Appendix 4 4a. Significant Flora Management Plan (covering ... · This Flora Management Plan (FMP) is intended to support referrals under the Environmental Protection Act 1986 and

Appendix 4

4a. Significant Flora Management Plan (covering Ironcaps Banksia)

Covalent Lithium Earl Grey Lithium Project FLORA MANAGEMENT PLAN

Prepared by Strategen Environmental Consultants Pty Ltd COVALENT LITHIUM PTY LTD | L18 109 ST GEORGE’S TERRACE, PERTH WA 6000

Covalent Earl Grey Lithium Project

Flora Management Plan

January 2019 Version 4.0

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Executive Summary

This Environmental Management Plan (EMP) is submitted to support environmental referrals under the Environmental Protection Act 1986 (EP Act) and Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) for the Earl Grey Lithium Project which will be developed by Covalent Lithium Pty Ltd (Covalent), a joint venture between Kidman Resources Limited and SQM (Sociedad Química y Minera de Chile S.A.). The following table presents the purpose of the EMP in the context of Western Australia Environmental Protection Authority (EPA) objectives and the Commonwealth Department of Environment and Energy (DoEE) guidelines.

Table ES1: Summary and Purpose of the Environmental Management Plan Item Description

Proposal title Earl Grey Lithium Project.

Proponents name Covalent Lithium Pty Ltd (Covalent).

Short description of Proposal

This Proposal is for the development of an open cut lithium mine within the abandoned Mt Holland Mine Site, located approximately 105 km south–southeast of Southern Cross, Western Australia. The Proposal will have a total footprint of 660 ha of which 392 ha would be new clearing and 268 ha already disturbed. The life of mine is 40 years.

Purpose of the Environmental Management Plan

This Flora Management Plan (FMP) is intended to support environmental impact assessment under the Environmental Protection Act 1986 and the Environment Protection and Biodiversity Conservation Act 1999. The purpose of this Environmental Management Plan is to provide a framework to ensure that impacts on Ironcaps Banksia (Banksia sphaerocarpa var. dolichostyla), and other conservation significant species found to be attributable to the Earl Grey Lithium Project are avoided to the maximum extent practicable and impacts do not compromise the EPA objectives for flora. The FMP has been developed to address the Significant Impact Guidelines 1.1 – Matters of National Environmental Significance.

Key environmental factors

Flora and Vegetation.

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

Key Management Plan Objectives

Environmental criteria • No more than 0.56% of the known population (equates to 92 of 16,503 individuals) of Banksia

sphaerocarpa var. dolichostyla or 18.07% or 18.017% of the known population (equates to 7,498 of 41,492 individuals) of Microcorys sp. Mt Holland (D. Angus DA 2397) directly impacted from clearing.

• No more than 392 ha of native vegetation to be cleared within the Development Envelop • No more than 50% mortality of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt

Holland (D. Angus DA 2397) from indirect impacts that is statistically different from changes observed at analogue sites.

Management targets • No unauthorised clearing of native vegetation. • No unauthorised clearing of native vegetation, Banksia sphaerocarpa var. dolichostyla or

Microcorys sp. Mt Holland (D. Angus DA 2397). • No reduction in health of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland

(D. Angus DA 2397) that is statistically different from analogue measurements. • Avoid incidence and minimise intensity of accidental spill events • Minimise new weeds introduced to site • Prevent fires attributed to mining and associated Project activities

This EMP is designed to be adaptive and will be updated over the life of the Project. As monitoring programs are undertaken, quantifiable environmental criteria will be further defined. The Proponent will update this EMP in consultation with relevant government departments, as such, this EMP remains a working document.

Table of contents

1. Context, Scope, and Rationale 1 1.1 Proposal 1 1.2 Key Environmental Factors 1 1.3 Condition Requirements 4 1.4 Rationale and Approach 4

1.4.1 Survey and Study Findings 4 1.4.2 Key assumptions and uncertainties 11 1.4.3 Management Approach 11 1.4.4 Rationale for choice of provisions 12

2. Management plan provisions 14 2.1 Outcome-based provisions 14

2.1.1 Environmental Criteria justification 14 2.2 Management-based provisions 20 2.3 Implementation 26

2.3.1 Environmental induction 26 2.3.2 Incidents and corrective actions 27

2.4 Monitoring 27 2.5 Reporting 28

3. Adaptive Management and FMP Review 29 3.1 Early response triggers 29 3.2 Benchmarking and Best-Practice 30 3.3 Plan Revisions 30

4. Stakeholder consultation 31 4.1 Key Stakeholders 31

4.1.1 Stakeholder Engagement Process 32 5. Definitions 33 6. Acronyms and short titles 34 7. References 35

List of tables Table 1-1: Flora and vegetation studies completed for the Proposal 5 Table 1-2: Banksia sphaerocarpa var. dolichostyla surveyed within the Development Envelope, and the local vicinity of

the Proposal. 6 Table 1-3: Conservation Significant Flora Species Recorded in the Development Envelope 10 Table 2-1: Environmental Criteria justification 15 Table 2-2: Outcome-based provisions 17 Table 2-3: Management-based provisions 21 Table 2-4: Summary of roles and responsibilities relevant to the Earl Grey Lithium Project FMP. 26 Table 5: Monitoring action summary 27 Table 2-6: Flora Management Plan reporting actions 28 Table 3-1: Early response triggers and actions 30 Table 4-1: Key Stakeholders 31

List of figures Figure 1-1: Regional location 2 Figure 1-2: Development Envelope and indicative Proposal footprint 3 Figure 1-3: Banksia sphaerocarpa var. dolichostyla locations 8 Figure 1-4: Other Conservation Significant flora in the Survey Area 9

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1. Context, Scope, and Rationale The proposed Earl Grey Lithium Project (the Proposal) is located approximately 105 km south–southeast of Southern Cross, Western Australia in the Shire of Yilgarn (Figure 1-1). A large, economic pegmatite–hosted lithium deposit was discovered by Kidman Resources Limited in 2016. The deposit is situated at the previously abandoned Mt Holland Mine Site, which was operated between 1988 and 2001, and comprises open pits, an underground mine, a processing plant, waste rock dumps, tailings storage facilities (TSF) and associated infrastructure. The Mt Holland Mine is largely unrehabilitated and currently a liability of the State of Western Australia.

This Flora Management Plan (FMP) is intended to support referrals under the Environmental Protection Act 1986 and the Environment Protection and Biodiversity Conservation Act 1999. The purpose of this Management Plan is to provide a framework to ensure that impacts on Ironcaps Banksia (Banksia sphaerocarpa var. dolichostyla) and other conservation significant flora species (particularly Microcorys sp. Mt Holland (D. Angus DA 2397)) found to be attributable to the Earl Grey Lithium Project are minimised to the maximum extent practicable and impacts do not compromise the EPA objectives for flora.

1.1 Proposal

The Proposal will comprise open cut mining and processing of lithium ore, with transport of a lithium concentrate to an existing Western Australian port for export to overseas markets or a future potential lithium refinery in Kwinana. Within the Development Envelope (1984 ha) the total Proposal footprint is 660 ha with the full extent of the Proposal to be developed progressively over a 40 year period. The location of the Development Envelope and indicative Proposal footprint in shown in Figure 1–2.

The Proposal has been designed to maximise the use of existing disturbance areas. The Proposal requires clearing of 392 ha of native vegetation and will use 268 ha of the existing cleared areas. The additional clearing is predominately required for the mine pit, waste landforms and ancillary infrastructure.

1.2 Key Environmental Factors

The Proposal was referred under s 38 of the EP Act on 19 May 2017. The Environmental Protection Authority (EPA) determined the Proposal requires a Public Environmental Review (PER) level of assessment on 14 July 2017. The EPA approved an Environmental Scoping Document (ESD) on 14 December 2017 identifying the preliminary key environmental factors, impacts to be assessed and work required to prepare the ERD.

The ESD identified the following two key preliminary environmental factors: 1. Flora and Vegetation. 2. Terrestrial Fauna.

The Proposal was also referred under the Commonwealth Government Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) and received a ‘Controlled Action’ decision (2017/7950), which was authorised to be assessed under the WA bilateral assessment process. The EPBC Act requires an assessment as to whether a proposed action is likely to have a significant effect on a matter of national environmental significance MNES.

