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F I N A L R E P O R T R E S P O N S E T O S U B M I S S I O N S ( V o l u m e 1 )
Proposed Relocation of the Voyager Quarry Land Clearing and Quarry Expansion, Avon Loc 1881, Lot 14 Horton Road, The Lakes (EPA Assessment Number 1413)
Prepared for
BGC (Australia) Pty Ltd Lot 4 Stirling Crescent HAZELMERE WA 6055
14 December 2004
42905483/DK:582-F6211.1
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
Project Manager: ………………………………….. Karen Ariyaratnam Project Environmental Scientist
Project Director: ………………………………….. Ian LeProvost Senior Principal Environment
URS Australia Pty Ltd Level 3, The Hyatt Centre 20 Terrace Road East Perth, WA 6004 Australia Tel: 61 8 9221 1630 Fax: 61 8 9221 1639
Date: Reference: Status:
14 December 2004582-F6211.1 Final
Contents
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
i
Executive Summary
I Introductory Notes ------------------------------------------------------------------------------------------ 1
I.I Purpose of this Document 1I.II Structure of this Document 1I.III Assessment Process for this Document 3I.IV Number and Source of Submissions Received 3I.V Summary of Issues Raised in Submissions 4I.VI Issues Raised Outside the Guidelines 5
1 Response to Submissions on the Introduction------------------------------------------------- 1-1
1.1 The Proposal 1-1
2 Response to Submissions on the Project Justification ------------------------------------- 2-1
2.1 Evaluation of Alternative Sites 2-12.1.1 Historical Perspective on the Development of the Existing Quarry 2-12.1.2 Site Selection Process for Proposal 2-1
2.2 Project Need 2-92.3 Project Benefits 2-11
2.3.1 Environmental and Social Benefits 2-112.3.2 State Benefits 2-12
2.4 Consequences of Not Proceeding 2-14
3 Response to Submissions on the Project Description--------------------------------------- 3-1
3.1 Overview 3-13.2 Construction 3-43.3 Operations 3-8
3.3.2 Drilling and Blasting 3-83.3.4 Crushing and Screening 3-93.3.6 Water Usage and Storage 3-9
3.5 Hours of Operation 3-113.7 Environmental Management and Monitoring 3-13
3.7.1 Environmental Licensing 3-133.7.2 Environmental Monitoring 3-193.7.3 Complaints Register 3-203.7.4 Recent Improvements to BGC’s Operations 3-213.7.5 Environmental Management 3-253.7.7 Benchmarking of Existing Operations 3-25
3.8 Decommissioning, Rehabilitation and Closure 3-263.8.1 Decommissioning and Rehabilitation of the Existing Quarry
Operations 3-273.8.2 Closure and Rehabilitation of the Proposed Quarry Operations 3-293.8.3 Void Closure and Rehabilitation 3-30
4 Response to Submission on the Existing Environment ------------------------------------- 4-1
4.1 Climate 4-1
Contents
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
ii
4.2 Geology, Landforms and Soils 4-14.3 Surface Water 4-24.4 Groundwater 4-54.5 Vegetation and Flora 4-74.6 Vertebrate Fauna 4-134.7 Invertebrate Fauna 4-214.8 Social Setting 4-244.9 Noise 4-25
5 Response to Submissions on Community and Government Consultation ----------- 5-1
6 Response to Submissions on the Environmental Effects Summary-------------------- 6-1
6.1 Identification of Environmental Effects 6-1
7 Response to Submissions on Environmental Issues and Management --------------- 7-1
7.1 General 7-17.2 Landform and Soils 7-17.3 Surface Water 7-27.4 Groundwater 7-167.5 Vegetation and Flora 7-247.6 Vertebrate Fauna 7-317.7 Invertebrate Fauna 7-387.8 Local and Regional Biodiversity Conservation 7-437.9 Greenhouse Gas Emissions 7-487.10 Dust 7-497.11 Noise 7-567.12 Ground Vibration and Airblast 7-657.13 Flyrock 7-717.14 Site Access and Transport 7-727.15 Visual Amenity 7-747.16 Aboriginal Heritage 7-76
8 References -------------------------------------------------------------------------------------------------- 8-1
9 Limitations -------------------------------------------------------------------------------------------------- 9-1
List of Tables
Table ES1 Summary of Key Issues Raised in the Submissions......................................................ES-2 Table 1 Ranges of Fees Received for the Project....................................................................... 2-13Table 2 Amount of Hard Rock Produced from the Existing Voyager Quarry ............................. 3-2Table 3 Justifications for Acceptance or Rejection of Proposed Licence Conditions................ 3-16Table 4 Types of Complaints about the Existing Quarry Received by the DoE (15 December
2001 to 13 January 2003) .............................................................................................. 3-20Table 5 Improvements Implemented at the Existing Voyager Quarry, 2002-2004 ................... 3-21Table 6 Inventory of New Machinery Purchased for the Existing Voyager Quarry .................. 3-24Table 7 Pit Completion Options for the Proposed Voyager Quarry........................................... 3-31
Contents
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
iii
Table 8 Size and Weight Comparison of the Chuditch and Brush-tailed Phascogale................ 4-17Table 9 Details of Mammal Trapping Records for Biota and Johnstone (2003)........................ 4-18Table 10 Resolution of Terms of Reference................................................................................... 5-2Table 11 Atmospheric Conditions Used in the Predictive Modelling.......................................... 7-59Table 12 Average Number of Daily Truck Movements for the Existing Quarry (2001 – 2004) . 7-73
List of Figures
Figure 1 Locality of Proposed Voyager Quarry Relocation Figure 2 Proposed Operations and 85 ha Boundary Overlain onto Recent Aerial Photography Figure 3 Indicative Stages of Development
List of Appendices
Appendix A Summary of Submissions Table Appendix B Surface Water Study Appendix C Groundwater Study Appendix D Preliminary Closure Plan – Voyager Quarry Relocation Appendix E Flora lists for the Survey Area, January and October 2002 Appendix F Survey of Significant Trees within Proposed Expansion Area (Lots 11 & 14) of the
Voyager Quarry Site Appendix G Voyager Quarry Relocation Fauna Management Plan Appendix H Summary of Trapdoor Spider and Trapdoor Spider Reports Appendix I Land Snail Report Appendix J Proposed Environmental Offsets Package Appendix K Noise Study and Peer Review Appendix L Blasting Impact Assessment and Monitoring Plan
Executive Summary
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
ES-1
BGC (Australia) Pty Ltd currently operates the Voyager Quarry at the Lakes, some 16 km east of the Town of Mundaring on the Great Southern Highway. This quarry has been in operation since 1990 and supplies approximately 40% of the crushed rock required by the building and construction industries in the Perth Metropolitan Region. The quarry has about five years of commercially winnable resources remaining, and needs to expand in order to maintain supplies of this economically strategic resource. The nearest available resource is situated on land located immediately adjacent the existing quarry, in Lot 14 Horton Road, owned by BGC. This resource is an extension of a Key Extraction Area designated by the Basic Raw Materials Planning Policy Statement, which was established to protect the availability of basic raw materials close to Perth (Western Australian Planning Commission, 2000). BGC therefore propose to relocate the Voyager Quarry to Lot 14, Horton Road.
A Public Environmental Review (PER) for a proposal by BGC to relocate the Voyager Quarry was available for public review from 6 January to 3 March 2003. A total of 32 submissions on the PER were received by the Department of Environment (DoE). Seven submissions on the PER were received from local and State government agencies, nine submissions were received from community and industry groups and 16 submissions were received from members of the public.
During the PER public review period, a report on a vertebrate fauna survey of the proposed Project Area was released to those parties that had made a submission on the PER. Fourteen submissions were received on the vertebrate fauna survey report, which was prepared by Biota Environmental Sciences.
Whilst there was support expressed for the proposal from the Chamber of Commerce and Industry, most submissions did not support the proposal or required further clarification of scale of potential impacts. Key issues raised in the submissions included:
Justification of site selection;
Clarification of the project description, particularly regarding the disturbance footprint;
Significant concern regarding the potential for adverse impacts on neighbouring properties from dust, noise, blast induced vibration and flyrock;
Concern regarding the potential for health impacts arising from dust;
Concern regarding the impacts of clearing remnant bushland and quarry operation on the surface and groundwater regime of the Wooroloo Brook catchment;
Clarification of the proposed revegetation strategy;
Clarification of the conservation status of invertebrate fauna (snails and spiders) found on the property; and
Concern regarding the impacts on vertebrate fauna currently inhabiting Lot 14.
The Proponent has therefore commissioned a wide range of further studies and investigations to address the issues raised. These include:
Executive Summary
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
ES-2
Characterisation of the water balance of the existing quarry – URS;
Evaluation of downstream impacts of proposed discharge to the Western Stream – URS;
Development of an enhanced water monitoring and management plan – URS;
Census of bores, wells, soaks and dams on nearby properties – URS;
Installation and monitoring of groundwater bores – URS;
Development of a preliminary closure plan for the proposed quarry – URS;
Survey of significant trees within the Project Area – R.E & C. Johnstone and T. Kirkby;
Development of a fauna management plan – Biota Environment Sciences;
Trapdoor spider survey – University of Western Australia and Biota Environmental Sciences;
Land snail survey – Museum of Western Australia;
Noise study – Herring Storer Acoustics and peer reviewed by Dick Langford;
Dust health risk assessment – Peter DiMarco (managed by the Environmental Protection Authority [EPA]);
Blasting impact assessment and monitoring plan – SRK Consulting; and
Environmental offsets package – Frank Batini.
The reports prepared by the above specialists are provided in Appendices A-M in Volume 2 of this document.
Volume 1 of this document presents the Proponent’s response to the submissions received on the PER. As required under the Environmental Impact Assessment (Part IV Division 1) Administrative Procedures 2002, the submissions on the PER were summarised by URS on behalf of the Proponent, and subsequently accepted by the DoE. The responses have been provided by the Proponent and the specialist subconsultants, including URS, who has also collated the responses and produced this document.
In response to the submissions, the Proponent has slightly modified the proposal as follows:
The location of the 85 ha footprint disturbance boundary on Lot 14 has been clearly defined (refer Figures 1 and 2). The Proponent commits not to disturb vegetation outside this boundary.
The Project will now be developed in six zones or stages, over the +50 year life of the quarry (refer Figure 3). Zones 1 and 2 will be developed initially to provide room for the new below ground facilities. Subsequent zones will be developed as the need for access to new sources of hard rock arises.
Executive Summary
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
ES-3
Clearing and topsoil removal during the construction stage will occur only during the wetter months of the year and under favourable wind conditions in an effort to minimise potential for fugitive dust emissions. Construction work will not be undertaken during unfavourable weather conditions for dust generation in summer.
Continuous monitoring of dust and noise will occur throughout the overburden removal stage to ensure that dust does not cross into neighbouring properties, and that noise regulations are met at the nearest residence.
Topsoil and overburden will not be stockpiled on site. Topsoil will be trucked directly to the proposed revegetation area and overburden (clay and gravel) will either be trucked to a final destination or stockpiled at the existing quarry. Stockpiles shown to the west of the proposed quarry on Figures 1 and 2 are there as a contingency for temporary storage purposes only.
A Community Liaison Group (CLG) has been established to keep neighbouring residents informed of proposed construction and operations activities. An independent chairperson has been nominated by the residents and an appointment will be made in the next few months.
