MACKAY SULPHATE OF POTASH PROJECT EPA S38 REFERRAL ...€¦ · A.3 Detailed Flora and Vegetation...

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MACKAY SULPHATE OF POTASH PROJECT EPA S38 REFERRAL SUPPLEMENTARY REPORT PREPARED FOR AGRIMIN LIMITED BY STANTEC AUSTRALIA PTY LTD December 2018

Transcript of MACKAY SULPHATE OF POTASH PROJECT EPA S38 REFERRAL ...€¦ · A.3 Detailed Flora and Vegetation...

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MACKAY SULPHATE OF POTASH PROJECT EPA S38 REFERRAL SUPPLEMENTARY REPORT PREPARED FOR AGRIMIN LIMITED BY STANTEC AUSTRALIA PTY LTD

December 2018

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Stantec │ EPA s38 Referral Supplementary Report │ December 2018

Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

QUALITY STATEMENT PROJECT MANAGER PROJECT TECHNICAL LEAD

Tracy Schwinkowski Sarah Osborne

PREPARED BY

/ 21/12/2018 Sarah Osborne / Dr Fiona Taukulis

21/12/2018

CHECKED BY

Peter de San Miguel

/ 21/12/2018

REVIEWED BY

Dr Matthew Todd / Dr Fiona Taukulis

21/12/2018

APPROVED FOR ISSUE BY

Peter de San Miguel

Stantec have been granted of authority to act on behalf of Agrimin’s CEO.

21/12/2018

Authority to act on behalf of Agrimin Limited APPROVED BY

PERTH 41 Bishop Street, JOLIMONT, WA 6014 TEL +61 (08) 9388 8799

REVISION SCHEDULE

Rev No. Date Description

Signature or Typed Name (documentation on file)

Prepared by

Checked by

Reviewed by

Approved by

0.1 3/12/18 Internal Draft for Review SO/FT PD MT SO

0.2 4/12/18 Draft for Client Comment SO/FT PD PD SO

0.3 10/12/18 Internal Final for Review PD /FT PD SO SO

1.0 12/12/18 Final for Client Comment PD/FT/SO BH PD PD

Final 21/12/18 Final for Submission to EPA SO PD MS PD

Mark Savich

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Stantec │ EPA s38 Referral Supplementary Report │ December 2018

Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final │ Page iii

Abbreviations Agrimin Agrimin Limited

AH Act Aboriginal Heritage Act 1979

BAM Act Biosecurity and Agricultural Management Act 2007

BC Act Biodiversity Conservation Act 2016

CASA Civil Aviation Safety Authority

CALM Act Conservation and Land Management Act 1984

CCWA Conservation Council of Western Australia

CHMP Cultural Heritage Management Plan

Cwth Commonwealth

DBCA Department of Biodiversity, Conservation and Attractions

DFES Department of Fire and Emergency Services

DFS Definitive Feasibility Study

DJTSI Department of Jobs, Tourism, Science and Innovation

DMAs Decision Making Authorities

DMIRS Department of Mines, Industry Regulation and Safety

DoEE Commonwealth Department of the Environment and Energy

DPLH Department of Planning, Lands and Heritage

DWER Department of Water and Environmental Regulation

DWER – Regulation Department of Water and Environmental Regulation – Environmental Regulation

DWER – Water Department of Water and Environmental Regulation – Water

EIA Environmental Impact Assessment

EIL Ecological Investigation Level

EP Act Environmental Protection Act 1986

EPA Environmental Protection Authority

EPAS Department of Water and Environmental Regulation – EPA Services

EPBC Act Environment Protection and Biodiversity Conservation Act 1999

FID Final Investment Decision

GL gigalitre

GL/a gigalitre per annuum

GDEs Groundwater Dependent Ecosystem

ha hectare

HIL Health Investigation Levels

IPA Indigenous Protected Area

km kilometre

m meters

MCP Mine Closure Plan

MNES Matter of National Environmental Significance

MRWA Main Roads Western Australia

Mt million tonnes

MW megawatt

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Stantec │ EPA s38 Referral Supplementary Report │ December 2018

Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final │ Page iv

NGER Act National Greenhouse and Energy Reporting Act 2007

PEC Priority Ecological Communities

NT Northern Territory

NT Act Native Title Act 1993

PMST Protected Matters Search Tool

RO Reverse Osmosis

RIWI Act Rights in Water and Irrigation Act 1914

SOP Sulphate of Potash

SRE Short Range Endemic

TDS total dissolved solids

TEC Threated Ecological Communities

tpa tonnes per annum

WA Western Australian

WC Act Wildlife Conservation Act 1950

WAH Western Australian Herbarium

WHO World Health Organisation

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Stantec │ EPA s38 Referral Supplementary Report │ December 2018

Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

MACKAY SULPHATE OF POTASH PROJECT EPA s38 Referral Supplementary Report

CONTENTS Abbreviations ................................................................................................................................................................ iii 1. Purpose and Scope of Supplementary Report ........................................................................................... 1 2. Proponent and Proposal Description (Part A) ............................................................................................ 2 2.1 Proponent ......................................................................................................................................................... 2 2.2 Proposal Type ................................................................................................................................................... 2 2.3 Proposal Description ........................................................................................................................................ 2 2.3.1 Tenure and Land Access ........................................................................................................................ 4 2.3.2 Mining (Brine Extraction) ......................................................................................................................... 7 2.3.3 Evaporation Ponds and Waste Salt Disposal ....................................................................................... 8 2.3.4 Processing Plant ....................................................................................................................................... 8 2.3.5 Supporting Infrastructure ........................................................................................................................ 9 2.3.6 Infrastructure Corridors .......................................................................................................................... 10 2.3.7 Transport .................................................................................................................................................. 10 2.3.8 Timing and Staging ................................................................................................................................ 10 2.3.9 Local and Regional Context ................................................................................................................ 10 2.4 Proposal Justification ..................................................................................................................................... 11 3. Stakeholder Engagement (Part B) .............................................................................................................. 12 3.1 Stakeholder Consultation ............................................................................................................................. 12 4. Environmental Impacts (Part B) ................................................................................................................... 13 4.1 Key Environmental Factors ........................................................................................................................... 15 4.1.1 Flora and Vegetation ............................................................................................................................ 15 4.1.2 Terrestrial Fauna ..................................................................................................................................... 19 4.1.3 Inland Waters .......................................................................................................................................... 27 4.2 Other Environmental Factors or Matters .................................................................................................... 31 4.2.1 Landforms ................................................................................................................................................ 31 4.2.2 Subterranean Fauna .............................................................................................................................. 32 4.2.3 Terrestrial Environmental Quality .......................................................................................................... 35 4.2.4 Air Quality ................................................................................................................................................ 37 4.2.5 Social Surrounding ................................................................................................................................. 39 4.2.6 Human Health ......................................................................................................................................... 43 5. Other Approvals and Regulation (Part C) ................................................................................................. 44 5.1 State and Local Government Approvals ................................................................................................... 44 5.2 Commonwealth Government Approvals .................................................................................................. 46 5.2.1 Summary of the Existing Environmental Value(s) that related to MNES ........................................ 46

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Stantec │ EPA s38 Referral Supplementary Report │ December 2018

Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

5.2.2 Nuclear Action ....................................................................................................................................... 50 5.2.3 Potential Impacts to MNES and Mitigation Measures ...................................................................... 50 6. Proposed Outcomes and Offsets ............................................................................................................... 54 7. Holistic Impact Assessment .......................................................................................................................... 55 8. References ..................................................................................................................................................... 57

LIST OF TABLES Table 2-1: Summary of the Proposal ......................................................................................................................... 2 Table 2-2: Mackay Proposal Location and Proposed Extent of Physical and Operational Elements ............ 4 Table 3-1: Mackay Proposal Project Stakeholders .................................................................................................. 12 Table 4-1: Baseline Environmental Studies ............................................................................................................... 13 Table 4-2: Flora and Vegetation .............................................................................................................................. 15 Table 4-3: Terrestrial Fauna ....................................................................................................................................... 19 Table 4-4: Inland Waters ........................................................................................................................................... 27 Table 4-5: Landforms ................................................................................................................................................. 31 Table 4-6: Subterranean Fauna ................................................................................................................................. 32 Table 4-7: Terrestrial Environmental Quality ............................................................................................................. 35 Table 4-8: Air Quality ................................................................................................................................................... 37 Table 4-9: Social Surrounding ..................................................................................................................................... 39 Table 4-10: Human Health .......................................................................................................................................... 43 Table 5-1: State and Local Government Approvals ............................................................................................... 44 Table 5-2: MNES Potentially Present within the Development Envelope (360 Environmental 2018a) ............. 47 Table 5-3:Potential Impacts on MNES and Mitigation Measures .......................................................................... 51

LIST OF FIGURES Figure 2-1: Mackay Proposal Local and Regional Context ..................................................................................... 3 Figure 2-2: On-lake and Off-lake Development Envelope and Indicative Mine Footprint and Trench Layout5 Figure 2-3: Access Road and Pipeline Corridor Development Envelopes ............................................................ 6 Figure 2-4: Mackay Proposal Conceptual Hydrogeological Model (Note: Brine extraction trenches are not drawn to scale) .............................................................................................................................................................. 7 Figure 2-5: Mackay Proposal Evaporation Pond Layout (20 Years) ....................................................................... 9 Figure 4-1: Mackay Proposal Priority Flora, Potentially Conservation Significant Flora and Weed Species .. 18 Figure 4-2: Mackay Proposal On-lake Fauna Habitat Mapping and Conservation Significant Fauna (Vertebrate Fauna) ..................................................................................................................................................... 23 Figure 4-3: Mackay Proposal Conservation Significant Fauna (Waterbirds) ...................................................... 24 Figure 4-4: Mackay Proposal Fauna Habitat Mapping and Conservation Significant Fauna (Aquatic Invertebrates and SREs) .............................................................................................................................................. 25 Figure 4-5: Mackay Proposal Access Corridors Fauna Habitat Mapping and Conservation Significant Fauna (Vertebrate Fauna) ..................................................................................................................................................... 26 Figure 4-6: Mackay Proposal Lake Elevation and Hydrology ................................................................................ 30 Figure 4-7: Mackay Proposal Subterranean Fauna Potential Conservation Significant Species .................... 34

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Stantec │ EPA s38 Referral Supplementary Report │ December 2018

Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

Figure 4-8: Mackay Proposal On-lake and Off-lake Aboriginal Heritage Places (Lodged and Registered) . 41 Figure 4-9: Mackay Proposal Corridor Envelops Aboriginal Heritage Places (Lodged and Registered) ....... 42 Figure 7-1: Preliminary Conceptual Site Model of Lake Mackay indicating Connectivity and Interactions between Key Environmental Factors, in relation to Potential Impacts and Mitigation Measures. ................. 56

LIST OF PLATES Plate 1: Mackay Proposal Trial Brine Extraction Trench ............................................................................................ 7

APPENDICES Appendix A Flora and Vegetation Survey Reports A.1 Level 1 Fauna and Single Phase Level 2 Flora and Vegetation Survey (ecologia Environment 2017) A.2 Detailed Flora and Vegetation Assessment (360 Environmental 2017) A.3 Detailed Flora and Vegetation Assessment at Lake Mackay (Strategen 2018) A.4 Vertebrate Fauna and Flora Risk Assessment (Strategen 2018) Appendix B Terrestrial Fauna Survey Reports B.1 Kiwirrkurra Indigenous Protected Area Bushblitz Survey (Cowan et. al. 2015) B.2 Single Phase Level 2 Fauna Survey at Lake Mackay (360 Environmental 2018) B.3 Waterbird Survey at Lake Mackay (360 Environmental 2017) B.4 Level 2 Vertebrate and Targeted Fauna Survey (Strategen 2018) Appendix C Aquatic Ecology Reports C.1 Survey for Aquatic Macroinvertebrates and SRE Fauna for the Mackay SOP Project, Western

Australia (Invertebrate Solutions 2017) C.2 Survey for Aquatic Macroinvertebrates for the Mackay SOP Project, Western Australia (Invertebrate

Solutions 2018) C.3 Dual Phase Survey for Short Range Endemic Fauna for the Lake Mackay SOP Project, Western

Australia (Invertebrate Solutions 2017). Appendix D Hydrology Report Appendix E Subterranean Survey Reports E.1 Subterranean Fauna Risk Assessment (ecologia Environment 2017) E.2 Pilot Survey for Subterranean Fauna for the Mackay SOP Project, Western Australia (Invertebrate

Solutions 2017) E.3 Phase 1 Survey for Subterranean Fauna for the Mackay SOP Project, Western Australia

(Invertebrate Solutions 2018) Appendix F Acid Sulphate Soil Investigation Appendix G Uranium and Thorium Analytical Review Appendix H Protected Matters Search Tool Results H.1 PMST Results On-Lake and Off-lake H.2 PMST Results Access Corridors

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

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1. Purpose and Scope of Supplementary Report

This Supplementary Report is being submitted in accompaniment to the referral of the Mackay Sulphate of Potash Project (the Project; the Proposal) under Section 38 of the Environmental Protection Act 1986 (EP Act). This document is structured to provide detailed information on:

• Part A

○ the proponent and proposal description;

• Part B

○ stakeholder engagement;

○ consideration of environmental impacts including key environmental factors:

- flora and vegetation;

- terrestrial fauna; and

- inland waters.

• Part C

○ consideration of other State and Local approvals;

○ consideration of Commonwealth Government approvals including Matters of National Environmental Significance protected under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act);

○ consideration of proposed outcomes and offsets; and

○ consideration of holistic impact assessment.

This document has been prepared in accordance with the:

• Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures 2016;

• EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c);

• Instructions for the referral of a Proposal to the Environmental Protection Authority (EPA) under Section 38 of the EP Act (EPA 2018d); and

• requirements set out in the EPA “Instructions on how to prepare an Environmental Review Document” for Part B of the Section 38 referral (EPA 2018e).

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

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2. Proponent and Proposal Description (Part A)

2.1 Proponent Agrimin Limited (Agrimin) (the Proponent) is a Western Australian minerals company that has 100% ownership of the Mackay Sulphate of Potash (SOP) Project (the Proposal). Agrimin’s Australian Company Number is 122 162 396.

2.2 Proposal Type The Proposal may be considered a significant proposal requiring a formal environmental impact assessment under Part IV, Section 38 of the EP Act. Therefore, referral of the Proposal is warranted for consideration for assessment by the EPA.

The Proposal may trigger a ‘controlled action’ under the Commonwealth EPBC Act. Therefore, Agrimin is referring this Proposal concurrently under the EP Act and EPBC Act. If the Proposal requires assessments under both Acts, Agrimin will seek bilateral assessment process to allow the EPA to assess any controlled action as defined by the Commonwealth Department of the Environment and Energy (DoEE).

2.3 Proposal Description The Proposal is located in the East Pilbara region of Western Australia (WA), adjacent to the WA and Northern Territory (NT) border, approximately 490 km south of Halls Creek (Figure 2-1). A summary of the Proposal is provided in Table 2-1.

Table 2-1: Summary of the Proposal

Proposal title Mackay SOP Project

Proponent name Agrimin Limited

Short description The Proposal involves the development of a greenfields SOP fertiliser operation which is currently designed to operate for a 20-year period. The Proposal involves the on-lake development of trenches and solar evaporation ponds for brine extraction and SOP production. The off-lake development includes a processing plant, associated site infrastructure and access roads for trucking SOP product to Wyndham Port. A northern linear access corridor will include the primary site access road, and potentially a water supply pipeline. A southern infrastructure corridor may be used as an alternate water supply option.

Agrimin proposes to extract brine (hypersaline groundwater) from the void spaces in the salt lake sediments and harvest the precipitated potassium-bearing salts to produce a SOP fertiliser product. It is proposed that brine will be extracted from a network of shallow trenches established on the surface of Lake Mackay. The Proposal has a project life of 20 years with targeted construction commencement in 2020 and first production in 2022.

Table 2-2 provides a summary of the proposed extent of physical and operational elements of the Proposal.

Agrimin has completed more than 17 environmental baseline studies to develop an understanding of the Proposal area’s ecological and social values. A holistic impact assessment has commenced to understand the ways in which the Proposal may impact Lake Mackay and surrounding environments, and the best means to mitigate these impacts. As Agrimin moves into the final feasibility and design stages of the Proposal, further studies will be undertaken to increase the robustness of the holistic impact assessment. Agrimin has actively engaged with a variety of stakeholders, in particular the traditional owners around Lake Mackay.

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

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Figure 2-1: Mackay Proposal Local and Regional Context

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

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Table 2-2: Mackay Proposal Location and Proposed Extent of Physical and Operational Elements

Element Location Proposed extent

Physical elements

On-lake Development Envelope: Brine extraction trenches and evaporation ponds.

Figure 2-2 Disturbance of no more than 10,000 ha within the 218,400 ha On-lake Development Envelope (less than 3 % of the lake’s surface).

Off-lake Development Envelope: Processing infrastructure, access roads, associated project infrastructure (camp, airstrip).

Figure 2-2 Clearing of no more than 100 ha of native vegetation within the 680 ha Off-lake Development Envelope.

Northern Infrastructure Development Envelope: Access road and water pipeline.

Figure 2-3 Clearing of no more than 1,000 ha of native vegetation within the 57,808 ha Northern Infrastructure Development Envelope.

Southern Infrastructure Development Envelope: Potential water pipelines.

Figure 2-3 Clearing of no more than 300 ha of native vegetation within the 12,300 ha Southern Infrastructure Development Envelope.

Operational elements

Brine Abstraction Figure 2-2 Abstraction of up to 70 GL per annum (GL/a) of hypersaline brine.

Water Abstraction Pending Abstraction of up to 5 GL/a of groundwater for processing.

Water Treatment Figure 2-2 Treatment of no more than 5 GL/a of water through a reverse osmosis plant.

Waste Salt Figure 2-2 Disposal of no more than 18 million tonnes per annum of waste salt to be retained on the lake surface.

2.3.1 Tenure and Land Access Agrimin currently holds Exploration Licences and Miscellaneous Licences associated with the Proposal area. Relevant mining tenure will be obtained under the Mining Act 1978 to support mining and processing activities.

The Proposal is within the Kiwirrkurra determination area (Determination Number: WCD2001/002) under the Native Title Act 1993 (NT Act). Agrimin has signed a Native Title Agreement (WAD6019/1998) with the Tjamu Registered Native Title Body Corporate for the Kiwirrkurra People. Agrimin has also prepared Cultural Heritage Management Plan (CHMP) with the Kiwirrkurra People Native Title holders to manage interactions and dealings with Traditional Owners.

The Proposal is also located within Part III Aboriginal Reserve 24923 that was created under the Aboriginal Affairs Planning Authority Act 1972. Under this Act the Kiwirrkurra Native Title holders have exclusive rights to occupy, use and benefit from the Reserve. Land within the within Part III Aboriginal Reserve 24923 is non-transferable freehold title under the Aboriginal Land Rights Act 1976. Agrimin has been issued with mining entry permits by the Minister for Aboriginal Affairs, authorising it to access the Aboriginal Reserve and the Minister for Mines and Petroleum has issued the corresponding Consent to Mine notices.

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Figure 2-2: On-lake and Off-lake Development Envelope and Indicative Mine Footprint and Trench Layout

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Figure 2-3: Access Road and Pipeline Corridor Development Envelopes

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2.3.2 Mining (Brine Extraction) The Proposal includes a trench network on the lake’s surface (Figure 2-2), facilitating abstraction of up to 70 GL/a of hypersaline groundwater (brine). The depth of the trenches varies to allow sufficient volume and gradient for the brine to naturally flow along the trench network southwards to the feed channel. Lake trenches will have an approximate width of 7 m and will be approximately 4.5 m deep. The conceptual hydrological model provides a representation of the brine extraction process and general recharge regime (Figure 2-4). Plate 1 provides a photograph of a current trial trench located in the Proposal area.

Figure 2-4: Mackay Proposal Conceptual Hydrogeological Model (Note: Brine extraction trenches are not drawn to scale)

Plate 1: Mackay Proposal Trial Brine Extraction Trench

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The excavated trench material will be used to create a 1 m high bund along the sides of each trench. The purpose of the bund is to prevent trench inundation from surface water and to temporarily divert surface water associated with seasonal rainfall around the trenches.

