance. As additional data is collected it will be

possible to establish classifications unique to each system.



conditions.


79

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.77 9.5.6.1

Recommended site specific pH value despite

acknowledging not enough data points collected as per

ANZECC. This is not appropriate.












conditions.

19 19.78 9.5.7

A description of the groundwater quality of bores and any

similarity and differences between major ions within bores

and aquifers is not presented in the EIS.

The water quality within the shallow aquifer is sampled and

data is presented in the EIS. There is no data presented on

the water quality within the deeper GAB aquifer. There are

potentially water quality differences between these

aquifers however data describing the quality of the GAB

aquifer has not been presented in the EIS.

The shallow aquifer is proposed to be used for drinking

water and the deep GAB aquifer for other uses. The water

quality in both aquifers needs to be compared to guidelines

based on the proposed use of the water.

The piper diagram of groundwater samples (Figure 9-6,

page 9-41) suggests ionic differences between bores in the

shallow aquifer. Based on this data there may be

differences between the bores in BH1 and BH6.

Metro Mining has submitted a temporary water permit application

pursuant to s237 of the Water Act 2000. Information required to

assess this application has been submitted through a separate

approval process to DNRM. Refer to Section 4.3.4 of the

Supplementary Report in regard to the application process.

The groundwater quality of the shallow aquifer relevant to the

water permit is described in Section 9.5.7 of the EIS. This includes

discussion around the analysis of the major ions and also a piper

diagram presents the relationship of the water quality between the

bores.

Section 9.5.2 of the Supplementary Report has been updated to

include additional discussion regarding groundwater quality through

the three recent rounds of groundwater sampling and monitoring.

Should it be the case that GAB water is required further assessment

of the water quality characteristics will be undertaken and the EA

amended accordingly.


80

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.79 9.5.7 Interim local groundwater WQO have not been proposed in

the EIS.












conditions.

19 19.80 9.5.7

Table 9-16 indicates that despite being a major area of

proposed impact, there has been no wet season

groundwater quality data collected from the BH1 mining

area.

The seasonal variations in groundwater levels and quality

should be established prior to mining commencing in order

for test site/compliance data collected during and after

mining to be able to detect any impacts as a result of

mining activities.

Continuous groundwater level data is provided in Section 2.4.4 of

Appendix E1 of the EIS.

Background groundwater quality establishing the 20th, 50th and 80th

percentiles over an average of 65 data points across the parameters

is presented in detail in Section 9 of the Supplementary Report.

Once the Project is operational ongoing wet season groundwater

monitoring will be undertaken.

19 19.81 9.6.1

The EIS states that the Irish Creek tributary of the Skardon

River is at most risk of sedimentation impacts due to the

BH1 haul road and mining areas. The freshwater quality

sampling undertaken to date does not appear to have

focused on establishing baseline water quality data for this

freshwater system. Based on the risk of impacts, this data

gap should be addressed.

An additional water quality monitoring site has been nominated for

the Irish Creek system downstream of the haul road and mining

activities. The location of this site (W2(SW01)) is illustrated in

Appendix I in the Supplementary Report.


81

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.82 9.7.1

The EIS states that the water quality of Big Footprint

Swamp may be impacted by the close proximity of mining

activities. Also it states that “Detailed erosion and sediment

control measures will be implemented to minimise

sediment mobilisation into Big Footprint Swamp”. The ESCP

provided in Appendix A3 is “conceptual” by nature and has

not been designed based on the protection of the Big

Footprint Swamp environmental values. Also, it states that

no releases of contaminated water will occur in Big

Footprint Swamp however the ESCP has proposed to

“minimise” not “prevent” sediment mobilisation into Big

Footprint Swamp.

The EIS includes a performance outcome for wetlands on

page 9-4 as “The activity will be managed in a way that

prevents or minimises adverse effects on wetlands” which

is inconsistent with that listed in the EP Regulation.

It appears that basic erosion hazard assessments have been

used to inform the design of the “conceptual” ESCP

however the significant EV’s of the Big Footprint Swamp,

should also be considered as a means of designing a

“detailed” ESCP that will adequately protect the Big

Footprint Swamp and other freshwater systems prone to

sedimentation impacts.

Refer to Sections 5.3, 5.4, 6.6 and Appendix I of the Supplementary

Report.


82

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.83 20

While it is recognised that Figure 20-3 of Chapter 20

indicates the location of RP1 and coordinates are provided

in the draft EA Conditions in Chapter 20, Chapter 9 does

not contain a map at a suitable scale to indicate the likely

location of release points for the project. This would

include point of release from sediment dams but also

potential release points in the vicinity of the MIA in the

event of a spill or accident in handling hazardous

substances.

The following matters need to be amended or resolved in

the draft EA conditions:

Table 20-7 notes there is no release points, however

receiving water monitoring locations have been

proposed. If no release is proposed for this system,

then the EIS should clarify why SW01 and SW03 are

proposed as receiving water monitoring locations

for tables 20-7 and 20-8, no description of the receiving

waters has been provided (eg” Skardon River, Namaleta

Creek, Irish Creek). This information will be used to

form release limit and receiving water trigger values

release limits have not been proposed for RP1 (listed in

Table 20-8)

Metro Mining will utilise the approved SRBP MIA to service the

Bauxite Hills Project. As a consequence no release points are

proposed for the Bauxite Hills Project. Refer Section 9 of the



83

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.84 9.6

EHP reviewed the proposed sediment basin design and

concluded that it is inappropriate for the scale of operation

and location (wet tropics with high rainfall events during

summer). The 5 day storm design following the

International Erosion Control Association Manual is

typically used as design criteria for high efficiency sediment

basins. They are generally used for smaller projects and in

practice, these design storm criteria are typically smaller

than the 1 in 10 year 24 hour storm event as they exclude

very high rainfall periods. EHP recommends that the

minimum design standard of the erosion and sediment

control ponds should be designed to capture rainfall during

a 1:10 ARI 24 hour storm event.

The location and design of the wharf drainage sump and

MIA recovery slot referred to in Figure 9-8 needs to be

included in the assessment of potential impacts on water

quality.






19 19.85 9.6

Onshore management of ASS is proposed as a management

method during construction of the RoRo facility in Chapter

2, Section 2.7.5 and Chapter 4, Section 4.8.1.4. The location

of onshore management of ASS is not discussed in the EIS.

The potential impacts to water quality from the

disturbance, removal or onshore management of ASS are

not discussed in Chapter 9.




from ASS.



84

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.86 9.8.8

The design of a REMP program should be undertaken in

accordance with the Receiving Environment Monitoring

Program Guideline - For use with Environmental Relevant

Activities under the Environmental Protection Act (1994)

(EHP 2014).