The relevant MNES for this Proposal are:

• Chuditch (Dasyurus geoffroii) – Vulnerable

• Malleefowl (Leipoa ocellata) – Vulnerable

• Ironcaps Banksia (Banksia sphaerocarpa var. dolichostyla) – Vulnerable.

Chuditch (Dasyurus geoffroii) and Malleefowl (Leipoa ocellata) are discussed in the Fauna Management Plan.

Figure 1-1: Regional location

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[email protected]

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Source: Landgate: Aerial imagery - 2017;

SQM: Development envelop - 17/11/2017.

Note that positional errors may occur in some areas

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Figure 1-2: Development Envelope and indicative Proposal footprint

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1.3 Condition Requirements

The objectives of this FMP are firstly, to ensure that Conservation Significant Flora found within the Project are protected and managed in accordance with the requirements of the Biodiversity Conservation Act 2016 (BC Act) and to the satisfaction of the Department of Biodiversity, Conservation and Attractions (DBCA). The Proposal is currently being assessed by the EPA (Assessment 2123) under a bilateral assessment for DoEE (EPBC Act). As such, the FMP will need to manage impacts to MNES to the satisfaction of DoEE. A Ministerial Statement, associated Proposal Implementation conditions and approval under the EPBC Act are yet to be issued.

This FMP addresses the requirements of the EPA Scoping document item 9 and details:

• management and monitoring of Threatened Banksia sphaerocarpa var. dolichostyla

• management and monitoring of conservation significant flora, including Priority flora and newly identified species

• monitoring and control of weeds

• adaptive management actions to be implemented in response to environmental criteria (triggers and thresholds) or management targets being reached.

1.4 Rationale and Approach

The Proposal was designed to minimise impacts related to the Proposal footprint. The use of existing infrastructure in close proximity to flora species and operations within a largely uncleared local context may result in the potential for indirect impacts on species and habitats.

1.4.1 Survey and Study Findings

Surveys

Floristic and vegetation surveys outlined in Table 1-1 have been used to support the assessment of potential impacts of the Proposal on flora and vegetation and commensurate mitigation of potential impacts.

The surveys were completed in accordance with the standards set out in Technical Guidance – Flora and Vegetation Surveys for Environmental Impact Assessment (EPA 2016b) and Environmental Factor Guideline: Flora and Vegetation (EPA 2016a). This included targeted surveys for Banksia sphaerocarpa var. dolichostyla and other key conservation significant flora, including Priority 1 flora and new species.

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Table 1-1: Flora and vegetation studies completed for the Proposal

Investigation Scope Number of Personnel

Survey Effort (Person Days)

Mattiske Consulting Pty Ltd (2018d).

Mattiske Consulting and Strategen Environmental conducted targeted floristic surveys focused on Priority 1 flora, range extensions and new species with potential to be impacted by the Proposal in November 2018. Species of focus due to potential presence in the Development Envelope and potential impacts included: • Brachyloma stenolobum (P1) • Grevillea lissopleura (P1) • Grevillea marriottii (P1) • Labichea rossii (P1) • Microcorys sp. Mt Holland (D. Angus DA 2397) (P1) • Acacia sp. 1 (undescribed) • Acacia sp. Mt Holland (B. Ellery BE1147) (P1) • Eremophila verticillate (Threatened) (previously stated as

Eremophila sp. aff. verticillate) • Hibbertia aff. oligantha (undescribed) • Acacia undosa (P3) • Eutaxia lasiocalyx (P2) • Hakea pendens (P3) • Dicrastylis capitellata (P1) • Daviesia newbeyi (P3) • Stenanthemum bremerense (P4) • Daviesia sarissa subsp. redacta (P2) • Olearia laciniifolia (P2) • Orianthera exilis (P2) • Chorizema circinale (P2) • Callitris verrucosa (range extension) • Centrolepis strigosa subsp. rupestris (range extension). Targeted surveys were conducted both within and outside the Development Envelope to characterise local context in addition to understanding the direct impacts of the Proposal.

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Mattiske Consulting Pty Ltd (2018b).

Mattiske Consulting Pty Ltd was commissioned between April and June of 2018 by Western Australian Lithium Pty Ltd to undertake a survey of the threatened Banksia sphaerocarpa var. dolichostyla both within the Earl Grey Lithium Development Envelope and within the broader region surrounding the proposal area. 18 individual populations of Banksia sphaerocarpa var. dolichostyla were recorded during the surveys. A total of 16,503 Banksia sphaerocarpa var. dolichostyla individuals were recorded across all the areas surveyed. When the estimated numbers are included (6,083), the local population is potentially 22,586 plants.

3-4 36

Mattiske Consulting Pty Ltd (2018a).

Flora and vegetation surveys have been conducted within the Earl Grey Lithium Project Development Envelope, a 1 km area around the Development Envelope and 200 m either side of the centre line of the access routes. The total area surveyed was 4,417.83 ha, of which 1,993.59 ha was within the Earl Grey Lithium Project Development Envelope. A total of 214 vegetation survey quadrats were established and surveyed across the survey area.

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Blueprint Environmental Strategies (2017).

In April 2017, Goldfields Landcare Services conducted surveys for Banksia sphaerocarpa var. dolichostyla within proposed landform and infrastructure areas of the Development Envelope.

2 6

Mattiske Consulting Pty Ltd (2017).

The assessment of the flora and vegetation of the Earl Grey, Irish Breakfast and Prince of Wales prospects at Mt Holland was undertaken by Mattiske, from 24 to 26 October 2016 and 9 to 10 November 2016. A total of 43 vegetation survey quadrats were established.

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Investigation Scope Number of Personnel

Survey Effort (Person Days)

Native Vegetation Solutions (2016).

In September 2016, Native Vegetation Solutions conducted surveys for Banksia sphaerocarpa var. dolichostyla within proposed exploration areas of the Earl Grey deposit.

Not defined

Not defined

Native Vegetation Solutions (2014).

Native Vegetation Solutions (NVS) conducted surveys for Banksia sphaerocarpa var. dolichostyla around existing infrastructure areas (including roads, the historic camp, landfill and airstrip) of the site.

Not defined

Not defined

Conservation significant flora species identified or estimated to occur within the Development Envelope are detailed in Table 1-3. The local and regional impact of the Proposal on conservation significant species has been assessed in the Environmental Review Document. Conservation significant species that have a total impact from the Proposal greater than 10% of the Regional Population are discussed below and included in the FMP. 10% is considered an appropriate threshold to regional populations whereby further management measures are required.

Survey results

Banksia sphaerocarpa var. dolichostyla (Threatened) is an easily identified shrub 2 to 4 m tall, with bluish green leaves and golden inflorescences. It is confined to an area east of the cleared wheatbelt within the Narrogin and Merredin Districts. It occurs on Vacant Crown Land north from Digger Rocks through Forrestania to Mt Holland. This species prefers iron–capped rises on ironstone profiles. It is found in low woodlands to low shrublands with associates which include Banksia and Allocasuarina species.

Banksia sphaerocarpa var. dolichostyla is currently known to be distributed between Mt Holland and South Ironcap, east of Hyden, Western Australia. Its preferred habitat is lateritic gravel on hills and rises. It commonly grows in association with Banksia spp., Allocasuarina spp., and Hakea spp. (Brown et al.1998, Collins et al. 2008, WAH 1998-). Banksia sphaerocarpa var. dolichostyla is currently listed as a Threatened species under the BC Act and is listed as Vulnerable under the EPBC Act.

Targeted surveys in 2018 (Mattiske 2018b) recorded 16,503 plants in the Proposal survey area occurring within 18 distinct populations, nine of which occur outside of the Development Envelope.

Observation made in the field indicate that populations are healthy, are recruiting juveniles, and in areas which have been subject to fires, have recovered rapidly. Given these factors, and the observation that Banksia sphaerocarpa var. dolichostyla was growing in previously disturbed areas, it is likely that this taxon would be a good candidate for seeding in rehabilitation areas with suitable soils.