A feed trench will be excavated along the southern limits of the trench network. Brine will be travel along the feed channel to the solar evaporation ponds with the assistance of pumping stations. The design of trench network will focus on retaining natural surface water movement patterns wherever possible.

2.3.3 Evaporation Ponds and Waste Salt Disposal A series of evaporation ponds (Figure 2-5) will be constructed on the south-western side of the salt lake. This will involve the cut-to-fill construction of pond walls on the surface of the lake using the lakebed clay sediments. The ponds can be unlined due to the lake’s suitable geotechnical foundations. The ponds will cover an initial area of approximately 3,400 ha and will be expanded up to 6,000 ha over a 20-year period. The ponds will have an eventual height of between 7 m to 20 m (Figure 2-5). The ponds will occupy less than 1.7% of the lake’s surface.

The Proposal will target potassium bearing salts through an initial process of evapoconcentration. This process will see brine enter the evaporation ponds from the feed channel, with waste salts including Halite, Thenardite and Epsomite precipitating out as the brine progresses through the ponds. The final pond will accumulate the targeted Kainite salt, which will then be wet harvested and pumped to the processing plant for conversion to the final SOP product.

The evaporation pond process is as follows (Figure 2-5):

• Pond 0 is a pre-saturation pond that concentrates the brine up to the point where salt precipitation will commence;

• Ponds 1 and 2 will precipitate mainly Halite and Thenardite. These are waste salts and will be left to accumulate in Pond 1 at an approximate rate of 70 cm per year. The pond walls will be raiser over time (to a maximum height of 7 m). In year 10 of the operation Pond 1B will be constructed and Pond 1A will subsequently be closed. Waste salts in Pond 2 will be wet harvested and retained on the lake within the pond. The eventual height of Pond 2 will be approximately 20 m;

• Pond 3 will precipitate mainly Epsomite. The waste salts in Pond 3 will be wet harvested and retained on the lake within the pond. The eventual height of Pond 3 will be approximately 20 m; and

• Pond 4 will precipitate the target Kainite. This will be wet harvested and pumped to the processing plant. No salt will be left within the pond.

The potassium bearing salts that are wet harvested from Pond 4 will be pumped in slurry formation, together with the pond brine, to the off-lake processing plant to produce SOP using conventional processing techniques.

Waste solids and brines from the processing plant will be returned to the evaporation ponds and selectively utilised to manage the precipitation pathway of the brine. All waste salt will be gradually dissolved back into the lake utilising ongoing rainfall events as the catalyst. Approximately 18 million tonnes per annum of waste salt will be generated and all waste salts will be retained on the lake surface. The residual waste salts will cover an area of up to 4,000 ha with an eventual height of between 7 m to 20 m.

Waste brine from any reverse osmosis (RO) plant will be transferred via a pipeline to the on-lake evaporation ponds.

2.3.4 Processing Plant The off-lake processing plant will be constructed on the western edge of the lake (Figure 2-2). The total processing infrastructure area (including supporting infrastructure) is proposed to be up to 100 ha. The plant has been designed to be slightly inland to avoid impacts on riparian vegetation of the lake. The key components of the plant will include flotation tanks, conversion tanks and crystallisation equipment.

The processing plant will receive potassium bearing salts via a pipeline connected to a wet harvester located in Pond 4. The salt will be screened and crushed to create a salt slurry which will be fed into a flotation process to remove any remaining unwanted waste salt. Following flotation, the concentrated salt will be decomposed (e.g. mixed) with brine and then combined with heated water (50°C) to dissolve Magnesium Sulphate which in turn precipitates SOP. Waste brine will either be recirculated for reuse in the process or pumped via a pipeline back to the evaporation ponds (Figure 2-2). The precipitated SOP will

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then be dried and loaded into trucks. Approximately 426,000 tonnes per annum (tpa) of SOP will be produced.

Figure 2-5: Mackay Proposal Evaporation Pond Layout (20 Years)

2.3.5 Supporting Infrastructure 2.3.5.1 Power Supply

A gas-fired power station will provide the power supply for the Proposal, estimated to have a maximum operating load of 16.8 megawatts. The power station will be located next to the processing plant with transmission lines feeding relevant infrastructure. The gas-fired power station will provide the co-benefit of heating water for processing requirements. Gas will be trucked to the Project via the Northern Access Corridor and stored onsite in tanks.

Remote diesel and/or solar powered generators will be utilised to power water pumping stations on the lake.

2.3.5.2 Water Supply

It is estimated that 3.3 GL/a of low-salinity water will be used to support the Proposal, primarily for use in the processing plant. This will require up to 5 GL/a of groundwater to be abstracted and treated via reverse osmosis to produce the Proposal’s estimated consumption of 3.3 GL/a. Two potential groundwater sources are being assessed, both comprising borefields that are external to the current proposed development envelopes. Water would be abstracted from the borefield and transported to the processing plant site via a pipeline. The pipeline will be aligned with proposed access corridors. A fresher quality water resource may reduce or remove the need for treatment by a RO plant.

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2.3.5.3 Site Infrastructure

Site infrastructure will include a RO plant (located next to the processing plant near the lake’s edge), waste water treatment facilities, a 200-room accommodation camp, buildings including administration, laboratory, medical treatment, vehicle and maintenance workshops, wastewater ponds and a communications tower.

Vehicles will access the Proposal area using existing roads that connect the processing plant site to the existing public road network. Internal site access roads will also be developed to support operations.

2.3.6 Infrastructure Corridors 2.3.6.1 Northern Infrastructure Development Envelope

The Northern Infrastructure Development Envelope (Northern Corridor) is defined as the envelope within which the Proposal’s access road will be contained, along with a potential water supply pipeline. The access road will extend north from the Project’s processing plant to the public Tanami Road. Approximately 75% of the proposed 389 km access road will occur along the existing cleared track that currently links the Proposal area to the Tanami Road. The access road will involve a disturbance footprint of up 1,000 ha within the 57,808 ha Northern Infrastructure Development Envelope.

Agrimin is reviewing the option of sealing a single lane of this access road. This would be after an initial period (12 to 18 months) of operations to allow compaction of the running surface prior to sealing.

2.3.6.2 Southern Infrastructure Development Envelope

The Southern Infrastructure Development Envelope (Southern Corridor) is the envelope within which a potential water supply pipeline may be contained. This corridor will extend south-west from Project’s processing plant location to the NT border. The corridor will involve a disturbance footprint of 300 ha to be located within the 12,300 ha Southern Corridor Development Envelope.

2.3.7 Transport The Proposal’s SOP product will be loaded onto quad road-trains via the load-out facility at the processing plant. The SOP product will then be transported offsite 980 km north to a storage shed located at Wyndham Port via the proposed access road (Northern Corridor), Tanami Road and then the Great Northern Highway (Figure 2-3). The SOP product will be loaded onto ships using existing wharf facilities at the Wyndham Port.

Agrimin intends to sell 5% of SOP products within Australia and export the remaining 95% of SOP products internationally.

2.3.8 Timing and Staging Agrimin is currently undertaking a Definitive Feasibility Study (DFS) for the Proposal that is expected to be completed in late 2019 and will form the basis for finalising financing for the construction of the Proposal and in making a Final Investment Decision (FID). After FID, funding approval and regulatory approvals processes, the Proposal’s construction and commissioning is estimated to take 36 months. A production ramp-up to 70% of full production is expected in the first 12 months of operations before progressing to the full production target of 426,000 tpa.

Agrimin is also reviewing the feasibility of a staged mine plan whereby the excavation and rehabilitation of brine extraction trenches will occur progressively over the Proposal’s 20-year life.

The current proposed Project Life is 20 years, however ongoing exploration and refinements in SOP processing techniques could extend the Proposal’s life to greater than 20 years.

2.3.9 Local and Regional Context An overview of the local and regional context of the Proposal is provided in Figure 2-1. The Proposal is located within Western Australia, 600 km south of Halls Creek and 790 km west of Alice Springs by road. It is located within the Kimberley Mineral Field 80, and the Shire of East Pilbara Local Government Area. The Kiwirrkurra community is the closest township to the Project, located 120 km south-west by road.

The Gibson Desert Nature Reserve is the located approximately 450 km south west of the Proposal and the nearest conservation reserve is the Karlamilyi National Park located approximately 600 km west of the Proposal.

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The closest industrial activity to the Proposal is Newmont’s Tanami Gold Operations in the Northern Territory, located 300 km north-east of the Proposal area. The Lake Disappointment Potash Project is located 600 km west of the Proposal area.

The Proposal is located on Lake Mackay, which is surrounded by numerous smaller peripheral lakes. The closest large lake systems to the Proposal include Lake Hazlett located 110 km to the north, Lake MacDonald located 110 km to the south and Lake Bennett located 260 km to the east. There are no RAMSAR wetlands located in close proximity to the Proposal area. No previous mining has occurred at Lake Mackay, although historical exploration activities have occurred in the area.

2.4 Proposal Justification The Proposal is aiming to produce a value-added SOP fertiliser product that can increase crop yields while improving national value, taste and appearance. Global SOP demand is experiencing rapid growth due to evolving food production practices, and Agrimin can have an important role in providing reliable seaborne supply of this high-quality fertiliser. Additionally, Australia is entirely reliant on imports of potash fertiliser and the Mackay SOP has the strategic benefit of developing an Australian-based supply of potash for local farmers.

The Proposal will create 200 jobs, including those in local communities. It will also be a catalyst for investment in regional infrastructure throughout the central and top end of Australia. The local Kiwirrkurra people have provided strong support to Agrimin and are enthusiastic about the range of opportunities that a long-term and large-scale Project can create. The Proposal has the potential to provide substantial benefits, including support for several land projects that are being implemented under the Kiwirrkurra Indigenous Protected Area (IPA) Plan for Country which manages and protects the biodiversity and cultural resources within the vast Kiwirrkurra region.

Lake Mackay has the following technical attributes that allow for large scale and low-cost SOP production:

• shallow and continuous brine resource suitable for sustainable extraction;

• large on-lake area suitable for unlined evaporation ponds. Unlined ponds have a low capital construction cost and the lake surface is the most favourable geotechnical location for the ponds;

• wet harvesting of targeted potassium bearing salts provides a reduced disturbance footprint, less diesel consumption and a low operating cost; and

• brine chemistry at Lake Mackay is suitable for conventional processing techniques to produce SOP.

Due to the nature of the SOP deposit on Lake Mackay being accessible from the shallow aquifer, the most feasible option is to abstract the groundwater is via excavation of trenches, as opposed to pumping via a deep borefield.

Agrimin has considered a range of alternatives to avoid and minimise any potential environmental impacts that could be associated with the Proposal:

• mine planning will focus on retaining surface water movement patterns on the lake’s surface wherever possible, and Agrimin will review the option for progressive excavation and rehabilitation of trenches during the life of the operation;

• all processing infrastructure and supporting facilities have been placed at least 500 m off the lake, therefore avoiding impacts to riparian vegetation and potentially conservation significant species of Tecticornia;

• any development on peripheral claypans has been avoided;

• culturally sensitive areas have been, and are planned to be, avoided within the off-lake, on-lake and infrastructure corridor envelopes;

• avoiding old growth spinifex (potential night parrot habitat) in off-lake and infrastructure corridor envelopes;

• the gas-fired power station provides the co-benefit of heating the water required in the processing plant. This has reduced the overall power demand of the Proposal, and driven the use of gas over diesel or renewable power generation; and

• water supply pipelines will be placed within existing and planned access road corridors wherever possible.

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3. Stakeholder Engagement (Part B) Agrimin is committed to ongoing stakeholder communication, engagement and consultation through the planning and approvals phase, as well as the construction, operational and closure phases of the Proposal. Key stakeholders have been outlined in Table 3-1.

Table 3-1: Mackay Proposal Project Stakeholders

Group Stakeholders

Commonwealth Government Agencies

• Commonwealth Department of the Environment and Energy (DoEE).

State Government Agencies • Environmental Protection Authority (EPA); • Department of Mines, Industry Regulation and Safety (DMIRS); • Department of Water and Environmental Regulation – EPA Services

(EPAS); • Department of Water and Environmental Regulation – Water (DWER –

Water); • Department of Water and Environmental Regulation - Environmental

Regulation (DWER – Regulation); • Department of Biodiversity, Conservation and Attractions (DBCA); • Department of Planning, Lands and Heritage (DPLH); • Main Roads Western Australia (MRWA); • Department of Jobs, Tourism, Science and Innovation (DJTSI); • Department of Fire and Emergency Services (DFES); • Civil Aviation Safety Authority (CASA); and • Members of Parliament.

Local Government Authorities

• Shire of East Pilbara; • Shire of Halls Creek; and • Shire of Wyndham-East Kimberley.

Native Title Representative Bodies

• Central Desert Native Title Services; and • Kimberley Land Council.

Indigenous Groups • Tjamu Aboriginal Corporation and Kiwirrkurra People; • Parna Ngururrpa Aboriginal Corporation and Ngururrpa People; and • Tjurabalan Native Title Land Aboriginal Corporation.

Environmental Interest Groups

• Conservation Council of Western Australia (CCWA); • Wildflower Society of Western Australia; • Goldfields Naturalist Club; and • Waterbird Conservation Group.

Industry Groups • Chamber of Commerce and Industry.

Note: Key stakeholders are in bold.

3.1 Stakeholder Consultation Agrimin has undertaken extensive community and stakeholder consultation as part of the design and feasibility assessments of the Proposal. These including presentations and briefings to stakeholder groups including representatives from environment, heritage, community and Indigenous groups, local, State and Commonwealth Government agencies.

Agrimin’s maintain a Stakeholder Engagement Register that includes specific consultation with stakeholders and a detailed response to issues is provided.

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4. Environmental Impacts (Part B) Agrimin has commissioned a substantial number of baseline environmental studies to gain an understating of the receiving environment for the Proposal (Table 4-1).

These studies formed the basis for the identification of key environmental factors for the Proposal, outlined in the Statement of Environmental Principles, Factors and Objectives (EPA 2016g), which require consideration under s38 EP Act assessments. Agrimin has also considered relevant EPA guidance for each of the factors and consulted with stakeholders including Decision Making Authorities (DMAs), Native Title Representative Bodies, Aboriginal communities and local shires.

The significance of the environmental factors relevant to the Proposal were also assessed in accordance with the EPA’s framework. The key environmental factors for the Proposal were identified as; Flora and Vegetation; Terrestrial Fauna; and Inland Waters (Table 4-2 to Table 4-4). Other environmental factors for the Proposal comprised: Landforms, Subterranean Fauna, Terrestrial Environmental Quality, Air Quality, Social Surroundings and Human Health (Table 4-5 to Table 4-10 ).

Key environmental factor tables (Table 4-2 to Table 4-4) have been developed in accordance with the EPA’s Instructions for the referral of a Proposal to the Environmental Protection Authority (EPA 2018d) under s38 EP Act and the Instructions and Template: Environmental Review Document (EPA 2018e). A preliminary impact assessment has been undertaken for each environmental factor, based on available information and studies completed to date.

A summary of current knowledge gaps is also provided within each of the environmental factor tables (Table 4-2 to Table 4-10), with additional studies underway to provide the required information and understanding for subsequent assessment phases. It is expected that the Proposal poses a low risk to the receiving environment and environmental values, with limited residual impacts expected. Where possible, Agrimin aims to preserve biological diversity and maintain ecological integrity, while recognising potential connections and interactions within the receiving environment.

Table 4-1: Baseline Environmental Studies

Environmental Factor

Reference Survey Dates Appendix

Flora and Vegetation

Level 1 Fauna and Single Phase Level 2 Flora Assessment Survey (ecologia Environment 2017a).

10 to 19 May 2018 Appendix A.1

Detailed Flora and Vegetation Survey – Lake Mackay (360 Environmental 2017a).

14 to 23 April 2017 Appendix A.2

Detailed Flora and Vegetation Assessment at Lake Mackay (Strategen Environmental 2018a).

10 to 15 November 2017 Appendix A.3

Vertebrate Fauna and Flora Risk Assessment (Strategen Environmental 2018b).

April 2018 Appendix A.4

Terrestrial Fauna

Kiwirrkurra Indigenous Protected Area Bushblitz Survey (Cowan et al. 2015).

5 to 19 September 2015 Appendix B.1

Level 1 Fauna and Single Phase Level 2 Flora Assessment Survey (ecologia Environment 2017a).

10 to 19 May 2018 Appendix A.1

Single Phase Level 2 Fauna Survey at Lake Mackay (360 Environmental 2018c).

10 to 19 May 2017 Appendix B.2

Waterbird Survey at Lake Mackay (360 Environmental 2017b).

14 to 17 April 2017 Appendix B.3

Level 2 Vertebrate and Targeted Fauna Survey (Strategen Environmental 2018a).

10 to 21 November 2017 Appendix B.4

Vertebrate Fauna and Flora Risk Assessment (Strategen Environmental 2018b).

April 2018 Appendix A.4

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Environmental Factor

Reference Survey Dates Appendix

Survey for Aquatic Macroinvertebrates and SRE Fauna for the Lake Mackay SOP Project, Western Australia (Invertebrate Solutions 2017c).

13 to 17 May 2017 (SREs) 14 to 17 April 2017 (Macroinvertebrates)

Appendix C.1

Survey for Aquatic Macroinvertebrates for the Lake Mackay SOP Project, Western Australia (Invertebrate Solutions 2018).

January 2018 Appendix C.2

Dual Phase Survey for Short Range Endemic Fauna for the Lake Mackay SOP Project, Western Australia (Invertebrate Solutions 2017a).

May/November 2017 Appendix C.3

Inland Waters Refer to Flora and Vegetation, Terrestrial Fauna and Subterranean Fauna Factors

Chapter 6. Hydrological and Hydrogeological Modelling for the Mackay SOP Project Prefeasibility Study. Report for Agrimin, Western Australia (Advisian 2018).

May 2018 N/A

Hydrology and hydrogeology of the Lake Mackay Sulphate of Potash (SOP) Project, Western Australia (Agrimin Ltd 2018).

October 2018 Appendix D

Subterranean Fauna

Subterranean Fauna Risk Assessment for the Lake Mackay SOP Project (ecologia Environment 2017b).

N/A Appendix E.1

Pilot Survey for Subterranean Fauna for the Lake Mackay SOP Project, Western Australia (Invertebrate Solutions 2017b).

12 to 18 May Appendix E.2

Phase 1 Survey for Subterranean Fauna for the Lake Mackay SOP Project, Western Australia (Invertebrate Solutions 2018).

12 to 20 November 2017 Appendix E.3

Landforms Refer to Flora and Vegetation, Terrestrial Fauna and Inland Waters Factors

Environmental Terrestrial Quality

Preliminary Acid Sulphate Soil Investigation (360 Environmental 2018b).

August to October 2017 Appendix F

Uranium and Thorium Analytical Review for Agrimin’s Mackay SOP Project (360 Environmental 2018d).

September 2018 Appendix G

Air Quality N/A N/A N/A

Social Surrounds

Cultural Heritage Management Plan (CHMP).

2015 to2018 N/A

Human Health Uranium and Thorium Analytical Review for Agrimin’s Mackay SOP Project (360 Environmental 2018d).

September 2018 Appendix G

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4.1 Key Environmental Factors 4.1.1 Flora and Vegetation Table 4-2: Flora and Vegetation

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

EPA Policy and Guidance What have you considered and how have you applied them in relation to this factor?