The proposed surface water and groundwater monitoring

sites, parameters, monitoring frequency and trigger levels

that would be used to assess impacts for freshwater,

marine and groundwater sites are not included in Chapter

9. Monitoring of the GAB as part of the REMP was also

missing.

Metro Mining notes the need to follow EHP's guideline in preparing

the REMP. Metro Mining also note that the purpose of the REMP is

to monitor potential impacts from actual or potential releases of

contaminants to water. As the Project is only proposing to release

water from the MIA to the Skardon River, the purpose of including

standard water quality monitoring requirements in the REMP is

queried as Metro Mining believes these are adequately covered in

the water monitoring section of the draft EA conditions.

Monitoring of the GAB is not relevant for the REMP due to the

shallow nature of the bauxite mining. Water quality monitoring will

be undertaken as part of the operational requirements of the mine

and will be included in the groundwater monitoring requirements of

the draft EA. Detailed discussion around the extent to which the

Project will interact with the GAB is provided throughout Appendix

E1 – Groundwater of the EIS.

Monitoring frequencies and parameters for other water monitoring

commitments are described in Appendix I of the Supplementary

Report.

Given Metro Mining has committed to the preparation of a REMP,

and the further commitment to prepare the REMP in accordance

with the Receiving Environment Monitoring Program Guideline - For

use with Environmental Relevant Activities under the Environmental

Protection Act (1994) (EHP 2014) no update to the information

included in the EIS is proposed. It is proposed to add a condition to

monitoring water quality from the GAB production bore as part of

the groundwater monitoring requirements in the draft EA.


85

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.87 9.10 The Chapter Summary does not include potential impacts

from sediment basins or ASS.

Metro Mining acknowledges that the Chapter 9 summary does not

include impacts from sediment ponds or ASS. Sediment ponds and

ASS are discussed in detail in Appendix A3 of the EIS (specifically

Section 3.4.2.1 and Section 5.5.3). Section 5.1.2 and 5.1.3 of the

Supplementary Report discuss ASS. Sediment ponds are discussed in

Sections 4.3.1, 11.1.1 and 11.1.6 of the Supplementary Report.

19 19.88 11.4.2.3

From Figure 11-4 and Figure 11-6 it appears that the MIA

may be impacted by the peak 1,000 year ARI, including the

RoRo facility and sediment traps. It is however, difficult to

determine due to the scale of the map provided showing

the MIA.

Metro Mining will utilise the approved SRBP MIA to service the

Bauxite Hills Project. As such this comment is no longer relevant.

19 19.89 10.4.3

The EIS identified that haul roads would be impacted by

flooding (see 11-4 and Figure 11-6). It is proposed in the EIS

to construct low flow culverts which allow a 2 year ARI to

pass under the haul road (Section 11.5). In larger flows,

flood water would pass over a floodway.

The design for a 2 year ARI event may be a sufficient culvert

sizing design to adopt if the operations are proposed only

during the dry season. However, in this case the culvert

sizing and design would also need to suit wet season

conditions.

It is not clear in the EIS how the culverts will be affected by

wet season rain events and what potential issues could

arise as a result of the designs. There could be potential

impacts to water quality during wet weather when haul

roads are inundated by flood waters.



86

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.90 Appendix D

These pages present what appears to be raw data for 5

different monitoring locations, referred to as WQ1 – WQ5.

However, these locations have not been referred to in the

water quality chapter (Chapter 9), therefore it is not known

where these locations are and how these are relevant to

the project and the data collected. If these refer to a

monitoring location that has been listed in the EIS (EG: W1

– W5), clarification should be provided (preferably in the

water quality chapter) on which location this refers to and

why the reference name has changed. The naming

convention should always be kept consistent between all

chapters and appendices, for ease of reference.

The time series data for WQ5 collected in January 2012,

and the calculated mean for each physiochemical

parameter, includes data collected from WQ1 (date 2/6/12,

time 10:47). As such, the data is skewed. Likewise, as this

data has not been included in the mean for WQ1, the mean

for this will also be skewed.

The error in the calculations of means for physiochemical

parameters for WQ5 in January 2012 as presented in Appendix D is

noted and will be corrected for any revisions of the EIS.

More recent data has been used to establish interim reference

criteria for the 20th, 50th and 80th percentiles for upper estuary

waters of Skardon River as presented in Section 9 and Appendix I of

the Supplementary Report.

19 19.91 10.6.3

There is uncertainty as to whether bauxite mining will

intercept any meandering paleo-channels that may affect

Lunette Swamp, Namaleta Creek and Big Footprint Swamp.

If this was the case, the hydrology of these wetlands may

be adversely affected.



87

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.92 10.6.3.5

The EIS states that the spring observed during the 2015 wet

season (SP01) is not considered a GDE as it does not meet

the classification of a GDE. Sufficient justification why the

spring (SP01) does not meet the definition of a GDE has not

been provided.

The EIS assumed the spring (SP01) is an ephemeral wet

season feature, based on a desktop study of aerial imagery

in 2011 by WorleyParsons. No follow up survey details

were undertaken of the area to determine the extent and

period the spring flows and if there are any other springs

within the area. The spring (SP01) is found immediately

within the footprint of the haul road between BH6 east and

BH1 mining areas (see figure) and therefore likely to be

impacted by mining activities. The spring (SP01) is absent

from the impact assessment.

During the wet season the water table rises and intersects the

ground surface over low lying areas. The groundwater impact

assessment considered the effects of bauxite mining on

groundwater discharge and found that due to a very small increase

in peak discharge rate (up to 5%) it is unlikely that significant

potential impacts on the health of the ecosystem would arise.

The identified ephemeral spring (SP01) is located outside the area of

predicted influence (and on the adjacent side of the local

groundwater flow system/discharge zone), indicating that bauxite

mining will not result in a significant impact.


19 19.93 10.6.5

The section named Calibration Performance Criteria states

the “dry season stress period lengths range from 276 to

305 days”. It appears unrealistic that a dry season stress

period would last 276 to 305 days of a year.

Dry season stress periods are, as described, periods over in which

there has been insufficient rainfall to cause recharge and associated

increase in groundwater level. The bore hydrographs and rainfall

presented in Section 2.4.4 of EIS Appendix E1 clearly show that the

groundwater level steadily declines from the highest to the lowest

elevation over a period that ranges from 276 to 305 days. Stress

periods have been appropriately set to match the periods of

effective recharge and peaks in the groundwater levels, producing

annual recharge rates that are entirely consistent with recharge

estimated from other modelling studies. If stress period lengths are

altered, periods of active recharge will change, producing

discrepancies between the computed and observed hydrographs.

Refer to Section 10.5 of the Supplementary Report for further

discussion.