BGC has encountered practical difficulties with the implementation of the proposed offsets strategy of revegetating 170 ha of privately owned land. As a result, it has engaged Mr Frank Batini to develop a new offsets package which is both feasible and supported by local authorities, and meets the EPA requirement of generating a “net benefit” to the environment. The new proposed offsets package consists of three elements:
1. The covenanting, in perpetuity, of about 120 ha of jarrah-marri woodland in good condition, held as freehold by BGC, to either the Department of Conservation and Land Management (CALM), Department of Agriculture or the National Trust.
2. The provision of up to 15 km of fencing materials to the Ministry of Justice, to protect remnant vegetation and the Wooroloo Brook from grazing, on land managed by the Ministry as prison farms. Prisoners would then erect this fencing as part of their farm training. It is expected that between 100 and 150 ha of remnant vegetation would be protected.
3. The rehabilitation of about 60 ha of gravel pits and other degraded lands on land managed by the Shires of Mundaring and Northam, CALM and the Water and Rivers Commission.
The Proponent and his consultant team believe that the proposal can be developed and operated without disturbing the amenity of neighbouring residents. In fact, the new quarry will be much easier to manage than the existing quarry because all infrastructure, crushing and screening plant and product stockpiles will now be housed below ground level, and a buffer of trees will surround the quarry pit.
A summary of the key issues and concerns raised in the submissions, the Proponent’s response to those issues, and the predicted outcome or commitment is presented in the following Table ES.1.
Exe
cuti
ve S
umm
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Tab
le E
S1
Sum
mar
y of
Key
Issu
es R
aise
d in
the
Subm
issi
ons
Issu
e R
aise
d Pr
opon
ent’
s Res
pons
e Pr
edic
ted
Out
com
es
A n
umbe
r of s
ubm
issi
ons q
uerie
d th
e si
te se
lect
ion
proc
ess a
nd in
dica
ted
that
ther
e ar
e m
ore
suita
ble
quar
ry si
tes f
or B
GC
to re
loca
te to
, oth
er th
an th
e pr
opos
ed re
loca
tion
site
.
The
iden
tific
atio
n an
d ga
inin
g ac
cess
to si
tes f
or th
e de
velo
pmen
t of a
har
d ro
ck q
uarr
y is
an
extre
mel
y co
mpl
ex p
roce
ss.
The
occu
rren
ce o
f gra
nite
with
the
nece
ssar
y ge
otec
hnic
al
prop
ertie
s and
at a
shal
low
dep
th is
com
para
tivel
y lim
ited.
Whe
n ot
her f
acto
rs a
re ta
ken
into
co
nsid
erat
ion,
such
as t
he lo
catio
n of
inap
prop
riate
zon
ings
and
lega
l eas
emen
ts, t
he p
oten
tial
site
s are
redu
ced
furth
er.
The
exis
ting
quar
ry m
eets
app
rova
l and
com
plia
nce
requ
irem
ents
and
is lo
cate
d in
an
area
id
entif
ied
as a
long
-term
reso
urce
of h
ard
rock
. A
s the
re is
a g
eolo
gica
l con
tinua
tion
of th
e ex
istin
g re
sour
ce, i
t is l
ogic
al th
at B
GC
wou
ld re
loca
te to
the
adja
cent
pro
perty
rath
er th
an
esta
blis
hing
a n
ew o
pera
tion
at a
n en
tirel
y ne
w lo
catio
n.
The
prop
osed
site
for t
he re
loca
tion
of th
e V
oyag
er Q
uarr
y is
the
only
si
te a
vaila
ble
that
can
ens
ure
cont
inua
tion
of su
pply
of t
his
econ
omic
ally
stra
tegi
c re
sour
ce a
t co
mpe
titiv
e pr
ices
to th
e Pe
rth
met
ropo
litan
regi
on.
The
pric
e of
th
is re
sour
ce w
ill st
ay c
ompe
titiv
e if
the
proj
ect i
s app
rove
d.
Cla
rific
atio
n w
as re
ques
ted
in re
latio
n to
cer
tain
as
pect
s of t
he P
roje
ct D
escr
iptio
n, su
ch a
s the
pr
opos
ed fo
otpr
int o
f dis
turb
ance
, the
vol
ume
of
over
burd
en in
rela
tion
to th
e vo
lum
e of
har
d ro
ck to
be
ext
ract
ed, w
ater
usa
ge a
nd st
orag
e, h
ours
of
oper
atio
n, re
habi
litat
ion
and
the
final
isat
ion
of th
e si
te c
losu
re st
rate
gy.
The
prop
osed
foot
prin
t of d
istu
rban
ce is
show
n on
Fig
ures
1 a
nd 2
of t
his d
ocum
ent,
with
the
foot
prin
t cov
erin
g an
are
a of
85
ha.
The
tota
l am
ount
of g
rave
l and
cla
y is
exp
ecte
d to
be
1-2
mill
ion
tonn
es a
nd 1
2 m
illio
n to
nnes
, re
spec
tivel
y. I
t is e
stim
ated
that
ther
e is
at l
east
59.
7 m
illio
n to
nnes
of h
ard
rock
with
in th
e pr
opos
ed q
uarr
y pi
t. It
shou
ld b
e no
ted
that
in c
alcu
latin
g th
e am
ount
of h
ard
rock
reso
urce
, the
de
nsity
of t
he h
ard
rock
is 2
.6 to
nnes
/m3 .
BG
C c
onfir
ms t
hat t
he a
vera
ge d
aily
wat
er re
quire
men
ts fo
r the
exi
stin
g an
d pr
opos
ed q
uarr
ies
have
bee
n es
timat
ed to
be
376.
6 kL
in su
mm
er a
nd 7
7.4
kL, w
hich
equ
ates
to a
tota
l ann
ual
wat
er u
sage
of a
ppro
xim
atel
y 94
,250
kL.
The
wat
er fo
r the
pro
pose
d qu
arry
will
be
stor
ed in
th
e w
ater
stor
age
dam
loca
ted
with
in th
e pr
opos
ed p
it at
a d
epth
of 5
m b
elow
gro
und.
The
dam
w
ill b
e se
aled
by
the
appl
icat
ion
of p
owde
red
bent
onite
to st
op le
akag
e of
wat
er.
The
hour
s of o
pera
tion
for t
he p
ropo
sed
quar
ry w
ill b
e th
e sa
me
as th
ose
curr
ently
em
ploy
ed a
t th
e ex
istin
g qu
arry
. Th
e ho
urs o
f ope
ratio
n fo
r the
pro
pose
d qu
arry
hav
e no
t bee
n re
duce
d be
caus
e B
GC
may
be
requ
ired
to in
crea
se p
rodu
ctio
n to
mee
t hig
her d
eman
d. H
owev
er, i
f BG
C
wer
e ab
le to
mee
t the
dem
and
for h
ard
rock
with
in re
duce
d ho
urs o
f ope
ratio
n, th
e pr
opos
ed
quar
ry o
pera
tions
wou
ld o
nly
oper
ate
for a
s lon
g as
requ
ired
to m
eet t
he d
eman
d.
BG
C h
as p
repa
red
a pr
elim
inar
y cl
osur
e pl
an fo
r the
pro
pose
d qu
arry
. Th
is is
pre
sent
ed a
s V
olum
e 2;
App
endi
x D
and
iden
tifie
s the
key
obj
ectiv
es fo
r min
e cl
osur
e. A
clo
sure
pla
n w
ould
be
dev
elop
ed a
fter t
he d
ecis
ion
on th
e fin
al la
nd u
se is
mad
e. D
evel
opm
ent o
f the
clo
sure
pla
n w
ould
occ
ur d
urin
g th
e lif
e of
the
Proj
ect a
nd b
e re
view
ed o
n a
regu
lar b
asis
(e.g
. eve
ry 3
-5
year
s).
The
max
imum
are
a of
dis
turb
ance
w
ill b
e 85
ha.
The
prop
osed
qua
rry
will
yie
ld
1-2
mill
ion
tonn
es o
f gra
vel,
12 m
illio
n to
nnes
of c
lay
and
59.7
mill
ion
tonn
es o
f har
d ro
ck.
The
wat
er re
quire
men
t for
the
prop
osed
qua
rry
is 9
4,25
0 kL
per
an
num
.
The
wat
er st
orag
e da
m w
ill b
e se
aled
.
The
hour
s of o
pera
tion
prop
osed
for
the
new
qua
rry
are
the
sam
e as
thos
e cu
rren
tly in
pla
ce a
t the
exi
stin
g qu
arry
, but
will
be
redu
ced,
if
poss
ible
.
A p
relim
inar
y cl
osur
e pl
an fo
r the
pr
opos
ed q
uarr
y ha
s bee
n de
velo
ped
and
is p
rese
nted
as V
olum
e 2;
A
ppen
dix
D.
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cuti
ve S
umm
ary
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ES-5
Tab
le E
S1 (c
ontin
ued)
Issu
e R
aise
d Pr
opon
ent’
s Res
pons
e Pr
edic
ted
Out
com
es
Sign
ifica
nt c
once
rn w
as ra
ised
in re
latio
n to
the
pote
ntia
l for
adv
erse
impa
cts o
n lo
cal r
esid
ents
due
to
dus
t, no
ise,
gro
und
vibr
atio
n, a
irbla
st a
nd fl
yroc
k du
ring
the
five-
year
con
stru
ctio
n an
d th
e op
erat
ion
perio
d. T
he p
oten
tial f
or si
licos
is to
occ
ur a
s a
resu
lt of
dus
t gen
erat
ion
at th
e pr
opos
ed q
uarr
y w
as
also
iden
tifie
d as
a si
gnifi
cant
con
cern
. A
dditi
onal
st
udie
s and
furth
er w
ork
on th
e m
anag
emen
t pla
ns
rela
ting
to th
ese
issu
es w
ere
requ
este
d.
The
Prop
onen
t has
eng
aged
a n
umbe
r of i
ndep
ende
nt sp
ecia
lists
to a
dvis
e on
man
y of
thes
e is
sues
. Th
ese
spec
ialis
ts a
re:
Her
ring
Stor
er A
cous
tics (
HSA
) – N
oise
stud
y.
Dic
k La
ngfo
rd –
Pee
r rev
iew
er fo
r noi
se st
udy.
SR
K C
onsu
lting
– B
last
ing
impa
ct a
sses
smen
t. Pe
ter D
iMar
co –
Dus
t hea
lth ri
sk a
sses
smen
t. T
his w
as in
itial
ly c
omm
issi
oned
by
BG
C,
but d
ue to
the
requ
est m
ade
by th
e La
kes A
ctio
n G
roup
(LA
G),
it w
as d
ecid
ed th
at th
e st
udy
wou
ld b
e m
anag
ed b
y th
e EP
A.