Table 1-2: Banksia sphaerocarpa var. dolichostyla surveyed within the Development Envelope, and the local vicinity of the Proposal.

Location Individual Plants Populations Notes

Within the Development Envelope 5,220 7 Based on targeted surveys for Banksia sphaerocarpa var. dolichostyla across the entire Development Envelope in 2018, (Mattiske 2018b).

Local population 16,503 8 Targeted survey records. Mattiske (2018b) estimated 22,586 individuals in the vicinity of the Development Envelope.

Microcorys sp. Mt Holland (D. Angus DA2397) was first recorded by Mattiske Consulting during a reconnaissance survey of the Earl Grey prospect in 2016 (Mattiske 2017). A total of 8,353 individual Microcorys sp. Mt Holland (D. Angus DA2397) have been recorded across a range of areas both within and external to the Development Envelope. Within the Development Envelope, 5,692 individuals have been recorded, of which 1,799 individuals have been recorded within the Proposed Layout. However, based on local population estimates, the currently known local population has been estimated as 41,492 individuals with 7,498 potentially occurring within the Proposed Layout.

7

Within the Development Envelope, Microcorys sp. Mt Holland (D. Angus DA2397) was principally recorded within the S3 vegetation community. This species was also recorded within the MW7 vegetation community immediately downslope from the adjacent S3 community but was not recorded elsewhere within the MW7 vegetation community. The S3 vegetation community is also the vegetation community which is the principal habitat of Banksia sphaerocarpa var. dolichostyla. Microcorys sp. Mt Holland (D. Angus DA2397) was recorded growing on disturbed track edges in parts of the proposed accommodation village and externally in vegetation inferred to correspond to the W6 vegetation community. Therefore, the Microcorys sp. Mt Holland (D. Angus DA2397) tends to be highly associated with areas where Banksia sphaerocarpa var. dolichostyla is growing.

Microcorys sp. Mt Holland (D. Angus DA2397) was recorded within the Jilbadji Nature Reserve, as well as S3 type vegetation external to the Development Envelope where Banksia sphaerocarpa var. dolichostyla is known to be present. Microcorys sp. Mt Holland (D. Angus DA2397) was recorded growing on sandplain areas within the Jilbadji Nature Reserve.

Proposal impacts

Table 1-3 details the direct and potential indirect impacts to the conservation significant flora species identified within the Development Envelope. This FMP addresses the conservation significant flora species that have a greater than 10% total impact to the regional population (Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA2397)). The total impacts to the currently known local populations are 17.68% for Banksia sphaerocarpa var. dolichostyla (92 directly impacted and 2,826 potentially indirectly impacted individuals of 24,636) and 21.75% for Microcorys sp. Mt Holland (D. Angus DA2397) (7,498 directly impacted and 1,525 potentially indirectly impacted individuals of 41,492).

Figure 1-3: Banksia sphaerocarpa var. dolichostyla

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Path: C:\GIS\Consult\2017\SQM\SQM17406\01_GIS_documents\ArcMap_documents\SQM17406_G023_RevE.mxd

Scale at A4

Source: SQM: Aerial imagery - ESRI 2015-2017Development Envelope, Banksia species - 17/11/2017 & 3/10/2018.


0 0.5 1 1.5km

1:65,000


Date: 18/01/2019

Author: Cthatcher

�Legend


Indicative Site Layout

Banksia sphaerocarpa var.dolichostyla population area

Banksia sphaerocarpa var.dolichostyla plants

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INSET MAP

Figure 1-4: Other Conservation Significant flora in the Survey Area

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Path: Q:\Consult\2017\SQM\SQM17406\01_GIS_documents\ArcMap_documents\SQM17406_G038_RevC.mxd

Scale at A4

Source: SQM: Aerial imagery - ESRI 2015-2017Development Envelope, Banksia species - 17/11/2017 & 3/10/2018.


0 0.5 1 1.5km

1:65,000


Date: 18/01/2019

Author: Cthatcher

�Legend


Indicative Site Layout

Vegetation codeH1

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Priority flora

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Acacia sp. Mt Holland (B. Ellery BE 1147)

Acacia sp.1

Acacia undosa

Brachyloma stenolobum Chorizema circinale

Daviesia sarissa subsp. redacta Eremophila verticillata Eutaxia lasiocalyx

Grevillea lissopleura

Grevillea marriottii

Hakea pendens

Hibbertia aff. oligantha

Labichea rossii

Microcorys sp. Mt Holland (D. Angus DA2397)

Olearia laciniifolia

Orianthera exilis

Teucrium sp. dwarf (R. Davis 8813)

Verticordia stenopetala

10

Table 1-3: Conservation Significant Flora Species Recorded in the Development Envelope

Species Conservation Status

Regional Population Individuals

Local population individuals

Individuals within Proposed Layout

Individuals within 50 m Proposed Layout buffer

Local Population Impacts Regional Population Impacts

% Direct Impacts

% Potential Indirect Impacts

% Total Impacts

% Direct Impacts

% Potential Indirect Impacts

% Total Impacts

BC Act/DBCA Priority List EPBC Act

Banksia sphaerocarpa var. dolichostyla

Threatened (Vulnerable)

Vulnerable 24,636 16,503 92 2,826 0.56% 17.12% 17.68% 0.37% 11.47% 11.84%

Acacia sp. Mt Holland (B. Ellery BE1147)

Priority 1 NA 109,426 109,426 458 309 0.42% 0.28% 0.70% 0.42% 0.28% 0.70%

Labichea rossii Priority 1 NA 2,254 2153 189 0 8.78% 0.00% 8.78% 8.39% 0.00% 8.39%

Microcorys sp. Mt Holland (D. Angus DA 2397)

Priority 1 NA 41,492 41,492 7,498 1,525 18.07% 3.68% 21.75% 18.07% 3.68% 21.75%

Eutaxia lasiocalyx Priority 2 NA 10 1 1 0 100.00%

0.00% 100.00%

10.00% 0.00% 10.00%

Orianthera exilis Priority 2 NA 47 1 0 1 0.00% 100.00%

100.00%

0.00% 2.13% 2.13%

Acacia undosa Priority 3 NA 340 265 30 0 11.32% 0.00% 11.32% 8.82% 0.00% 8.82%

Hakea pendens Priority 3 NA 252 225 1 15 0.44% 6.67% 7.11% 0.40% 5.95% 6.35%

Chorizema circinale

Priority 3 NA 174 2 0 1 0.00% 50.00% 50.00% 0.00% 0.57% 0.57%

Verticordia stenopetala

Priority 3 NA 23 2 0 1 0.00% 50.00% 50.00% 0.00% 4.00% 4.00%

11

1.4.2 Key assumptions and uncertainties

Assumptions • it is assumed that by utilising areas of existing disturbance, minimising clearing, and implementing

progressive rehabilitation throughout the life of the Project, the impacts to conservation significant species will be minimised

• surveys to date provide sufficient information to confirm the extent of conservation significant flora, including Ironcaps Banksia (Banksia sphaerocarpa var. dolichostyla), and suggest healthy populations exist within the Project area and surrounding region. Regionally, records of Banksia sphaerocarpa var. dolichostyla exist in the Avon Wheatbelt, Southern Cross, and Western Mallee IBRA sub-regions

• the Banksia sphaerocarpa var. dolichostyla population surveys indicate a combination of favourable factors for this species; suitable soils, good seasons for recruitment, and long unburnt vegetation communities

• targeted surveys for Declared Rare Flora and other conservation significant flora adequately characterise the populations potentially impacted and are of suitable quality to implement proposed management measures and achieve management targets.

Uncertainties • the extent to which climatic factors outside of Covalent’s control will impact on successful rehabilitation

• variation in soil condition over the Proposal footprint and within the revegetation zones

• the extent to which climatic factors outside of Covalent’s control will impact on the health and extent of populations of conservation significant flora, including Banksia sphaerocarpa var. dolichostyla.

1.4.3 Management Approach

Management measures to minimise impacts from project activities are necessary to ensure the Proposal will not have a significant detrimental impact on flora and vegetation. Specific application of mitigation hierarchy for the Proposal is as follows.