88

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.94 10.6.3.5,

10.6.5

The groundwater predictive modelling predicts about a

1.5m increase in groundwater elevation due to mining at

BH6MB3D and it is assumed a similar increase would be

applicable to BH6MB2D next to Big Footprint Swamp.

Figure 10-15 Big Footprint Swamp schematic cross-section

indicates that the wet season groundwater level rises to

the base of the bauxite layer. A predicted 1.5m increase in

groundwater level would bring the wet season

groundwater level to an elevation well-above the ironstone

layer. It appears that if the groundwater levels are

predicted to increase to an elevation well above the

ironstone layer, then it will be contributing significantly to

overland flow following mining.

The reference to "overland flow" is assumed to represent

overtopping of groundwater discharging into the

mined/rehabilitated pits. If so, this is highly unlikely to happen. An

increase of up to 1.5 m is predicted to occur (before bauxite is

removed) due to the rapid filling of macropores (tight vugs and

fissures) as recharge is increased over the adjacent mined areas.

Once the bauxite is stripped away and a depression is formed after

mining, the rising water table will intersect the floor of the pit and

groundwater will discharge into the pit. Because of the large volume

of the pit (open space that provides significant increase in storage

compared to the macropores) and effects of evaporation, significant

volumes of groundwater would be necessary to completely fill the

pit and overflow. Given that the maximum 1.5 m increase in the

water table is not predicted to reach the pre-mining ground surface,

it is highly unlikely that there will be sufficient volume of

groundwater discharging into the open pit (representing a much

larger storage volume) to cause overland flow. Refer to Section 10.5

of the Supplementary Report for further discussion.

19 19.95 10.6.5.3

The EIS has not provided any details around the modelling

of groundwater impacts to the shallow aquifers as a result

of groundwater extraction, only the basic outcome has

been provided. Furthermore, the predicted extraction rates

from the Gulf Alumina project have not been included in

the impact assessment.

Section 10.6.5.3 of the EIS describes modelling undertaken to assess

the potential impacts of extracting 400 ML/yr groundwater from the

shallow aquifer. Potential combined effects of pumping due to the

Bauxite Hills Project and SRBP can be assessed although this is likely

to be small due to the predicted localised drawdown and the

location of Gulf Alumina's bores within Namaleta and Lunette

aquifer, at some distance from Bauxite Hills proposed water supply

bores drawing from the Bulimba aquifer.

Refer to Section 10.5 of the Supplementary Report for further

discussion.

19 19.96 10.9.2

The section does not provide details about the proposed

groundwater monitoring network, assessment approach, or

reporting proposals. These details are relevant to the

development of a draft environmental authority.

Refer to Section 9 and Appendix I of the Supplementary Report.


89

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.97 10.9.1

The REMP will be an important management and

mitigation tool used to detect changes to groundwater

quality and therefore trigger management actions but it

has not been mentioned in this section.

Metro Mining notes the need to follow EHP's guideline in preparing

the REMP despite this not being included in Section 10.9.1 of the

EIS. The REMP is discussed in Chapter 9 of the EIS (Section 9.8.8).

Metro Mining has made a commitment in Table 9-21 of the EIS to

develop and implement a REMP to monitor water levels and quality

and Big Footprint Swamp. Given Metro Mining has committed to the

preparation of a REMP, and the further commitment to prepare the

REMP in accordance with the Receiving Environment Monitoring

Program Guideline - For use with Environmental Relevant Activities

under the Environmental Protection Act (1994) (EHP 2014) no

update to the information included in the EIS is proposed.

19 19.98 10.9.2.1 to

10.9.2.3

More information is required regarding groundwater

monitoring to inform the conditions on the EA.

As stated in Section 10.9.2.3 of the EIS, Metro Mining commits to preparing and implementing a Water Management Plan and collection of additional data, which will ensure ongoing information relating to groundwater conditions for the EA. The Water Management Plan will address potential water quality impacts as assessed in Chapter 9 and be relevant to the final EA Conditions. Metro Mining proposes, in the Draft EA conditions (Appendix I of the Supplementary Report), that the Water Management Plan be submitted to the administering authority at least 30 business days prior to the commencement of construction. Metro Mining has also undertaken an additional three rounds of both surface water and groundwater monitoring since the EIS was submitted. The additional water quality data is included in Section 9 of this Supplementary Report.

19 19.99 10.10

The draft ESCP is discussed in Sections 10.9.1.2 and

10.9.1.3 as a surface water management and mitigation

measure. ESCP should be included in Table 10-25 as a

surface water management and mitigation measure.

Section 10.9.1.2 and 10.9.1.3 of the EIS demonstrates that the ESCP

will be used as a management and mitigation measure for surface

water. Water quality monitoring is discussed in Section 9 of the



90

19 19.100

2.6.5, 11.6,

Appendix E2

(Section 4.1)

In Chapter 2 on Description of the Project, in Section 2.6.5,

it states that the MIA Sediment Basin would be sized to

capture and treat the 1 in 10 year ARI, 24 hour storm event.

This is the standard required by the DEHP Stormwater

Guideline. The EIS also states that sediment basins would

have sediment removed prior to the commencement of the

wet season to provide a maximum storage capacity.

The 1 in 10 year ARI, 24 hour storm from BOM is 235

millimetres at Skardon River. The area of the Mine

Infrastructure Area shown in Table 2-1 of the EIS is 6.05 ha.

Based on these two figures the runoff which needs to be

held in the MIA Sediment Basin in a 1 in 10 year rainfall

event is 14.2 Megalitres (ML).

In Chapter 2 in Figure 2-4 and again in Figure 2-14 the two

Sediment Dams catching sediment from the MIA are shown

on the eastern side of the product storage and works area.

To hold the 1 in 10 year rainfall event from the MIA two

Dams would need to be 7.1 ML each. Based on the scale

shown in Figure 2-4 these two Sediment Dams are only 30

m x 15 m and manifestly too small to hold the runoff

volume of 14.2 ML. If the average depth is 2 metres, these

Dams would hold only 0.9 ML each, seriously short of the

total requirement for the MIA. In addition the locations

shown on Figure 2-4 may not be suitable if the river bank

slopes and contours are unfavourable.

The proximity of the MIA Sediment Dams to the Skardon

River increases the risk of sediment discharge to the River if

the Basins are not effective. There are diversion banks

shown as lines in Figure 2-4 which are critical to

successfully collecting runoff from the MIA. There is also a

sediment trap grill/gate at the RoRo facility. How these

elements would work together effectively is not discussed.

There is no indication shown on Figure 2-20 as to how

runoff from the MIA in storm events would be directed

towards the Sediment Dams rather than flowing straight

down onto the ramp of the RoRo facility and then into the


successful takeover of Gulf Alumina’s assets, including the SRBP and

all existing infrastructure and proposed operations. The acquisition



Refer to Sections 4.4.1 of the Supplementary Report.