The
resu
lts o
f the
se st
udie
s are
as f
ollo
ws:
N
oise
– T
he H
SA su
pple
men
tary
repo
rt is
pre
sent
ed in
Vol
ume
2; A
ppen
dix
K. I
n su
mm
ary,
mod
ellin
g re
sults
indi
cate
that
eve
n un
der t
he w
orst
cas
e co
nditi
ons m
odel
led,
no
rmal
ope
ratio
n of
the
new
qua
rry
will
not
exc
eed
appl
icab
le n
oise
regu
latio
ns a
t the
ne
ares
t sen
sitiv
e pr
emis
es. M
odel
ling
show
s tha
t onc
e op
erat
ions
reac
h th
e –2
0 m
dep
th
belo
w g
roun
d le
vel,
exce
edan
ce o
f noi
se re
gula
tions
at t
he b
ound
ary
are
mos
t unl
ikel
y ev
en u
nder
wor
st c
ase
cond
ition
s. H
owev
er, a
bove
–20
m d
epth
, the
pot
entia
l for
ex
ceed
ance
incr
ease
s clo
ser t
o th
e gr
ound
surfa
ce a
nd o
pera
tions
will
requ
ire m
anag
emen
t in
this
zon
e w
hen
wor
st c
ase
cond
ition
s occ
ur to
ens
ure
com
plia
nce
with
noi
se re
gula
tions
. M
anag
emen
t pro
posa
ls in
clud
e re
duci
ng th
e nu
mbe
r of s
crap
ers f
rom
thre
e to
one
whe
n m
onito
red
nois
e le
vels
app
roac
h ex
ceed
ance
val
ues,
and
cess
atio
n of
wor
ks u
nder
wor
st
case
con
ditio
ns.
Peer
revi
ew fo
r noi
se –
Lan
gfor
d A
cous
tical
Ser
vice
s rev
iew
ed th
e H
SA re
port
and
cons
ider
ed th
at th
e m
odel
ling
unde
rtake
n pr
ovid
ed a
real
istic
and
pra
ctic
able
ass
essm
ent
of th
e pr
esen
t and
pro
pose
d op
erat
ions
and
that
the
pred
ictio
ns d
eriv
ed fr
om th
e m
odel
are
co
nsid
ered
to b
e ac
cura
te.
The
full
text
of t
he p
eer r
evie
w b
y La
ngfo
rd A
cous
tical
Se
rvic
es is
pre
sent
ed in
Vol
ume
2, A
ppen
dix
K fo
llow
ing
the
HSA
supp
lem
enta
ry re
port.
A
irbla
st, g
roun
d vi
brat
ion
and
flyro
ck st
udy
– Th
e st
udy
prov
ided
an
inde
pend
ent
asse
ssm
ent o
f the
pot
entia
l im
pact
s of b
last
ing.
The
stud
y co
nfirm
ed re
sults
in th
e PE
R
that
the
antic
ipat
ed g
roun
d vi
brat
ions
(<5
mm
/s) a
nd a
ir ov
erpr
essu
re le
vels
are
ext
rem
ely
unlik
ely
to c
ause
dam
age
to re
side
ntia
l typ
e st
ruct
ures
.
Dus
t hea
lth ri
sk a
sses
smen
t – T
he re
sults
of t
he h
ealth
risk
ass
essm
ent a
re p
rese
nted
in a
re
port
to th
e EP
A b
y Pe
ter D
iMar
co.
Con
stru
ctio
n no
ise
will
be
limite
d to
to
psoi
l and
subs
oil r
emov
al (1
-5 m
de
pth)
, will
onl
y oc
cur d
urin
g th
e w
ette
r mon
ths o
f the
yea
r, an
d w
ill
occu
r per
iodi
cally
on
six
occa
sion
s du
ring
the
life
of th
e m
ine.
Ove
rbur
den
rem
oval
(3-2
0 m
dep
th)
can
be m
anag
ed to
mee
t noi
se
regu
latio
ns a
t the
nea
rest
sens
itive
pr
emis
es b
y a
com
bina
tion
of
wea
ther
fore
cast
ing,
use
of s
ilenc
ed
earth
mov
ing
equi
pmen
t, re
al-ti
me
mon
itorin
g of
noi
se le
vels
, red
uctio
n in
num
ber o
f ear
thm
ovin
g pl
ant i
n us
e if
requ
ired,
and
ces
satio
n of
op
erat
ions
und
er w
orst
cas
e co
nditi
ons.
Bel
ow 2
0 m
dep
th, q
uarr
ying
op
erat
ions
will
not
exc
eed
nois
e re
gula
tions
at s
ensi
tive
prem
ises
.
Gro
und
vibr
atio
n an
d ai
rbla
st w
ill
not e
xcee
d th
e re
gula
tory
lim
its n
or
caus
e da
mag
e to
adj
acen
t res
iden
ces.
The
resu
lts o
f the
hea
lth ri
sk
asse
ssm
ent a
re p
rese
nted
in a
repo
rt to
the
EPA
by
Pete
r DiM
arco
.
Exe
cuti
ve S
umm
ary
KM
A/4
2905
483/
DK
:582
-F62
11.1
/DE
CE
MB
ER 2
004
ES-6
Tab
le E
S1 (c
ontin
ued)
Issu
e R
aise
d Pr
opon
ent’
s Res
pons
e Pr
edic
ted
Out
com
es
A n
umbe
r of s
ubm
issi
ons p
rovi
ded
com
men
t on
the
adeq
uacy
of t
he b
asel
ine
data
use
d fo
r the
surf
ace
wat
er a
nd g
roun
dwat
er a
sses
smen
ts, a
nd re
ques
ted
addi
tiona
l sur
vey
wor
k. T
he m
ain
issu
es ra
ised
in
subm
issi
ons r
elat
ed to
the
pote
ntia
l for
the
prop
osed
cle
arin
g an
d qu
arry
ing
oper
atio
ns
(incl
udin
g w
ater
dis
char
ge fr
om th
e si
te) t
o ad
vers
ely
impa
ct o
n su
rfac
e w
ater
and
gro
undw
ater
qu
ality
and
qua
ntity
, and
agg
rava
te e
xist
ing
salin
isat
ion
prob
lem
s on
near
by p
rope
rties
and
in
the
Woo
rolo
o B
rook
cat
chm
ent.
Con
cern
s wer
e al
so ra
ised
on
the
pote
ntia
l im
pact
s of p
it de
wat
erin
g on
the
envi
ronm
ent a
nd lo
cal w
ater
su
pplie
s, an
d on
the
abili
ty fo
r the
are
a to
mee
ts it
s fu
ture
func
tion
as a
Pub
lic D
rinki
ng W
ater
R
eser
ve.
Furth
er in
form
atio
n on
how
thes
e im
pact
s w
ould
be
man
aged
and
mon
itore
d w
as re
ques
ted,
al
ong
with
the
final
isat
ion
of th
e G
roun
dwat
er
Man
agem
ent P
lan.
Add
ition
al g
roun
dwat
er a
nd su
rfac
e w
ater
wor
k ha
s bee
n un
derta
ken
for t
he p
ropo
sed
Proj
ect.
Th
is w
ork
incl
uded
: C
ensu
s of b
ores
, wel
ls, d
ams a
nd so
aks o
n ne
arby
pro
perti
es u
nder
take
n in
May
/Jun
e 20
04.
Dril
ling
and
cons
truct
ion
of 1
1 m
onito
ring
bore
s con
duct
ed in
May
200
4.
Seep
age
inflo
w te
sts o
f the
sum
p an
d pr
oces
s dam
in A
pril
and
June
200
4.
Ref
inem
ent o
f the
wat
er b
alan
ce fo
r the
exi
stin
g an
d pr
opos
ed q
uarr
y ba
sed
on re
cent
w
eath
er d
ata
and
seep
age
test
resu
lts.
Eval
uatio
n of
dow
nstre
am im
pact
s of p
ropo
sed
disc
harg
e to
the
Wes
tern
Stre
am.
The
resu
lts o
f the
surf
ace
wat
er st
udie
s con
firm
ed th
e re
sults
of t
he o
rigin
al in
form
atio
n pr
esen
ted
in th
e PE
R in
rela
tion
to th
e w
ater
bal
ance
of t
he p
ropo
sed
pit a
nd p
oten
tial i
mpa
cts
on th
e do
wns
tream
env
ironm
ent.
The
ext
ensi
on o
f the
pro
pose
d pi
t foo
tprin
t has
resu
lted
in a
n in
crea
se in
the
volu
mes
of w
ater
to b
e re
leas
ed, b
ut th
is d
oes n
ot c
ause
adv
erse
impa
cts.
The
qu
arry
will
not
adv
erse
ly im
pact
on
salin
ity in
stre
ams n
orth
of t
he q
uarr
y an
d is
like
ly to
redu
ce
stre
am fl
ow sa
linity
in th
e up
per c
atch
men
t by
rele
asin
g la
rger
vol
umes
of f
resh
wat
er, t
han
wou
ld o
ther
wis
e be
the
case
.
The
quar
ry w
ill n
ot a
dver
sely
impa
ct
on sa
linity
in st
ream
s nor
th o
f the
qu
arry
.
The
disc
harg
e of
fres
h w
ater
to th
e W
este
rn S
tream
dur
ing
win
ter i
s lik
ely
to re
duce
stre
am fl
ow sa
linity
in
the
uppe
r cat
chm
ent.
Con
cern
was
rais
ed a
bout
the
pote
ntia
l im
pact
of
clea
ring
85 h
a of
nat
ive
vege
tatio
n in
the
Shire
of
Nor
tham
(whe
re th
ere
is o
nly
appr
oxim
atel
y 16
.4%
of
rela
tivel
y in
tact
nat
ive
vege
tatio
n) a
nd in
the
uppe
r cat
chm
ent o
f Woo
rolo
o B
rook
. Th
ese
conc
erns
rela
te p
rimar
ily to
the
effe
cts o
f cle
arin
g on
cat
chm
ent s
alin
ity a
nd sa
linis
atio
n, a
nd
redu
ctio
n of
repr
esen
tatio
n of
veg
etat
ion
type
s, an
d th
e ro
le o
f veg
etat
ion
as fa
una
habi
tat.
Fur
ther
in
form
atio
n on
thes
e im
pact
s and
on
how
they
w
ould
be
man
aged
was
requ
este
d.
Add
ition
al in
form
atio
n w
as so
ught
in re
latio
n to
th
e re
vege
tatio
n st
rate
gy p
ropo
sed
to o
ff-s
et so
me
of th
e re
duct
ion
in b
iodi
vers
ity v
alue
s tha
t wou
ld
occu
r as a
resu
lt of
veg
etat
ion
clea
ring
with
in th
e pr
opos
ed P
roje
ct A
rea.
To o
ffse
t the
cle
arin
g of
85
ha o
f nat
ive
vege
tatio
n w
ithin
the
Shire
of N
orth
am, t
he P
ropo
nent
pr
opos
ed to
impl
emen
t a R
eveg
etat
ion
Stra
tegy
, whi
ch in
volv
ed th
e pl
antin
g of
170
ha
of n
ativ
e ve
geta
tion
with
in th
e Sh
ire.
How
ever
, one
of t
he w
eakn
esse
s of t
he st
rate
gy w
as th
at sp
ecifi
c ar
eas a
vaila
ble
for r
eveg
etat
ion
wer
e di
ffic
ult t
o id
entif
y. T
here
fore
, UR
S/B
GC
eng
aged
Fra
nk
Bat
ini t
o pr
ovid
e ad
vice
on
pote
ntia
l off
set p
acka
ges,
and
revi
ew th
e R
eveg
etat
ion
Stra
tegy
. M
r B
atin
i’s re
port
is p
rese
nted
in V
olum
e 2;
App
endi
x J.