Impacts

The potential impacts of relevance include: • direct loss of conservation significant flora from vegetation clearing

• indirect impact from dust, during construction and mining operations

• indirect impact from weed infestation during construction and mining operations

• indirect impact from hypersaline water during construction and mining operations

• indirect impact from changed fire regime.

Focus on Avoidance

As described above, flora surveys of the site have been used in the design of proposed facilities to ensure that direct impacts on Banksia sphaerocarpa var. dolichostyla and conservation significant flora species have been minimised. Based on the current design and available survey information, the proposal will result in direct loss of 0.56% of the currently known local population (92 individuals) of Banksia sphaerocarpa var. dolichostyla and 18.07% of the currently known local population (7,498 individuals) of Microcorys sp. Mt Holland (D. Angus DA 2397).

As part of the detailed design for the Proposal, infrastructure will be placed to avoid direct impacts on conservation significant flora species where possible. Environmental criteria and response actions as outlined in Section 2.1, will assist in avoiding direct impacts to the maximum extent practicable.

12

Minimising impact

While the objective is to minimise direct impacts on Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397), some impacts may be unavoidable if new plants establish within the proposed layout, additional individuals are identified in surveys or the placement of critical infrastructure requires a design change that will result in the removal of an individual plant. In these cases, redesign to avoid impacts may not be practicable. Environmental criteria and response actions intended to minimise direct loss have been proposed in Section 2.1.

Similarly, indirect impacts on Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397), may be unavoidable, especially in areas where existing infrastructure (such as roads) or existing disturbance that will be used for new infrastructure is in close proximity to individual plants. Indirect impacts include impacts from dust deposition, hypersaline water use, spills, weeds and changes to fire regimes. Indirect impacts could occur to individuals within 50 m of the Proposed Layout. The 50 m distance is based on the DWER Clearing Regulation Fact Sheet 24: Environmentally Sensitive Areas (August 2014), whereby a declared environmentally sensitive area is considered the area covered by vegetation within 50 m of rare flora, to the extent to which the vegetation is continuous with the vegetation in which the rare flora is located. In addition, a 50 m distance is considered sufficient to minimise any potential indirect impacts (for example, dust, hypersaline water overspray and runoff and weed invasion).

Up to an additional 17.12% of the currently known local population (2,826 individuals of 16,503) of Banksia sphaerocarpa var. dolichostyla and 3.68% of the currently known population (1,525 individuals of 41,492) of Microcorys sp. Mt Holland (D. Angus DA2397) could potentially be indirectly impacted.

Indirect impacts are minimised to the maximum extent practicable using best management practices to suppress dust and minimise invasive plant species as described in Section 2.2. Management actions and targets to minimise indirect impacts are proposed in Section 2.2.

Additional surveys for Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397) shall be undertaken to improve population distribution and data. Improved data will assist in minimising the proportion of impacts to the currently known population.

Remediation actions where impacts cannot be avoided

Direct impacts to Banksia sphaerocarpa var. dolichostyla or indirect losses resulting from dust generation or other activities associated with the Proposal shall be mitigated through rehabilitation and translocation activities to ensure no net loss of individuals occurs within the Development Envelope. Banksia sphaerocarpa var. dolichostyla has been identified as a good candidate for seeding in rehabilitation areas with suitable soils. It has been observed to be a recruiting species in previously burnet and disturbed areas. Therefore, in the event of a Banksia sphaerocarpa var. dolichostyla individual direct loss associated with the Proposal, the Proponent aims to achieve no net loss of individuals of the currently known local population (16,503 individuals) through the following:

• undertaking rehabilitation trials and implementing research programs (in consultation with DBCA and Kings Park and Botanical Gardens) to increase translocation and rehabilitation success and investigate active propagation

• translocation of individuals to be directly impacted into an area of suitable habitat

• rehabilitation of areas to provide suitable habitat for Banksia sphaerocarpa var. dolichostyla. The previously disturbed former airstrip is a potential location for rehabilitation trials as it intersects the local population area

• seeding of areas with suitable habitat within the Development Envelope with Banksia sphaerocarpa var. dolichostyla seeds

• monitoring of translocated individuals and rehabilitated areas.

Rehabilitation trials and activities shall be undertaken for Microcorys sp. Mt Holland (D. Angus DA 2397).

1.4.4 Rationale for choice of provisions

The mitigation hierarchy is based on the objective of avoiding direct impacts and minimising indirect impacts to conservation significant species and their habitat.

13

The management approach is informed by results of baseline surveys and the Project as detailed in the Environmental Review Document. The Project will have a relatively small footprint within the Coolgardie bioregion with greater than 98% of vegetation remaining including in conservation areas. Development of the mine will occur over 40 years and will utilise up to 40% of existing disturbance. Progressive rehabilitation will be undertaken during the life of mine and at closure including rehabilitation of some existing State liabilities.

Periodic review of the management approach will be undertaken based on monitoring results and incident data. Adaptive management measures will be implemented with a view to achieving continuous improvement in minimising impacts to conservation significant species.

This Flora Management Plan includes both outcome-based and management-based provisions. Outcome-based provisions have been established where the level of impact is known and quantifiable, in this case specifically associated with clearing and measurable impacts to conservation significant flora individuals. Potential threats to conservation significant flora populations also includes accidental spill events, weed introduction and changed fire regimes. The level of potential indirect impacts to populations is unable to be accurately quantified. Consequently, a quantifiable population target is not considered appropriate and management-based provisions have been established to minimise individual mortality from indirect project impacts. As population monitoring is undertaken, quantifiable outcome-based provisions may be able to be established.

14

2. Management plan provisions The key objectives of the management plan are to:

• define measures to manage potential impacts from project activities

• design management actions that are implementable and easily understood by site personnel

• develop mechanisms that enable adaptive management and continuous improvement throughout the life of the project

• facilitate evidence-based review and auditing to demonstrate compliance.

Management provisions have been established for the following potential impacts (as summarised in Section 1.4.3):

• direct loss of conservation significant flora from vegetation clearing

• indirect impact from dust, during construction and mining operations

• indirect impact from weed infestation during construction and mining operations

• indirect impact from hypersaline water during construction and mining operations

• indirect impact from changed fire regime.

As environmental impacts incorporate both quantifiable and non-quantifiable impacts, outcomes-based and management-based provisions have been included in this FMP.

Outcome-based provision are performance-based and may be used where the part of the environment is capable of objective measurement and reporting. Therefore, outcome-based provisions have been established to specify trigger and thresholds on direct impacts and to ensure the Proposal achieves acceptable environmental outcomes. Management-based provisions relate to management actions and may be used where the part of the environment is not capable of objective measurement and reporting. Therefore, management-based provisions have been established to specify management actions and targets, particularly for indirect impacts that are non-quantifiable. In addition, manage-based provisions will assist with onsite management and achieving the outcome-based environmental criteria. Early response triggers for management-based provisions are detailed in Section 3.1.

2.1 Outcome-based provisions

The primary objective of flora and vegetation management is to avoid direct and indirect impact of Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397), and native vegetation and habitat to the maximum extent practicable. The following thresholds will be implemented:

• no more than 392 ha of native vegetation to be cleared within the Development Envelope

• no more than 0.56% of the known population (currently equates to 92 individuals of the currently known population of 16,503) of Banksia sphaerocarpa var. dolichostyla or 18.07% of the known population (currently equates to 7,498 individuals of the currently known population of 41,492) of Microcorys sp. Mt Holland (D. Angus DA 2397) directly impacted from clearing

• no more than 50% mortality from indirect impacts that is statistically different from changes observed at analogue sites based on the following limits:

∗ 17.12% of the known population (currently equates to 2,826 individuals of the currently known population of 16,503) of Banksia sphaerocarpa var. dolichostyla

∗ 3.68% of the known population (currently equates to 1,525 individuals of the currently known population of 41,492) of Microcorys sp. Mt Holland (D. Angus DA 2397).

Environmental criteria, both triggers and thresholds, are detailed in Table 2-2.

2.1.1 Environmental Criteria justification

The environmental criteria’s triggers and thresholds have been established on the direct impacts discussed in the Environmental Review Document (Revision 6). Justification for the environmental criteria is detailed in Table 2-1.