91

Submitter

No.

Submission

Reference No.

Relevant EIS


Skardon River.

In Chapter 11 in Section 11.6 on Regulated Structures it is

stated that the sediment dams required for the project

would be less than 2.5 ML in size. As discussed above it

appears that the two Sediment Dams shown in Figure 2-4

for the MIA may have to be much larger than 2.5 ML, or

alternatively there would have to be many more than two

Dams to retain the sediment and runoff if the sediment

retention standard is to be achieved.

The commitment to retain stormwater runoff and sediment

in the 1 in 10 year ARI, 24 hour event, as described in the

EHP Stormwater Guideline, was also made in Section 4.1 of

Appendix E2 – the Surface Water Technical Report. The

Erosion and Sediment Control Plan is referenced in

Appendix 3 for further information about sediment control;

but there is no information in Appendix 3 about the

Sediment Dams collecting runoff from the MIA.

The information supplied in Chapter 2 and Appendix E2

does not provide assurance that the site would be able to

direct, capture and manage sediment laden runoff flowing

out of the MIA towards the Skardon River.


92

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.101 11.6

The EIS states that the project met the following exemption

requirements for the undertaking of the consequence

category assessment under EHP’s Manual for assessing

consequence categories and hydraulic performance of

structures 2016:

contain fluids for no longer than 24 months

store less than 2.5ML of fluids

However the manual also provides the following

exemptions, which have not referred to:

minimise the site-specific risks of seepage

minimise passage of the wetting front and

allow the structure to be managed in a way that first

prevents then minimises the potential of fluids

overtopping

The exemption of the consequence category assessment

should meet all the exemption requirements in the

Guideline.


successful takeover of Gulf Alumina’s assets, including the SRBP and

all existing infrastructure and proposed operations. The acquisition



Refer to Sections 4.4.1 of the Supplementary Report.

19 19.102 11.9.1

The EIS indicates that bridge structures would be necessary

for the construction of the haul roads at river crossing

locations. There are two areas within the ML100047 and

ML100058 that would require the crossing of

approximately 400 to 500m of estuarine areas – see the

figures below. It is assumed that these bridge structures

would need to be designed and constructed in a specialised

way to be capable of crossing a considerable length of

estuarine area and provide support for haul road

operations. The EIS provides little to no details about the

design, construction, operation, potential impacts and

management measures regarding the bridge structures.

The relocation of the east-west BH1 haul road and use of existing

SRBP main haul road removes the potential need for bridge

structures. Refer to Section 11.7 of the Supplementary Report for

further discussion on bridge structures.


93

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.103 11.9.1

The EIS has not provided sufficient detail about how the

haul roads will perform under various flooding conditions

based on their location and design. The haul roads are

located within estuary areas and the predicted flooding

zone.

There is insufficient detail provided about the size and

capacity of the spoon drains, where they will be located,

where they will be releasing to and whether they will be

releasing directly to marine vegetation and therefore

receiving waters.

Refer to Sections 11.2 to 11.6 of the Supplementary Report.

19 19.104 11.4.2.3

No information is provided in the EIS regarding the likely

duration of flooding. This information is required to

understand how long the port infrastructure may be

inundated and for how long the haul road to the port may

be unpassable. This information is important to understand

for how long sediment pond releases and any other issues

at the port may not be able to be monitored during a flood

event, given that 4WD and helicopter access to the port

may not be possible during or post-cyclone.

Refer to Sections 11.2 to 11.7 of the Supplementary Report.

19 19.105 12.5.5

The EIS outlines that two 500 kW and two 250 kW diesel

fired power generation units would be installed at the site.

NOx emissions from these units would be main issue and

stack emission limits would be specified in the EA. EIS did

not provide any information on the stack emission

parameters.


19 19.106 12.6.1

It is stated in the EIS that for the preparation of the site for

construction involves clearing and burning vegetation.

Burning of vegetation would create odour and dust

nuisance. It is unclear how this issue would be minimised.


19 19.107 12.8

This section does not provide information on the dust

mitigation of conveyer belt, barge loading system, and bulk

carrier loading system and how dust spillage would be

managed so as to avoid release to waters.


the Bauxite Hills Project. Dust management within the SRBP MIA

and BLF will be undertaken in accordance with the EA for that

Project.


94

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.108 13, Appendix

G

The closest sensitive receiver is identified as being R44

which is 18km SW of MLA yet there is the accommodation

village within the MLA of the adjacent Skardon River

Bauxite project identified in Table 2-2 page 11 of Appendix

G. Campers at the river mouth of the Skardon River are also

potential sensitive receptors but this camp has not been

considered in the EIS.


the Bauxite Hills Project. Noise management within the SRBP MIA

and BLF will be undertaken in accordance with the EA for that

Project.

19 19.109 Appendix G

The background noise was measured to be below 30dB for

several nights. The minimum default value of 30dB should

therefore be used in model mining conditions equation.

The resulting model mining condition should include the

following table and criteria (refer to submission for the

criteria).



(Section 4.2.2)

The worse weather condition should be used to correspond

to the resulting worse favourable propagation condition.

Stability Class G is a temperature inversion strength which

corresponds to the winter temperature inversion. It is

consequently considered that Stability Class G should be

used for propagation for winter night time.

The CONCAWE methodology determines the stability classes into

categories and classes F and G are in the same category. VIPAC have

run a test comparing the two classes and there is 0.1 -0.2 dB

difference. As the results are rounded, there will be no material

change in the results between Class F which was used and the

suggested Class G. No change to the EIS is proposed.


95

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.111 13.6.2.2, 13.8

The EIS states that the noise level predicted to affect Gulf

Alumina’s accommodation camp is up to 62dB(A) LAeq

which is an exceedance of the 35dB(A) criterion. Due to its

close proximity, 62 dB(A) can also be taken to be the

predicted noise level at the Bauxite Hills project

accommodation camp. An attenuation of 30dB(A) would

need to be achieved at both camps to make the project

acceptable.

Section 13.8 paragraphs 1 (dot point 10), 3 and 4 describe

management and mitigation measures. Dot point 10 is not

accurate as the camp location is located within a high noise

operational environment. EHP notes Metro Mining’s

intention in paragraph 3 & 4 but EHP requires that the EIS

provides greater assurance that the required level of

attenuation (30dB(A)) can be achieved through location,

building design and mitigation measures and therefore that

they can comply with the model mining condition at this

location.

The Project will now utilise the existing and to be constructed

accommodation facilities approved for the SRBP. Consequently, the

comments in regard to potential noise impacts associated with

having two separate accommodation facilities in operation are no

longer relevant.