His
reco
mm
ende
d st
rate
gy in
volv
es a
pa
ckag
e of
var
ious
act
ions
whi
ch a
re fe
asib
le a
nd su
ppor
ted
by lo
cal a
utho
ritie
s. Th
e pr
opos
ed
new
off
set p
acka
ge fo
r thi
s Pro
ject
con
sist
s of t
hree
ele
men
ts:
1.Th
e co
vena
ntin
g fo
r con
serv
atio
n in
per
petu
ity o
f 120
ha
of re
mna
nt b
ushl
and
on L
ots
11 a
nd 1
4 H
orto
n R
oad.
2.
The
prov
isio
n of
15
km o
f fen
cing
to p
rote
ct a
bout
100
-150
ha
of re
mna
nt v
eget
atio
n fr
om g
razi
ng a
t the
Woo
rolo
o pr
ison
farm
. 3.
The
reha
bilit
atio
n of
som
e 60
ha
of g
rave
l pits
and
oth
er d
egra
ded
land
s cur
rent
ly
man
aged
by
the
Shire
s of M
unda
ring
and
Nor
tham
, CA
LM, a
nd th
e W
ater
s and
Riv
ers
Com
mis
sion
.In
rela
tion
to th
e ef
fect
s of c
lear
ing
on c
atch
men
t sal
inity
, the
gro
undw
ater
stud
y ha
s con
firm
ed
that
the
new
qua
rry
will
not
cau
se a
rise
in th
e w
ater
tabl
e do
wns
tream
, but
will
act
as a
gr
ound
wat
er si
nk.
This
will
redu
ce sa
linis
atio
n do
wng
radi
ent f
rom
the
quar
ry.
The
prop
osed
new
env
ironm
enta
l of
fset
s pac
kage
con
sist
s of b
oth
prim
ary
and
seco
ndar
y of
fset
s and
w
ill g
ener
ate
a “n
et b
enef
it” to
the
loca
l env
ironm
ent i
n ge
nera
l and
the
Woo
rolo
o B
rook
cat
chm
ent i
n pa
rticu
lar.
Loca
l aut
horit
ies h
ave
indi
cate
d su
ppor
t for
the
prop
osal
, and
CA
LM
has i
ndic
ated
a w
illin
gnes
s to
unde
rtake
the
reve
geta
tion
wor
ks
unde
r con
tract
to B
GC
. The
refo
re
chan
ces o
f suc
cess
are
hig
h.
Exe
cuti
ve S
umm
ary
KM
A/4
2905
483/
DK
:582
-F62
11.1
/DE
CE
MB
ER 2
004
ES-7
Tab
le E
S1 (c
ontin
ued)
Issu
e R
aise
d Pr
opon
ent’
s Res
pons
e Pr
edic
ted
Out
com
es
Som
e su
bmis
sion
s req
uest
ed a
dditi
onal
info
rmat
ion
on th
e po
tent
ial i
mpa
ct o
n H
emig
enia
vis
cida
(a
Prio
rity
4 flo
ra sp
ecie
s) in
the
Proj
ect A
rea
and
ques
tione
d w
heth
er th
e 50
m b
uffe
r pro
pose
d fo
r H
eath
Com
mun
ity 5
, whi
ch c
onta
ins 9
5% o
f the
H
emig
enia
vis
cida
in th
e Pr
ojec
t Are
a, w
ould
be
adeq
uate
.
Any
impa
cts t
o th
e H
emig
enia
vis
cida
will
be
min
imis
ed, a
s the
Hea
th C
omm
unity
5 th
at
cont
ains
the
spec
ies,
will
not
be
clea
red
and
ther
e w
ill b
e a
50 m
buf
fer o
f und
istu
rbed
ve
geta
tion
arou
nd th
e co
mm
unity
. In
add
ition
, BG
C m
ade
a co
mm
itmen
t in
the
PER
to m
onito
r th
e he
alth
of t
he c
omm
unity
dur
ing
all p
hase
s of t
he P
roje
ct.
Hea
th C
omm
unity
5 a
nd th
e H
emig
enia
vis
cida
pla
nts w
ill n
ot b
e im
pact
ed b
y th
e pr
opos
ed a
ctiv
ities
. Th
e 50
m b
uffe
r and
impl
emen
tatio
n of
dus
t con
trol m
easu
res w
ill
adeq
uate
ly p
rote
ct th
is sp
ecie
s.
Furth
er in
form
atio
n w
as so
ught
in re
latio
n to
the
exte
nt o
f the
inve
rtebr
ate
faun
a st
udie
s con
duct
ed
and
prop
osed
to b
e co
nduc
ted.
A n
umbe
r of
subm
issi
ons d
iscu
ssed
the
cons
erva
tion
sign
ifica
nce
of a
n un
iden
tifie
d sp
ecie
s of t
rapd
oor
spid
er (G
aius
sp.)
and
the
adeq
uacy
of t
he p
ropo
sed
man
agem
ent m
easu
res.
An
addi
tiona
l lan
d sn
ail s
urve
y w
as u
nder
take
n in
May
200
4. T
he p
urpo
se o
f thi
s stu
dy w
as to
su
rvey
pot
entia
l sui
tabl
e ha
bita
ts in
the
Dar
ling
Scar
p re
gion
to g
ain
a be
tter u
nder
stan
ding
of
the
geog
raph
ical
dis
tribu
tion
of th
ese
land
snai
l spe
cies
. Tw
o of
the
thre
e un
nam
ed la
nd sn
ails
th
at w
ere
foun
d in
the
initi
al su
rvey
of t
he P
roje
ct A
rea
wer
e fo
und
in S
tate
For
est.
Lan
d sn
ails
be
long
ing
to th
e un
nam
ed sp
ecie
s of t
he g
enus
Bot
hrie
mbr
yon
wer
e fo
und
at fo
ur o
f the
surv
ey
stat
ions
and
tiny
spec
imen
s fro
m th
e fa
mily
Pun
ctid
ae w
ere
foun
d at
eig
ht su
rvey
stat
ions
, one
w
ithin
the
Proj
ect A
rea
and
the
rest
with
in S
tate
For
est.
The
oth
er u
nnam
ed a
nd u
ndes
crib
ed
spec
ies f
rom
the
genu
s Lui
nodi
scus
, whi
ch w
as fo
und
in th
e Pr
ojec
t Are
a du
ring
the
2002
su
rvey
, was
not
foun
d du
ring
the
rece
nt su
rvey
. H
owev
er, t
he sp
ecim
ens s
eem
to b
e th
e sa
me
or
clos
ely-
rela
ted
to sp
ecie
s tha
t hav
e be
en fo
und
at v
ario
us lo
calit
ies o
n th
e Sw
an C
oast
al P
lain
.
BG
C re
cogn
ised
that
the
trapd
oor s
pide
r iss
ue w
as u
nres
olve
d an
d th
eref
ore
com
mis
sion
ed
Prof
esso
r Yor
k M
ain
to u
nder
take
furth
er in
vest
igat
ion
durin
g M
arch
200
4 an
d ag
ain
in
Nov
embe
r 200
4. T
he o
utco
mes
of t
hese
inve
stig
atio
ns a
re p
rese
nted
in V
olum
e 2;
App
endi
x H
.
A m
ale
spec
imen
was
col
lect
ed fr
om L
ot 1
4 in
Mar
ch 2
004
and
brie
fly a
naly
sed.
It d
iffer
s m
orph
olog
ical
ly fr
om o
ther
mal
e sp
ecim
ens o
f Gai
ussp
ider
pop
ulat
ions
that
hav
e be
en fo
und
to
the
east
of t
he A
von.
How
ever
, the
Voy
ager
(mal
e) sp
ecim
en d
oes h
ave
som
e m
orph
olog
ical
af
finity
with
“so
uthe
rn”
spid
ers a
nd m
ay b
e ei
ther
the
sam
e or
a d
iffer
ent s
peci
es (d
eriv
ed fr
om
a po
ssib
ly o
nce
cont
inuo
us p
opul
atio
n) a
s the
spec
ies f
arth
er so
uth
(i.e.
Col
lie).
In N
ovem
ber 2
004,
add
ition
al se
arch
es w
ere
mad
e fo
r oth
er p
opul
atio
ns o
f the
spid
er a
nd so
me
spec
imen
s wer
e co
llect
ed.
A ro
bust
pop
ulat
ion
of a
t lea
st 2
2-25
spid
ers w
ere
loca
ted
at a
site
ne
ar th
e in
ters
ectio
n of
Ber
akin
g Po
ol R
oad
and
Bro
okto
n H
ighw
ay. I
t is l
ikel
y th
at th
ese
spid
ers a
re o
f the
sam
e sp
ecie
s as t
he G
aius
sp. f
ound
at t
he V
oyag
er si
te, a
lthou
gh th
is re
quire
s co
nfirm
atio
n vi
a m
orph
olog
ical
stud
ies.
A m
ale
spec
imen
from
this
pop
ulat
ion
will
be
colle
cted
in
late
aut
umn
2005
to a
llow
con
firm
atio
n of
taxo
nom
ic a
ffin
ity w
ith th
e V
oyag
er sp
ecie
s.
Two
of th
e th
ree
unna
med
land
snai
l sp
ecie
s fou
nd d
urin
g th
e 20
02
surv
ey o
f the
Pro
ject
Are
a w
ere
foun
d in
Sta
te F
ores
t. T
he o
ther
sp
ecie
s is t
he sa
me
or c
lose
ly-r
elat
ed
to sp
ecie
s on
the
Swan
Coa
stal
Pla
in.
Ther
efor
e th
e pr
ojec
t will
not
resu
lt in
the
extin
ctio
n of
the
spec
ies.
An
addi
tiona
l rob
ust p
opul
atio
n of
G
aius
spid
ers h
as b
een
loca
ted
at a
si
te re
mov
ed fr
om th
e qu
arry
and
th
ese
are
likel
y to
be
the
sam
e sp
ecie
s alth
ough
they
may
be
gene
tical
ly d
iffer
ent.
In a
dditi
on,
appr
oxim
atel
y 30
% o
f the
Voy
ager
po
pula
tion
occu
rs o
n la
nd in
Lot
s 11
and
14 th
at w
ill n
ot b
e di
stur
bed
and
will
be
cove
nant
ed fo
r con
serv
atio
n pu
rpos
es, i
n pe
rpet
uity
, as p
art o
f the
pr
opos
ed o
ffse
ts p
acka
ge.
Ther
efor
e su
rviv
al o
f the
spec
ies i
s un
likel
y to
be
at ri
sk if
it is
co
nfirm
ed th
at th
e B
erak
ing
Pool
R
oad
popu
latio
n is
the
sam
e sp
ecie
s as
that
at V
oyag
er Q
uarr
y.
Exe
cuti
ve S
umm
ary
KM
A/4
2905
483/
DK
:582
-F62
11.1
/DE
CE
MB
ER 2
004
ES-8
Tab
le E
S1 (c
ontin
ued)
Issu
e R
aise
d Pr
opon
ent’
s Res
pons
e Pr
edic
ted
Out
com
es
A n
umbe
r of s
ubm
issi
ons d
iscu
ssed
the
envi
ronm
enta
l sig
nific
ance
of t
he p
ropo
sed
Proj
ect
Are
a as
hab
itat f
or v
erte
brat
e fa
una,
par
ticul
arly
C
arna
by’s
Bla
ck C
ocka
too,
Bau
din’
s Bla
ck
Coc
kato
o an
d th
e C
hudi
tch.