15

Table 2-1: Environmental Criteria justification

Environmental Criteria Trigger and Threshold Justification

Avoidance of direct loss of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397)

Trigger criteria: Unauthorised clearing of 1 Banksia sphaerocarpa var. dolichostyla individual or Microcorys sp. Mt Holland (D. Angus DA 2397) individual

Threshold criteria is associated with the impact assessed in the Environmental Review Document. Based on the Management Actions, the Proponent will manage the proportion of conservation significant flora species cleared. If clearing occurs which has not received an approved internal clearing permit , it is considered a non-compliance (as a Permit to take Declared Rare Flora would not have been completed). In addition, it presents a risk that the Proponent will exceed the proportion of individuals that can be directly impacted.

Threshold criteria: No more than 0.56% of known population of Banksia sphaerocarpa var. dolichostyla or 18.07% of known population of Microcorys sp. Mt Holland (D. Angus DA 2397) directly impacted from clearing

The direct loss thresholds are based on the impact assessed in the Environmental Review Document for the Proposal and determined as a percentage of the local population at the time of loss.

Field observations indicate a high level of ongoing recruitment within existing Banksia sphaerocarpa var. dolichostyla populations in areas that have been subject to disturbance demonstrating the ability of this taxon to readily recruit and rapidly recover. As ongoing recruitment has the potential to occur in areas that may be directly or indirectly impacted it is considered appropriate that the thresholds for direct and indirect impact to Banksia sphaerocarpa var. dolichostyla be based on a percentage of the known population at the time of loss. Similar observation have been made regarding Microcorys sp. Mt Holland (D. Angus DA 2397) and therefore a similar approach is taken.

The thresholds are no greater than the known percentage of direct impact to the currently known populations: • Banksia sphaerocarpa var. dolichostyla

population as outlined in the ERD (0.56% of the currently known local population based on 92 individuals of 16,503)

• Microcorys sp. Mt Holland (D. Angus DA 2397) population as outlined in the ERD (18.07% of the currently known local population based on 7,498 individuals of 41,492).

Minimise loss and fragmentation of native vegetation and habitat

Trigger criteria: One incident of unauthorised clearing occurs

A trigger of any unauthorised clearing has been set so any clearing incident triggers the response actions. This trigger assumes that 392 ha of vegetation clearing will occur for the Proposal. The risk of non-compliance is associated with clearing beyond approved limits. Therefore, any unauthorised clearing would require a review of compliance to approvals.

Threshold criteria: No more than 392 ha of native vegetation to be cleared within the Development Envelope

The 392 ha of vegetation clearing threshold is based on the impact assessed in the Environmental Review Document for the Proposal.

16

Avoidance of indirect impacts to Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397)

Trigger criteria: Reduction in health of one or more Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397) populations within Development Envelope that is statistically different from analogue measurements

Vegetation monitoring will be undertaken and if a decline in health is identified, the response actions will allow investigation to determine if the causes are attributed to the Proposal. The triggers associated with decline in health is connected with analogue monitoring to provide allowances for climatic variation.

Threshold criteria: No more than 50% mortality of Banksia sphaerocarpa var. dolichostyla populations (17.12% of known local populations) or Microcorys sp. Mt Holland (D. Angus DA 2397) populations (3.68% of known local population) resulting from indirect impacts that is statistically different from changes observed at analogue sites

The thresholds are based on the proportion of the local population potentially impacted by the Proposal which is assessed in the Environmental Review Document. Based on the Management Actions for indirect impacts, it has been determined that potentially 50% of the portion of the individuals identified in the Environmental Review Document are likely to be indirectly impacted. Therefore, 50% mortality is considered the threshold.

The thresholds are no greater than the known percentage of indirect impact to the currently known populations: • Banksia sphaerocarpa var. dolichostyla

population as outlined in the ERD (17.12% of the currently known local population based on 2,826 individuals of 16,503)

• Microcorys sp. Mt Holland (D. Angus DA 2397) population as outlined in the ERD (3.68% of the currently known local population based on 1,525 individuals of 41,492).

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Table 2-2: Outcome-based provisions Environmental objective Environmental criteria Response actions Monitoring Reporting

Avoidance of direct loss of Banksia sphaerocarpa var. dolichostyla

Trigger criteria: Unauthorised clearing of 1 Banksia sphaerocarpa var. dolichostyla individual Threshold criteria: No more than 0.56% of known population (92 individuals) of Banksia sphaerocarpa var. dolichostyla directly impacted from clearing

Trigger response: • Review management strategies to determine key cause for

unauthorised clearing • Review proposed layout to determine if additional individuals can

be avoided • Implement any required changes to prevent additional

unauthorised clearing • Consultation with key stakeholders (DBCA, EPA and DoEE) to

determine if approval amendments are required • Reported as an incident to DBCA • Review known population numbers to determine if

rehabilitation/translocation/propagation is required to ensure no net loss of individuals over known local populations from Proposal activities.

• Implement active propagation and seeding into other areas of the Development Envelope in consultation with DBCA to achieve no net loss of individual plants.

Threshold response: • Immediate notification of DoEE, EPA and DBCA • Engagement with key stakeholders including DBCA, and relevant

specialists where required to determine key actions • Implement active propagation and seeding into other areas of the

Development Envelope in consultation with DBCA to achieve no net loss of individual plants.

• Survey record of all clearing undertaken during operation of the Project

• Population monitoring

• Annual reporting • Clearing Register • Internal clearing

permits • Survey data

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Environmental objective Environmental criteria Response actions Monitoring Reporting

Avoidance of direct loss of Microcorys sp. Mt Holland (D. Angus DA 2397)

Trigger criteria: Unauthorised clearing of 1 Microcorys sp. Mt Holland (D. Angus DA 2397) individual Threshold criteria: No more than 18.07% of known population (7,498 individuals) of Microcorys sp. Mt Holland (D. Angus DA 2397) directly impacted from clearing

Trigger response: • Review management strategies to determine key cause for

unauthorised clearing • Review proposed layout to determine if additional individuals can

be avoided • Implement any required changes to prevent additional

unauthorised clearing • Consultation with key stakeholders (DBCA, EPA and DoEE) to

determine if approval amendments are required. Threshold response: • Immediate notification of DoEE, EPA and DBCA • Engagement with key stakeholders including DBCA, and relevant


Development Envelope in consultation with DBCA


• Population monitoring




Trigger criteria: One incident of unauthorised clearing occurs Threshold criteria: No more than 392 ha of native vegetation to be cleared within the Development Envelope

Trigger response: • Review proposed layout to determine if additional individuals can

be avoided • Consultation with key stakeholders (DBCA, EPA and DoEE) to

determine if approval amendments are required • Review management strategies to determine key cause for

unauthorised clearing • Implement any required changes to prevent additional

unauthorised clearing Reported as an incident to DMIRS and EPA. Threshold response: • Cease all vegetation clearing activities • Notification of DoEE, EPA and DMIRS to determine corrective

actions.




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Environmental objective Environmental criteria Response actions Monitoring Reporting

Avoidance of indirect impacts to Banksia sphaerocarpa var. dolichostyla

Trigger criteria: Reduction in health of one or more Banksia sphaerocarpa var. dolichostyla population within Development Envelope that is statistically different from analogue measurements Threshold criteria: No more than 50% mortality of Banksia sphaerocarpa var. dolichostyla populations (17.12% of known local populations) resulting from indirect impacts that is statistically different from changes observed at analogue sites

Trigger response: • Determine whether the changes observed in the impact sites are

comparable to the observations in the analogue sites • Review management strategies to determine the cause of the

health decline • Increase monitoring to biannual assessments • Review known population numbers to determine if

rehabilitation/translocation/propagation is required to ensure no net loss of individuals over known local populations from Proposal activities.

Threshold response: • Immediate notification of DoEE and EPA • Engagement with key stakeholders including DBCA, and relevant


Development Envelope in consultation with DBCA to achieve no net loss of individual plants.