(Table 7-1)

While the noise level LAeq was predicted to be 62 dBA in

page 27, in the table 7-1 the village is shown with level of

41 to 44dBA.



(Section 3.2)

Underwater noise propagation in shallow water is sensitive

to the acoustic nature of the seabed. The river bed may be

acoustically reflective or acoustically absorptive and

whichever it is would change the acoustics propagation

beyond the proximity of the pilling. It is not clear in the EIS

what values were used for the seabed

absorption/reflectivity.


19 19.114 14.7.1.4

The EIS has not appropriately acknowledged or identified

the potential impacts to the groundwater environment, in

particular the shallow groundwater environment from

waste streams such as; hydrocarbons and chemicals in the

MIA, sewage effluent and leachate from bio-remediation

pads.

The management of waste streams within the MIA and BLF will be in

accordance with the SRBP EA. Metro Mining will utilise the approved

SRBP accommodation facilities to service the Bauxite Hills Project.

Management of the SRBP STP will be in accordance with the EA for

that Project.


96

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.115 14.9.1.2,

14.9.1.6

The EIS proposes to undertake bio-remediation of

hydrocarbons and the soil conditioning of compostable

wastes and bio-remediated hydrocarbons. Insufficient

details have been provided about the potential

environmental impacts associated with these activities and

the management practices that will be employed to ensure

this waste management practices is not a source of

contaminants to the receiving environment. Bio-

remediation pads and composting facilities can be sources

of contaminants to the receiving environment.

Metro Mining is not proposing specific bio-remediation pads. Any

hydrocarbon contaminated soils will be managed at the bio-

remediation pad located within the approved SRBP MIA.

The biosolids area is no longer required as the approved SRBP

accommodation facilities will be utilised for the Bauxite Hills Project.

Should a composting are be required in addition to that approved

for the SRBP it will be appropriately sized, the pad floor will be lined

or constructed with impermeable material and appropriately

bunded to prevent further contamination.

Refer to Sections 1.1 and 4.4 of the Supplementary Report in regard

to the utilisation of the approved SRBP infrastructure.

19 19.116 14.6

The EIS does not identify ASS as a potential waste stream

that should be managed, however, in Chapter 4 – Land ASS

is proposed to be removed and treated in land pads.




from ASS.



97

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.117 14.9.1.3

A sewage treatment plant (STP) is proposed to be located

near the accommodation camp. Insufficient information

has been provided in the EIS to enable the EA to include a

condition to regulate the activity.

Indicative treated sewage effluent characteristics provided

in Table 14-5 includes effluent characteristics that differ

markedly (especially with respect to nutrient

concentrations) to those specified in draft EA conditions

listed in Section 20.2.10 of the EIS, Schedule G – Sewage

Treatment, Table 2-111. It is not clear which effluent

quality characteristics are to be delivered by the proposed

STP treatment system for the project.

In addition, the EIS does not describe how solid waste

(typically as “biosolids”, screenings and grit) from the STP

would be managed and where the proposed composting

facility (involving the probable beneficial use of these

“biosolids”) would be located and managed.

The Project will utilise the existing and to be constructed

accommodation facilities approved for the SRBP. Consequently, the

comments in regard to the Bauxite Hills STP are no long applicable. Refer to Section 4.4 of the Supplementary Report in regard to the

utilisation of the approved SRBP infrastructure.

19 19.118 19.5.1

The section refers to the current design of the coastal

infrastructure required for the project but does not address

the alternative option on combining the infrastructure with

the adjacent Skardon River Bauxite Project.



utilise the approved SRBP accommodation camp, haul roads, MIA

(including the fuel farm and hazardous material storage area) and

BLF rather than constructing standalone MIA, BLF and RoRo

infrastructure. The originally proposed duplication of major

infrastructure for the Project has been completely avoided.

Refer to Sections 1.1 and 4.4 of the Supplementary Report in regard

to the utilisation of the approved SRBP infrastructure.


98

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.119 19.7, 19.7,

The EIS in Section 19.8 estimates the number of vessels

likely to be using the river to transport bauxite from the

project and the adjacent Skardon River Bauxite Project. It

has not indicated how many additional vessels will be

required for the delivery of plant and equipment and

removal of waste, the frequency of these movements, and

the potential impacts associated with them.

Logistic barge operations, including estimated number of barges and

support vessels during construction and operations, have been

provided in Section 17.6.3.5 of the EIS.

As stated in Section 17.6.3.5 of the EIS all materials associated with

the construction of the Project will be barged to site using shallow

draught barges from either the Port of Cairns or the Port of Weipa. It

is anticipated that approximately 30 barge movements, including

both to and from the site, will be required during the construction

period for equipment and infrastructure. These barges will typically

be 40 to 55 m in length with a maximum draft of between 2.4 to 2.9

m. Some smaller barge movements may be required for

consumables, anticipated to be at four movements per week during

construction.

It is anticipated that a single logistics barge will be required each

week during the operation of the mine. The barge will be used to

transport materials to site and take waste material from site on the

return transit. The logistic barges will be approximately 40 m in

length with a maximum draft of 2.4 m.

Potential impacts from these barge operations is discussed in

Section 17.6.4 and cumulative impacts are discussed in Section

17.6.5 of the EIS.

Note since the acquisition, barge operations will utilise the approved

SRBP BLF rather than the originally proposed standalone BLF.


99

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.120 19.7.4, 19.7.9

The project proposes 6-7 barge movements within the

Skardon River each day within a HEV river. There is no

quantitative assessment of the potential impacts of these

barge movements on the shoreline and bank evolution. It is

stated that mangroves on the shoreline will attenuate wave

action, resulting in a low risk rating of barge movements to

shore line and bank evolution. However, no quantitative

assessment of barge movement impacts in the river has

been made to support this finding. Section 19.7.4 does not

provide a conclusion as to whether the project would

impact on the shoreline or not. Section 19.7.9 does not

address shoreline erosion and states that barge

movements are not considered to have potential to cause

significant changes to coastal processes.

Since the EIS was released Metro Mining has undertaken wake and

wave modelling, presented in Appendix E, to assess potential impact

of barge movement on the shoreline and bank evolution. The results

from this assessment are also presented in Section 19.3 of the


Note since the acquisition of Gulf Alumina, barge operations will

utilise the BLF, at the approved SRBP port area, rather than the

originally proposed standalone BLF.

19 19.121 19.9

This section does not include management and mitigation

measures for potential impacts to water quality. Other

chapters of the EIS refer to the potential use of sediment

curtains as a mitigation measure for increased turbidity and

impacts on seagrass and marine fauna during construction

(e.g. during piling). The use of sediment curtains in tidal

areas can however be problematic and result in damage to

surrounding benthic habitats.