Con
cern
s wer
e ra
ised
re
gard
ing
the
pote
ntia
l im
pact
on
thes
e an
d ot
her
verte
brat
e fa
una
spec
ies d
ue to
the
clea
ring
of 8
5 ha
of
nat
ive
vege
tatio
n an
d ot
her a
spec
ts o
f the
pr
opos
ed P
roje
ct.
Cla
rific
atio
n on
thes
e im
pact
s w
as so
ught
, alo
ng w
ith fu
rther
info
rmat
ion
on
faun
a m
anag
emen
t.
A tr
ee h
ollo
w su
rvey
was
con
duct
ed b
y R
.E. J
ohns
tone
and
T. K
irkby
in D
ecem
ber 2
003.
Thi
s in
volv
ed a
n as
sess
men
t of t
ree
hollo
ws f
or n
estin
g co
ckat
oos (
i.e. C
arna
by’s
Bla
ck C
ocka
too
and
Fore
st R
ed-ta
iled
Bla
ck C
ocka
too)
. A
tota
l of 1
63 tr
ees w
ith la
rge
hollo
ws w
ere
visu
ally
in
spec
ted
for s
igns
of u
se b
y co
ckat
oos.
33
trees
wer
e cl
imbe
d an
d of
thes
e, o
nly
thre
e w
ere
iden
tifie
d as
hav
ing
hollo
ws t
hat h
ad b
een
used
ove
r the
pas
t 1-3
yea
rs.
How
ever
, non
e of
thes
e ho
llow
s wer
e us
ed d
urin
g th
e 20
03-2
004
bree
ding
seas
on.
Bio
ta a
nd Jo
hnst
one
(200
3) a
nd Jo
hnst
one
and
Kirk
by (2
003)
com
plet
ed ta
rget
ed fa
una
surv
eys
seek
ing
evid
ence
of t
hrea
tene
d fa
una
use.
Thi
s inc
lude
d th
e Ph
asco
gale
and
the
Chu
ditc
h. N
o ev
iden
ce o
f Pha
scog
ale
use
of th
e su
bjec
t lan
d w
as re
cord
ed.
A si
ngle
Chu
ditc
h w
as re
cord
ed
durin
g th
e su
rvey
, but
as n
oted
in B
iota
and
John
ston
e (2
003)
, the
are
a to
be
clea
red
for t
he
quar
ry w
ould
repr
esen
t a sm
all p
erce
ntag
e of
the
hom
e ra
nge
of th
is in
divi
dual
.
The
clea
ring
of 8
5 ha
of n
ativ
e ve
geta
tion
wou
ld n
ot h
ave
a si
gnifi
cant
impa
ct o
n co
ckat
oos o
r ot
her v
erte
brat
e fa
una
of
cons
erva
tion
sign
ifica
nce.
In re
latio
n to
a c
omm
itmen
t by
BG
C to
est
ablis
h a
Com
mun
ity L
iais
on G
roup
(CLG
), a
num
ber o
f su
bmis
sion
s com
men
ted
on th
e di
ffic
ultie
s en
coun
tere
d in
setti
ng u
p th
is g
roup
, par
ticul
arly
in
rela
tion
to a
gree
ing
on th
e te
rms o
f ref
eren
ce,
pow
ers a
nd c
hairi
ng o
f the
gro
up.
The
obje
ctiv
e of
the
CLG
is to
ena
ble
peop
le to
rais
e is
sues
and
con
cern
s abo
ut th
e ex
istin
g qu
arry
and
rece
ive
a re
spon
se fr
om B
GC
.
The
LAG
and
the
Woo
rolo
o B
rook
land
Con
serv
atio
n D
istri
ct C
omm
ittee
(WB
LCD
C)
sugg
este
d th
e te
rms o
f ref
eren
ce fo
r the
CLG
at a
mee
ting
on 2
6 N
ovem
ber 2
002.
BG
C w
as
will
ing
to d
iscu
ss th
ese
at th
e ne
xt m
eetin
g, b
ut m
embe
rs o
f the
LA
G o
r WB
LCD
C w
ere
not
pres
ent a
t the
mee
ting.
The
term
s of r
efer
ence
cou
ld n
ot b
e ag
reed
upo
n, a
s rep
rese
ntat
ives
from
th
e LA
G a
nd W
BLC
DC
did
not
atte
nd th
e C
LG m
eetin
gs, u
ntil
rece
ntly
afte
r BG
C a
dvis
ed th
at
CLG
mee
tings
wer
e go
ing
to c
ease
due
to th
e la
ck o
f atte
ndan
ce.
In th
e re
cent
CLG
mee
ting
on 2
2 Se
ptem
ber 2
004,
the
stru
ctur
e of
the
CLG
was
dis
cuss
ed in
de
tail.
The
LA
G re
ques
ted
that
an
inde
pend
ent c
hairp
erso
n w
as re
quire
d fo
r the
CLG
and
BG
C
aske
d th
e LA
G to
look
for p
oten
tial c
andi
date
s and
pre
sent
this
info
rmat
ion
for d
iscu
ssio
n at
the
next
mee
ting.
LA
G h
as n
ow re
com
men
ded
an in
depe
nden
t cha
irman
and
BG
C a
re in
vest
igat
ing
his a
ppoi
ntm
ent.
The
CLG
mee
tings
are
con
tinui
ng to
oc
cur e
very
two
mon
ths.
R
epre
sent
ativ
es fr
om th
e LA
G a
nd
WB
LCD
C h
ave
rece
ntly
atte
nded
a
CLG
mee
ting.
An
inde
pend
ent
chai
rper
son
is a
bout
to b
e ap
poin
ted.
Fu
ture
mee
tings
shou
ld n
ow b
e m
ore
prod
uctiv
e th
an p
ast m
eetin
gs.
The
pote
ntia
l for
the
prop
osed
qua
rry
oper
atio
ns to
ad
vers
ely
affe
ct th
e vi
sual
am
enity
of t
he a
rea
was
ra
ised
by
a nu
mbe
r of s
ubm
issi
ons.
The
mai
n co
ncer
ns re
late
d to
the
impa
ct o
f lig
htin
g at
nig
ht
on n
earb
y re
side
nts a
nd th
e vi
sibi
lity
of th
e pr
opos
ed q
uarr
y fr
om n
eigh
bour
ing
prop
ertie
s.
A d
eskt
op re
view
of t
he v
isua
l acc
essi
bilit
y of
the
Proj
ect w
as u
nder
take
n by
a la
ndsc
ape
arch
itect
usi
ng c
onto
ur d
ata.
It w
as d
eter
min
ed th
at p
rono
unce
d rid
ges s
epar
ate
the
prop
ertie
s to
the
wes
t of t
he q
uarr
y fr
om th
e Pr
ojec
t. T
here
fore
, the
se p
rope
rties
shou
ld n
ot h
ave
visu
al
acce
ssib
ility
to th
e pr
opos
ed q
uarr
y si
te.
How
ever
, the
qua
rry
may
be
visi
ble
to th
e re
side
nts
imm
edia
tely
to th
e no
rth a
nd n
orth
wes
t of t
he q
uarr
y fr
om th
e ac
tual
resi
denc
es.
It is
impo
rtant
to n
ote
that
the
vege
tatio
n co
ver w
ill c
reat
e su
bsta
ntia
l ‘fo
regr
ound
clo
sure
’ (v
isua
l scr
een)
and
will
form
a h
ighl
y ef
fect
ive
visu
al b
uffe
r.
The
prop
osed
qua
rry
will
not
be
seen
fr
om th
e re
side
nces
imm
edia
tely
to
the
wes
t of t
he q
uarr
y. T
he
resi
denc
es to
the
north
and
nor
thw
est
may
hav
e so
me
view
s of t
he P
roje
ct.
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
Figures
0
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Wed20Apr05
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I. Introductory Notes
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
1
I.I Purpose of this Document
The purpose of this document is to respond to submissions made on the Proposed Relocation of the Voyager Quarry Public Environmental Review (PER), prepared for BGC (Australia) Pty Ltd. The document was available for government and public review from 6 January to 3 March 2003. The deadline for the submission of comments was 3 March 2003, though extensions to this deadline were granted by the Environmental Protection Authority (EPA) to some parties.
This document also provides responses to submissions made on the report entitled Voyager Quarry Extension - Targeted Fauna Survey and prepared by Biota Environmental Sciences. Following the finalisation of the report in March 2003, it was released to the groups and individuals that had made a submission on the PER.
I.II Structure of this Document
This Response to Submissions document has been structured in a similar way to the PER, with the numbering of the sections in this document following the format of that used in the PER. The appendices contain the results of follow-up studies and surveys that were undertaken to provide clarification and also technical information to support the text in this document.
This document comprises text and appendices. The format of the report is presented as follows:
I. Introductory Notes that outline the number and source of submissions that were received and presents a summary of the key issues that were raised.
Sections 1 to 7 Responses to all submissions received are provided in these sections. Each submission is presented (in summary form) in bold and italics. The response is provided immediately below in normal text. If the submissions were similar, one response has been provided and this is presented immediately below the group of submissions.
The submissions are presented in the same section as the relevant section in the PER so that the responses can be cross-referenced with the PER. The source of the submission is also identified to enable the authors of the submissions to identify responses to their comments and questions. Submissions from members of the public have been identified as Public Submissions 1-16, as the identity of the public submission authors was removed by the Department of Environment (DoE) before the submissions were provided to URS.
Section 8 References used in the responses to submissions.
The appendices are presented in Volume 2 as follows:
Appendix A A summary table of the key issues, concerns and questions raised in the submissions is presented in this appendix. The issues were sorted according to PER section number are listed in the table in the same order as presented in this document. This provides
I. Introductory Notes
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readers with a quick reference to the issues provided in this Response of Submissions, and a guide to their location.
Appendix B A surface water technical report was prepared to support the Proponent’s response to issues raised by the government and community in relation to surface water and erosion management at the proposed relocation site of the Voyager Quarry.
Appendix C A groundwater technical report was prepared to present the results of the census of bores, dams, soaks and wells and assess the groundwater impacts of the proposal.
Appendix D A preliminary closure plan for the proposed Voyager Quarry was developed as the first stage of the closure planning process and is considered to be a working document.
Appendix E This appendix contains the flora lists to accompany Appendix B of the PER. The first list is a summary of vascular plant species recorded within the survey area. The second list is a summary of rare, priority and threatened vascular plant species potentially near the survey area.
Appendix F The results of a tree hollow survey conducted by R.E. Johnstone and T. Kirkby in December 2003 are presented in this appendix. The tree hollows were surveyed to assess use and nesting opportunities for Carnaby’s Black Cockatoo, Baudin’s Black Cockatoo and the Forest Red-tailed Black Cockatoo. The hollows were also assessed for their use by vertebrates of conservation significance.
Appendix G A fauna management plan for the proposed Voyager Quarry was prepared and includes management measures to address pest species and the enhancement of habitat for target species at the local scale.
Appendix H A summary of the results of the additional trapdoor spider survey was produced by URS. This document was reviewed and approved by Barbara York Main. Two reports were produced by Professor York Main and Mr Stephen Trent. A report was also produced by Biota Environmental Sciences on the regional survey work undertaken in November 2004. These reports are provided in this appendix.
Appendix I The results of the additional land snail survey by Shirley Slack-Smith are presented in this appendix.