• Quarterly observations of plant health

• Annual monitoring assessment of Banksia sphaerocarpa var. dolichostyla population health both inside (impact) and outside (analogue) the Development Envelope

• Annual reporting • Quarterly and

annual vegetation monitoring

• Incident reports of speeding

Avoidance of indirect impacts to Microcorys sp. Mt Holland (D. Angus DA 2397)

Trigger criteria: Reduction in health of one or more Microcorys sp. Mt Holland (D. Angus DA 2397) populations within Development Envelope that is statistically different from baseline measurements Threshold criteria: No more than 50% mortality of Microcorys sp. Mt Holland (D. Angus DA 2397) populations (3.68% of known local population) resulting from indirect impacts that is statistically different from changes observed at analogue sites

Trigger response: • Determine whether the changes observed in the impact sites are

comparable to the observations in the analogue sites • Review management strategies to determine the cause of the

health decline • Increase monitoring to biannual assessments. Threshold response: • Immediate notification of DMAs • Engagement with key stakeholders including DBCA, and relevant


Development Envelope in consultation with DBCA

• Quarterly observations of plant health

• Annual monitoring assessment of Microcorys population health both inside (impact) and outside (analogue) the Development Envelope

• Annual reporting • Quarterly and

annual vegetation monitoring

• Incident reports of speeding

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2.2 Management-based provisions

The following management actions will assist in meeting the trigger and thresholds proposed in the outcome-based provisions. These actions will be reviewed as part of the monitoring and reporting process and changes made where required.

The management actions are detailed in Table 2-3, however are summarised as:

• vegetation clearing management • Ironcaps Banksia and Priority Flora avoidance management

• dust management

• hypersaline water management

• weed management

• spill management

• fire regime management.

The management targets are:

• no unauthorised clearing of native vegetation

• no unauthorised clearing of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397)

• no reduction in health of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397) that is statistically different from analogue measurements

• avoid incidents and minimise intensity of accidental spill events

• minimise new weeds introduced to site

• prevent fires attributed to mining and associated activities.

Early response triggers have been established for management targets and are detailed in Section 3.1.

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Table 2-3: Management-based provisions Management Objective Management Action Management targets Monitoring Reporting


Implementation of an internal clearing permit procedure and preclearance surveys.

No unauthorised clearing of native vegetation

Survey record of all areas cleared under the Project

Annual reporting Clearing Register Internal clearing permits Survey data

Minimise direct loss of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397)

Avoidance • implementation of an internal clearing permit procedure and

preclearance surveys • all populations of Banksia sphaerocarpa var. dolichostyla

and Microcorys sp. Mt Holland (D. Angus DA 2397) will have a 50 m buffer and development of new infrastructure within the buffer will be avoided if possible

Minimisation • all populations of Banksia sphaerocarpa var. dolichostyla

and Microcorys sp. Mt Holland (D. Angus DA2397) within 50 m buffers adjacent to disturbed areas will be demarcated and signed as Conservation Significant Flora Exclusion Zones

• minimise saline water overspray through use of dribble bars in roadway dust suppression and construction of earthen bunds on road sides

• plants will be recorded in the Significant Flora Register which will include date, observer, status (flowering, poor health etc.) and a GPS/location description

• Conservation Significant Flora Exclusion Zones will be incorporated into the mine plan

• avoid accidental disturbance by enforcing strict traffic management rules (e.g. keeping to designated tracks, reduced speed limits, prohibiting access to native vegetation areas containing Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397) except for monitoring purposes, signage installation warning personnel of the presence of Conservation Significant Flora.

Rehabilitation

No unauthorised clearing of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397)

Record of any Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397) removed during clearing Clearing register

Annual reporting Clearing Register Internal clearing permits Survey data

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Management Objective Management Action Management targets Monitoring Reporting

In the event of a Banksia sphaerocarpa var. dolichostyla individual direct loss associated with the Proposal, the Proponent aims to achieve no net loss of individuals of the currently known local population (16,503 individuals) through the following: • undertaking rehabilitation trials and implementing research

programs (in consultation with DBCA and Kings Park and Botanical Gardens) to increase translocation and rehabilitation success and investigate active propagation.

• translocation of individuals to be directly impacted into an area of suitable habitat

• rehabilitation of areas to provide suitable habitat for Banksia sphaerocarpa var. dolichostyla. The previously disturbed former airstrip is a potential location for rehabilitation trials as it intersects the local population area

• seeding of areas with suitable habitat within the Development Envelope with Banksia sphaerocarpa var. dolichostyla seeds

• monitoring of translocated individuals and rehabilitated areas.

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Minimise dust deposition on vegetation from mining and related activities

The Proponent will minimise dust deposition on vegetation through:

• dust suppression on cleared areas • maximise efficiency of loads when transporting ore or

concentrate (including haul trucks and conveyers) • maintain at least 0.5 m of freeboard in hauling trucks or

cover loads • use dust covers on machinery and water suppressants

on exposed areas wherever required • minimise open area footprint and rehabilitate or cover

(using vegetation, rock, water and/or dust suppressant) exposed areas as soon as practicable

• implement good house–keeping practices including ensuring that product spills are cleaned up as soon as possible, and water sprays and emissions control equipment is properly maintained

• minimise saline water overspray through use of dribble bars in roadway dust suppression and construction of earthen bunds on road sides

• reduce vehicle traffic on unsealed roads and other exposed areas, where practicable, and limit traffic speeds on unsealed roads to 25 km/h.

No reduction in health of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397) that is statistically different from analogue measurements

Quarterly observations of plant health Annual monitoring assessment of Banksia and Microcorys population health on baseline transects

Annual reporting Quarterly and annual vegetation monitoring Incident reports of speeding Visual dust monitoring Incident report of significant dust plumes

Minimise overspray of hypersaline water used for dust suppression

The Proponent will minimise impacts of hypersaline water use through:

• implementation of dribble bars in roadway dust suppression and construction of earthen bunds on road sides, prioritised in existing roadway sections within 50 m of Banksia sphaerocarpa var. dolichostyla

• locating pipes transferring saline water within bunds, fitted with leak detection systems and routinely inspected

• hypersaline water shall not be used for dust suppression during rainfall events

• lining water storages potentially storing hypersaline or poor-quality water to prevent or minimise seepage. They will be operated with adequate freeboard to store inflows associated with 1 in 100 year, 72 hour rainfall event.

No reduction in health of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397) that is statistically different from analogue measurements

Baseline monitoring assessment of Banksia sphaerocarpa var. dolichostyla population health on 100 m transects Quarterly observations of plant health Annual monitoring assessment of Banksia and Microcorys population health on baseline transects

Annual reporting Quarterly and annual vegetation monitoring Incident reports

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Minimise spillage of tailings, hypersaline water, hydrocarbons and chemicals

The Proponent will minimise impacts from spills through: • spill kits will be located at strategic locations throughout the

project area and employees trained in their use • hydrocarbon wastes will be segregated from other wastes

and collected for offsite disposal by a licensed contractor • all hydrocarbon and chemical storages will be designed and

constructed in accordance with Australian Standards AS1940 and AS1692

• pipes transferring saline water or tailings will be located within bunds, fitted with leak detection systems and routinely inspected

• water storages potentially storing saline or poor-quality water will be lined to prevent or minimise seepage. They will be operated with adequate freeboard to store inflows associated with 1 in 100 year, 72 hour rainfall event

• landfill and waste water treatment plants will be operated in accordance with an Environmental Licence.

Avoid incidence and minimise intensity of accidental spill events No reduction in health of Banksia sphaerocarpa var. dolichostyla or Microcorys sp. Mt Holland (D. Angus DA 2397) that is statistically different from baseline measurements

Quarterly observations of plant health Annual monitoring assessment of Banksia and Microcorys population health on baseline transects

Annual reporting Incident reports

Minimise spread of weeds

The Proponent will minimise the risk of introduction of invasive species through: • minimise the risk of introduction of invasive species through

implementation of a vehicle hygiene procedure and weed control

• will be required to stockpile excavated topsoil so it can be reused for revegetation on the Proposed Project site as needed. To ensure maximum topsoil recovery, topsoil will be stockpiled separately from other excavated materials

• Development Envelope will be surveyed for weeds periodically, so that any infestations of invasive species that establish can be eradicated before the plants can flower and set seed.