Key EPA Guidance • Environmental Factor Guideline: Flora and Vegetation (EPA 2016b). • Statement of Environmental Principles, Factors and Objectives (EPA 2016g). • Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures 2016. • EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c). Relevant Acts • Wildlife Conservation Act 1950 (WC Act). • Mining Act 1978. • Conservation and Land Management Act 1984 (CALM Act). • EP Act. • EPBC Act. • Biosecurity and Agricultural Management Act 2007 (BAM Act). • Biodiversity Conservation Act 2016 (BC Act) Relevant Technical Guidance • Technical Guidance: Terrestrial Flora and Vegetation Surveys for Environmental Impact Assessment (EPA 2016l). • Environmental Protection of Native Vegetation in WA: Clearing of Native Vegetation with Particular Reference to Agricultural Areas. Position Statement No. 2 (EPA 2000). • Environmental Protection (Clearing of Native Vegetation) Regulations 2004 (Clearing Regulations). • Guidance Statement No. 6 – Rehabilitation of Terrestrial Ecosystems (EPA 2006). • WA Environmental Offsets Policy (Government of Australia 2011). • WA Environmental Offsets Guidelines (Government of Western Australia 2014). Application of Policies and Guidance The EPA Factor Guideline for Flora and Vegetation was considered in relation to the following aspects: • Proposal design and layout were developed in direct consultation with DWER, DMIRS and DBCA. • Flora and vegetation surveys have been conducted in accordance with relevant technical guidance. • Referral information, and common issues encountered, with specific reference to potash proposals on salt lake systems. • Characterisation of the flora and vegetation within the receiving environment and identification of preliminary environmental values. • Identification of preliminary direct and indirect impacts for the Proposal and the application of the EPA mitigation hierarchy. • Potential interactions and connectivity in relation to holistic impact assessment.

Receiving Environment Describe the current condition of the receiving environment in relation to this factor.

On-lake and Off-lake Development Envelopes • Flora and vegetation surveys have been undertaken for the on-lake and off-lake development envelopes (Table 4-1; Appendix A.1 to Appendix A.4). • More than 250 plant taxa have been recorded, including one weed species (Malvastrum americanum) (in low abundance outside of the off-lake development envelope), with vegetation

condition generally described as excellent. • Up to five Priority species have been recorded (Figure 4-1) including:

• Tecticornia globulifera (P1); Goodenia virgata (P2); Thysanotus sp. Desert East of Newman (R.P. Hart 964), (P2), Stackhousia clementii (P3) and Goodenia modesta (P3). • Up to five potentially new species of Tecticornia (which may be of conservation significance) have been recorded (Figure 4-1) including:

• Tecticornia aff. calyptrata [M. Stone LM01.05], Tecticornia aff. calyptrata [M. Stone LM01.06], Tecticornia aff. calyptrata [M. Stone LM02.03], Tecticornia aff. calyptrata [A. Dalton LM0P.03] and Tecticornia aff. halocnemoides subsp. longispicata [M. Stone LM01.04].

• To date, no groundwater dependent flora or vegetation have been recorded. • No rare or threatened flora species listed under the EPBC Act or the WC Act have been recorded within the surveyed areas for the on-lake and off-lake development envelope. • No Threated Ecological Communities (TECs) or Priority Ecological Communities (PECs) have been recorded within the surveyed areas for the on-lake and off-lake development envelopes. Access Corridors • The northern and southern access corridors traverse through several different vegetation associations. • Desktop database searches identified up to 10 Priority flora species that may potentially occur in the northern access corridor development envelope including:

• Goodenia suffrutescens (P1), Teucrium sp. Sturt Creek (A.A. Mitchell 5536) (P1), Goodenia virgata (P2), Peplidium sp. Tanami (P.K. Latz 11904) (P2), Comesperma pallidum (P3), Crotalaria smithiana (P3), Goodenia halophila (P3), Goodenia modest (P3), Indigofera ammobia (P3), and Rothia indica subsp. australis (P3).

• Desktop database searches identified up to seven Priority flora species that may potentially occur in the southern corridor development envelope including: • Goodenia virgata (P2), Peplidium sp. Tanami (P.K. Latz 11904) (P2), Bergia occultipetala (P3), Goodenia halophila (P3), Goodenia modesta (P3), Rothia indica subsp. australis (P3), and Senna artemisioides subsp. alicia (P3).

• No rare or threatened flora species listed under the EPBC Act were identified as potentially occurring within the access corridors. • It is unlikely that any TECs or PECs would occur within the access corridors, with the majority of the northern corridor comprising existing, cleared tracks.

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*Photos from 360 Environmental Detailed Flora and Vegetation Survey August 2017

Key Knowledge Gaps and Proposed Further Studies / Investigations

• Verification of Tecticornia species with K. Shepherd from the Western Australian Herbarium (WAH). • Additional flora and vegetation surveying of the lake islands (if required, based on results of hydrogeological investigation and internal risk assessment). • Detailed flora and vegetation survey of the access corridors. • Risk assessment of Proposal impacts to Flora and Vegetation factor.

Proposal Activities Describe the proposal activities that have the potential to impact the environment.

• Disturbance of up to 10,000 ha (<5%) within a 218,359 ha on-lake development envelope (<3% of the total lake surface), including trenching, bunding and evaporation ponds. • Abstraction of up to 70 GL/a of brine from trenches over 20-year period and up to 5 GL/a of groundwater from bores for use in the processing plant. • Storage of waste salts in the evaporation ponds and gradual release to the lake over time. • Clearing of up to 100 ha of flora and vegetation within a 680 ha off-lake development envelope. • Clearing of up to 1,300 ha of flora and vegetation for access corridors within a 57,808 ha northern corridor development envelope and 12,300 ha southern corridor development envelope

(<3% of the total area). • Use of light and heavy vehicles and equipment for construction and operations including fuel storage. • Fugitive dust emissions from vehicles and equipment during construction and operation.

Assessment of Impacts Assess the impacts of the proposal and review the residual impacts against the EPA objective.

A preliminary assessment of potential direct and indirect impacts is provided for the Flora and Vegetation factor based on available information from studies completed to date and likely mitigation measures. Direct Impacts • Clearing for off-lake development and access corridors (avoiding Priority species) impacting flora and vegetation: low risk (minimal). • Hydrocarbon and/or chemical leaks and spills impacting peripheral flora and vegetation: low risk (minimal). Indirect Impacts • Increases in surface water and groundwater salinity due to runoff and release of waste salts from ponds, impacting peripheral flora and vegetation: low-medium risk (unknown). • Groundwater drawdown impacting island and peripheral flora and vegetation (including potential GDEs): low-medium risk (minimal). • Changes in hydraulic connectivity and groundwater quality impacting island and peripheral flora and vegetation (including potential GDEs): low risk (minimal). • Erosion and sedimentation due to on-lake and off-lake development, impacting peripheral flora and vegetation: low risk (minimal). • Potential formation of acid-generating material impacting peripheral flora and vegetation: low risk (minimal). • Introduction or spread of weeds and/or pathogens from throughout the Proposal area, impacting flora and vegetation: low risk (minimal). • Fugitive dust emissions from the Proposal including on-lake and off-lake development and access corridors impacting on flora and vegetation: low risk (minimal). • Increased incidents of bushfires from Proposal development and activities: low risk (minimal).

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Mitigation Describe the measures proposed to manage and mitigate the potential environmental impacts.

Avoid • Less than 5% of the on-lake development envelope and less than 2 % of the off-lake development envelopes will be subject to disturbance, and habitats are well-represented in the area. • Trenches and evaporation ponds will be located on the open playa of the lake, avoiding vegetation clearing, where possible. • Off-lake infrastructure has been configured to avoid riparian vegetation and conservation significant flora species, where possible. • Clearing and disturbance will be managed via a Ground Disturbance Permitting System to avoid unauthorised clearing of vegetation outside approved boundaries. Minimise • Vegetation clearing and disturbance will be minimised for on-lake and off-lake development and utilise existing tracks where possible. • Groundwater investigations and modelling will be used to investigate drawdown extent and minimise impacts to riparian vegetation associated with the lake and islands. • Evaporation ponds will contain waste salts and will be engineered to minimise excessive runoff of waste salts into the lake habitat, with gradual release over time. • Access roads to be appropriately engineered, with compaction, appropriate bunding and drainage implemented to prevent erosion and sedimentation. • Access roads will be subject to speed restrictions and dust suppression to minimise impacts on flora and vegetation, while the option of sealing the road is investigated to reduce dust. Manage • Hydrocarbon and /or chemical leaks and spills (expected to be rare) will be managed using bunding techniques, leak detection mechanisms and spill kits to restrict impacts. • Development and implementation of a Weed Control Management Plan to prevent the spread of weeds (if required), utilising the Kiwirrkurra IPA Rangers were possible. • Development and implementation of a site Hot Work Permit System, and Emergency Management Procedures, to minimise the risk of bushfires. • Development and implementation of a Dust Management Plan to minimise dust emissions within the Proposal area. Monitor • Regular weed monitoring and weed control program as per management plans and as required. • Development and implementation of riparian vegetation monitoring as part of the ecological monitoring program for the lake and peripheral habitat as required. Rehabilitate • Disturbed areas will be rehabilitated progressively, where possible or at closure. • A Mine Closure Plan (MCP) (in accordance with DMIRS guidelines) will outline specific closure objectives and completion criteria for the lake and peripheral habitat, including rehabilitation

as required.

Predicted Outcomes Describe the predicted outcome against the environmental objective and discuss whether there is likely to be a significant residual impact.

Residual Impacts • Detailed environmental impact and risk assessments have not yet been undertaken for the Flora and Vegetation factor, although based on available information from studies completed to

date significant residual impacts are not expected. • Knowledge gaps are currently being addressed to inform this process and develop suitable mitigation measures to avoid or minimise impacts, including any residual impacts. • This may include further refinement of the Proposal design, layout, development, operation and/or closure strategies to ensure the environmental risk is acceptable.

Assumptions Describe any assumptions critical to your assessment e.g. particular mitigation measures or regulatory conditions.

• The extent of impacts associated with the Proposal have likely been overestimated, with further refinement of engineering and design to maintain flora and vegetation values where possible.

• Loss of native vegetation due to clearing is not expected to be significant and vegetation units appear more broadly distributed, with biological diversity and ecological integrity to be maintained where possible.

• Impacts to Priority flora species will be avoided where possible. • Access corridors will utilise existing tracks where possible. • Additional surveying to address current knowledge gaps will provide suitable recommendations and mitigation measures to minimise impacts from the proposal where possible. • The EPA objective for Flora and Vegetation is expected to be met.

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Figure 4-1: Mackay Proposal Priority Flora, Potentially Conservation Significant Flora and Weed Species

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4.1.2 Terrestrial Fauna Table 4-3: Terrestrial Fauna

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

EPA Policy and Guidance What have you considered and how have you applied them in relation to this factor?

Key EPA Guidance • Environmental Factor Guideline: Terrestrial Fauna (EPA 2018c). • Statement of Environmental Principles, Factors and Objectives (EPA 2016g). • Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures 2016. • EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c). Relevant Acts • WC Act. • Mining Act 1978. • CALM Act. • EP Act. • EPBC Act. • BC Act. Relevant Technical Guidance • Technical Guidance Sampling Methods for Terrestrial Vertebrate Fauna (EPA 2016g). • Technical Guidance: Terrestrial Fauna Surveys (EPA 2016k). • Technical Guidance: Sampling of short-range endemic invertebrate fauna (EPA 2016i). • Interim Guideline for Preliminary Surveys of Night Parrot (Pezoporus occidentalis) in Western Australia (DBCA 2017). • Matters of National Environmental Significance. Significant impact guidelines 1.1 - Environment Protection and Biodiversity Conservation Act 1999 (DEWHA 2013). • Survey Guidelines for Australia's Threatened Birds (DEWHA 2010). • Guidelines for EPBC Act listed species. • General EPBC Act guidelines and policies. • Significant impact guidelines. Application of Policies and Guidance The EPA Factor Guideline for Terrestrial Fauna was considered in relation to the following aspects: • Proposal design and layout were developed in direct consultation with DWER, DMIRS and DBCA. • Fauna surveys have been conducted in accordance with relevant technical guidance. • Referral information, and common issues encountered, with specific reference to potash proposals on salt lake systems. • Characterisation of fauna habitat within the receiving environment and identification of preliminary fauna values. • Identification of preliminary direct and indirect impacts for the Proposal and the application of the EPA mitigation hierarchy. • Potential interactions and connectivity in relation to holistic impact assessment.

Receiving Environment Describe the current condition of the receiving environment in relation to this factor.

On-lake and Off-lake Development Envelopes • Fauna surveys, including vertebrate fauna (and waterbirds) (Table 4-1; Appendix A.1, Appendix A.4, Appendix B.1 to Appendix B.4), aquatic invertebrates (Table 4-1; Appendix C.1 to

Appendix C.2) and SREs (Table 4-1; Appendix C.1 to Appendix C.3) have been undertaken for the on-lake and off-lake development envelopes. Vertebrate Fauna • Four broad fauna habitats have been identified including Dune, Swale, Claypan Swale (high fauna value) (Figure 4-2), and Lake Margin, which were common and widespread, and in

close to pristine condition. • More than 110 fauna species have been recorded in total, comprising mostly birds and including 26 waterbird species. • Up to seven conservation significant fauna species have been recorded, including (Figure 4-2 and Figure 4-3):

• two mammals; Marsupial Mole (Notoryctes caurinus) (P4) and Bilby (Macrotis lagotis) (S3, Vu) • one reptile (Great Desert Skink (Liopholis kintorei) (S3,Vu) • four migratory waterbird species; Australian Painted Snipe (Rostratula australis) (S2, En), Common Greenshank (Tringa nebularia) (S5, Mi), Red-necked Stint (Calidris ruficollis), (S5, Mi) Sharp-tailed Sandpiper (Calidris acuminata) (S5, Mi).

• No Night Parrots have been recorded to date. Aquatic Invertebrates and SREs • One species of aquatic invertebrate has been recorded from the lake (Parartemia sp.) and another eight taxa have been identified from the peripheral claypans (including ostracods

and insects), with no species of conservation significance identified (Figure 4-4). • Up to 12 invertebrate taxa have been identified as possible SRE species, while an additional species is considered a likely SRE species (the isopod Buddelundiinae gen. nov. sp ‘mackay’)

(Figure 4-4). Access Corridors • Database searches and historical surveys of the northern access corridor development envelope identified 12 conservation significant fauna species that have been previously

recorded within the broader search area including (Figure 4-5 and Appendix B.1): • Grey Falcon (Falco hypoleucos) (T), Great Desert Skink (Liopholis kintorei) (T/Vu), Bilby (Macrotis lagotis) (T/Vu), Oriental Pratincole (Glareola maldivarum) (S5/Mi), Sharp-tailed Sandpiper (Calidris acuminata) (S5, Mi), Brush-tailed Mulgara (Dasycercus blythi) (P4), Spectacled Hare-wallaby (mainland) (Lagorchestes conspicillatus subsp. leichardti) (P4), Northern

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Short-tailed Mouse (Leggadina lakedownensis) (P4), Northern Marsupial Mole (Notoryctes caurinus) (P4), Marsupial mole (Notoryctes sp.) (P4), Southern Marsupial Mole (Notoryctes typhlops) (P4), and Princess Parrot (Polytelis alexandrae) (P4).

• Database searches and historical surveys of the southern access corridor development envelope five conservation significant fauna species that have been previously recorded within the broader search area including (Figure 4-5 and Appendix B.1): • Great Desert Skink (Liopholis kintorei) (T/Vu), Oriental Plover (Charadrius veredus) (IA/Mi), Brush-tailed Mulgara (Dasycercus blythi) (P4), Northern Marsupial Mole (Notoryctes caurinus) (P4), and Marsupial mole (Notoryctes sp.) (P4).

• Database searches identified additional conservation significant fauna species with the potential to occur within 20 km of the access corridors.

*Photos from 360 Environmental Single Phase Fauna May 2018, 360 Environmental Waterbirds Survey July 2017, Invertebrate Solutions Macroinvertebrate/SRE September 2017

Key Knowledge Gaps and Proposed Further Studies and Assessments

• Analysis of night parrot recordings against call reference library from WA populations. • Additional survey of conservation significant fauna of the lake islands (if required, based on results of hydrogeological investigation and internal risk assessment). • Additional SRE survey of the lake and islands (if required, based on results of hydrogeological investigation and internal risk assessment). • Additional aquatic ecology study of the lake and peripheral wetlands during flooding. • Targeted conservation significant fauna survey and habitat mapping along the access corridors. • Risk Assessment of Proposal impacts to Terrestrial Fauna factor.

Proposal Activities Describe the proposal activities that have the potential to impact the environment.

• Disturbance of up to 10,000 ha (<5%) within a 218,359 ha on-lake development envelope (<3% of the total lake surface), including trenching, bunding and evaporation ponds. • Abstraction of up to 70 GL/a of brine from trenches over 20-year period and up to 5 GL/a of groundwater from bores for use in the processing plant. • Storage of waste salts in the evaporation ponds and gradual release to the lake over time. • Clearing of up to 100 ha of flora and vegetation within a 680 ha off-lake development envelope. • Clearing of up to 1,300 ha of flora and vegetation for access corridors within a 57,808 ha northern corridor development envelope and 12,300 ha southern corridor development

envelope (<3% of the total area). • Use of light and heavy vehicles and equipment for construction and operations including fuel storage.

Potential Impacts Assess the impacts of the proposal and review the residual impacts against the EPA objective.

A preliminary assessment of potential direct and indirect impacts is provided for the Terrestrial Fauna factor based on available information from studies completed to date and likely mitigation measures. Direct Impacts • Disturbance for on-lake development of trenches and ponds impacting lake fauna: low risk (minimal). • Clearing for off-lake development and access corridors impacting fauna habitat: low risk (minimal). • Reduction in fauna habitat availability and increased habitat fragmentation and edge effects along access corridors: low-medium risk (unknown). • Hydrocarbon and /or chemical leaks and spills impacting fauna: low risk (minimal). • Increased risk of fauna injury or death accessing trenches or ponds: low risk (minimal). • Increased risk of fauna injury or death from vehicle or equipment strikes throughout the Proposal area: low-medium risk (unknown). • No direct impacts to migratory waterbirds as sufficient lake and peripheral habitat to remain and surface water movement patterns to be maintained where possible: low risk (minimal). • No direct impacts to Night Parrots or associated key habitat (considered minimal) within the off-lake development and along access corridors: low risk (minimal). Indirect Impacts • Introduction or spread of weeds/pathogens/feral animals from throughout the Proposal area, impacting fauna (including SREs, macroinvertebrates and waterbirds): low-medium risk

(unknown). • Changes in surface water movement patterns, due to on-lake and off-lake development, impacting lake or peripheral habitat and fauna (including SREs, macroinvertebrates and

waterbirds): low-medium risk (unknown). • Increases in surface water and groundwater salinity due to runoff and release of waste salts from ponds, impacting lake or peripheral habitat and fauna (including SREs,

macroinvertebrates and waterbirds): low-medium risk (unknown). • Groundwater drawdown impacting island and peripheral habitat and fauna (including SREs and macroinvertebrates): low risk (minimal). • Changes in hydraulic connectivity and groundwater quality impacting island and peripheral habitat and fauna (including SREs and macroinvertebrates): low risk (minimal). • Erosion and sedimentation due to on-lake and off-lake development, impacting peripheral habitat and fauna (including SREs and macroinvertebrates): low risk (minimal). • Potential formation of acid-generating material impacting lake and peripheral habitat and fauna: low risk (minimal). • Fugitive dust emissions including on-lake and off-lake development and access corridors impacting on fauna habitat: low risk (minimal). • Increased incidents of bushfires from Proposal development and activities impacting on fauna habitat or causing fauna mortality: low risk (minimal). • Noise, vibration or light impacting on fauna from Proposal development and activities: low risk (minimal).

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Mitigation Describe the measures proposed to manage and mitigate the potential environmental impacts.