As per the ToR, water quality is discussed in Chapter 9 of the EIS.

Management and mitigation measures are discussed in Section 9.8

of the EIS.

Metro Mining will consider a range of operational and practical

management measures to minimise potential impacts to water

quality. Practical measures are outlined in Appendix A3 of the EIS.

Note piling will now be limited to the construction of the cyclone

moorings as the approved SRBP BLF will be utilised to support the

Bauxite Hills Project.

19 19.122 20

EHP acknowledges the draft EA conditions provided in

chapter 20 of the EIS. Draft EA conditions will be provided

as part of EHP’s EIS assessment report and would be based

on the following;

Model mining conditions;

Site specific conditions;

The EHP regulatory approach, which focuses on

providing outcome focused conditions; and

Prescriptive conditions, when considered necessary.

The draft EA conditions presented in Chapter 20 of the EIS has been

reviewed and updated based on received submissions. The updated

conditions are included in Appendix I of the Supplementary Report.


100

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.123 20 Condition D3 does not refer to sawfish and sharks and

needs to be amended.

Metro Mining addresses potential impacts to marine fauna from

underwater noise (particularly piling) in Section 6.8.1.1 of the EIS. In

summary, there is no scientific assessment on the impacts of noise

to these species to enable a thorough analysis of the potential

impacts from piling activities.

It is noted that Gulf Alumina’s draft EA has no conditions directly

relating to sawfish and sharks being impacted by underwater noise

mitigation, despite their more invasive bed-levelling activities that

are proposed. Metro Mining does not propose to include a specific

measure in the revised draft EA conditions presented in Appendix I.

19 19.124 20, Appendix

K

The EIS states that it is proposed to monitor the sediment

dam release point “initial after first release then monthly”

(Table 11-4 in Appendix K, page. 11-9). Monitoring initially

and then monthly may not allow sufficient sampling during

an event.

In this scenario, extreme summer rainfall events may

overwhelm sediment basins reducing their treatment

efficiency. During events, weekly sampling is unlikely to

provide sufficient information to characterise peak flows

which pose the highest risk for sediment runoff.

A final decision regarding the timing of initial and

subsequent sampling should be based on the modelled

characteristics of expected overflows from the water

release point.

Refer to Sections 4.4.1 of the Supplementary Report. Since the

release of the EIS, Metro Mining has completed a successful

takeover of Gulf Alumina’s assets, including the existing




19 19.125 20 (Schedule

F)

There is concern regarding access to the MIA during the

wet season when the haul road may be inundated by flood

water. The proponent needs to provide a commitment to

undertaking water quality monitoring during the wet

season and provide assurance that all reasonable steps are

taken to collect samples.

Metro Mining will utilise the approved SRBP MIA and existing haul

road to service the Bauxite Hills Project. The existing haul road is

located outside of the PMF and thereby providing year round access

to the SRBP MIA.


101

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.126

20 (Schedule

E, Table 20-6,

Schedule F,

Table 20-9,

Table 20-10)

The proposed limits for all parameters do not reflect the

approaches recommended in the QWQG (DEHP, 2009). For

a HEV area there should be no change in the 20th, 50th and

80th percentiles of all monitoring data. The proposed limits

should be amended to reflect this.


19 19.127 Appendix C

(Section 7)

In Appendix C Offsets Strategy (section 7 Next Steps)

discussions with stakeholders are proposed to develop an

offset package consisting of a combination of direct and

compensatory measures. The EIS notes that as a condition

of approval the proponent will have to submit a Direct

Benefit Management Plan (DBMP) and Offset Delivery Plan

to the Chief Executive at least three months prior to project

commencement.

Section 255D of the Sustainable Planning Act 2009 (SPA)

would apply for tidal works and removal or interference

with marine plants proposed outside of the mining lease.

The Department of Infrastructure, Local Government and

Planning (DILGP) would seek advice on an application

authorising these activities from EHP and DAF, specifically

on how the application meets the requirements of the

State Development Assessment Provisions (SDAP),

including offsets. However, only the Chief Executive of the

DILGP has the authority to enter into any subsequent

environmental offset agreements under SPA if offsets are

required.

Metro Mining will continue to work with relevant government

departments such as EHP, DILGP and DAF to complete the final

offset package.

Metro Mining will be submitting an Operational Works application

for tidal works and impact to marine plants for infrastructure

outside the MLA. Metro Mining will be completing a pre-lodgement

meeting with the State Assessment Referral Agency (SARA), part of

DILGP, to discuss the proposed infrastructure regulatory

requirements prior to submission.


102

Submitter

No.

Submission

Reference No.

Relevant EIS



(Section 6.4)

A DBMP may be suitable to offset some of the impacts of

the project but not all. For example, impacts to mangroves

may be achieved through a direct land based offset further

south along the Cape. Financial payments could also be

made. Any DBMP proposed would need to be able to

demonstrate a conservation outcome can be achieved for

the impacted matter. The program implemented via an

approved DBMP would need to have a strict monitoring

framework to measure changes in ecological indicators and

demonstrate conservation outcomes. See section 2.2.2 of

the Queensland Environmental Offsets Policy (V1.1).

Offsets proposed would need to meet the requirements of

the Queensland Environmental Offset Act, and should give

EHP confidence that offsets will compensate for the loss of

the matter and are achievable.

Table 6-1 of the Offset Strategy refers to an area of

Melalueca quinquinervia forest as an offset. The suitability

of this area to offset impacts is not clear. The EIS would

need to demonstrate a conservation/condition gain for the

particular matters impacted and a measurable increase in

habitat quality of at least 2 points. A habitat quality

assessment would need to be undertaken on the impact

site and the offset site to set a baseline from which to

measure improved habitat quality.

Consideration of a direct offset or an offset payment for

impacts to mangroves is encouraged.

Offsets cannot be actions that would already be required as

part of the management and mitigation measures. The

monitoring of Big Footprint Swamp and other wetlands and

springs would be required a part of carrying out the activity

on the site in any case and could not be taken to be an

offset.

The proponent could consider a financial offset if other

offset options do not comply with the policy.

Metro Mining will continue to work with relevant government

departments such as EHP, DILGP and DAF to complete the final

offset package.


103

Submitter

No.

Submission

Reference No.

Relevant EIS



(Section 5.2)

This section states that offsets are required for residual

impacts to 19.4 ha of HES wetlands. However, the

Executive Summary (page 22) states that 25 ha of HES

wetlands would be impacted at the port.


road to service the Bauxite Hills Project and in addition Metro

Mining has relocated the east-west BH1 haul road outside of the

mapped HES wetland area. As a result of these changes only 1.05 ha

of watercourse REs will be impacted. Refer to Section 6.12 of the



(Table 4-1)

The likely hood of occurrence assessment indicated that

the species is confirmed for the purposes of the

assessment. The Offset Strategy has not included an offset

for impacts to this species.