Minimise new weeds introduced to site

Quarterly observations of plant health and presence of weeds Annual monitoring assessment presence of weeds within Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397) habitat

Annual reporting Washdown/vehicle hygiene certificates and auditing Invasive species control reports Aerial photos Incident reports

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Avoid alteration of fire regimes

The Proponent will contribute to fire management at the mine site and in the region through the following measures: • implement fire management procedures

(e.g. maintenance of fire breaks, Hot Work Permit system, firefighting training, Emergency Response Plan)

• firefighting equipment will be located on site and in vehicles

• lightning protection equipment will be installed as part of Project design where necessary

• coordination with DBCA and Department of Fire and Emergency Services (DFES) to undertake prescribed burns.

Prevent fires attributed to mining and associated Project activities

Quarterly observations of plant health and presence of weeds Annual monitoring assessment presence of weeds within Banksia sphaerocarpa var. dolichostyla habitat

Aerial photos Incident reports

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2.3 Implementation

The implementation of the FMP will be assisted through an Environmental Management System that will incorporate systems, processes, procedures and work instructions relating to the management, monitoring and reporting components of the FMP.

Covalent is committed to conducting its activities at the Earl Grey Lithium Project (the Project) in an ecologically responsible manner. The key personnel involved in implementation of the FMP and their roles and responsibilities are listed in Table 2-4.

Table 2-4: Summary of roles and responsibilities relevant to the Earl Grey Lithium Project FMP. Role Responsibility

Covalent • Covalent have the overall responsibility for the implementation of this FMP if any roles are delegated to a contractor or consultant, Covalent has the responsibility to audit compliance and ensure any contingency actions are implemented.

Covalent Environmental Manager

• overall accountability for auditing and compliance assessment with this FMP during operation to ensure it is maintained and meets objectives and targets

• provide technical support to all Project personnel to ensure this FMP is implemented correctly and complied with

• implement and maintain this FMP, review its effectiveness and review the implementation as required

• obtain relevant approvals for disturbance as required • ensure all personnel involved in the project are inducted and will adhere to FMP requirements • undertaking ongoing monitoring and documenting monitoring results • liaise with stakeholders and technical advisors for advice and resolution of management

aspects/objectives as required • review and close out any contingency actions • report as required to regulating authorities • may delegate all or part responsibility to an appropriately qualified person • must be on-site during clearing operations.

Construction Manager (if different to Environmental manager)

• overall accountability for auditing and compliance assessment with this FMP during construction to ensure it is maintained and meets objectives and targets

• overall accountability to ensure this FMP is implemented, reported and maintained on-site • ensure personnel attend inductions, have sufficient resources and training to meet the

requirements of this FMP • support the proponent’s flora management initiative and culture • comply with all legal requirements and the requirements of this FMP • seek advice from proponent when in doubt about requirements • appoint appropriate consultants to undertake specific activities set out in the FMP if required.

All personnel • must receive induction prior to commencement of work on site • comply with all legal requirements and the requirements of this FMP • attend environmental inductions and any other training required • participate in toolbox meetings and encourage personnel to suggest improvements.

2.3.1 Environmental induction

The Proponent will require all workers, both during construction and operation of the mine, to attend a worker awareness training/environmental induction covering the following topics.

• Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397) (e.g. how to identify it, conservation status, the importance of minimising impacts on the species, requirements of personnel including adherence to speed limits and staying on roads as well as locations and incidents, reporting to Environment Department)

• information on other potential conservation significant flora

• information on feral species (weeds) and the impact on Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397) and all weeds to be reported

• information on the prevention and management of fires.

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2.3.2 Incidents and corrective actions

Environmental incidents are defined as breaches or non-adherences to objectives and procedures applied to the Project and prescribed in this FMP. Environmental incidents are to be reported to the Covalent Environmental Manager by the person responsible for the incident or the first person at the site of an incident.

The Covalent Environmental Manager will assess the type and severity of the incident in accordance with internal procedures. Relevant personnel shall be notified and consulted whether the incident requires notification to regulatory agencies.

2.4 Monitoring

Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397) populations will be monitored prior to commencement of operations, during operations, and post–closure to enable early detection of indirect impacts on individuals within 50 m of construction and mining activities.

Table 5: Monitoring action summary Monitoring Event Monitoring Action Frequency Responsibility

Preclearance Monitoring

• pre–clearance surveys: A targeted site pre–clearance survey of areas scheduled for clearing will be undertaken to delineate a precise count of direct impacts on Threatened Flora populations boundaries before clearing proceeds.

As required (prior to commencement of clearing)


Population monitoring

• clearing survey: Survey and recording of all areas cleared, to be submitted on an annual basis

• quarterly observations: Undertake quarterly visual observations of Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397) populations in close proximity to the access roads and operations. Written and photographic records will be kept of the visual inspections of plant conditions. Presence of invasive weeds will also be recorded if present

• annual monitoring: Undertake annual transect monitoring of all populations. Transect monitoring will address plant health and recruitment of Banksia sphaerocarpa var. dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397) populations. Plant condition for each individual that intersects the transect will be assessed using a rating method that assigns a score based on species health/vigour (e.g. 0 = dead, 1 = poor health (i.e. extensive crown decline), 2 = moderate health (i.e. some evidence of crown decline) and 3 = very healthy (i.e. no evidence of crown decline). Presence of invasive weeds will also be recorded if present. Analogue transects, outside of the Development Envelope will be established and monitored concurrently to provide a control for climatic conditions outside of Covalent’s control. Statistical analysis will be undertaken to determine if a significant difference between populations within the development envelope and those outside exists and any changes to the known population. Annual reports will be submitted no later than 1 April for the preceding calendar year monitoring.

Annual (During construction and operations)


Post closure population monitoring

• annual monitoring: Monitoring will continue until completion of rehabilitation activities. Annual monitoring will summarise data collected during the year on Banksia sphaerocarpa var. dolichostyla transects and additional data as follows: * monitoring of Banksia sphaerocarpa var.

dolichostyla and Microcorys sp. Mt Holland (D. Angus DA 2397) relating to damage, death, unauthorised clearing and fire.

Annual (during post-closure monitoring


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2.5 Reporting

The FMP sets out the reporting requirements relating to its implementation. Reporting includes:

• preparation annually of a Compliance Assessment Report (CAR) to be submitted to the appropriate regulatory authorities. The CAR will include:

∗ a summary of compliance requirements

∗ summary of compliance during the reporting period

∗ non-compliances and corrective / preventative actions • compliance assessment table

• documentary evidence

• provision of data (annually) from monitoring programs to relevant regulatory authorities

• in the event that a management target is exceeded (or not met), the relevant regulatory authorities will be notified within 7 days of identification of the exceedance, including information on remediation actions that have been or will be implemented.

Additionally, Table 2-6 outlines proposed internal and external reporting actions specific to notification events outside of the required CAR.

Table 2-6: Flora Management Plan reporting actions Notification Event Action Responsibility Timing

Unauthorised clearing of conservation significant flora

The relevant regulatory authorities (DBCA, DoEE and DWER) will be notified within 48 hours of the incident

Environmental Manager

At time of event

Threshold exceedance The relevant regulatory authorities (DWER and DoEE) will be notified within 7 days of identification of the exceedance, including threshold contingency actions which have been implemented due the exceedance of threshold criteria


At time of event

Evaluation and revision triggered

Review and report to regulator, as required by legislation or legislative condition


At time of event

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3. Adaptive Management and FMP Review Covalent recognises the dynamic nature of ecosystems and supports adaptive management under this FMP. Adaptive management involves:

• implementing mitigation measures

• monitoring and evaluation against management targets (including early response triggers) and environmental criteria (including triggers and thresholds)

• systematically adapting management and mitigation measures and monitoring to meet the environmental objectives.

There remain some uncertainties associated with the Proposal and associated management actions that will require ongoing review and consideration. Assumptions and predicted ecosystem responses will be evaluated against collected monitoring data on a recurrent basis in a process of continual improvement and establishing early response indicators/criteria. Examples of adaptive management throughout operations include:

• the introduction of a different / alternative monitoring initiative to better understand parts of an ecosystem responding differently to that expected

• the identification of more effective trigger criteria or early response triggers in light of more comprehensive monitoring information

• updated modelling and revision of trigger criteria or early response triggers in a system responding differently to that predicted in original modelling

• changes to management actions and targets in response to monitoring data

• changes in technology.