Avoid • Less than 5% of the on-lake development envelope and less than 2% of the off-lake development envelopes will be subject to disturbance and fauna habitats are well-represented in

the area. • Trenches and evaporation ponds will be located on the open playa of the lake, avoiding islands and peripheral habitat. • Off-lake infrastructure has been configured to avoid riparian vegetation and favourable habitat for conservation significant fauna species, where possible. • Clearing and disturbance will be managed via a Ground Disturbance Permitting System to avoid unauthorised clearing of vegetation and fauna habitat outside approved boundaries. • Access corridors will be suitably designed and engineered to avoid key habitat that may support conservation significant fauna. Minimise • Clearing and disturbance will be minimised for on-lake and off-lake development and utilise existing tracks where possible. • A staged approach to trenching will be investigated to minimise impacts to the lake habitat. • Trenches and bunding will be engineered to maintain surface water movement patterns on the lake, where possible. • Groundwater investigations and modelling will be used to investigate drawdown extent and minimise impacts to lake, islands and peripheral fauna habitat. • Evaporation ponds will contain waste salts and will be engineered to minimise excessive runoff of waste salts into the lake habitat, with gradual release over time. • Access roads to be appropriately engineered, with compaction, appropriate bunding and drainage implemented to prevent erosion and sedimentation. • Access roads will be subject to speed restrictions and dust suppression to minimise impacts on fauna, while the option of sealing the road is investigated to reduce dust. • Implementation of traffic management system (including vehicle speed limits and driving on designated roads), and environmental awareness training, to minimise the likelihood of

fauna injury or mortality due to interaction with vehicles. • Removal of fauna habitat for the northern corridor will be minimised by utilising existing cleared tracks. • Putrescible waste off-lake will be stored in secure bins, to reduce the likelihood of attraction and/access of feral animals. Manage • A database of conservation significant fauna species and sightings will be established and maintained. • Site inductions and awareness training will be provided to site-staff for conservation significant species, and their preferred habitats. • A suitably qualified fauna spotter (holding a permit to handle and move conservation significant fauna under Regulation 15 of the WC Act) will be present for all clearing activities and

will have access to a care facility for rehabilitation of injured fauna (if required). • Wherever practical, clearing will be undertaken from one direction only, providing an opportunity for fauna to escape into surrounding vegetation. • Hydrocarbon and/or chemical leaks and spills (expected to be rare) will be managed using bunding techniques, leak detection mechanisms and spill kits to restrict impacts. • Appropriate waste management off-lake will be undertaken to reduce the likelihood of attraction and/access of feral animals. • All service trenches, pipelines and ponds for the Proposal will have suitably designed fauna egress or ramps to allow native fauna to escape, and will be regularly inspected by a fauna

spotter, with entrapped fauna removed and relocated to surrounding vegetation. • Investigate the options to provide fauna habitat connections along access corridors to allow movement between habitats and regular removal of fauna carcasses. • Signage will be installed along access roads for areas identified as key fauna habitat. • The northern corridor will be designated a private road with appropriate signage to reduce vehicular traffic where possible. • All native fauna injuries or mortalities will be recorded and reported internally and to appropriate regulatory agencies as required. • Development and implementation of Fauna Management Plans (for conservation significant fauna and feral animals) to protect native fauna and outline reporting requirements where

activities from the Proposal have resulted in injury or mortality, in collaboration with the Kiwirrkurra IPA Rangers where possible. • Development and implementation of a Dust Management Plan to minimise dust emissions within the Proposal area. • Development and implementation of a site Hot Work Permit System, and Emergency Management Procedures, to minimise the risk of bushfires. • Development and implementation of a Surface Water Management Plan to maintain ecological flows. Monitor • Monitoring of fauna species of conservation significance as per management plans and as required. • Development and implementation of an ecological monitoring program for the lake and peripheral habitat as required. Rehabilitate: • Disturbed areas will be rehabilitated progressively, where possible or at closure. • An MCP (in accordance with DMIRS guidelines) will outline specific closure objectives and completion criteria for the lake and peripheral habitat, including rehabilitation as required.

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Predicted Outcomes Describe the predicted outcome against the environmental objective and discuss whether there is likely to be a significant residual impact.

Residual Impacts • Detailed environmental impact and risk assessments have not yet been undertaken for the Terrestrial Fauna factor, although based on available information from studies completed to

date significant residual impacts are not expected. • Knowledge gaps are currently being addressed to inform this process and develop suitable mitigation measures to avoid or minimise impacts, including any residual impacts. • This may include further refinement of the Proposal design, layout, development, operation and/or closure strategies to ensure the environmental risk is acceptable.

Assumptions Describe any assumptions critical to your assessment e.g. particular mitigation measures or regulatory conditions.

• The extent of impacts associated with the Proposal have likely been overestimated, with further refinement of engineering and design to maintain fauna values where possible. • Key fauna habitat throughout the Proposal area (including for SREs, macroinvertebrates and SREs) appears more broadly distributed, with biological diversity and ecological integrity to

be maintained where possible. • Any conservation significant species associated with the lake, islands, subterranean or peripheral habitat are likely to be broadly distributed across the lake or peripheral habitat. • Migratory waterbirds previously recorded are transient, and are unlikely to be impacted by the Proposal, with broader availability of inland water resources • Adaptive management opportunities applied to Night Parrot monitoring will adopt leading practice conservation strategies in consultation with key stakeholder groups, including the

Kiwirrkurra IPA Rangers. • Access corridors will be designed to avoid significant disturbance to fauna habitat. • Additional surveying to address current knowledge gaps will provide suitable recommendations and mitigation measures to minimise impacts from the proposal where possible. • The EPA objective for Terrestrial Fauna is expected to be met.

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Figure 4-2: Mackay Proposal On-lake Fauna Habitat Mapping and Conservation Significant Fauna (Vertebrate Fauna)

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Figure 4-3: Mackay Proposal Conservation Significant Fauna (Waterbirds)

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Figure 4-4: Mackay Proposal Fauna Habitat Mapping and Conservation Significant Fauna (Aquatic Invertebrates and SREs)

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Figure 4-5: Mackay Proposal Access Corridors Fauna Habitat Mapping and Conservation Significant Fauna (Vertebrate Fauna)

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4.1.3 Inland Waters Table 4-4: Inland Waters

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

EPA Policy and Guidance What have you considered and how have you applied them in relation to this factor?

Key EPA Guidance • Environmental Factor Guideline: Inland Water Environmental Quality (EPA 2018a). • Statement of Environmental Principles, Factors and Objectives (EPA 2016g). • Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures.2016. • EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c). Relevant Acts • Rights in Water and Irrigation Act 1914 (RIWI Act). • WC Act. • Mining Act 1978. • CALM Act. • EP Act. • EPBC Act. • BC Act. Key Regulatory Technical Guidance and Policies • DWER Policies for the take and use of water. • DWER (Water) Policies for better understanding water resources and planning for their use. • DWER Policies for protecting public drinking water supplies and the natural environment. • DWER - Western Australian water in mining guidelines, May 2013 (DoW 2013). • Australian Rainfall and Runoff Guidelines (Geoscience Australia 2016). • Australian Groundwater Modelling Guidelines (Australian Government National Water Commission 2012). • Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC and ARMCANZ 2000). Application of Policies and Guidance The EPA Factor Guideline for Inland Waters was considered in relation to the following aspects: • Proposal design and layout were developed in direct consultation with DWER, DMIRS and DBCA. • Surveys have been conducted in accordance with relevant technical guidance. • Referral information, and common issues encountered, with specific reference to potash proposals on salt lake systems. • Characterisation of the receiving environment and identification of preliminary environmental values. • Identification of preliminary direct and indirect impacts for the Proposal application of the EPA mitigation hierarchy. • Potential interactions and connectivity in relation to holistic impact assessment.

Receiving Environment Describe the current condition of the receiving environment in relation to this factor.

On-lake and Off-lake Development Envelopes • Surface hydrology and hydrogeology investigations (Table 4-1; Appendix D), as well as flora (Table 4-1; Appendix A.1 to Appendix A.4) and fauna surveys (waterbirds, aquatic

invertebrates, SREs) (Table 4-1; Appendix A.1, Appendix A.4, Appendix B.1 to Appendix B.4) and subterranean fauna surveys (Table 4-1; Appendix E.1 to Appendix E.3) have been undertaken for the on-lake and off-lake development envelopes.

Surface Hydrology and Geomorphology • Lake Mackay is an ephemeral salt lake (3,500km2 or 350,000 ha), the fourth largest in Australia, set within a poorly defined catchment. • The lake is a closed system subject to irregular flooding during the wet season, which can resulting in surface inundation. • Minor drainage channels located in the south-east (coinciding with the deeper sections of the lake), contribute to surface runoff during heavy rainfall. • When inundated the lake is shallow and hypersaline (>100,000 mg/L TDS), with the extent, distribution and depth of surface water influenced by prevailing winds and elevation. • Evaporation and transpiration are the only recognised forms of discharge and loss from the water balance. • A surficial halite crust generally only 5 mm thick is present, intermixed with gypsum in the east, becoming less permeable in the west. • Numerous gypsiferous islands interrupt the playa in the east, while the periphery is characterised by east-west trending dunes, interspersed with claypans (<10,000 mg/L TDS). Hydrogeology • Regional groundwater flow is predominantly in a westerly direction towards the lake, which acts as a regional hydraulic sink. • Hydrostratigraphic units comprise, lake sediments (gypsum sand and clay), island sediments (gypsiferous sands) and palaeovalley fill sediments. • Brine groundwater exists beneath the lake (>200,000 mg/L TDS), with typically low metal concentrations (below ANZECC marine trigger values). • Groundwater levels are generally close to the surface (0.1 to 0.4 m bgl) across the lake. • Groundwater drawdown is not expected to be substantial, with preliminary levels modelled at less than 0.5 m over a 20 year-period. • Lower salinity groundwater (60,000 to 100,000 mg/L TDS) occurs within the island sediments (via infiltration from rainfall), forming a lens overlying the brine, which may be hydraulically

connected. • Fresh to low salinity groundwater (typically <20,000 mg/L TDS) occurs within the calcrete on the periphery of the lake, which is recharged by rainfall. • Rainfall and possibly upward leakage are the primary recharge mechanisms.

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Environmental Values • The survey effort of the lake and periphery (including claypans) is outlined in other factors (Table 4-1; Appendix C.1 and C.2). • The lake is not a wetland of international importance and is not listed in the Directory of Important Wetlands in Australia. • The lake and periphery are known to support Parartemia sp., several potential SREs and migratory waterbird species (Figure 4-3 and Figure 4-4); Appendix B.3, Appendix C.1, Appendix C.3

and Appendix B.3). • The islands of the lake potentially support significant flora, fauna, SREs and subterranean fauna (refer to relevant factors for species) (Figure 4-1 to Figure 4-4, Appendix A.1 to Appendix A.4;

Appendix B.1 to Appendix B.4 to Appendix C.3 and Appendix E.1 to Appendix E.3). • The riparian zone of the lake supports several new species of Tecticornia, which may be of conservation significance (Figure 4-1) Appendix A.1 to Appendix A.4).

*Photos from Stantec Site Reconnaissance, October 2018

Proposal Activities Describe the proposal activities that have the potential to impact the environment.

• Disturbance of up to 10,000 ha (<5%) within a 218,359 ha on-lake development envelope (<3% of the total lake surface), including trenching, bunding and evaporation ponds. • Abstraction of up to 70G L/a of brine from trenches over 20-year period and up to 5 GL/a of groundwater from bores for use in the processing plant. • Storage of waste salts in the evaporation ponds and gradual release to the lake over time. • Clearing of up to 100 ha of flora and vegetation within a 680 ha off-lake development envelope.

Key Knowledge Gaps and Proposed Further Studies and Assessments

• Surface hydrology modelling and flood mitigation assessment. • Recharge and drawdown investigations to revise the hydrogeological conceptualisation and numerical modelling. • Additional aquatic ecology study of the lake and peripheral wetlands during flooding. • Risk assessment of Proposal impacts to Inland Waters factor.

Potential Impacts Assess the impacts of the proposal and review the residual impacts against the EPA objective.

A preliminary assessment of potential direct and indirect impacts is provided for the Inland Waters factor based on available information from studies completed to date and likely mitigation measures. Direct Impacts • Disturbance for on-lake development of trenches and ponds impacting lake habitat and biota: low risk (minimal). • Clearing for off-lake development and access corridors impacting peripheral habitat and biota: low risk (minimal). • Hydrocarbon and /or chemical leaks and spills impacting peripheral or lake habitat and biota: low risk (minimal). • Increased risk of fauna injury or death accessing trenches or ponds: low risk (minimal). Indirect Impacts • Changes in surface water movement patterns, due to on-lake and off-lake development, impacting lake or peripheral habitat and biota: low-medium risk (unknown). • Groundwater drawdown impacting lake, island, subterranean and peripheral habitat and biota (including potential GDEs): low-medium risk (minimal). • Increases in surface water and groundwater salinity due to runoff and release of waste salts from ponds, impacting lake or peripheral habitat and biota: low-medium risk (unknown). • Changes in hydraulic connectivity and groundwater quality impacting lake, island, subterranean and peripheral habitat and biota (including potential GDEs): low risk (minimal). • Erosion and sedimentation due to on-lake and off-lake development, impacting lake or peripheral habitat and biota: low risk (minimal). • Potential formation of acid-generating material from on-lake development and sediment disturbance for trenches and ponds, impacting lake habitat and biota: low risk (minimal). • Introduction or spread of weeds/pathogens/feral animals from throughout the proposal area, impacting on-lake or peripheral habitat and biota: low risk (minimal).

Lake and Islands Islands and Dunes Peripheral Claypan and DunesLake and PeripheryPeripheral Claypans

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Mitigation Describe the measures proposed to manage and mitigate the potential environmental impacts.

Regulatory guidance and policies were used during the development of the proposal following the EPA’s mitigation hierarchy to identify, avoid and minimise impacts, as follows: Avoid • Less than 5% of the on-lake development envelope and less than 2% of the off-lake development envelopes will be subject to disturbance, and habitats are well-represented in the area. • Trenches and evaporation ponds will be located on the open playa of the lake, avoiding islands and peripheral habitat. • Off-lake infrastructure has been configured to avoid riparian vegetation and favourable habitat for conservation significant flora and fauna species, where possible. • Clearing and disturbance will be managed via a Ground Disturbance Permitting System to avoid unauthorised clearing of vegetation and fauna habitat outside approved boundaries. • Drawdown from any off-lake groundwater supply is not expected to impact on-lake habitat. Minimise • Vegetation clearing, and disturbance will be minimised where possible for on-lake and off-lake development and utilise existing cleared tracks where possible. • A staged approach to trenching will be investigated to minimise impacts to the lake habitat. • Trenches and bunding will be engineered to maintain surface water movement patterns on the lake, where possible. • Groundwater investigations and modelling will be used to understand drawdown extent and minimise impacts to lake, islands and peripheral habitat. • Evaporation ponds will be engineered to minimise excessive runoff of waste salts into the lake habitat, with gradual release over time. Manage • Site inductions and awareness training will be provided to site-staff for conservation significant species, and their preferred habitats. • Hydrocarbon and /or chemical leaks and spills (expected to be rare) will be managed using bunding techniques, leak detection mechanisms and spill kits to restrict impacts. • Development and implementation of a Surface Water Management Plan to maintain environmental values. • Manage groundwater abstraction in accordance with 5C Licence under the RIWI Act. Monitor • Development and implementation of an ecological monitoring program for the lake and peripheral habitat as required. • Development and implementation of a groundwater monitoring program for the lake and/or peripheral habitat as required. Rehabilitate • Disturbed areas will be rehabilitated progressively, where possible or at closure. • An MCP (in accordance with DMIRS guidelines) will outline specific closure objectives and completion criteria for the lake and peripheral habitat, including rehabilitation as required.

Predicted Outcomes Describe the predicted outcome against the environmental objective and discuss whether there is likely to be a significant residual impact.

Residual Impacts • Detailed environmental impact and risk assessments have not yet been undertaken for this Proposal for the Inland Waters factor, although based on available information from studies

completed to date significant residual impacts are expected to be minor with natural attenuation over time. • Knowledge gaps are currently being addressed to inform this process and develop suitable mitigation measures to avoid or minimise impacts, including any residual impacts. • This may include further refinement of the Proposal design, layout, development, operation and/or closure strategies to ensure the environmental risk is acceptable.

Assumptions Describe any assumptions critical to your assessment e.g. particular mitigation measures or regulatory conditions.

• The extent of impacts associated with the proposal have likely been overestimated, with further refinement of engineering and design to maintain environmental values where possible. • The lake and peripheral habitat (including claypans) are well-distributed, with biological diversity, ecological integrity, and hydrological processes to be maintained where possible. • Any conservation significant species associated with the lake, islands, subterranean or peripheral habitat are likely to be more broadly distributed across the lake and peripheral habitat. • Migratory waterbirds are transient fauna, and are unlikely to be impacted by the Proposal, with broader availability of inland water resources that can be utilised. • Additional surveying to address current knowledge gaps will provide suitable recommendations and mitigation measures to minimise impacts from the proposal. • The EPA objective for Inland Waters is expected to be met.

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Figure 4-6: Mackay Proposal Lake Elevation and Hydrology

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4.2 Other Environmental Factors or Matters 4.2.1 Landforms Table 4-5: Landforms

EPA Objectives To maintain the variety and integrity of significant physical landforms so that environmental values are protected.

EPA Policy and Guidance What have you considered and how have you applied them in relation to this factor?

Key EPA Guidance • Environmental Factor Guideline: Landforms (EPA 2018b). • Statement of Environmental Principles, Factors and Objectives (EPA 2016g). • Environmental Factor Guideline: Flora and Vegetation (EPA 2016b). • Environmental Factor Guideline: Terrestrial Fauna (EPA 2018c). • Environmental Factor Guideline: Inland Waters (EPA 2018a). • Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures 2016. • EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c). Relevant Acts • RIWI Act. • WC Act. • Mining Act 1978. • CALM Act. • EP Act. • EPBC Act. • BC Act. Application of Policies and Guidance • The EPA Factor Guideline for Landforms was considered for the Proposal, which are defined as distinctive recognisable features, defined by geology and morphology, however

consideration of key and other environmental factors was considered adequate to address any concerns.

Receiving Environment Describe the current condition of the receiving environment in relation to this factor.

• Refer to Flora and Vegetation, Terrestrial Fauna and Inland Waters factors (Table 4-2, Table 4-3 and Table 4-4).

Key Knowledge Gaps and Proposed Further Studies and Assessments

• Refer to Flora and Vegetation, Terrestrial Fauna and Inland Waters factors (Table 4-2, Table 4-3 and Table 4-4).

Proposal Activities Describe the proposal activities that have the potential to impact the environment.

• Disturbance of up to 10,000 ha (<5%) within a 218,359 ha on-lake development envelope (<3% of the total lake surface), including trenching, bunding and evaporation ponds. • Abstraction of up to 70 GL/a of brine from trenches over 20-year period and up to 5 GL/a of groundwater from bores for use in the processing plant. • Storage of waste salts in the evaporation ponds and gradual release to the lake over time. • Clearing of up to 100 ha of flora and vegetation within a 680 ha off-lake development envelope. • Clearing of up to 1,300 ha of flora and vegetation for access corridors within a 57,808 ha northern corridor development envelope and 12,300 ha southern corridor development

envelope (<3% of the total area). • Use of light and heavy vehicles and equipment for construction and operations including fuel storage. • Fugitive dust emissions from vehicles and equipment during construction and operation.

Potential Impacts Assess the impacts of the proposal and review the residual impacts against the EPA objective.

• Refer to Flora and Vegetation, Terrestrial Fauna and Inland Waters factors (Table 4-2, Table 4-3 and Table 4-4).

Mitigation Describe the measures proposed to manage and mitigate the potential environmental impacts.

• Refer to Flora and Vegetation, Terrestrial Fauna and Inland Waters factors (Table 4-2, Table 4-3 and Table 4-4).

Predicted Outcomes Describe the predicted outcome against the environmental objective and discuss whether there is likely to be a significant residual impact.

Residual Impacts

• Detailed environmental impact and risk assessments have not yet been undertaken for this Proposal for the Landforms factor, although based on available information from studies completed to date significant residual impacts are expected to be minor with natural attenuation over time.

• Knowledge gaps are currently being addressed to inform this process and develop suitable mitigation measures to avoid or minimise impacts, including any residual impacts. • This may include further refinement of the Proposal design, layout, development, operation and/or closure strategies to ensure the environmental risk is acceptable.

Assumptions Describe any assumptions critical to your assessment e.g. particular mitigation measures or regulatory conditions.

• Refer to Flora and Vegetation, Terrestrial Fauna and Inland Waters factors (Table 4-2, Table 4-3 and Table 4-4). • The EPA objective for Landforms is expected to be met.

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4.2.2 Subterranean Fauna Table 4-6: Subterranean Fauna

EPA Objectives To protect subterranean fauna so that biological diversity and ecological integrity are maintained.

EPA Policy and Guidance What have you considered and how have you applied them in relation to this factor?