Appendix J An Offsets Strategy has been developed by Mr Frank Batini, and is presented in this appendix.
Appendix K Additional noise modelling was undertaken by Herring Storer Acoustics (HSA) to verify the reliability of the acoustic model presented in the PER and address the issue of construction noise. The peer review undertaken by Dick Langford (Langford Acoustical Services) is also presented in this appendix.
I. Introductory Notes
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Appendix L A blasting impact assessment and monitoring/management plan. The plan was prepared for the management of airblast and ground vibration at the proposed Voyager Quarry so that the regulatory limits are not exceeded.
I.III Assessment Process for this Document
The Environmental Impact Assessment (Part IV Division 1) Administrative Procedures 2002 state that the proponent is required to prepare a summary of the pertinent issues raised in public and government agency submissions. The submissions on the PER and the Biota report were summarised by URS on behalf of the proponent, BGC (Australia) Pty Ltd. The Summary of Submissions was forwarded to the EPA for confirmation of its adequacy in capturing the key issues.
In preparing the Summary of Submissions, the following methodology was adopted:
Each submission was reviewed and those sections of text that described an environmental issue, concern or question were identified.
A “cut and paste” summary of the submissions was produced that collated the key issues, concerns and questions into categories according to topic.
A PER section number was allocated to all key issues, concerns and questions raised in the submissions. Where the submissions referred to sections of the Executive Summary (Volume 1) and the Appendices (Volume 3), reference was made to the relevant section of the PER text (Volume 2).
The key issues, concerns and questions raised in the submissions were then sorted according to PER section number and summarised in Table A1 (Volume 2; Appendix A). These items are listed in Table A1 in the same order as presented in this document. This provides readers with a quick reference to the issues provided in this Response of Submissions, and a guide to their location.
Details on the key issues, concerns and questions are provided in the main text of this document under the relevant PER section. For example, those issues raised in relation to Section 2 of the PER (Project Justification) are listed in Section 2 of this Response of Submissions. This enables cross-referencing with the PER.
Following the approval of the Summary of Submissions document, studies and surveys were undertaken for the Response to Submissions. Responses were prepared for each of the submissions presented in the approved Summary of Submissions document.
I.IV Number and Source of Submissions Received
Submissions on the PER were received from seven local and State government agencies, as follows:
Department of Indigenous Affairs (DIA); Water and Rivers Commission (WRC);
I. Introductory Notes
KMA/42905483/DK:582-F6211.1/DECEMBER 2004
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DoE - Licensing Branch; DoE – Ecological Systems Branch; DoE – Environmental Regulation Division; Office of Soil and Land Conservation (OSLC), Department of Agriculture; Department of Conservation and Land Management (CALM); Department of Industry and Resources (DoIR); and Shire of Mundaring.
Nine submissions on the PER were received from community and industry groups, as follows:
Avon Valley Environmental Society (AVES); Wooroloo Brook Land Care District Committee (WBLCDC); Earth;Wildflower Society of WA (Eastern Hills Branch); Wildflower Society of WA Inc.; Conservation Council of WA; Birds Australia WA Conservation and Research Committee; Chamber of Commerce and Industry (CCI); and Lakes Action Group (LAG).
Following the finalisation of the report entitled ‘Voyager Quarry Extension - Targeted Fauna Survey’ prepared by Biota Environmental Sciences, the report was released to the groups and individuals that had made a submission on the PER. Submissions were received on the report from the following groups:
AVES;Wildflower Society of WA (Eastern Hills Branch); Earth; and LAG.
Sixteen members of the public made submissions on the PER document. For the purposes of this document, these have been identified as Public Submissions 1-16 as the identity of the public submission authors was removed by the DoE before the submissions were provided to URS. Of the 16 members of the public that made submissions on the PER, 10 went on to make submissions on the Biota report. The DoE grouped these submissions with the submissions made on the PER. In addition, two additional members of the public made submissions on the Biota report. These members of the public have been identified as Public Submissions 17 and 18.
I.V Summary of Issues Raised in Submissions
Table A1 (Volume 2; Appendix A) provides a summary of the key issues, concerns and questions raised in the submissions on the PER. Full responses are provided in Sections 1-7 of this report. Column 1 of the table identifies the agency or group that raised particular issues. Abbreviations of the names of
I. Introductory Notes
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government departments and other organisations have been used in Column 1. However, the legend below the table provides the full name corresponding to each abbreviation. Column 2 indicates the number of the PER section to which the issue relates and the corresponding title of the PER section or relevant topic is presented in Column 3. The nature of the issue raised in the submission is summarised in Column 4.
I.VI Issues Raised Outside the Guidelines
A number of submissions commented on or questioned local and State government processes or parties other than BGC. BGC cannot respond on behalf of other parties. Therefore, these issues have not been included in this Summary of Submission document.
SECTION 1Response to Submissions on the Introduction
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1 Response to Submissions on the Introduction
1.1 The Proposal
Public Submissions 1 and 6 asked whether the proposal was a new quarry or whether it was an expansion of the existing quarry.
The proposal involves the relocation of the existing Voyager Quarry to Lot 14 Horton Road, The Lakes. This relocation would involve the development of a second open pit and the construction of a new crushing plant in the southern end of the proposed pit. Following the completion of construction activities for the pit, crushing plant and other infrastructure, the existing pit and crushing plant would be decommissioned.
Public Submission 1 asked if the zoning for Lots 11 and 14 were the same even though Lot 11 is located in the Shire of Mundaring and Lot 14 is located in the Shire of Northam.
The zonings for Lots 11 and 14 are different, due to the location of Lot 11 in the Shire of Mundaring and Lot 14 in the Shire of Northam. The zoning for Lot 11 is General Rural and as specified in the Shire of Mundaring’s Use Class Table from the Town Planning Scheme No. 3, the following uses are permitted:
Communications installation – private; Public recreation; Rural pursuit; and Single house.
Other uses require special permission from the Council.
It was stated in Sections 1.4 and 4.8 of the PER (Volume 2) that Lot 14, which is located in the Shire of Northam, has a zoning classification of Rural 3 Zone under Town Planning Scheme No. 2. This zoning indicates that the Council would not support further subdivision of the land, except where this may be necessary for the protection of the natural and rural environment or the acquisition of additional reserves. Within the Rural 3 Zone, ‘Industry-Extractive’ is an ‘AA’ use, which means it is not permitted unless Planning Approval is granted by Council. Secondly, the site also falls within the Eastern Slopes Planning Precinct of the Local Rural Strategy (Shire of Northam, 1999). Basic raw material extraction is identified as a conditional land use in this Precinct. Intensive stock yards and urban uses are identified as the only undesirable uses in this Precinct. Thirdly, in the subsequent Draft Town Planning Scheme 3 (circa October 2002), Lot 14 will be in an Agricultural Local zone. It is proposed that for this zone Extractive Industry will be an ‘A’ use which means it is not permitted except by Council exercising discretionary approval. Hence, at the very least there is provision for extractive industry to be approved by the local authority in a Rural Zone.
SECTION 2Response to Submissions on the Project Justification
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2 Response to Submissions on the Project Justification
2.1 Evaluation of Alternative Sites
2.1.1 Historical Perspective on the Development of the Existing Quarry
In relation to information on the history of the existing quarry presented in the PER, Public Submission 14 and the LAG submission stated that the existing quarry started without the knowledge of the EPA.
The Proponent disputes the Minister’s assertion that the EPA was first advised of the existing quarry in early November 1990 after construction of the crushing plant had commenced. BGC has copies of correspondence written on 26 April 1990, by the Shire of Northam to the EPA advising them that the Shire had received an application for an extractive industry licence to operate a quarry, and seeking their comment. That letter pre-dates the resolution of Council approving the quarry, notice of which was given to BGC on 21 May 1990, and the subsequent issue of an Extractive Industry Licence by the Shire on 7 June 1990.
Upon being contacted by the EPA in November 1990, the Proponent referred the project as requested, and was subsequently advised that as the site was located outside of the water catchment area and 2 km from the nearest residence, the project did not require formal environmental assessment, but instead required a works approval and licence under Part V of the Act. Works approval and a Departmental Licence were subsequently granted in early 1991.
2.1.2 Site Selection Process for Proposal
A number of submissions indicated that there are more suitable quarry sites for BGC to relocate to, other than the proposed relocation site. The Wildflower Society (Eastern Hills Branch) submission asked why options of acquisition of nearby previously cleared land for granite commodities had not been investigated. Public Submissions 2, 10 and 15 also stated that the proposed quarry should be located on previously cleared land.
First Point: There are suitable quarry sites to relocate to, other than the proposed relocation site.
The view that ‘there are more suitable quarry sites for BGC to relocate to other than the proposed relocation site’ is easily stated, but severely underestimates the complexities in identifying and securing a viable quarry site in or near the Perth Metropolitan Region, and the significant effort involved.
The existing quarry is a well run operation, originally established by meeting approval and compliance requirements, including due consideration of regional strategic planning aspects.
The PER frames the proposed quarry as a ‘relocation’ (in order to simplify different land tenure versus lease arrangements concerning the land involved) which in practical and functional terms this means that a comprehensive suite of improved technologies and environmental best practices can be introduced as the old quarry operations are phased out. The latter point is explicit in the PER.
SECTION 2Response to Submissions on the Project Justification
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Any productive and viable mine or quarry with further extractible resources in the immediate site location (i.e. a geological continuation of the existing resource) would seek to achieve an expansion of an existing operation in preference to a full relocation and the cost and operational complexities of establishing an entirely new operation in a new location. While this is an obvious commercial imperative, there are also very good planning, social and environmental reasons for doing so.
In strategic planning terms, for the past two decades the state government has sought to ensure not only that basic raw material resources essential to the regional economy are secured and available for extraction (at some point in time), but also that as far as possible there is ‘spatial efficiency’ in the occurrence of extractive industry. A guiding principle in achievement of the latter is that extractive industry be concentrated or ‘agglomerated’ wherever possible. This encourages both efficient exploitation of the resources, and the minimisation of potential land use conflicts. This applies to a whole range of land use categories and is a basic principle of land use planning. The negative consequences of allowing extractive industry to proliferate throughout the urban area without strategic guidance would be very high. This is why the various Basic Raw Materials studies were undertaken from the 1980s onwards and why the Statement of Planning Policy No. 10 (WAPC, 2000) was prepared.
A specific and very important strategic planning consideration that supports extension of a current operation is that existing freight transport movements via major highways from the quarry to distribution points to supply the market remains constant. A ‘high impact’ aspect of a major quarry is transport to and from the quarry. In the case of the proposed Voyager Quarry proposal, this important functional aspect will remain the same, with the opportunity for progressive improvement of transport technology over time.
Hence, the point is made that the relocation of the quarry to the adjacent lot would be the preferable option, both for BGC as an extractive industry operator and also for government and the wider community.
Second point: Options for acquisition of nearby cleared land for granite commodities not considered? The proposed quarry should be on cleared land.
To locate extraction activities on cleared land (rural or vacant) rather than uncleared land (i.e. native vegetation cover) would be the preference for any extractive industry operators. BGC first explored possible ways of negotiating an extension of the existing operations on the adjacent cleared land with the current landowner. Agreement to do so could not be reached.
If the submissions also mean the extraction activities ‘should be on cleared land in some other location’, then much the same response as provided to the first point (as above) also applies.