3.1 Early response triggers

Early response triggers have been established for the management-based provisions in Table 2-3 that do not have associated environmental criteria trigger criteria and are detailed in Table 3-1.

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Table 3-1: Early response triggers and actions Management targets Early response trigger Early response action Early response trigger justification

Avoid incidence and minimise intensity of accidental spill events

• Spill occurrence that impacts on Conservation Significant Flora species buffer

• Undertake incident investigations and determine improvement strategy

• Review positioning of infrastructure and activities in proximity to the buffer and determine if relocation is possible

If there is an increase in spill, the environmental management system will assist in the identification and rectification of issues (in addition to incident investigations). However, if a spill impacts on the Conservation Significant Flora buffer, this is an indication the Management Actions require refinement.

Minimise new weeds introduced to site

• Significant increase in weed sightings

• Review weed control programme and amend as required

• Consultation with DBCA and conservation groups to identify opportunities for local and regional weed control program

The potential for population decline due to weed impacts is currently unknown as impacts to populations have not been quantified. As population monitoring data is gathered, trending will indicate any threats (including weeds) and acceptable population changes. In the interim, the early response trigger has been established to identify any significant increases to weed species that could result in an indirect impact to conservation significant flora species and provide an indication if the management actions detailed in Table 2-3 require review.

Prevent fires attributed to mining and associated t activities

• A fire occurrence within the Development Envelope that impacts on native vegetation

• Internal audit of fire management plan

• Coordination with local and regional stakeholders (conservation groups, DBCA, DFES, Shire) to further develop regional bushfire management plans

The management actions are considered sufficient to prevent fire impacts to the conservation significant flora species. However, in the event a fire occurs within the Development Envelope that impacts on native vegetation, this is an indicator that further refinement of the management actions is required.

3.2 Benchmarking and Best-Practice

For some environmental factors, environmental outcomes may include compliance with state, national or international standards, guidance or legislation. The Proponent will conduct ongoing benchmarking against best practice options. Adaptive management in this context may include initiatives to implement improvements in technology and emission control technologies to meet best-practice in the relevant industry, proponent-driven improvements in operations, and keeping up-to-date with improvements in monitoring methods and standards for implementation.

3.3 Plan Revisions

The proponent will amend this Management Plan as required to include any adaptive management updates. These amendments will be internal (and not require re-submission to the EPA) unless the information gained through the adaptive management approach demonstrates that an amendment to an approved condition is required. If the Proponent has gathered sufficient information through research and long-term monitoring to propose revisions to management targets, a formal request for amendment of an approved condition may be submitted to the relevant authority.

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4. Stakeholder consultation

4.1 Key Stakeholders

Covalent have commenced an extensive consultation process with key stakeholders, including:

• State government

• Federal government

• Local government • Non–government organisations and interest groups.

A comprehensive list of key stakeholders is provided in Table 4-1.

Table 4-1: Key Stakeholders

Stakeholder Group Stakeholder Key Interests

State Government Environmental Protection Authority (EPA)

• Administration of the Environmental Protection Act 1986 (EP Act)

• Part IV (EP Act) Environmental Impact Assessments

Department of Mines, Industry Regulation and Safety (DMIRS)

• Administration of the Mining Act 1978 (Mining Act) • Tenement conditions • Mining proposals and programs of work • Mining Rehabilitation Fund (MRF) • Closure and rehabilitation • Safety

Department of Biodiversity, Conservation and Attractions (DBCA)

• Administration of the Biodiversity Conservation Act 2016 (BC Act)

• Flora, fauna and habitat conservation

Department of Planning, Lands and Heritage (DPLH)

• Native title and indigenous requirements • Heritage sites

Department of Fire and Emergency Services (DFES)

• Emergency services • Fire breaks • Fire reduction

Main Roads Western Australia (MRWA)

• Use of public roads

Federal Government Department of the Environment and Energy (DoEE)

• Administration of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)

• Referral and assessment of environmental impact assessments of matters of national environmental significance

Local Government Shire of Yilgarn and Shire of Kondinin

• Use of public roads and infrastructure

Non–government organisations and interest groups

Conservation Council of Western Australia Wilderness Society National Malleefowl Recovery Team

• Protection of conservation significant species • Potential interest in baseline flora and fauna survey

data

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4.1.1 Stakeholder Engagement Process

Stakeholder engagement with State Departments and Local Government Authorities commenced in late 2016. The Proponent has since developed and implemented an external stakeholder consultation strategy for ongoing social engagement and community investment. As the joint venture manager, Covalent will be responsible for all engagement moving forward.

The stakeholder consultation strategy has adopted the principles from the Ministerial Council on Mineral and Petroleum Resources (MCMPR) Principles for Engagement with Communities and Stakeholders (2005). This includes:

• open and effective communication:

∗ two–way communication ∗ clear, accurate and relevant information

∗ timeliness

• transparency, requiring a process for communication and feedback

• collaboration, working cooperatively to seek mutually beneficial outcomes

• inclusiveness, with the aim of recognising, understanding and involving stakeholders early and throughout the process

• integrity, with engagement undertaken in a manner that fosters mutual respect and trust.

The outcomes of the consultation strategy are recorded in the Stakeholder Consultation Register. Consultation to date has comprised predominately of meetings and correspondence with a number of State and Federal Departments and Agencies, Local Government Authorities, Traditional Owners and non–government organisations and interest groups.

The Proponent is committed to ongoing stakeholder identification, communication, engagement and consultation through the planning and approval phase, and through to construction, operational and closure phases of the Project.

Stakeholder Consultation

Ongoing stakeholder consultation has been underway since late 2016. Key engagement to date is summarised in Section 3.3 of the Environmental Review Document.

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5. Definitions Term Definition

Direct impact Impact through direct loss of conservation significant flora from vegetation clearing.

Indirect impact Impact fire: • dust, during construction and mining operations • weed infestation during construction and mining operations • hypersaline water during construction and mining operations • changed fire regime.

Unauthorised clearing Clearing of vegetation or individuals without an approved internal clearing permit that is a legal non-compliance.

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6. Acronyms and short titles Abbreviation Full Description

BC Act Biodiversity Conservation Act 2016

CAR Compliance Assessment Report

DBCA Department of Biodiversity, Conservation, and Attractions

DFES Department of Fire and Emergency Services

EMP Environmental Management Plan

EPA Environmental Protection Authority

EP Act Environmental Protection Act 1986

EPBC Act Environment Protection and Biodiversity Conservation Act 1999

ESD Environmental Scoping Document

FMP Flora Management Plan

MCMPR Ministerial Council on Mineral and Petroleum Resources

MNES Matter of National environmental significance

NMRT National Malleefowl Recovery Team

PER Public Environmental Review

SQM Sociedad Química y Minera

TSF Tailings Storage Facility

WRD Waste Rock Dump

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7. References EPA (2016). Environmental Factor Guideline: Flora. EPA. Perth, Western Australia.

Mattiske Consulting (2017). Flora and Vegetation of the Earl Grey, Irish Breakfast and Prince of Wales Prospects. Unpublished report to Kidman Resources Limited.

Mattiske Consulting (2018a). Flora and Vegetation Assessment Earl Grey Lithium Project. Unpublished report to Kidman Resources Limited.

Mattiske Consulting (2018b). Earl Grey Lithium Project, Banksia sphaerocarpa var. dolichostyla – Targeted Survey. Unpublished report to Kidman Resources Limited.

Mattiske Consulting (2018c). Memorandum: Earl Grey Lithium Project – Statistical Comparison of Vegetation within the Earl Grey Lithium Project with the Ironcap Hills Vegetation Complex. Unpublished Memo to Kidman Resources Limited.

Mattiske Consulting (2018d). Earl Grey Lithium Project Conservation Significant Flora Targeted Survey. Unpublished Memo to Covalent Lithium.

Ministerial Council on Mineral and Petroleum Resources (MCMPR) (2005). Principles for Engagement with Communities and Stakeholders.

Documents

Appendix 4 4a. Significant Flora Management Plan (covering ... · This Flora Management Plan (FMP) is intended to support referrals under the Environmental Protection Act 1986 and