Key EPA Guidance • Environmental Factor Guideline: Subterranean Fauna (EPA 2016e). • Statement of Environmental Principles, Factors and Objectives (EPA 2016g). • Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures 2016. • EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c). Relevant Acts • RIWI Act. • WC Act. • Mining Act 1978. • CALM Act. • EP Act. • EPBC Act. • BC Act. Relevant Technical Guidance • Technical Guidance: Subterranean Fauna Survey (EPA 2016j). • Technical Guidance: Sampling methods for Subterranean fauna (EPA 2016h). • Refer to Inland Waters factor (Table 4-4). Application of Policies and Guidance The EPA Factor Guideline for Subterranean Fauna was considered in relation to the following aspects: • Proposal design and layout were developed in direct consultation with DWER, DMIRS and DBCA. • Subterranean fauna surveys have been conducted in accordance with relevant technical guidance. • Referral information, and common issues encountered, with specific reference to potash proposals on salt lake systems. • Characterisation of subterranean fauna within the receiving environment and identification of preliminary environmental values. • Identification of preliminary direct and indirect impacts for the Proposal and the application of the EPA mitigation hierarchy. • Potential interactions and connectivity in relation to holistic impact assessment.

Receiving Environment Describe the current condition of the receiving environment in relation to this factor.

On-Lake and Off-Lake Development Envelopes • Subterranean fauna surveys have been undertaken from groundwater associated within the on-lake and off-lake development envelopes, sampling groundwater associated with the

lake, islands and peripheral habitat (Table 4-1; Figure 4-7; Appendix E.1 to Appendix E.3). Stygofauna • Groundwater beneath the lake (deep alluvial aquifer) does not appear to be prospective for stygofauna due to the extremely high salinities. • Groundwater beneath the islands and superficial calcrete (lake periphery) support stygofauna. • 18 stygal species have been identified to date including:

• two stygal taxa recorded from the islands (copepods), one of which was a new species. • 16 stygal taxa recorded from the surficial calcrete aquifer (copepods, ostracods, dytiscids, parabathynellids), 14 of which were new species (Figure 4-7; Appendix E.1 to Appendix E.3).

Troglofauna • No troglofauna have been found within the sediments associated with the lake habitat. • No troglofauna have been found within the superficial calcrete (lake periphery).

Key Knowledge Gaps and Proposed Further Studies and Assessments

• Pilot stygofauna assessment of groundwater associated with the lake habitat (if required). • Pilot subterranean fauna assessment of the groundwater associated with the islands habitat (if required, based on results of hydrogeological investigation and internal risk assessment). • Level 2 Subterranean Fauna Assessment of the water supply area (if required, based on results of hydrogeological investigation and internal risk assessment). • Risk Assessment of Proposal impacts to Subterranean Fauna factor.

Proposal Activities Describe the proposal activities that have the potential to impact the environment.

• Disturbance of up to 10,000 ha (<5%) within a 218,359 ha on-lake development envelope (< 3% of the total lake surface), including trenching, bunding and evaporation ponds. • Abstraction of up to 70 GL/a of brine from trenches over 20-year period and up to 5 GL/annum of groundwater from bores for use in the processing plant. • Storage of waste salts in the evaporation ponds and gradual release to the lake over time.

Potential Impacts Assess the impacts of the proposal and review the residual impacts against the EPA objective.

A preliminary assessment of potential direct and indirect impacts is provided for the Subterranean Fauna factor based on available information from studies completed to date, with the risk assessment expected to be refined the as the Proposal engineering design and layout progresses, and ongoing studies address knowledge gaps. Direct Impacts • Groundwater drawdown impacting the islands and peripheral habitat and subterranean fauna (<0.5 m over a 20 year-period): low risk (minimal)

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Indirect Impacts • Hydrocarbon and /or chemical leaks and spills impacting groundwater and subterranean fauna: low risk (minimal). • Changes in hydraulic connectivity and groundwater quality impacting subterranean fauna: low risk (minimal). • Increases in groundwater salinity due to runoff and release of waste salts from ponds, impacting subterranean fauna: low risk (minimal).

Mitigation Describe the measures proposed to manage and mitigate the potential environmental impacts.

Avoid • Trenches and evaporation ponds will be located on the open playa of the lake, avoiding islands and peripheral habitat that may host subterranean fauna. • It is expected that drawdown will be limited to within close proximity of the trenches on the playa, with minimal impacts to groundwater associated with the island’s habitat. • It is expected that groundwater identified as a water supply for the Proposal will avoid prospective subterranean fauna habitat. Minimise • Groundwater investigations and modelling will be used to understand drawdown extent and minimise impacts to lake, islands and peripheral habitat. • Evaporation ponds will be engineered to minimise excessive runoff of waste salts into groundwater, with gradual release over time. Manage • Manage groundwater abstraction in accordance with 5C Licence under the RIWI Act. • Development and implementation of a Groundwater Management Plan to assess changes in groundwater quality and depth. Monitoring • Development and implementation of a groundwater monitoring program as required.

Predicted Outcomes Describe the predicted outcome against the environmental objective and discuss whether there is likely to be a significant residual impact.

Residual Impacts • Detailed environmental impact and risk assessments have not yet been undertaken for this Proposal for the Subterranean Fauna factor, although based on available information from

studies completed to date significant residual impacts are not expected. • Knowledge gaps are currently being addressed to inform this process and develop suitable mitigation measures to avoid or minimise impacts, including any residual impacts. • This may include further refinement of the Proposal design, layout, development, operation and/or closure strategies to ensure the environmental risk is acceptable.

Assumptions Describe any assumptions critical to your assessment e.g. particular mitigation measures or regulatory conditions.

• Preliminary groundwater modelling indicates there will be minor drawdown over time, with minimal impacts to groundwater on the lake islands. • Detailed hydrogeological investigations are underway to further characterise groundwater within the Project area and understand the effects of drawdown. • Additional investigation is being undertaken to identify a suitable water supply area, which will minimise impacts to subterranean fauna values. • The EPA objective for Subterranean Fauna is expected to be met.

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Figure 4-7: Mackay Proposal Subterranean Fauna Potential Conservation Significant Species

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4.2.3 Terrestrial Environmental Quality Table 4-7: Terrestrial Environmental Quality

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

EPA Policy and Guidance What have you considered and how have you applied them in relation to this factor?

Key EPA Guidance • Environmental Factor Guideline: Terrestrial Environmental Quality (EPA 2016f). • Statement of Environmental Principles, Factors and Objectives (EPA 2016g). • Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures 2016. • EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c). Relevant Acts • EP Act. • Contaminated Sites Act 2003. Key Regulatory Technical Guidance and Policies • Acid Sulphate Soils Guideline Series – Identification and Investigation of Acid Sulphate Soils and Acidic Landscapes (DER 2015a). • Acid Sulphate Soils Guideline Series – Treatment and Management of Soil and Water in Acid Sulphate Soils Landscapes (DER 2015b). • Preventing acid and metalliferous drainage – Leading practice sustainable development program for the mining industry (DIIS 2016). • Assessment and Management of Contaminated Sites: Contaminated Sites Guidelines (DER 2014). • Draft Guidance Materials Characterisation Baseline Data Requirements of Mining Proposals (DMP 2016). Application of Policies and Guidance The EPA Factor Guideline for Terrestrial Environmental Quality was considered in relation to the following aspects: • Proposal design and layout were developed in direct consultation with DWER, DMIRS and DBCA. • A preliminary acid sulphate soil investigation has been conducted in accordance with relevant technical guidance. • Referral information, and common issues encountered, with specific reference to potash proposals on salt lake systems. • Characterisation of terrestrial environmental quality within the receiving environment and identification of preliminary environmental values. • Identification of preliminary direct and indirect impacts for the Proposal and the application of the EPA mitigation hierarchy. • Potential interactions and connectivity in relation to holistic impact assessment.

Receiving Environment Describe the current condition of the receiving environment in relation to this factor.

On-Lake and Off-Lake Development Envelopes • Surveys relating to terrestrial environmental quality have been undertaken from soils within the on-lake and off-lake development envelopes (Table 4-1; Appendix F and Appendix G). Geology • Regionally, surface geology surrounding Lake Mackay consists of lacustrine deposits typically comprising mud, silt, evaporate, limestone and minor sand. • Local geological units include:

• halite, gypsum, sand, silt, clay and sand on the lake. • Aeolian deposits of sand and clayey sand occurring as longitudinal dunes on the periphery and intermittent calcrete.

Acid Sulphate Soils and Metals • On-lake and off-lake preliminary analysis of soils and sediments indicated that there is unlikely to be any risk associated with acid sulphate generation. • On-lake analysis of metals indicated concentrations were below the health investigation levels (HIL-D industrial/commercial) and the Ecological Investigation Level (EIL Public Open

Space), with a negligible risk to human health and the receiving environment. • Metal concentrations of the waste salts were within a similar range or less concentrated than on-lake concentrations. Environmental Values • Lake sediment contains the propagules of aquatic biota, and peripheral soils contain the seed bank for flora and vegetation.

Key Knowledge Gaps and Proposed Further Studies and Assessments

• Sediment analysis of lake and peripheral wetlands (as part of aquatic ecology study of the lake and peripheral wetlands during flooding). • Additional characterisation of waste salts on the lake, in comparison to natural background levels. • Risk Assessment of Proposal impacts to Terrestrial Environment factor.

Proposal Activities Describe the proposal activities that have the potential to impact the environment.

• Disturbance of up to 10,000 ha (<5%) within a 218,359 ha on-lake development envelope (<3% of the total lake surface), including trenching, bunding and evaporation ponds. • Abstraction of up to 70 GL/a of brine from trenches over 20-year period and up to 5 GL/annum of groundwater from bores for use in the processing plant. • Storage of waste salts in the evaporation ponds and gradual release to the lake over time. • Clearing of up to 100 ha of flora and vegetation within a 680 ha off-lake development envelope.

Potential Impacts Assess the impacts of the proposal and review the residual impacts against the EPA objective.

A preliminary assessment of potential direct and indirect impacts is provided for the Flora and Vegetation factor based on available information from studies completed to date and likely mitigation measures. Direct Impacts • Increases in sediment salinity due to runoff and release of waste salts from ponds: low-medium risk (unknown). • Disturbance to sediment and soil for on-lake and off-lake development: low risk (minimal). • Contamination of sediment or soil through hydrocarbon and /or chemical leaks and spills: low risk (minimal). • Potential formation of acid-generating material from on-lake development and sediment disturbance for trenches and pond: low risk (minimal).

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Indirect Impacts • Drying and mobilisation of sediments due to drawdown of brine groundwater on the lake: low-medium risk (unknown). • Increased potential for sediment and soil contamination from runoff from the Proposal: low risk (minimal). • Increased potential for erosion and sedimentation following heavy rainfall events: low risk (minimal).

Mitigation Describe the measures proposed to manage and mitigate the potential environmental impacts.

Avoid • Less than 5% of the on-lake development envelope and less than 2% of the off-lake development envelopes will be subject to disturbance. • Trenches and evaporation ponds will be located on the open playa of the lake, avoiding vegetation clearing and soil disturbance, and salinisation of the terrestrial environment,

where possible. • Clearing and disturbance will be managed via a Ground Disturbance Permitting System to avoid unauthorised clearing of vegetation outside approved boundaries. • Proposal engineering and design to avoid the risk of soil and sediment contamination and preserve soil quality for rehabilitation. Minimise • A staged trenching design will be investigated to minimise impacts to the lake sediments and habitat. • Clearing and disturbance will be minimised where possible for on-lake and off-lake development and utilise existing cleared tracks where possible. • On-lake and off-lake development will utilise suitable engineering and drainage design to maintain surface water movement patterns and prevent erosion and sedimentation where

possible. • Groundwater investigations and modelling will be used to understand drawdown extent and minimise impacts to lake sediments and habitat. • Evaporation ponds will be engineered to minimise excessive runoff of waste salts into the lake habitat, with gradual release over time. Manage • Waste salts are not expected to contain detrimental additives or reagents, with similar properties to the ionic composition of the lake (<1% removal of constituents for processing). • Hydrocarbon and /or chemical leaks and spills (expected to be rare) will be managed using bunding techniques, leak detection mechanisms and spill kits to restrict impacts. • Manage groundwater abstraction in accordance with 5C Licence under the RIWI Act. Monitor • Development and implementation of sediment analysis and assessment of aquatic biota propagules as part of the ecological monitoring program for the lake and peripheral habitat

as required. Rehabilitate • An MCP (in accordance with DMIRS guidelines) will outline specific closure objectives and completion criteria for soils and sediment, including rehabilitation as required.

Predicted Outcomes Describe the predicted outcome against the environmental objective and discuss whether there is likely to be a significant residual impact.

Residual Impacts • Detailed environmental impact and risk assessments have not yet been undertaken for this Proposal for the Terrestrial Environmental Quality factor, although based on available

information from studies completed to date significant residual impacts are not expected. • Knowledge gaps are currently being addressed to inform this process and develop suitable mitigation measures to avoid or minimise impacts, including any residual impacts. • This may include further refinement of the Proposal design, layout, development, operation and/or closure strategies to ensure the environmental risk is acceptable.

Assumptions Describe any assumptions critical to your assessment e.g. particular mitigation measures or regulatory conditions.

• The lake and peripheral habitat are well-distributed, with biological diversity and ecological integrity to be maintained where possible. • Implementation of industry leading practices for the transport, storage and handling of hydrocarbons and reagents will ensure adverse impacts are prevented or minimised. • The EPA objective for Terrestrial Environmental Quality is expected to be met.

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4.2.4 Air Quality Table 4-8: Air Quality

EPA Objectives To maintain air quality and minimise emissions so that environmental values are protected.

EPA Policy and Guidance - What have you considered and how have you applied them in relation to this factor?

Key EPA Guidance • Environmental Factor Guideline: Air Quality (EPA 2016a). • Statement of Environmental Principles, Factors and Objectives (EPA 2016g). • Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures 2016. • EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c). Relevant Acts and Regulations • EP Act. • National Greenhouse and Energy Reporting Act 2007 (NGER Act). • Environmental Protection (Noise) Regulations 1997. Key Technical Guidance and Policies • National Environment Protection (Ambient Air Quality) Measure (NEPM) (Government of Australia 2013). • World Health Organisation (WHO) Air Quality Guidelines and Criteria. • Greenhouse and Energy Reporting (Measurement) Determination 2008. Application of Policies and Guidance The EPA Factor Guideline for Air Quality was considered in relation to the following aspects: • Proposal design and layout were developed in direct consultation with DWER, DMIRS and DBCA. • Referral information, and common issues encountered, with specific reference to potash proposals on salt lake systems. • Characterisation of the receiving environment and identification of preliminary environmental values. • Identification of preliminary direct and indirect impacts for the Proposal and the application of the EPA mitigation hierarchy. • Potential interactions and connectivity in relation to holistic impact assessment.

Receiving Environment - Describe the current condition of the receiving environment in relation to this factor.

• Nearest potentially sensitive receptors will be: • Proposal accommodation camp, within 3 km of the power station and SOP loadout facility. • Flora and vegetation and fauna habitat along access corridors, refer to Flora and Vegetation and Terrestrial Fauna factors (Table 4-2 and Table 4-3). • Kiwirrkurra community, 75 km south-west of the Proposal and 60 km south-west of the southern corridor. • Balgo community, 2 km west of the northern corridor.

Key Knowledge Gaps and Proposed Further Studies and Assessments

N/A

Proposal Activities - Describe the proposal activities that have the potential to impact the environment.

• Disturbance of up to 10,000 ha (<5%) within a 218,359 ha on-lake development envelope (<3% of the total lake surface), including trenching, bunding and evaporation ponds. • Abstraction of up to 70 GL/a of brine from trenches over 20-year period and up to 5 GL/a of groundwater from bores for use in the processing plant. • Storage of waste salts in the evaporation ponds and gradual release to the lake over time. • Clearing of up to 100 ha of flora and vegetation within a 680 ha off-lake development envelope. • Clearing of up to 1,300 ha of flora and vegetation for access corridors within a 57,808 ha northern corridor development envelope and 12,300 ha southern corridor development

envelope (<3% of the total area). • Use of light and heavy vehicles and equipment for construction and operations including fuel storage. • Fugitive dust emissions from vehicles and equipment during construction and operation.

Potential Impacts - Assess the impacts of the proposal and review the residual impacts against the EPA objective.

A preliminary assessment of potential direct and indirect impacts is provided for the Air Quality factor based on available information from studies completed to date and likely mitigation measures. Direct Impacts • Generation of dust via clearing for off-lake development and access corridors, SOP material handling and vehicle movement on unsealed access roads: low risk (minimal). • Generation of greenhouse gas emissions from energy consumption associated with the Proposal operation (estimated at approximately 50,000 tpa): low risk (minimal).

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Mitigation - Describe the measures proposed to manage and mitigate the potential environmental impacts.

Avoid • Avoid dust impacts to potentially sensitive environmental receptors where possible. Minimise • A gas-fired power station provides the co-benefit of heating the water to minimise overall power demand. • Vegetation clearing, and disturbance will be minimised for the Proposal and utilise existing tracks where possible. • Vehicle traffic will be confined to defined roads and tracks which will be properly formed and compacted with appropriate drainage. • Access roads will be subject to speed restrictions and dust suppression to minimise impacts on flora and vegetation, while the option of sealing the road is investigated to reduce dust. • Energy efficient power supply options and equipment will be investigated and commissioned where possible. Manage • Development and implementation of a Dust Management Plan to minimise dust emissions within the Proposal area. • Vehicles and power generating equipment will be maintained to minimise emissions where possible. • SOP product will be suitably sealed for transport from the Proposal area. Monitor • Visual dust monitoring may be undertaken as required. • Monitoring and reporting of emissions under the NGER Act may be required.

Predicted Outcomes – Describe the predicted outcome against the environmental objective and discuss whether there is likely to be a significant residual impact.

Residual Impacts • Detailed environmental impact and risk assessments have not yet been undertaken for this Proposal for the Air Quality factor, although based on available information from studies

completed to date significant residual impacts are not expected. • This may include further refinement of the Proposal design, layout, development, operation and/or closure strategies to ensure the environmental risk is acceptable.

Assumptions - Describe any assumptions critical to your assessment e.g. particular mitigation measures or regulatory conditions.

• Potentially sensitive receptors including Kiwirrkurra and Balgo communities are unlikely to be within the range of dust generated by the Proposal, while dust impacts on vegetation are expected to be minimal.

• The EPA objective for Air Quality has been met based on available information.

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4.2.5 Social Surrounding Table 4-9: Social Surrounding

EPA Objectives To protect social surroundings from significant harm.

EPA Policy and Guidance - What have you considered and how have you applied them in relation to this factor?

Key EPA Guidance • Environmental Factor Guideline: Social Surroundings (EPA 2016d). • Statement of Environmental Principles, Factors and Objectives (EPA 2016g). • Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures 2016. • EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c). Relevant Acts and Regulations • Aboriginal Heritage Act 1979 (AH Act). • EP Act. • NT Act. • Environmental Protection (Noise) Regulations 1997. • NGER Act. Relevant Technical Guidance • EPA Guidance Statement No. 41: Assessment of Aboriginal Heritage (EPA 2004). • Aboriginal Heritage Due Diligence Guidelines (DAA 2013). • Guidelines for Preparing Aboriginal Heritage Survey Reports (DAA 2018). • DPLH Guidelines for the Development of an Aboriginal Cultural Heritage Management Plan for the Aboriginal Heritage Act 1972 (DIA 2009). • World Health Organisation (WHO) Air Quality Guidelines and Criteria. • Greenhouse and Energy Reporting (Measurement) Determination 2008. • Draft Guideline on Environmental Noise for Prescribed Premises (DER 2016). Application of Policies and Guidance The EPA Factor Guideline for Social Surroundings was considered in relation to the following aspects: • Proposal design and layout were developed in direct consultation with Traditional Owners. • Heritage surveys were undertaken and a Cultural Heritage Management Plan (CHMP) • Identification of preliminary direct and indirect impacts for the Proposal and the application of the EPA mitigation hierarchy. • Potential interactions and connectivity in relation to holistic impact assessment.

Receiving Environment - Describe the current condition of the receiving environment in relation to this factor.