The Black-footed Tree Rat has been assessed against the significant

impact guidelines and no significant residual impact is likely and

henceforth no offset is proposed for this species.

The information for the Black-footed Tree Rat is included in Section

8.4.3.3 of the Supplementary Report.

Assessment of significant residual impacts for this species is

discussed in Sections 7.8 and 7.9 of the EIS.


(Table 4-1)

There is a real chance or possibility that the red goshawk,

northern quoll, masked owl and the bare-rumped sheath-

tail bat will occur on the project site.

EHP has recommended earlier in these comments that the

likelihood of occurrence assessment should reflect that

these species are considered “likely” to occur on the site.

Consequently these species should be subject to a full

assessment and offsets may be required for impacts to

their breeding, feeding or foraging habitat.


19 19.132 Appendix K

(Section 7.9)

Bio-remediation/land farming pads have not been

discussed in this section of the EM Plan. Bioremediation

and land farming has been proposed as a waste

management strategy.

Metro Mining is not proposing specific bio-remediation pads. Any

hydrocarbon contaminated soils will be managed at the bio-

remediation pad located within the approved SRBP MIA.

The composting area will be appropriately sized, the pad floor will

be lined or constructed with impermeable material and

appropriately bunded to prevent further contamination.



104

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.133

Appendix K

(Section 7.8,

Table 7.2)

Insufficient information has been provided regarding the

following disposal and management measures listed in

Table 7-2 of the EMP:

Disposal of organic waste disposed in the onsite inert

landfill area;

Effluent will be treated and used for irrigation on-site;

Sewage sludge and bio-solids used for soil conditioning

practices;

Disposal of concrete in mining pits.

Metro Mining will utilise the approved SRBP MIA, BLF and

accommodation facilities to service the Bauxite Hills Project.

Metro Mining is considering using the approved SRBP landfill for the

disposal of inert waste; however, the base case is still to have all

waste removed from site. Regulated waste will be removed from

site as described in the EIS.

As discussed in Section 14.9.1.2 of the EIS a composting system is

planned to be trialled to incorporate a number of organic waste

streams, including green waste and food wastes.

With the use of the approved SRBP accommodation facilities to

support the Bauxite Hills Project, effluent management is no longer

relevant to the Bauxite Hills Project. Effluent will be managed in

accordance with the SRBP EA.

19 19.134

Appendix K

(Section

7.9.1.6)

The location of the irrigation area for the sewage treatment

effluent has not been proposed and there are no

monitoring requirements stated to monitoring the

potential for shallow water aquifer contamination.

With the use of the approved SRBP accommodation facilities to

support the Bauxite Hills Project, effluent management is no longer

relevant to the Bauxite Hills Project. Effluent will be managed in

accordance with the SRBP EA.


105

19 19.135

Appendix K

(Section

10.7.1)

This section states that sediment control structures will be

used to control runoff of cleared slopes near watercourses,

however the majority of the EIS chapters do not recognise

the need for sediment control structures apart from the

one proposed in the MIA.

The EIS contains details of sediment controls in a number of

sections. These sections include:

Section 2.6.5 – MIA Sediment Basin

Section 2.7.2 – Construction Program

Section 2.7.3.1 – Civil Works

Section 2.8.4 – Mining Sequence

Section 4.5.1.4 – Soils (specifically section on soil erosion

susceptibility)

Section 4.6.1.2 – Erosion and Sediment Mobilisation

Section 4.8.1.1 – Topography and Surface Water Runoff

Section 4.8.1.3 – Erosion and Sediment Controls

Section 9.8.2 – Mine Pits and Sediment Management

Section 9.8.3 – Mine Infrastructure Area Drainage

Section 9.8.4 – Haul Road Cross Drainage

Section 9.8.5 – Erosion and Sediment Control

Section 11.9.1 – Haul Road Cross-Drainage

The Erosion and Sediment Control Plan (ESCP) is included as

Appendix A3 to the EIS. The ESCP should be referenced when

identifying sediment control structures for the Project. Sediment

control management measures are discussed in Section 5 of

Appendix K of the EIS. Sediment controls are also discussed in

Section 4.8.1.3 of the EIS and Appendix A3. Given the Project

sediment control structures are identified throughout the EIS no

further updates to the EIS are proposed.


106

Submitter

No.

Submission

Reference No.

Relevant EIS


Note that the sediment controls for the originally proposed

standalone MIA are no longer relevant as the approved SRPB MIA

and BLF will be utilised to support the Bauxite Hills Project.


(Section 11)

Based on the number of comments made about the surface

water EIS chapters, the environmental management

strategies proposed in the EM Plan will need to be updated.

While an EM Plan is no longer a specific regulatory

requirement of new EA applications, EHP may require

specific management plans in relation to surface water

management including but not limited to;

Erosion and sediment control plans;

Water management plans;

Receiving Environment Monitoring Plans;

Aquatic Ecology Monitoring Plans.

Metro Mining has already developed or has committed to

developing a number of management plans, including those listed.

The Erosion and Sediment Control Plan is included in the EIS as

Appendix A3.

Management plans that have been committed to in the EIS include:

A Water Management Plan;

If ASS is confirmed, an Acid Sulfate Soils Management Plan;

A Receiving Environment Monitoring Program (including aquatic

ecology); and

Marine water quality and ecology monitoring plan.

A Significant Species Management Plan These plans are discussed in

Append K and relevant chapters in the EIS. Given Metro Mining

commits to implementing the aforementioned plans no further

updates to the EIS are proposed.


(Section 9.8)

Section 9 of the EMP commits to water quality monitoring

in response to visual monitoring observations, activities or

incidents which may impact water quality, however no

details of such a monitoring plan is included in the EMP as

required of the TOR 8.14.8. Also, a marine monitoring plan

is committed to however not enough detail is provided

despite this being required by the EIS TOR 8.14.8.

Section 9.8.8 and Section 11.8.1 of Appendix K of the EIS provides

detail around the monitoring proposed and a commitment to

prepare monitoring plans. This commitment to prepare and

implement marine monitoring is already included in the EMP. The

nominated section of the Terms of Reference does not require that

a detailed monitoring plan is included in the EIS. Metro Mining

commit to a monitoring plan to be submitted within three months of

the grant of the EA. No change to the EIS is proposed.


107

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.138

Appendix K

(Section

10.7.1)

The management of a number of potential sources of

impacts has not been included in this section such as:

ASS;

bio-remediation pads;

effluent irrigation areas;

haul road construction and operations.




from ASS. Refer to Sections 5.5 and 5.6 of the Supplementary

Report.