However, some further points can be made. One of the significant strategic attributes of both the current site and the proposed site is that they are located on Rural zoned land (in the Local Town Planning Scheme) outside:
the Perth Metropolitan Region (and therefore not the subject of the provisions of the Metropolitan Region Scheme);
SECTION 2Response to Submissions on the Project Justification
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any nature reserve; any ‘Bushland Forever Site; and any formal strategic environmental land classification in a Town Planning Scheme.
It is to be noted that the location of the proposed expansion occurs in the Eastern Slopes Planning Precinct of the Local Rural Strategy (Shire of Northam, 1999). Basic raw material extraction is identified as a conditional land use in this Precinct. In contrast to this, intensive stock yards and urban uses are the only nominated undesirable uses in this Precinct.
The location is also close to the limit of the viable transport distance from the market. Hence, locating any further distance from the Perth Metropolitan Region becomes rapidly uneconomic. A clear benefit of locating the quarry outside of urban areas, as is the case for the Voyager site, is that it minimises the potential for land use conflict. The corollary applies; to attempt to locate any closer in towards the urban area (and hence also within the Perth Metropolitan Region) is to rapidly increase the likelihood of social, environmental and land use conflicts, due to the existence of more complex land use control provisions and a generally intensifying land use ‘gradient’.
It is also important to note that ‘cleared land’ sites are not devoid of many limitations and constraints that prospective extractive industry operators must address. Cleared land, especially as one moves towards the edge of the built urban area, is more likely to be in use or to be designated for future land use change that is integrated into an existing strategic planning framework. Displacement of existing uses may be impossible or very difficult and potential conflict with strategic land use planning and evolving land use patterns is a major constraint. This, for example, applies strongly in the Gidgegannup locality and virtually the entire Darling Scarp and foothills zone.
These combined points mean that, all things considered, the BGC proposal conforms strongly with the spirit and intent of good strategic land use planning in the vicinity of a large metropolitan region, for which BGC is a major supplier of an important material vital to the regional economy.
The LAG submission stated that there are many alternative sites for the quarry that will satisfy BGC’s requirements and have “far less impact on the environment and the residents’ amenity”.
While the LAG concerns are understandable, this particular advice is unfortunately not correct, and as such, is strongly contested.
In discussions with a range of government departments concerned with the location and operation of extractive industry, there is clear agreement on the following point. While the Darling Range/Plateau is widely underlain with granitic rock, the occurrence of granite with the necessary geotechnical properties and at a shallow depth suitable for hard rock quarry operations is comparatively limited. When the factors of alienation of the potential locations or sites due to a host of land use control and legal constraints (e.g. inappropriate zonings, existence of a range of Land Act reserves, legal easements, etc.) are factored in, the potential sites are reduced further. Finally, when existing land use activities are considered, the practical and potentially viable sites are reduced to very few indeed.
SECTION 2Response to Submissions on the Project Justification
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To give this some perspective, in the early 1980s the Department of Resources Development prepared the Darling Escarpment Aggregate Resources Committee Report (known as the DEAR report) (DRD, 1980). This report identified initially some 40 granite resource deposits that were ‘geologically’ suitable. When assessed against realistic criteria, this number reduced to 12 possible sites for further consideration. This number in turn was reduced to 8 ‘approved’ sites, and the report also identified a maximum of 3 further ‘unapproved’ sites. A subsequent report, the Basic Raw Materials Strategy report prepared by consultants in 1985, and the subsequent Basic Raw Materials Policy Statement for the Perth Metropolitan Region (1992) contains a map showing four approved granite quarries on the Darling Scarp, and three unapproved sites (at Walyunga, Byford, Serpentine) (Landvision, 1996). In the 12 years since 1992 the constraints on ‘conflicting’ land uses have become greater and the statutory approvals process much more demanding and restrictive. The general view of planners is that the quarries now in operation would be unlikely to gain approval under current circumstances, and that it is highly unlikely that any new quarry will be approved in the vicinity of the Darling Scarp.
As pointed out in response to another submission, the practical challenges in securing viable and ‘least constrained’ opportunities for basic raw material extraction operations are the reason the state government commissioned the basic raw materials studies and has set in place the Statement of Planning Policy No. 10 (Basic Raw Materials). However, it is also true that for the most part the identification of priority resource locations and key extraction areas in the current policy are based largely on existing extractive industry operations. The policy does not give significant guidance to the industry on new extraction sites, because it is not possible or practical to do so.
This response goes to some effort to explain the very challenging task of finding new hard rock quarry sites in the Perth Metropolitan Region, and why the assertion that there are many alternative locations available is not correct. Rather, the opposite is true.
Public Submission 17 stated that a site on Great Northern Highway where the proponent would only need to cut into rockface and wouldn’t have to clear bush would be suitable. The LAG submission stated that the best option for quarry relocation is the Burgess Road, Gidgegannup site, as all infrastructure is already present and that Toodyay Road is a Red-class road and will accommodate BGC’s trucks.
In response to the first point, as with other responses given on submissions concerning possible alternative locations for hardrock quarries, the proponent is not aware of any such opportunity on the Great Northern Highway that has suitable geotechnical characteristics and is sufficiently free of all other constraints, and in close enough proximity to the market, such that it would prove to be either an obtainable or viable quarry option.
The second point makes a strong claim that the Burgess Road location at Gidgegannup is a ‘best option’.
While it is true that this location is identified as either a Priority Resource Location, Extraction Area or Key Extraction Area in the Statement of Planning Policy No. 10, these designations are principally for clay resources and gravel resources. The rock resource designation is confined to existing quarry operations only. Nevertheless, it is worth considering the various reasons why any prospect of an additional extractive industry establishing anywhere near Burgess Road, or for that matter anywhere in
SECTION 2Response to Submissions on the Project Justification
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the Darling Scarp areas of the City of Swan, are virtually nil. The main reasons why an additional extractive industry could not establish in the City of Swan are:
1. There is currently a major legal action underway against the Pioneer Quarry operations in this location, due to an alleged serious breach of environmental conditions. This controversy has had a major impact on the attitudes of residents of the City of Swan towards extractive industry.
2. The Swan Valley, foothills and hills communities of the City of Swan are very active in addressing a wide range of sensitive land use change issues in the area. This has led the City of Swan council to be very risk adverse in their response to contentious or potentially conflicting land use developments of any kind.
3. Despite the existence of current extractive industry operations, the entire portion of the Darling Scarp between John Forrest National Park and Walyunga National Park was recommended by the Metropolitan Region Planning Authority (MRPA) as far back as 1977 to be included in a ‘landscape protection zone’ (MRPA Submission to the System 6 Study). The City of Swan’s current Gidgegannup Rural Strategy shows that while the area south of Gidgegannup Road is identified as a ‘resource’ strategy precinct, and hence conforming with the Western Australia Planning Commission (WAPC) Statement of Planning Policy No. 10 designation (for clay, not hard rock), the land portions to the east and west are identified as ‘landscape’ strategy precincts. This reflects a long standing recognition of the high landscape, environmental and amenity values first emphasised by the MRPA. The area north of Burgess Road is an extensive area identified as an ‘agriculture’ strategy precinct, which emphasises retention of agricultural land use opportunities, rural pursuits, environmental and scenic values.
4. The City of Swan has a proposal well advanced for an Eastern Hills Settlement Pattern Plan, which extends over the area on either side of Burgess Road. This proposal is for a sizeable ‘hills living zone’ of low density residential living, based on an innovative concept of rural settlements. This planning approach is understood to be strongly supported by the local community. It is completely counter and conflicting with any notion of expanding extractive industry in this general locality.
5. Burgess Road itself, whilst supporting very high landscape values to the north and south, is also far more densely populated than the Voyager Quarry locality on the Great Southern Highway. On the north side of Burgess Road there are at least 10 existing residents with a further three absentee residents/weekender residents. To the south of Burgess Road there are seven residents and a further two seasonal/weekender residents. Therefore a total of 22 residents/landowners are located in very close proximity to any intended extractive industry, the majority of whom are active participants in the City of Swan’s initiatives to promote the Eastern Hills Settlement plan. Direct consultation with planning officers of the City of Swan and the Community Advisory Council Member to the City of Swan for the West Gidgegannup Area, strongly reinforce that any suggestion of further extractive industry in the area would receive no support whatsoever, and would be strongly opposed by both Council and the community.
6. The reference to Toodyay Road as a Red-class highway does not greatly advance the case for further extractive industry in this locality. While the freight transport designation is correct, the Toodyay
SECTION 2Response to Submissions on the Project Justification
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Road in the vicinity of Red Hill and the scarp face is still considered too narrow and too steep, with no overtaking possible and no ‘arrestor beds’. Added to which, while BGC freight haulage from the Voyager Quarry currently relies on a fleet of 14.5 tonne six wheelers, 15 tonne eight wheelers, 40 tonne eight wheelers plus ‘dog’ and 25 tonne semi-trailers all of which can use a Red-class highway, the 50 tonne road trains are not permitted. It should be noted that BGC’s fleet of trucks for any operation would be close to 60 trucks, which is far more than Pioneer’s fleet (thought to be between 15 and 20 trucks, at most). On a much lower traffic flow road, this would represent a major change in traffic conditions and impacts. By contrast the BGC trucking movements on Great Eastern Highway are already accommodated, and in a much higher traffic flow environment.
7. The limitations of Red Hill and Toodyay Road, including an extremely difficult and dangerous intersection with O’Brien Road (connecting Burgess Road with Toodyay Road) that would almost certainly require major re-alignment and road engineering, are far from ideal from any operator’s point of view, or in terms of community safety.
8. The prospects of a major road upgrade in the form of the proposed Perth to Adelaide National Highway (formerly known as the Eastern Corridor Major Road By-pass, or ‘orange route’) is still at least a decade or more away.
Given the above, it is clear that Burgess Road, Gidgegannup is not a suitable site for the extraction of granite.
Public Submission 11 suggested that the proposed quarry would be best suited to the arid inland areas of the North West and presented arguments for the relocation of the quarry to this region, such as “not near civilisation, noise abatement not a problem, very few fauna or flora disturbances, infrastructure (rail, roads, ships) already developed, adequate groundwater supplies, dust suppression not necessary and unlimited gravel reserves”. Public Submission 9 also stated that the scale of the operation should be in the Pilbara.
There may be resources in the arid inland areas of the North West, however the metropolitan market requires hard rock resources. As the crushed rock market that the Voyager Quarry is targeting is located within the metropolitan area, relocating the quarry to the North West is not economically viable. This is due to the fact that the value of the product is not high enough to cover the costs of transportation.
Public Submission 15 stated that the only real solution to the relocation of the Voyager Quarry is for BGC to look for another location.
The point raised in this submission is covered at length by the responses provided earlier to largely similar issues expressed in other submissions. In summary, the Voyager Quarry is probably one of the best, low impact hard rock quarry extractive industry sites in or near the Perth Metropolitan Region, and by far the best from a strategic metropolitan region planning point of view. Indeed the worst feature of the location is that it is at so great a distance from the market and BGC’s major distribution point in Midland, and hence involves a significant transport cost penalty. To force extractive industry any further away from the Perth market will be uneconomic for operators.
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Further, we reiterate the previous argument that from a strategic planning point of view, and in the interests of effective resource use, expansion of an existing quarry to achieve efficient use of a proven resource in the same location, makes planning sense and will logically minimize overall potential impacts associated with extractive industry operations.