On-lake and Off-lake Development Envelopes • Heritage surveys have been undertaken for the on-lake and off-lake development envelopes (Table 4-1). • The Kiwirrkurra community is located 75 km south-west of the Proposal area. • The Proposal is located within the Kiwirrkurra Native Title Determination Area and on an Aboriginal Reserve (Agrimin and the Kiwirrkurra native title holders have executed a Native Title

Agreement). • No Registered Aboriginal Sites or other places of heritage significance are located within close proximity to the Proposal area based on extensive heritage surveys. • The nearest Aboriginal Heritage site is Pulkarlnga (ID: 2049) located approximately 5.1 km west of the southern end of the Proposal’s area. • A search of the Heritage Council’s register identified there are no State Heritage Places within or nearby the lake. • A CHMP is in place to manage interactions and dealings with Traditional Owners. Access Corridors • The Kiwirrkurra community is located 60 km south-west of the southern corridor and the Balgo community is located 2 km west of the northern corridor. • The northern and southern corridors are located within the Kiwirrkurra, Parna Ngururrpa and Tjurabalan Native Title Determination Areas. • No World, National, Commonwealth or State heritage places within 20 km of the northern and southern corridor development envelopes. • Results of a DPLH’s Aboriginal Heritage database searched identified that the northern corridor development envelope intersects 25 Aboriginal heritage places of which five are

lodged and 21 are Registered (Figure 4-8), while the southern corridor intersects seven Aboriginal heritage places of which four are lodged (Figure 4-9).

Key Knowledge Gaps and Proposed Further Studies and Assessments

• Heritage surveys of the access corridors (preliminary support has been obtained).

Proposal Activities - Describe the proposal activities that have the potential to impact the environment.

• Clearing of up to 100 ha of flora and vegetation within a 680 ha off-lake development envelope. • Clearing of up to1,300 ha of flora and vegetation for access corridors within a 57,808 ha northern corridor development envelope and 12,300 ha southern corridor development

envelope (<3% of the total area), subsequent construction and operation. • Storage of waste salts in the evaporation ponds and gradual release to the lake over time and subsequent salt stockpiles (up to 20 m in height at closure). • Use of light and heavy vehicles and equipment for construction and operations including fuel storage and SOP haulage. • Fugitive dust emissions from the Proposal.

Assessment of impacts - Assess the impacts of the proposal and review the

A preliminary assessment of potential direct and indirect impacts is provided for the Social Surrounding factor based on available information from studies completed to date and likely mitigation measures. Direct Impacts

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residual impacts against the EPA objective.

• Impacts to Aboriginal Sites or other places of heritage significance leading to cultural land use changes: low risk (minimal). • Restrictions or prevention of traditional practices by Traditional Owners: low risk (minimal). • Changes to aesthetic values from the Proposal: low risk (minimal). • Refer to Air Quality Factor (Table 4-8): low risk (minimal).

Mitigation - Describe the measures proposed to manage and mitigate the potential environmental impacts.

Avoid • Access corridors to be engineered to avoid lodged and registered DPLH’s Aboriginal sites and listed heritage places. • Northern access corridor to be constructed to avoid the Balgo community at an agreed distance. Minimise • Refer to Air Quality Factor (Table 4-8). Manage • Adherence to all conditions set out in the Native Title Agreement and implementation of the CHMP for the Proposal. • Ongoing engagement and consultation with the Kiwirrkurra Native Title holders and Kiwirrkurra IPA Rangers and with local Traditional Owners as required. • Refer to Air Quality Factor (Table 4-8). Monitor • Refer to Air Quality Factor (Table 4-8).

Predicted Outcomes – Describe the predicted outcome against the environmental objective and discuss whether there is likely to be a significant residual impact.

Residual Impacts • Detailed environmental impact and risk assessments have not yet been undertaken for this Proposal for the Social Surrounding factor, although based on available information from

studies completed to date significant residual impacts are not expected.

Assumptions - Describe any assumptions critical to your assessment e.g. particular mitigation measures or regulatory conditions.

• The remoteness of the Proposal and its location 75 km from the closest community at Kiwirrkurra makes it unlikely to have a significant impact on the social surroundings. • Any impacts to heritage and traditional practices are considered to be minimal and manageable. • The Traditional Owners and Native Title holders have been engaged and consulted as the Proposal has progressed. • Native Title holders have provided in-principle support for the northern corridor. • The EPA objective for Social Surroundings has been met based on available information.

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Figure 4-8: Mackay Proposal On-lake and Off-lake Aboriginal Heritage Places (Lodged and Registered)

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Figure 4-9: Mackay Proposal Corridor Envelops Aboriginal Heritage Places (Lodged and Registered)

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4.2.6 Human Health Table 4-10: Human Health

EPA Objectives To protect human health from significant harm.

EPA Policy and Guidance - What have you considered and how have you applied them in relation to this factor?

Key EPA Guidance • Environmental Factor Guideline: Human Health (EPA 2016c). • Statement of Environmental Principles, Factors and Objectives (EPA 2016g). • Environmental Impact Assessment (EIA) (Part IV Divisions 1 and 2) Administrative Procedures 2016. • EIA (Part IV Divisions 1 and 2) Procedures Manual (EPA 2018c). Relevant Acts and Regulations • Radiation Safety Act 1975. • Radiation Safety (Qualifications) Regulations 1980. • Radiation Safety (General) Regulations 1983. • EP Act. • EPBC Act. • Mines Safety and Inspection Regulations 1995. • Australian Radiation Protection and Nuclear Safety Regulations 1999. • Radiation Safety (Transport of Radioactive Substances) Regulations 2002. Application of Policies and Guidance The EPA Factor Guideline for Human Health (arising from radiation emissions) was considered in relation to the following aspects: • Proposal design and layout were developed in direct consultation with DWER, DMIRS and DBCA. • A review of metals, uranium and thorium was conducted in relation to relevant technical guidance. • Identification of preliminary direct and indirect impacts for the Proposal and the application of the EPA mitigation hierarchy. • Potential interactions and connectivity in relation to holistic impact assessment.

Receiving Environment - Describe the current condition of the receiving environment in relation to this factor.

• The nearest potentially sensitive receptors for human health will be the Proposal’s accommodation camp (within 3 km of the power station and SOP loadout facility), Kiwirrkurra community (75 km south-west of the Project and 60 km south-west of the southern corridor), and the Balgo community (2 km west of the northern corridor).

• A review of metals, uranium and thorium was undertaken of on-lake and off-lake soils and sediments, groundwater, SOP product and waste salts (Appendix G), which found: • Metal concentrations, uranium and thorium concentrations were below the relevant human health assessment criteria.

Key Knowledge Gaps and Proposed Further Studies and Assessments

N/A

Proposal Activities - Describe the proposal activities that have the potential to impact the environment.

• Disturbance of up to 10,000 ha (<5%) within a 218,359 ha on-lake development envelope (<3% of the total lake surface), including trenching, bunding and evaporation ponds. • Abstraction of up to 70 GL/a of brine from trenches over 20-year period and up to 5 GL/a of groundwater from bores for use in the processing plant. • Storage of waste salts in the evaporation ponds and gradual release to the lake over time. • Clearing of up to 100 ha of flora and vegetation within a 680 ha off-lake development envelope. • Clearing of up to 1,300 ha of flora and vegetation for access corridors within a 57,808 ha northern corridor development envelope and 12,300 ha southern corridor development envelope

(<3% of the total area). • Use of light and heavy vehicles and equipment for construction and operations including fuel storage.

Potential Impacts - Assess the impacts of the proposal and review the residual impacts against the EPA objective.

A preliminary assessment of potential direct and indirect impacts is provided for the Flora and Vegetation factor based on available information from studies completed to date and likely mitigation measures. • On-lake and off-lake soils, sediments, groundwater, SOP and waste products are not radioactive: negligible risk.

Mitigation - Describe the measures proposed to manage and mitigate the potential environmental impacts.

• Mitigation measures are not required due to the negligible risk posed to human health and/or the environment.

Predicted Outcomes – Describe the predicted outcome against the environmental objective and discuss whether there is likely to be a significant residual impact.

Residual Impacts • Detailed environmental impact and risk assessments have not yet been undertaken for this Proposal for the Human Health factor, although based on available information from studies

completed to date significant residual impacts are not expected.

Assumptions - Describe any assumptions critical to your assessment e.g. particular mitigation measures or regulatory conditions.

• In the absence of Australian assessment criteria for uranium and thorium relevant international standards and criteria were used for comparison. • The assessment of occupational health and safety has not been included in this assessment for the Human Health factor, as it is comprehensively regulated by other DMAs. • The EPA objective for Human Health has been met based on available information.

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5. Other Approvals and Regulation (Part C) 5.1 State and Local Government Approvals A description of the land tenure including existing zoning, tenements and/or lease types is provided in Section 2.3.1. There are a number of state and local government environmental approvals and permits required for the Proposal that are summarised in Table 5-1.

Table 5-1: State and Local Government Approvals

Proposal Activities Land Tenure / Access Type of Approval Legislation Regulating the Activity

Responsible Government Agency

Additional Information

Mackay Proposal Development (including infrastructure corridors)

Mining Act 1978: mining leases and miscellaneous licences

Referral to the EPA Section 38 of the EP Act EPAS This document

Referral to the DoEE EPBC Act DoEE If any MNES are likely to be significantly impacted by the proposal referral to DoEE.

Grant of Mining Lease Mining Act 1978 DMIRS Grant of mining lease required for mining activities, processing and mining infrastructure such waste landforms.

Grant of Miscellaneous Licences

Mining Act 1978 DMIRS Grant of tenure required for infrastructure.

Native Title Agreement NT Act Attorney-General’s Department (Cwth) DPLH

Required prior to access and works.

Land Access Agreement DPLH Required prior to access of Proposal, clearing and mining activities.

Aboriginal Heritage Sites AH Act DPLH If the disturbance of any Aboriginal Heritage Sites site is required

Mining and Processing

Mining Act 1978: mining leases

Mining Proposal and Mine Closure Plan

Division 3 of Part IV of the Mining Act 1978

DMIRS Required prior for mining and processing activities and supporting infrastructure.

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Proposal Activities Land Tenure / Access Type of Approval Legislation Regulating the Activity

Responsible Government Agency

Additional Information

Dangerous Goods Licence Dangerous Goods Safety Act 2004 (DGS Act)

DMIRS Required for the storage, transport and use of Dangerous Goods.

Project Management Plan Mines Safety and Inspection Act 1994 (MSI Act) Mining Safety & Inspection Regulations 1995

DMIRS Required prior to construction or mining operations commencing.

Clearing of native vegetation

Mining Act 1978: mining leases and miscellaneous licences

Native Vegetation Clearing Permit

Part V of the EP Act DMIRS (via administrative agreement with DWER)

Not required if flora and vegetation is formally assessed as a key environmental factor under s38 of the EP Act.

Process plant construction and operations

Mining Act 1978: mining leases

Works Approval Part V of the EP Act Environmental Protection Regulations 1987

DWER - Regulation Required prior to construction of processing and other associated prescribed premises activities

Operating Licence Part V of the EP Act DWER - Regulation Required prior to the commencement of official production and shipment.

Construction of trenches, bores for process water supply

Mining Act 1978: mining leases

Application for 26D Licence Section 26D RIWI Act DWER - Water Required prior to construction of trenches and bores.

Groundwater abstraction – brine and process water

Mining Act 1978: mining leases

Application for a 5C Licence

Section 5C RIWI Act DWER - Water Required for groundwater abstraction.

Support infrastructure (wastewater treatment)

Mining Act 1978: mining leases and miscellaneous licences

Application to Construct or Install an Apparatus for the Treatment of Sewage

Health Act 1911 Health (Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulations of 1974

Shire of East Pilbara Department of Health DWER - Regulation

Requirement is dependent upon size and treatments options.

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5.2 Commonwealth Government Approvals The Matter of National Environmental Significance (MNES) Significant Impact Guidelines (DEWHA 2013) provide guidance to determine whether or not a Proposal will have, or is likely to have, a significant impact on a MNES as protected under the EPBC Act. The Guideline (DEWHA 2013) provides an assessment tool for MNES and should a MNES be considered likely to be impacted, referral to the DoEE is required.

MNES as listed under the Guidance (DEWHA 2013) to include:

• World Heritage Properties;

• National Heritage Places;

• Wetlands of International Importance (Ramsar Wetlands);

• Nationally Threatened Species and Ecological Communities;

• Migratory Species;

• Commonwealth Marine Areas;

• Great Barrier Reef Marine Park;

• Nuclear Actions (including uranium mining); and

• A Water Resource, in relation to Coal Seam Gas Development and Large Coal Mining Development.

The Proposal would not impact on a world heritage property or national heritage place and Lake Mackay is not listed as a RAMSAR wetland. SOP product, materials handled during SOP production or generated as by-products of SOP production by the Proposal are not radioactive and the proposed activities do not constitute a Nuclear Action (see Section 5.2.3).

EPBC Act Protected Matters Database Searches (Protected Matters Search Tool [PMST]) were undertaken by 360 Environmental for the on-lake, off-lake and access corridor development envelopes (360 Environmental 2018a), (Appendix H). The results of these searches are discussed within the following sections. The on-lake and off-lake PMST search area was centred on the Proposal area with a radial buffer of 85 km from the centre of Lake Mackay (Appendix H.1). The access corridors PMST search area included a radial buffer of 20 km from the northern and southern access corridors (Appendix H.2).

The PMST is based on the modelled distribution of species, not individual records of specimens or observations, consequently, a search can suggest a species or ecological community is present within a search area, however survey information on actual records and habitat critical to the species’ survival may be absent (360 Environmental 2018a). Thus, the results of the PMST searches for the Proposal should only be treated as indicative results that require confirmation by survey data (DEWHA 2013).

Agrimin planned to be concurrently refer the Proposal to the DoEE under the EPBC Act based upon the MNES assessment (undertaken by (360 Environmental 2018a)) provided in Section 5.2.1. If the Proposal is deemed to be a controlled action, Agrimin intends for the Proposal to be assessed under the Bilateral Agreement between the Commonwealth of Australia and the State of Western Australia. If the EPA decide to assess the Proposal, it is proposed that the EPA assessment process is used.

5.2.1 Summary of the Existing Environmental Value(s) that related to MNES The PMST searches identified six current nationally threatened species and eight current migratory species as potentially occurring within the Proposal Development Envelopes (Table 5-2, Appendix H.1 and Appendix H.2). These species are considered to be MNES or other matters protected under the EPBC Act. No other matters of MNES were identified during the PMST searches within the Proposal area (360 Environmental 2018a). Table 5-2 includes MNES returned in the PMST database search as well as MNES that were recorded during flora, vegetation and fauna surveys that were not identified during the PMST search.

The EPBC PMST is based on broader bioclimatic distribution models and in some instances, results are less accurate at local scales. Implications of inaccuracies result in species being included within PMST search results that do not occur within the search area, due to a lack of suitable habitat (360 Environmental 2018a).

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Table 5-2: MNES Potentially Present within the Development Envelope (360 Environmental 2018a)

Species EPBC Act Conservation Status

Type of Presence (DoEE 2018)

Species Summary Likelihood of Occurrence

Plants

Dwarf Desert Spike-rush (Eleocharis papillosa)

Vu Species or species habitat known to occur within area.

The Dwarf Desert Spike-rush is listed as Vulnerable under the EPBC Act. Only one record of the species is from the north-eastern edge of Lake Mackay within the Northern Territory, approximately 30 km from the Western Australian and Northern Territory borders (360 Environmental 2018a).

The species prefers fresh water swamps (with fringing vegetation) and semi-saline lakes. Suitable habitats are present around Lake Mackay however, they are limited in extent. This species has not previously been recorded during any of the flora and vegetation surveys that have been undertaken for the Proposal area (360 Environmental 2018a).

Due to the presence of some suitable habitat, it is considered Possible that the Dwarf Desert Spike-rush occurs within the Proposal area (360 Environmental 2018a). The potential impacts of the Proposal to the Dwarf Desert Spike-rush are considered to be low (Strategen Environmental 2018b).

Possible

Mammals

Bilby (Macrotis lagotis)

Vu Species or species habitat known to occur within area.

The Bilby is listed as Vulnerable under the EPBC Act. The Bilby was found to cover over 70% of the Australian mainland prior to European settlement (360 Environmental 2018a). Reduction in the Bilby’s geographic range has resulted in Bilby’s now only being found in Australian sandy deserts and the Pilbara (Southgate 2007). The population size is estimated to be fewer than 10,000 mature individuals and is undergoing continuing decline estimated to exceed 10% over the last three generations (12 years) and that is likely to continue (Woinarski 2014).

Bilbies occupy a variety of habitats including Mitchell Grass and stony downs country of cracking clays, desert sandplains and dune fields sometimes containing laterite, hummock grasslands (Spinifex) and massive red earths with Acacia shrubland (Van Dyck 2008).The Proposal area contains suitable sandy areas habitats (Swale and Claypan Swale habitats) for the Bilby where bilbies can construct burrows. The DBCA threatened database search identified 70 records for the Bilby within the area between the years of 2000 and 2016 whilst previous surveys (Cowan et al. 2015) have identified Bilbies within the wider Proposal area (360 Environmental 2018a).

Although no signs of the Bilby were identified with the Proposal area during surveys, recent local records together with the presence of suitable habitat (Swale Habitat) suggests that the Bilby is Likely to occur (360 Environmental 2018a).

Swale Habitat is widespread and common beyond the Proposal’s Development Envelope and more broadly across the region. Therefore, off-lake clearing of up to 1,400 ha of vegetation for the Proposal which is not considered preferred Bilby habitat, is not considered to have a significant impact on the species (360 Environmental 2018a).

Likely

Reptiles

Great Desert Skink (Liopholis kintorei)

Vu Species or species habitat known to occur within area.

The Great Desert Skink is listed as Vulnerable under the EPBC Act. It is a burrowing species in which large and complex burrowing systems may be occupied by family groups. Regular defecating spots are used and generally indicate occupied burrow systems. The Great Desert Skink is found in a variety of habitats on sandy, clay and loamy soils (360 Environmental 2017b). The Proposal’s Development Envelope lies within the known distribution of the Great Desert Skink and contains Swale and Dune habitats preferable to this species. Therefore, the species are considered Likely to occur, though no Great Desert Skinks have been identified within or nearby the Proposal area in the surveys undertaken to date (360 Environmental 2018a)

While the Proposal will involve the off-lake clearing of up to 1,400 ha of some Swale and Dune habitat types the Great Desert Skink will be not be significantly impacted by this clearing as these habitats are common and widespread through the Proposal area and on a regional scale (360 Environmental 2018a).

If the off-lake infrastructure construction disturbs active burrows, potential impacts to the Great Desert Skink are considered moderate. However, such impacts are considered unlikely given the flexibility with regard to configuration of the Project disturbance footprint which would be designed to avoid any Swale and Dune habitat areas containing active burrow sites (360 Environmental 2018a).

Likely

Birds

Australian Painted Snipe (Rostratula australis)

En Not identified in PMST report.

The Australian Painted Snipe is listed as Endangered under the EPBC Act. The species inhabits shallow, vegetated, temporary or infrequently filled inland wetlands of Australia (360 Environmental 2018c). Australian Painted Snipe numbers are thought to have declined considerably since European settlement, particularly over the last 50 years, due to the loss and alteration of wetlands (Garnett et al. 2011).

The Australian Painted Snipe was not identified within the EPBC PMST database or the DBCA threatened fauna databases however, it was recorded during the Waterbird survey (360 Environmental 2017b;2018a;c).

The Australian Painted Snipe was recorded on several occasions during the Waterbird survey (360 Environmental 2018a) within the Claypan Swale Habitat. However, it is not considered that the clearing of this habitat type for the Proposal will have a significant impact on the species given that the habitat is common within the wider Proposal area and regionally (360 Environmental 2018a).

Recorded

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Species EPBC Act Conservation Status

Type of Presence (DoEE 2018)

Species Summary Likelihood of Occurrence

Night Parrot (Pezoporus occidentalis)

En Species or species habitat may occur within area.