Metro Mining is not proposing specific bio-remediation pads, rather

any hydrocarbon contaminated soils will be managed in the

approved SRBP MIA.

A biosolids management area is no longer required as Metro Mining

will utilise the approved SRBP accommodation facilities to service

the Bauxite Hills Project.

Haul road construction and operations are discussed variously

throughout the EIS and the Supplementary Report. Metro Mining

propose to provide an updated EMP on receipt of draft EA

conditions and the management of haul roads during construction

and operations will form part of that document.


108

Submitter

No.

Submission

Reference No.

Relevant EIS



(Section 12.7)

Groundwater monitoring networks need to be designed on

a site specific basis and should be tailored to detect

impacts to sensitive ecosystems. This means that a

monitoring network should be designed to achieve certain

objectives and goals. The EIS proposes a groundwater

monitoring program as the groundwater impact control

strategy but does not provide sufficient detail to inform the

proposed groundwater monitoring strategy such as:

the location of bores in respect to contaminant sources

the location of bores in respect to sensitive ecosystems

the appropriate location and design of bores for the

purpose of reference sites

the appropriate location and design of bores for the

purpose of compliance sites

the reason why some aquifers are targeted for

monitoring, such as the shallow aquifer will be

monitored as it will be used for potable water and is

also prone to surface water contamination

the reason for why contaminant parameters have been

nominated for monitoring

Refer to Appendix E1 of the EIS which describes the existing

groundwater network for the Project including the rationale for the

location of the bores. As a number of the existing bores within the

proposed mining pits will be destroyed during mining alternate

bores have been located nearby to those bores that will be

destroyed and the establishment and monitoring of these bores will

commence prior to construction.

The proposed Water Management Plan including the location of

each bore (including reference bores) and parameters to be

monitored are shown at Figure 9-5 and discussed in Section 9 and

Appendix I of the Supplementary Report.


109

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.140

Appendix K

(Section

11.8.2, 12.8)

The design of a REMP program should be undertaken in

accordance with the Receiving Environment Monitoring

Program guideline - For use with Environmental Relevant

Activities under the Environmental Protection Act (1994)

(DEHP 2014).

There are a number of considerations that need to be

included in the design of the REMP. The number and

location of monitoring sites for both surface and

groundwater needs to be reassessed. Additional upstream

freshwater monitoring sites are required, the depth at

which the groundwater bores would be sampled needs to

be included, the groundwater monitoring program should

assess both shallow and deep aquifers in the Project Area,

additional reference groundwater bores are required and

the surface springs should be included in the monitoring.

The REMP should also include riparian vegetation

monitoring in Big Footprint Swamp and hydrologic

indicators in wetlands.

A stated aim of the REMP was to “monitor and record the

effects of contaminant release on the receiving

environment and changes to groundwater and surface

water levels.” yet Section 11.8.2 did not describe

adequately describe the water quality monitoring, or

ground or surface water levels.



110

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.141

The EIS refers in different chapters to either “overburden

material, or subsoil'. In chapter two there are also

references to ‘sediment basins, sediment traps, and

sediment dams’. Where the EIS is addressing the same

area, the terminology should be consistent throughout for

consistency of reference.

For clarification of these terms definitions are provided below.

Sediment ponds: Sediment ponds are the permanent sediment

control storage features located in the approved SRBP MIA. These

are permanent features and will be retained throughout the life of

the Project; however Metro Mining is not proposing to construct

sediment ponds in addition to those approved in the SRBP EA.

Sediment basins: Sediment basins are temporary structures to be

used during construction, if required. Where sediment basins are

discussed in the document as permanent structures, these are

incorrectly referenced and should be labelled as sediment ponds.

Sediment traps: Sediment traps can include rock filter dams,

sediment trenches or sediment weirs. Appropriate access will be

provided to all sediment traps for maintenance and sediment

removal.

Overburden: As discussed in Section 2.6.9.2 of the EIS overburden is

waste material associated with the pit development and mining

(including sub-soils and weathered rock).

19 19.142 2.6.1

Section 2.6.1 refers to figure 2-3 (project infrastructure) for

layout of mine infrastructure. However figure 2-3 does not

show the location of the STP and associated irrigation area.

Metro Mining will utilise the approved SRBP accommodation

facilities to support the Bauxite Hills Project. Refer to Section 4.4.4



111

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.143 5.7 Dot point 5 on page. 5-63 refers to coal resources.

Error noted. This section should read:

“Throughout the construction, operation and decommissioning

phases, the Project has the potential to impact on these ecological

values through the following activities:

Removal of remnant vegetation for the MIA, open-cut mine pits,

road corridors and barge landing;

Topsoil stripping;

Construction of above ground buildings and facilities;

Day and night time operation of bauxite mining activities;

Stockpiling and transportation of the bauxite resource; and

General transportation movements.”

The online version will be amended to reflect this comment.

19 19.144 The PDF was protected making it very difficult to navigate

and extract information for assessment purposes. Unlocked pdf versions will be provided to EHP.

19 19.145

Appendix B1

(Section 7.1,

8.1)

Section 8.1 says that Section 7.1 would provide a detailed

floristic description but the link does not take me to a

detailed floristic description.

The floristic description of RE3.5.2 is provided in Table 7-3 of

Appendix B1 of the EIS. Attachment 3 of Appendix B 1 provides

descriptions of structure and floristics observed for RE3.5.2. See also

Attachment 6 of Appendix B1.

Metro Mining notes this incorrect link; however, as a floristic

description is provided in the sections mentioned above no updates

to Appendix B1 are proposed.

19 19.146 9.5.6.1

The last sentence of the paragraph discussing pH on page

9-33 states “Hence, site specific trigger values for EC should

be used as outlined in Table 9-2.”

The last sentence on page 9-33 should read: “Hence, site specific

trigger values for pH should be used as outlined in Table 9-2.”

The online version will be amended to reflect this comment.

19 19.147 9.5.1 The spatial location of the groundwater monitoring bores is

not presented in the EIS.

The spatial location of the groundwater monitoring bores is

presented in the EIS. Please refer to Figure 9-5 of the Supplementary

Report for the location of groundwater monitoring bores.


112

Submitter

No.

Submission

Reference No.

Relevant EIS


19 19.148 Figure 2-4 and

10-1

The EIS uses inconsistent names for some infrastructure

when they are referred to between text, tables and figures

throughout the EIS. In particular, sediment basins,

sediment dam, Stockpile sediment pond (Figure 10-1) and

Sediment trap (Figure 2-4) are used.

Metro Mining acknowledges there was some inconsistency with

terminology for sediment controls. References to sediment

infrastructure and management have been corrected in the



113

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