The Night Parrot is listed as Endangered under the EPBC Act. The Night Parrot was thought possibly extinct until the recent recoveries of two dead specimens from Queensland. The type specimen and many early sightings originated from WA (360 Environmental 2018a). More recent sightings have come from a well near the Fortescue Marshes (April 2005) and breeding observations at Pullen Reserve in Western Queensland (Davis and Metcalf 2008). In March 2017, a population of the species was observed and photographed at an interior salt lake in central Western Australia (at this stage no further information is available) (360 Environmental 2018a).

No records of the Night Parrot were identified in the DBCA searches and very limited ecological information available for this species, including its preferred habitat (360 Environmental 2018a). Consultation with DBCA (11 October 2017) identified special interest habitats for Night Parrots include old, complex spinifex ring areas close to clay pans and samphire flats.

Night Parrot calls were not recorded during the November 2017 targeted fauna survey (Strategen Environmental 2018a). However, Night Parrot surveys are ongoing under the expert direction of Dr Stephen Murphy and assisted by Dr Allan Burbidge (DBCA) (360 Environmental 2018a).

Preliminary analyses of acoustic data from Queensland Night Parrot observations, suggest that the calling behaviour of the species varies significantly in relation to preceding rainfall (Murphy and Leseberg 2017). Specifically, when rainfall exceeds one standard deviation from the long-term mean, calling rates increase and more calling occurs through the night and are detected over a wider area from the roosting area (Strategen Environmental 2018b).

The availability of suitable habitat within the Proposal area, together with several records of the species within the region, suggests the Night Parrot is Possible to occur (Strategen Environmental 2018b).

Potential impacts from the Proposal on the Night Parrot include disturbance to roost areas (Strategen Environmental 2018b). Impacts are considered to be moderate and not likely to have a significant impact as there is minimal key habitat (old, unburnt spinifex) available within the Disturbance Footprint and that the Proposal has been designed to avoid riparian vegetation that has the potential to be key foraging habitats (360 Environmental 2018a).

Possible

Princess Parrot (Polytelis alexandrae)

En Species or species habitat may occur within area.

The Princess Parrot is listed as Vulnerable under the EPBC Act. The species distribution is scattered and irregular in across the arid regions of Australia from South Australia, west towards Coolgardie and east of the Murchison River in WA, and north to near the Fitzroy River in WA and Howell Ponds in the Northern Territory (360 Environmental 2018a).

The Princess Parrot inhabits shrublands and savanna woodlands in swales between sand dunes, with occupied sites typically consisting of Triodia spp. and a variety of shrubs and scattered emergent trees. Princess Parrot movements are poorly known (360 Environmental 2018a).

The DBCA database returned a single record of the Princess Parrot from Kiwirrkurra in 2012. Due to historical records, its known distribution and the presence of suitable habitat within the Proposal area, the Princess Parrot is considered Likely to occur (360 Environmental 2018a).

Dune and Swale Habitats are considered to potentially support the Princess Parrot however, these habitat types are common and widespread within the Proposal area and broader region. The Princess Parrot’s mobility means that it is not necessarily confined to Proposal area nor is it solely reliant on the habitats found within the Proposal area. Off-lake clearing of up to 1,400 ha of vegetation is unlikely to have significant impact on the Princess Parrot or its preferred habitat on local or regional scales (360 Environmental 2018a).

Likely

Fork-tailed Swift (Apus pacificus)

Mi Recorded / Species or species habitat likely to occur within area.

The Fork-tailed Swift is listed as Migratory under the EPBC Act. It is a non-breeding visitor to all states and territories of Australia (Higgins 1999). The Fork-tailed Swift is a summer migrant to Australia usually during the months of October to April. The species is predominantly aerial, foraging high above the tree canopy, and is largely independent of terrestrial habitats. It can occur in flocks of up to 2,000 birds (Johnstone and Storr 1998).

No records of the Fork-tailed Swift were identified within he DBCA threatened fauna database. However, the species was observed flying overhead Lake Mackay during the two surveys of the Proposal area (360 Environmental 2018a).

While the Fork-tailed Swift is not reliant on the habitats within the Proposal area, it is likely to utilise the area as part of a larger foraging home range. As the Fork-tailed Swift’s mobility means that it is not necessarily confined to Proposal area nor is it solely reliant on the habitats found within the Proposal area it that the Proposal will to significantly impact upon this species (360 Environmental 2018a).

Recorded

Barn Swallow (Hirundo rustica)

Mi Species or species habitat may occur within area.

Results of the 360 (360 Environmental 2018a) PMST search included that the Grey Wagtail has been identified as potentially occurring within the search area. However, based upon assessment of records of the DBCA threatened database the Grey Wagtail was not identified in historical records. In addition, surveys did not record the Grey Wagtail within the Proposal area and survey areas contained no suitable habitat. It is therefore considered that the Grey Wagtail is Unlikely to occur within the search area and therefore is not considered to be at risk of impact by the Proposal.

Unlikely

Yellow Wagtail (Motacilla flava)

Mi Species or species habitat may occur within area.

Results of the 360 (360 Environmental 2018a) PMST search included that the Yellow Wagtail has been identified as potentially occurring within the search area. However, based upon assessment of records of the DBCA threatened database the Yellow Wagtail was not identified in historical records. In addition, surveys did not record the Yellow Wagtail within the Proposal area and survey areas contained no suitable habitat. It is therefore considered that the Yellow Wagtail is Unlikely to occur within the search area and therefore is not considered to be at risk of impact by the Proposal.

Unlikely

Grey Wagtail (Matocailla cinerea)

Mi Species or species habitat may occur within area.

Results of the 360 (360 Environmental 2018a) PMST search included that the Grey Wagtail has been identified as potentially occurring within the search area. However, based upon assessment of records of the DBCA threatened database the Grey Wagtail was not identified in historical records. In addition, surveys did not record the Grey Wagtail within the Proposal area and survey areas contained no suitable habitat. It is therefore considered that the Grey Wagtail is Unlikely to occur within the search area and therefore is not considered to be at risk of impact by the Proposal.

Unlikely

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Species EPBC Act Conservation Status

Type of Presence (DoEE 2018)

Species Summary Likelihood of Occurrence

Pectoral Sandpiper (Calidris melanotos)

Mi Species or species habitat may occur within area.

Seven waterbirds were recorded during the survey or identified in the PMST search are listed as Migratory under the EPBC Act (360 Environmental 2018a).

Australia is an important location for migratory shorebirds both geographically and ecologically within the East Asian-Australasian flyway. Migratory shorebird species are mostly present during the non-breeding period, from as early as August to as late as April/May each year (360 Environmental 2017b), (360 Environmental 2018c).

The Pectoral Sandpiper was not recorded during the Waterbird Survey or Fauna Surveys and records were not present in the DBCA databases (360 Environmental 2018a). However, suitable habitat of bare ground and samphire flats next to freshwater and salt lakes was present within the surveyed areas, therefore they are Likely to occur mollusc (360 Environmental 2017b), (360 Environmental 2018c), (360 Environmental 2018a). With none of this species having been recorded to date within the Proposal area, and the extent of suitable habitat available elsewhere around Lake Mackay, it is unlikely that development of the Proposal will have a significant impact on these species.

Likely

Common Sandpiper (Actitis hypoleucos)

Mi Species or species habitat likely to occur within area.

The Common Sandpiper was not recorded during the Waterbird Survey or Fauna Surveys and records were not present in the DBCA databases (360 Environmental 2018a). However, suitable habitat of bare ground and samphire flats next to freshwater and salt lakes was present within the surveyed areas, therefore they are Likely to occur mollusc (360 Environmental 2017b), (360 Environmental 2018c), (360 Environmental 2018a). With none of these species having been recorded to date within the Proposal area, and the extent of suitable habitat available elsewhere around Lake Mackay, it is unlikely that development of the Proposal will have a significant impact on these species.

Likely

Sharp-tailed Sandpiper (Calidris acuminata)

Mi Recorded. The Sharp-tailed Sandpiper was not identified in the PMST or DBCA threatened fauna databases searches. This species were recorded during the surveys of the Proposal area (360 Environmental 2018a). The Proposal area contains suitable habitat of shallow freshwater and salt water bodies where these species may feed on insects and small mollusc (360 Environmental 2017b), (360 Environmental 2018c). However, since Lake Mackay is only seasonally inundated, it should not be considered the sole habitat in the region for the species. Therefore, the Proposal is unlikely to cause a significant impact to the Sharp-tailed Sandpiper (360 Environmental 2018a).

Recorded

Common Greenshank (Tringa nebularia)

Mi Recorded. The Common Greenshank was not identified in the PMST or DBCA threatened fauna databases searches. This species were recorded during the surveys of the Proposal area (360 Environmental 2018a). The Proposal area contains suitable habitat of shallow freshwater and salt water bodies where these species may feed on insects and small mollusc (360 Environmental 2017b), (360 Environmental 2018c). However, since Lake Mackay is only seasonally inundated, it should not be considered the sole habitat in the region for the species. Therefore, the Proposal is unlikely to cause a significant impact to the Common Greenshank (360 Environmental 2018a).

Recorded

Red-necked Stint (Calidris ruficollis)

Mi Recorded. The Red-necked Stint was not identified in the PMST or DBCA threatened fauna databases searches. This species were recorded during the surveys of the Proposal area (360 Environmental 2018a). The Proposal area contains suitable habitat of shallow freshwater and salt water bodies where these species may feed on insects and small mollusc (360 Environmental 2017b), (360 Environmental 2018c). However, since Lake Mackay is only seasonally inundated, it should not be considered the sole habitat in the region for the species. Therefore, the Proposal is unlikely to cause a significant impact to the Red-necked Stint (360 Environmental 2018a).

Recorded

Oriental Plover (Charadrius veredus)

Mi Species or species habitat may occur within area.

The Oriental Plover was not recorded during the surveys and records of this species was not present in the DBCA database (360 Environmental 2018a). However, the presence of bare ground and samphire flats adjacent to freshwater and salt lakes within the Proposal area provide Suitable habitat for both the species (360 Environmental 2018a). Therefore, Oriental Plover is considered Likely to occur within the Proposal area when Lake Mackay has suitable and sufficient resources (360 Environmental 2018a).

The Oriental Plover has extensive distributions and are only occasional visitors to Western Australia. Larger areas of suitable habitat for this species is available within other areas of Western Australia, East Asia, Mongolia and China. This species is considerably mobile and utilise areas inundated after major rainfall events and the Proposal area is not considered to be their sole habitat (360 Environmental 2018c). Therefore, given that the Proposal area is located outside of the known distribution area for this species, and the mobility of the species, it suggests that a reduction in suitable habitat through the development of the Proposal should not be considered as having a significant impact on the Oriental Plover (360 Environmental 2018a).

Likely

Oriental Pratincole (Glareola maldivarum)

Mi Species or species habitat may occur within area.

The Oriental Pratincole was not recorded during the surveys and records of this species was not present in the DBCA database (360 Environmental 2018a). However, the presence of bare ground and samphire flats adjacent to freshwater and salt lakes within the Proposal area provide Suitable habitat for both the species (360 Environmental 2018a). Therefore, Oriental Pratincole is considered Likely to occur within the Proposal area when Lake Mackay has suitable and sufficient resources (360 Environmental 2018a).

The Oriental Plover has extensive distributions and are only occasional visitors to Western Australia. Larger areas of suitable habitat for this species is available within other areas of Western Australia, East Asia, Mongolia and China. This species is considerably mobile and utilise areas inundated after major rainfall events and the Proposal area is not considered to be their sole habitat (360 Environmental 2018c). Therefore, given that the Proposal area is located outside of the known distribution area for this species, and the mobility of the species, it suggests that a reduction in suitable habitat through the development of the Proposal should not be considered as having a significant impact on the Oriental Pratincole (360 Environmental 2018a).

Likely

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5.2.2 Nuclear Action Early consultation with the DoEE (21 December 2017) highlighted the requirement to consider whether the Proposal constitutes a Nuclear Action or not, under the Sections 21 and 22 of the EPBC Act and the Australian Radiation Protection and Nuclear Safety Regulations 1999.

Under the DoEE’s Significant Impact Guidelines 1.1(DEWHA 2013), the following actions are considered a Nuclear Action under the EPBC Act: • establishing or significantly modifying a nuclear installation or a facility for storing spent nuclear fuel or

radioactive waste products arising from re-processing;

• establishing or significantly modifying a facility for storing radioactive waste products arising from re-processing;

• mining or milling uranium ore;

• establishing or significantly modifying a large-scale disposal facility for radioactive waste;

• de-commissioning or rehabilitating any facility or area in which an activity described above has been undertaken; or

• establishing, significantly modifying, decommissioning or rehabilitating a facility where radioactive materials at or above the activity level specified in regulation 2.02 of the Environment Protection and Biodiversity Conservation Regulations 2000 (EPBC Regulations) are, were, or proposed to be stored (DoE 2013).

DoEE advised that uranium, thorium and major & trace metals should be considered in potash projects and in response, Agrimin engaged 360 Environmental to undertake Uranium, Thorium and Metal Analytical review for the Proposal. The review included analysis of on-lake and off-lake soils and sediments; groundwater; SOP product and waste products associated with the Proposal (360 Environmental 2018d). The outcomes of the Uranium, Thorium and Metal review were that none of the off-lake and on-lake soils and sediments, groundwater and the SOP product and waste product associated with the Proposal were identified as being radioactive (360 Environmental 2018d). Therefore, as none of the Proposal attributes or actions meet the requirements for Nuclear Action the Proposal does not need to be assessed under the EPBA Act as a Nuclear Action.

5.2.3 Potential Impacts to MNES and Mitigation Measures A detailed impact assessment on MNES has not yet been undertaken for this Proposal as knowledge gaps are still being filled and detailed project design is still ongoing. Table 5-3 outlines the potential direct, indirect impacts from the Proposal from on MNES as well as proposed mitigation measures. It should be noted that impacts are qualitative and have not been quantified.

An additional measure intended to minimise and prevent impacts to MNES, Agrimin will develop a Conservation Significant Species Management Plan if required to document all management measures and monitoring targeted to threatened and other specially protected flora and fauna species known to occur within, or in close proximity to, the Mackay SOP Project development envelopes

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Table 5-3:Potential Impacts on MNES and Mitigation Measures

Impacts Mitigation Measures

Flora and Vegetation

Clearing for off-lake development (avoiding Priority species where possible) and access corridors impacting flora and vegetation.

• Less than 5% of the on-lake development envelope and less than 2% of the off-lake development envelopes will be subject to disturbance, and habitats are well-represented in the area.

• Trenches and evaporation ponds will be located on the open playa of the lake, avoiding vegetation clearing, where possible. • Off-lake infrastructure has been configured to avoid riparian vegetation and conservation significant flora species, where possible. • Clearing and disturbance will be completed progressively as areas are required, and minimised where possible for on-lake and off-lake

development and utilise existing tracks where possible. • Vegetation clearing associated with the northern corridor will be minimised by utilising existing access tracks. • Clearing and disturbance will be managed via a Ground Disturbance Permitting System to avoid unauthorised clearing of vegetation outside

approved boundaries. • Disturbed areas will be rehabilitated progressively, where possible or at closure. • A MCP (in accordance with DMIRS guidelines) will outline specific closure objectives and completion criteria for the lake and peripheral habitat,

including rehabilitation as required.

Hydrocarbon and /or chemical leaks and spills impacting peripheral flora and vegetation (expected to be rare and highly localised).

• Hydrocarbon and /or chemical leaks and spills (expected to be rare) will be managed using bunding techniques, leak detection mechanisms and spill kits to restrict impacts.

Groundwater drawdown impacting island and peripheral flora and vegetation (including potential GDEs).

• A staged approach to trenching design will be investigated to minimise impacts to the lake habitat. • Groundwater drawdown impacting island and peripheral flora and vegetation (including potential GDEs) although initial groundwater modelling

has indicated that this impact would be unlikely. Changes in hydraulic connectivity and groundwater quality impacting island and peripheral flora and vegetation (including potential GDEs).

• A staged approach to trenching design will be investigated to minimise impacts to the lake habitat. • Trenches and bunding will be engineered to maintain surface water surface water movement patterns, where possible.

Erosion and sedimentation due to on-lake and off-lake development, impacting peripheral flora and vegetation.

• Off-lake access roads and development to be appropriately engineered, with compaction, appropriate bunding and drainage implemented to prevent erosion and sedimentation.

Increases in surface water and groundwater salinity due to runoff and release of waste salts from ponds, impacting peripheral flora and vegetation.

• Evaporation ponds will contain waste salts and will be engineered to minimise excessive runoff of waste salts into the lake habitat, with gradual release over time.

Introduction or spread of weeds and/or pathogens from throughout the Proposal area, impacting flora and vegetation.

• Development and implementation of a Weed Control Management Plan to prevent the spread of weeds (if required), utilising the Kiwirrkurra IPA Rangers were possible.

• Regular weed monitoring and weed control program as per management plans and as required.

Fugitive dust emissions from the Proposal impacting on flora and vegetation • Development and implementation of a Dust Management Plan to minimise dust emissions within the Proposal area.

Increased usage of the northern corridor by local Aboriginal groups impacting on flora and vegetation (predominantly dust emissions).

Bushfires potentially caused by clearing (low risk for other activities). • Development and implementation of a Weed Control Management Plan to prevent the spread of weeds (if required), utilising the Kiwirrkurra IPA Rangers where possible.

Fauna Habitats

Clearing for off-lake development and access corridors impacting fauna habitat • Less than 5% of the on-lake development envelope and less than 2% of the off-lake development envelopes will be subject to disturbance, and habitats are well-represented in the area.

• Trenches and evaporation ponds will be located on the open playa of the lake, avoiding vegetation clearing, where possible. • Off-lake infrastructure has been configured to avoid riparian vegetation and conservation significant flora species, where possible. • Clearing and disturbance will be minimised where possible for on-lake and off-lake development and utilise existing tracks where possible. • Vegetation clearing associated with the northern corridor will be minimised by utilising existing access tracks. • Clearing and disturbance will be managed via a Ground Disturbance Permitting System to avoid unauthorised clearing of vegetation outside

approved boundaries. • Disturbed areas will be rehabilitated progressively, where possible or at closure. • MCP (in accordance with DMIRS guidelines) will outline specific closure objectives and completion criteria for the lake and peripheral habitat,

including rehabilitation as required.

Reduction in fauna habitat availability and increased habitat fragmentation and edge effects (along access corridors).

Changes in surface water movement patterns, due to on-lake and off-lake development, impacting lake or peripheral habitat and fauna (including SREs, macroinvertebrates and waterbirds).

• A staged approach to trenching will be investigated to minimise impacts to the lake habitat. • Trenches and bunding will be engineered to maintain surface water movement patterns, where possible.

Groundwater drawdown impacting island and peripheral habitat and fauna (including SREs and macroinvertebrates).

• A staged approach to trenching will be investigated to minimise impacts to the lake habitat. • Groundwater investigations and modelling will be used to investigate understand drawdown extent and minimise impacts to riparian vegetation

associated with the lake and islands.

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Impacts Mitigation Measures

Changes in hydraulic connectivity and groundwater quality impacting island and peripheral habitat and fauna (including SREs and macroinvertebrates).

• A staged trenching design will be investigated to minimise impacts to the lake habitat. • Groundwater modelling will be used to investigate drawdown extent and minimise impacts to riparian vegetation associated with the lake and

islands, although initial groundwater modelling has indicated that this impact would be unlikely. • Trenches and bunding will be engineered to maintain surface water movement patterns, where possible

Erosion and sedimentation due to on-lake and off-lake development, impacting peripheral habitat and fauna (including SREs and macroinvertebrates).

• Off-lake access roads and development to be appropriately engineered, with compaction, appropriate bunding and drainage implemented to prevent erosion and sedimentation.

Increases in surface water and groundwater salinity due to runoff and release of waste salts from ponds, impacting lake or peripheral habitat and fauna (including SREs, macroinvertebrates and waterbirds).

• Evaporation ponds will contain waste salts and will be engineered to minimise excessive runoff of waste salts into the lake habitat, with gradual release over time.

Introduction or spread of weeds/pathogens from throughout the Proposal area, causing fauna habitat decline (including SREs, macroinvertebrates and waterbirds).

• Development and implementation of a Weed Control Management Plan to prevent the spread of weeds (if required), utilising the Kiwirrkurra IPA Rangers were possible.

• Regular weed monitoring and weed control program as per management plans and as required.

Bushfires potentially caused by clearing (low risk for other activities), impacting on fauna habitat.

• Development and implementation of a Weed Control Management Plan to prevent the spread of weeds (if required), utilising the Kiwirrkurra IPA Rangers were possible.

Fauna

Increased risk of fauna injury or death from vehicle or equipment strikes. • Implementation of traffic management system (including vehicle speed limits and driving on designated tracks, where possible), and environmental awareness training, to minimise the likelihood of fauna injury or mortality due to interaction with vehicles.

• A database of conservation significant fauna species and sightings will be established and maintained. • Site inductions and awareness training will be provided to site-staff for conservation significant species, and their preferred habitats. • A suitably qualified fauna spotter (holding a permit to handle and move conservation significant fauna under Regulation 15 of the WC Act) will

be present for all clearing activities and will have access to a care facility for rehabilitation of injured fauna (if required). • Wherever practical, clearing will be undertaken from one direction only, providing an opportunity for fauna to escape into surrounding

vegetation. • Signage will be installed along access roads for areas identified as key fauna habitat. • All native fauna injuries or mortalities will be recorded and reported internally, and to appropriate regulatory agencies as required. • Development and implementation of Fauna Management Plans (for conservation significant fauna and feral animals) to protect native fauna

and outline reporting requirements where activities from the Proposal have resulted in injury or mortality, in collaboration with the Kiwirrkurra IPA Rangers where possible.

• Monitoring of fauna species of conservation significance as per management plans and as required. • Development and implementation of an ecological monitoring program for the lake and peripheral habitat as required.

Increased risk of fauna injury or death accessing trenches or ponds. • A database of conservation significant fauna species and sightings will be established and maintained. • Site inductions and awareness training will be provided to site-staff for conservation significant species, and their preferred habitats. • All service trenches, pipelines and ponds for the Proposal will have suitably designed fauna egress or ramps to allow native fauna to escape, and

will be regularly inspected by a fauna spotter, with entrapped fauna removed and relocated to surrounding vegetation. • A suitably qualified fauna spotter (holding a permit to handle and move conservation significant fauna under Regulation 15 of the WC Act) will

be present to relocated fauna from trenches or ponds and will have access to a care facility for rehabilitation of injured fauna (if required). • All native fauna injuries or mortalities will be recorded and reported internally, and to appropriate regulatory agencies as required. • Development and implementation of Fauna Management Plans (for conservation significant fauna and feral animals) to protect native fauna

and outline reporting requirements where activities from the Proposal have resulted in injury or mortality, in collaboration with the Kiwirrkurra IPA Rangers where possible.

• Monitoring of fauna species of conservation significance as per management plans and as required. • Development and implementation of an ecological monitoring program for the lake and peripheral habitat as required.

No direct impacts to migratory waterbirds as sufficient lake and peripheral habitat to remain and surface water movement patterns to be maintained where possible.

• Sufficient lake and peripheral habitat to remain and surface flow patterns to be maintained (where possible).

No direct impacts to Night Parrots or associated key habitat (considered minimal) within the off-lake development and along access corridors.

• Minimal Night Parrot habitat available (old, unburnt spinifex) and design and layout of Proposal to avoid key habitat.

Hydrocarbon and /or chemical leaks and spills impacting fauna (expected to be rare and highly localised).

• Hydrocarbon and /or chemical leaks and spills (expected to be rare) will be managed using bunding techniques, leak detection mechanisms and spill kits to restrict impacts.

Introduction of feral animals into the Proposal area, impacting fauna (including SREs, macroinvertebrates and waterbirds).

• Appropriate waste management off-lake will be undertaken to reduce the likelihood of attraction and access of feral animals. • Putrescible waste off-lake will be stored in secure bins, to reduce the likelihood of attraction and/access of feral animals.

Changes in hydraulic connectivity and groundwater quality impacting island and peripheral habitat and fauna (including SREs and macroinvertebrates).

• Sufficient lake and peripheral habitat to remain and surface flow patterns to be maintained (where possible). • Trenches and bunding will be engineered to maintain surface water movement patterns on the lake, where possible.

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Impacts Mitigation Measures

• Groundwater investigations and modelling will be used to investigate understand drawdown extent and minimise impacts to lake, islands and peripheral fauna habitat.

Changes in surface water movement patterns, due to on-lake and off-lake development, impacting lake or peripheral habitat and fauna (including SREs, macroinvertebrates and waterbirds).

• Sufficient lake and peripheral habitat to remain and surface movement patterns to be maintained (where possible). • Trenches and bunding will be engineered to maintain surface water movement patterns on the lake, where possible. • Development and implementation of a Surface Water Management Plan to maintain ecological flows.

Groundwater drawdown impacting fauna (including SREs and macroinvertebrates). • Groundwater investigation and modelling will be used to investigate understand drawdown extent and minimise impacts to fauna (including SREs and macroinvertebrates).

Erosion and sedimentation due to on-lake and off-lake development, impacting fauna (including SREs and macroinvertebrates).

• Off-lake access tracks roads and development to be appropriately engineered, with compaction, appropriate bunding and drainage implemented to prevent erosion and sedimentation.

Increases in surface water and groundwater salinity due to runoff and release of waste salts from ponds, impacting fauna (including SREs, macroinvertebrates and waterbirds).

• Evaporation ponds will contain waste salts and will be engineered to minimise excessive runoff of waste salts into the lake with gradual release over time reducing impacts to fauna (including SREs, macroinvertebrates and waterbirds).

Bushfires potentially caused by clearing (low risk for other activities) causing fauna mortality.

• Development and implementation of a site Hot Work Permit System, and Emergency Management Procedures, to minimise the risk of bushfires.

Noise, vibration or light impacting on fauna. • Development and implementation of a Dust Management Plan to minimise dust emissions within the Proposal area.

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6. Proposed Outcomes and Offsets At this stage no residual impacts have been identified. Further refinement of the Proposal design and associated investigations is required in order to fully ascertain the likelihood and longevity of impacts resultant from the proposal.

Agrimin’s proposed mitigation measures intended to avoid, minimise and rehabilitate impacts to environmental factors have been described within Section 4 of this document. However, if after application of these measures there are significant residual impacts on Key Environmental Factors or MNES, environmental offsets for conservation actions will be considered. In this instance offsets will be developed in accordance with principles of the WA Environmental Offsets Policy ((Government of Australia 2011) and the EPBC Act Environmental Offsets Policy (2012) to counter balance this impact.

Agrimin has made the following commitments relating to offsets within the Project’s Native Title Agreement:

a) In the event that the Company is required to provide environmental offsets as part of the approval and conditions on any Environmental Project Approvals, the Company will use its best endeavours to ensure that any offsets are directed towards matters that are relevant to and benefit the Kiwirrkurra People, particularly through support for the Kiwirrkurra Indigenous Protected Area program and its land management activities.

b) For the purpose of identifying potential environmental offsets, the Company must consult in good faith with Tjamu, with a view to jointly developing offset proposals to submit to the Environmental Protection Authority.

c) Nothing in this clause will require the Company to do anything that is contrary with the requirements of any Project Approval or with its obligations at Law.

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7. Holistic Impact Assessment The Lake Mackay receiving environment is connected via hydrological processes, which influence surface water and groundwater. Major rainfall events cause the lake to flood and recharge groundwater, with subsequent losses from the system primarily by evaporation. The connectivity of groundwater and surface water has the potential to influence biological diversity and ecological integrity, particularly where there is a dependence on hydrological processes, and prospective habitat is available.

Agrimin has commissioned a substantial number of environmental baseline studies, with the findings currently suggesting that there will be minimal impacts and minimal residual impacts to the receiving environment. A preliminary conceptual site model has been developed (Figure 7-1) with consideration of connections and interactions, and potential Proposal impacts and mitigation measures summarised for the key environmental factors (flora and vegetation, terrestrial fauna and inland waters), with other environmental factors to be considered as the Proposal progresses, to refine the holistic impact assessment.

Additional environmental baseline studies are required to address current knowledge gaps (including hydrological modelling and ecological assessment), to which Agrimin is committed, to ensure there is an adequate understanding of predicted outcomes and residual impacts for the Proposal. This will allow comprehensive risk assessments to be developed and additional mitigation measures to be implemented (following the mitigation hierarchy), to reduce residual impacts and meet the EPA’s objectives.

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Figure 7-1: Preliminary Conceptual Site Model of Lake Mackay indicating Connectivity and Interactions between Key Environmental Factors, in relation to Potential Impacts and Mitigation Measures.

Peripheral Wetlands

Surface Water

Groundwater

Lake

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8. References 360 Environmental. (2017a). Detailed Flora and Vegetation Assessment of the Mackay SOP Project. Report

prepared for Agrimin Ltd, Western Australia.

360 Environmental. (2017b). Waterbird Survey for the Mackay SOP Project. Report for Agrimin Ltd, Western Australia.

360 Environmental. (2018a). Mackay SOP Project EPA and EPBC Referral Supporting Document. Report for Agrimin Ltd, Western Australia.

360 Environmental. (2018b). Preliminary Acid Sulphate Soils Investigation for the Mackay SOP Project. Report prepared for Agrimin Ltd, Western Australia.

360 Environmental. (2018c). Single Phase Level 2 Fauna Survey of the Mackay SOP Project. Report prepared for Agrimin Ltd, Western Australia.

360 Environmental. (2018d). Uranium, Thorium and Metal Analytical Review for the Mackay SOP Project. Letter for Agrimin Ltd, Western Australia.

Advisian. (2018). Chapter 6. Hydrological and Hydrogeological Modelling for the Mackay SOP Project Prefeasibility Study. Report for Agrimin, Western Australia.

Agrimin Ltd. (2018). Hydrology and Hydrogeology of the Mackay SOP Project. Agrimin Ltd, Western Australia.

ANZECC and ARMCANZ. (2000). Australian and New Zealand guidelines for fresh and marine water quality. ANZECC and ARMCANZ.

Australian Government National Water Commission. (2012). Australian Groundwater Modelling Guidelines.

Cowan, C., Bray, R. and Paltridge, R. (2015). Kiwirrkurra Indigenous Protected Area Bushblitz Survey. Prepared for Agrimin Ltd, Western Australia.

DAA. (2013). Aboriginal Heritage Due Diligence Guidelines. Version 3. Prepared by Department of Aboriginal Affair and Department of Premier and Cabinet.

DAA. (2018). Guidelines for Preparing Aboriginal Heritage Survey Reports. Department of Aboriginal Affair (DAA).

Davis, R. and Metcalf, B. (2008). The Night Parrot (Pezoporus occidentalis) in northern Western Australia: a recent sighting from the Pilbara region. Emu 108: 233-236.

DBCA. (2017). Interim Guideline for Preliminary Surveys of Night Parrot (Pezoporus occidentalis) in Western Australia Department of Biodiversity Conservation and Attractions (DBCA), Western Australia.

DER. (2014). Assessment and Management of Contaminated Sites: Contaminated Sites Guidelines. Department of Environmental Regulation (DER).

DER. (2015a). Identification and Investigation of Acid Sulphate Soils and Acidic Landscapes Derpartment of Environmental Regulation (DER),, Western Australia.

DER. (2015b). Treatment and Management of Soil and Water in Acid Sulphate Soils Landscapes. Department of Environmental Regulation (DER),.

DER. (2016). Draft Guideline on Environmental Noise for Prescribed Premises. Department of Environmental Regulation (DER).

DEWHA. (2010). Survey Guidelines for Australia's Threatened Birds.

DEWHA. (2013). Significant impact guidelines 1.1 - Environment Protection and Biodiversity Conservation Act 1999.

DIA. (2009). Guidelines for the Development of an Aboriginal Cultural Heritage Management Plan for the Aboriginal Heritage Act 1972 Department of Indigenous Affairs (DIA).

DIIS. (2016). Preventing Acid and Metalliferous Drainage – Leading Practice Sustainable Development Program For the Mining Industry. Commonwealth Department of Industry Innovation and Science (DIIS),.

DMP. (2016). Draft Guidance Materials Characterisation Baseline Data Requirements of Mining Proposals. Department of Mines and Petroleum.

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DoW. (2013). Western Australian Water in Mining Guidelines. 12.

ecologia Environment. (2017a). Level 1 Fauna and Single Phase Level 2 Flora Assessment for the Mackay SOP Project. Report for Agrimin Ltd, Western Australia.

ecologia Environment. (2017b). Subterranean Fauna Risk Assessment for the Mackay SOP Project. Agrimin Ltd, Western Australia.

EPA. (2000). Environmental Protection of Native Vegetation in WA: Clearing of Native Vegetation with Particular Reference to Agricultural Areas. Position Statement No. 2. Environmental Protection Authority (EPA), Western Australia.

EPA. (2004). EPA Guidance Statement No. 41: Assessment of Aboriginal Heritage. Environmental Protection Authority (EPA), Western Australia.

EPA. (2006). Guidance Statement No. 6 – Rehabilitation of Terrestrial Ecosystems. Environmental Protection Authority (EPA), Western Australia.

EPA. (2016a). Environmental Factor Guideline: Flora and Vegetation. Environmental Protection Authority (EPA), Western Australia.

EPA. (2016b). Environmental Factor Guideline: Human Health. Environmental Protection Authority (EPA), Western Australia.

EPA. (2016c). Environmental Factor Guideline: Social Surroundings. Environmental Protection Authority (EPA), Western Australia.

EPA. (2016d). Environmental Factor Guideline: Subterranean Fauna. Environmental Protection Authority (EPA), Western Australia.

EPA. (2016e). Environmental Factor Guideline: Terrestrial. Environmental Protection Authority (EPA), Western Australia.

EPA. (2016f). Environmental Factor Guideline: Terrestrial Environmental Quality. Environmental Protection Authority (EPA). Western Australia.

EPA. (2016g). Technical Guidance Sampling Methods for Terrestrial Vertebrate Fauna Environmental Protection Authority (EPA), Western Australia.

EPA. (2016h). Technical Guidance: Sampling Methods for Subterranean Fauna. Environmental Protection Authority (EPA), Western Australia.

EPA. (2016i). Technical Guidance: Sampling of Short Range Endemic Invertebrate Fauna. Environmental Protection Authority (EPA), Western Australia.

EPA. (2016j). Technical Guidance: Subterranean Fauna Survey. Environmental Protection Authority (EPA),, Western Australia.

EPA. (2016k). Technical Guidance: Terrestrial Fauna Surveys. Environmental Protection Authority (EPA), Western Australia.

EPA. (2016l). Technical Guidance: Terrestrial Flora and Vegetation Surveys for Environmental Impact Assessment. Environmental Protection Authority (EPA),, Western Australia.

EPA. (2018a). Environmental Factor Guideline: Inland Waters. Environmental Protection Authority (EPA), Western Australia.

EPA. (2018b). Environmental Factor Guideline: Landforms. Environmental Protection Authority (EPA), Western Australia.

EPA. (2018c). Environmental Impact Assessment (Part IV Divisions 1 and 2) Procedures Manual Environmental Protection Authority (EPA), Western Australia.

EPA. (2018d). EPA “Instructions for the referral of a Proposal to the Environmental Protection Authority under Section 38 of the Environmental Protection Act 1986”. Environmental Protection Authority (EPA), Western Australia.

EPA. (2018e). EPA “Instructions on how to prepare an Environmental Review Document” for Part B of the Section 38 referral. Environmental Protection Authority (EPA), Western Australia.

Garnett, S. T., Szabo, J. K. and Dutson, G. (2011). The action plan for Australian birds 2010. CSIRO Publishing and Birds Australia, Collingwood, Victoria.

Geoscience Australia. (2016). Australian Rainfall and Runoff Guidelines

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Government of Australia. (2011). WA Environmnetal Offsets Policy. Government of Australia,, Western Australia.

Government of Australia. (2013). National Environment Protection (Ambient Air Quality) Measure (NEPM). National Environment Protection Council.

Government of Western Australia. (2014). WA Environmental Offsets Guidelines. Environmental Protection Authority (EPA), Western Australia.

Higgins, P. J. (1999). Handbook of Australian, New Zealand and Antarctic Birds. Oxford University Press, Melbourne.

Invertebrate Solutions. (2017a). Dual Phase Survey for Short Range Endemic Fauna for the Mackay SOP Project. Report for Agrimin, Western Australia.

Invertebrate Solutions. (2017b). Pilot Survey for Subterranean Fauna for the Mackay SOP Project. Report for Agrimin Ltd, Western Australia.

Invertebrate Solutions. (2017c). Survey for Aquatic Macroinvertebrates and Short Range Endemic Fauna for the Mackay SOP Project. Report for Agrimin Ltd, Western Australia.

Invertebrate Solutions. (2018). Phase 1 Survey for Subterranean Fauna for the Mackay SOP Project. Report for Agrimin, Western Australia.

Johnstone, R. E. and Storr, G. M. (1998). Handbook of Western Australian Birds. Oxford University Press, Melbourne.

Murphy, S. and Leseberg, N. (2017). Night Parrot Survey Advice for the Lake Mackay Area. Technical Report to Strategen Environmental, Malanda, QLD.

Southgate, R. P., R.; Masters, R.; Carthew, S. . (2007). Bilby distribution and fire: a test of alternative models of habitat suitability in the Tanami Desert, Australia. Ecography 30: 759-776.

Strategen Environmental. (2018a). Level 2 Vertebrate and Targeted Fauna Survey for the Mackay SOP Project. Report for Agrimin, Western Australia.

Strategen Environmental. (2018b). Vertebrate Fauna and Flora Risk Assessment for the Mackay SOP Project. Report for Agrimin, Western Australia.

Van Dyck, S. S., R. (2008). The Mammals of Australia. New Holland Publishers, New South Wales.

Woinarski, J. C. Z. B., A. A.; Harrison, P. L. . (2014). The action plan for Australian Mammals 2012. CSIRO Publishing.

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Appendices

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Appendix A Flora and Vegetation Survey Reports

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A.1 Level 1 Fauna and Single Phase Level 2 Flora and Vegetation Survey (ecologia Environment 2017)

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A.2 Detailed Flora and Vegetation Assessment (360 Environmental 2017)

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A.3 Detailed Flora and Vegetation Assessment at Lake Mackay (Strategen 2018)

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A.4 Vertebrate Fauna and Flora Risk Assessment (Strategen 2018)

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Appendix B Terrestrial Fauna Survey Reports

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

B.1 Kiwirrkurra Indigenous Protected Area Bushblitz Survey (Cowan et. al. 2015)

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

B.2 Single Phase Level 2 Fauna Survey at Lake Mackay (360 Environmental 2018)

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

B.3 Waterbird Survey at Lake Mackay (360 Environmental 2017)

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

B.4 Level 2 Vertebrate and Targeted Fauna Survey (Strategen 2018)

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

Appendix C Aquatic Ecology Reports

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

C.1 Survey for Aquatic Macroinvertebrates and SRE Fauna for the Mackay SOP Project, Western Australia (Invertebrate Solutions 2017)

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

C.2 Survey for Aquatic Macroinvertebrates for the Mackay SOP Project, Western Australia (Invertebrate Solutions 2018)

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

C.3 Dual Phase Survey for Short Range Endemic Fauna for the Lake Mackay SOP Project, Western Australia (Invertebrate Solutions 2017).

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

Appendix D Hydrology Report

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

Appendix E Subterranean Survey Reports

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

E.1 Subterranean Fauna Risk Assessment (ecologia Environment 2017)

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

E.2 Pilot Survey for Subterranean Fauna for the Mackay SOP Project, Western Australia (Invertebrate Solutions 2017)

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

E.3 Phase 1 Survey for Subterranean Fauna for the Mackay SOP Project, Western Australia (Invertebrate Solutions 2018)

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

Appendix F Acid Sulphate Soil Investigation

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

Appendix G Uranium and Thorium Analytical Review

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

Appendix H Protected Matters Search Tool Results

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

H.1 PMST Results On-Lake and Off-lake

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December 2018 │ Status: Final │ Project No.: LMAL-EA-18001 │ Our ref: LMAK-EA-18001_EPA Referral Supplementary Report_Final

H.2 PMST Results Access Corridors

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