The CCI submission stated that there are two problems with suggestions that the quarry be relocated to areas further away from residences. These are:
that you cannot select where to site a quarry because quarries occur where the resource exists; andthat the cost of transport can be huge, especially for a commodity such as granite.
The Proponent agrees with this statement.
It was stated by the CCI submission that every extra kilometre that the product has to be transported adds a significant cost burden and if granite quarries are sited too far away, this would have a drastic effect on the price of virtually every type of building constructed in Perth as well as the cost of roads and infrastructure.
This submission supports information presented in the PER, where it is stated in Section 2.1.1 of the PER (Volume 2), that BGC carries a substantial cost penalty per tonne when compared with competitors’ quarries in the metropolitan area. The relocation of the quarry further from the Perth metropolitan area, would adversely affect the cost of hard rock to the market.
The LAG submission asked why different criteria were used for Table 2.1 (Review of Regional Site Options) and Table 2.2 (Review of Local Options), and stated that the results presented in Table 2.1 were questionable. The submission suggested that the greatest ‘weighting’ factor in the project’s location is low cost of establishment, as BGC had purchased the land prior to development approval. Public Submission 1 asked whether the review of local options was carried out before or after the December 2001 land clearing. This submission also asked whether the greatest influencing factor for BGC is its ownership of the site, as this is not mentioned in the table.
Different criteria were used for Tables 2.1 and 2.2 for very good reasons, and that is because they reflect two different stages of a site selection planning process. The two stages of a generic site selection process are first a ‘coarse’ assessment of regional level criteria, and second a more detailed examination of the site specific criteria of the locations identified as feasible in the first stage.
The term ‘coarse assessment’ refers to the focus on key regional level criteria that must be met if it is worth pursuing further site level considerations. Criteria at this level include those listed on the horizontal axis of Table 2.1. Some of these are fatal flaw constraint criteria. For example, potentially viable locations must be within a threshold transport distance from the market or distribution points to the market, there must be a reasonable likelihood in obtaining statutory approvals, and there must not be highly contentious land use conflicts. The latter includes, very close proximity to expanding residential populations, locations involving prominent landscapes of regional significance, very close proximity to regional parks or national parks, localities with dense and changing land use patterns with
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correspondingly complex strategic planning frameworks and town planning scheme development control restrictions.
While BGC went to considerable effort over an extended period to evaluate the various alternative sites in Table 2.1, all have severe constraints.
In summary, the Copley Road option is very close to both Walyunga National Park and the upper Swan River, in a very high scenic recreational zone, in very close proximity to prestigious rural residential developments. It is also very close to the scarp face and contained within a landscape protection zone. Pearce Farm, Bullsbrook is similarly located very close to the scarp face, and generally within an area of high amenity and rapidly expanding ‘rural living’ and special rural subdivisions. Hardinge Road is, in effect, on the scarp face, and very close indeed to the Bickley reservoir. The entire area is a regionally significant recreation resource, reserve for parks and recreation in the metropolitan region scheme, and Hardinge Road is the sole access into and through this location. Waterway Farm Bedfordale is similarly very near to the scarp face, in a very high amenity zone with dense rural living, and extensive areas in parks and recreation reserves in the metropolitan region scheme. Both Kiln Road (Cardup) and Shale Road (Whitby) are located on or very close to the scarp face, and are located a great distance from the market. Finally, the Burgess Road location has been dealt with in depth, above. In summary, there is virtually no prospect whatever of gaining statutory approval for an additional quarry in these general locations.
Table 2.2, as explained above, summarises a range of site specific factors considered at the Toodyay Road site. It is reiterated that the options to expand north, east and south are all far more problematic than the westerly option. Also, as previously mentioned, BGC was unable to negotiate acceptable terms with the landowner to pursue these three alternatives despite best efforts to do so.
Public Submission 1 asked for data from site-specific geological surveys to support the comments made on page 14 of the PER (Volume 2) that sites to the north and east of the existing quarry are not suitable for quarrying as the bedrock dips away. The Wildflower Society submission stated that it understood that the proposed quarry could have been sited to the east of its proposed location and that this would have avoided the clearing of good quality native vegetation. The submission asked for an explanation for this.
The Proponent would like to clarify that the PER does not state that the granite resource dips to the east. However, it was stated in Section 2.1.2 of the PER (Volume 2) that the granite reserve dips to the north making it uneconomical to extract due to a large amount of overburden material. The results from the borehole drilling conducted for the groundwater study in May 2004 confirms that the granite dips to the north. The bore completion report for BGCM2, which is north-northeast of the existing quarry pit, shows that the fresh granite is at a depth of 33 m below ground level (Volume 2; Appendix B). The overburden layer is thick at this location compared to the northeastern section of the proposed quarry pit area, as a borehole known as BGC1 (drilled in March 2002), showed that the fresh granite was only 13.5 m below ground surface.
There were many constraints for the option to site the quarry to the east and these were presented in Section 2.1.2 of the PER (Volume 2). One of the main constraints in siting the quarry to the east is that
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the owner of the Voyager Farm is reluctant to allow further development of the quarry on the farm. In order to site the quarry to the east, the primary and tertiary crushers, stockpiles and infrastructure would need to be moved. As the owner of the Voyager Farm does not want to relinquish any additional land for the quarry operations and the structure of the existing pit does not allow for the establishment of the plant within the pit, there is no site available for relocated infrastructure. There would also be a significant cost involved in moving the infrastructure and stockpiles which are situated to the east of the existing pit. Therefore, relocating the quarry to the east of the existing site is not a viable option due to the logistical difficulties and the high costs associated with this option.
Public Submission 2 queried which of the following statements from page 11 and 17 (respectively) of the PER (Volume 2) were true: that BGC ‘currently carries a substantial cost penalty per tonne’ and ‘maintenance of low cost supplies of hard rock to the metropolitan market.’
Both statements from the PER are true, as the Voyager Quarry is located just outside of the Perth metropolitan area and carries a cost penalty per tonne when compared to other quarry operations located within the metropolitan area. As every extra kilometre that the hard rock needs to be transported adds a cost burden, siting the quarry further from the metropolitan market would increase the cost of the product. Therefore, relocating the quarry to Lot 14 Horton Road would ensure that the cost of the quarried product does not rise significantly, as the proposed site is easily accessible and relatively close to the metropolitan area. This is a very important consideration as far as the market is concerned.
2.2 Project Need
Public Submission 2 stated that the quarry should be moving further from the metropolitan area, not closer to a residential subdivision. The AVES submission stated that there are huge reserves of granite in WA and that it is unlikely that none of these are on already cleared land and a suitable distance from the metropolitan area. In relation to Section 2.2, where it reports that if the Toodyay and Voyager quarries ceased to operate, there would only be enough resources for less than ten years, Public Submissions 1, 2, 4 and 15 stated that granite resources are abundant in near-urban areas and that if the proposed quarry relocation did not occur, then the existing quarries could easily cope with the extra demand or that quarry development would occur elsewhere if sufficient consumer demand exists.
Hard rock resources are abundant, but the reserves are greatly limited by economic factors, environmental factors and pressure from competing land uses. Therefore, although granite resources are located in near-urban areas, there are other factors that constrain the location and site establishment of hard rock quarries.
Existing quarries already cater for their share of the market and would not be able to cope with the extra demand within the current hours of operation and existing licence conditions, should the Voyager Quarry cease to exist.
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The LAG submission, Public Submission 4 and Public Submission 5 referred to statements in the PER that Lot 14 has not been designated a Key Extraction Area by the Basic Raw Materials Planning Policy Statement. Public Submission 5 stated that only Lot 7 is to be used as a key extraction area. The WBLCDC submission also asked for this to be checked with the Shire of Northam.
The town planning and land use control context of the site in question is complex and certainly not clear. Nevertheless the basic assertion that only Lot 7 ‘is to be used as a key extraction area’ is not correct. Firstly, the subject site of the BGC proposal is zoned ‘Rural 3’ under Town Planning Scheme (TPS) No 2 of the Shire of Northam. Within the Rural 3 Zone (TPS2), ‘Industry-Extractive’ is an ‘AA’ use, which means it is not permitted unless Planning Approval is granted by Council. Secondly, the site also falls within the Eastern Slopes Planning Precinct of the Local Rural Strategy (1999). Basic raw material extraction is identified as a conditional land use in this Precinct. Intensive stock yards and urban uses are identified as the only undesirable uses in this Precinct. Thirdly, in the subsequent Draft TPS3 (circa October 2002) Lot 14 will be in an Agricultural Local zone. It is proposed that for this zone Extractive Industry will be an ‘A’ use which means it is not permitted except by Council exercising discretionary approval. Hence, at the very least there is provision for extractive industry to be approved by the local authority in a Rural Zone.
In reference to the provisions of the Basic Raw Materials Planning Policy (SPP10), the Shire of Northam is one of six local authorities outside the Perth Metropolitan Region to which the Policy applies. An important point, previously mentioned above, is that the SPP10 Key Extraction Areas principally identify only existing hard rock quarry sites as a matter of practicality and not future possible resources and quarry sites. However, the policy specifically states (for sound practical reasons) that it does not preclude development of a quarry outside identified Key Extraction Areas, and consultation with the Department for Planning and Infrastructure (DPI) has confirmed that this provision is intended to cover the need for the logical expansion of an existing quarry operation into adjacent land areas, where appropriate. Further, the policy also states (paragraph 6.2.1 of SPP10) that “Proposals in local town planning schemes, to prohibit extractive industries in zones that permit broad rural land uses, will not be supported without adequate justification.”
In addition, while the SPP10 generally does not basic raw materials in ownership other than of a known extractive industry company for protection, it should be noted that BGC purchased the subject site some six months after the SPP10 was gazetted in July 2000. It is therefore a reasonable assumption that in forthcoming reviews of the SPP10, the subject site would be identified as a resource worthy of protection, given the available resource, ownership and intentions of the owner. The DPI would also take into account the fact that the subject site is not identified as an area of environmental significance in the local TPS.
The CCI submission stated, “The hard rock resources at the Voyager Quarry are identified in State Planning Policy No. 10. This is in line with their strategic importance”.
The State Planning Policy No. 10 states that the availability of basic raw material resources that are located close to the metropolitan area is declining as the city expands. Therefore, the policy identifies the
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areas that are recognised regional resources providing for the long term supply of basic raw materials, which should be protected in town planning schemes.
The resources at the existing Voyager Quarry are nearing depletion and the granite resources located within Lot 14 Horton Road are an extension of those identified in the State Planning Policy No. 10. Therefore, these resources should be considered of strategic importance within the State Planning Policy No. 10.
2.3 Project Benefits
2.3.1 Environmental and Social Benefits
The Conservation Council submission stated that the proponent had failed to demonstrate any potential environmental benefits that could arise through the proposal proceeding and to make any commitments that could off-set environmental loss. The submission requested that the proponent demonstrate where the proposal directly relates to the protection, enhancement and management of the environment. Public Submission 2 stated that revegetation projects have been going on in this area for years and asked what BGC had contributed to these projects.
The major benefit to be gained from the proposal proceeding is the maintenance of supplies of a strategically and commercially important resource to some 40% of the building industry market in Perth at competitive prices. BGC accepts that its previous offsets strategy presented in the PER was undefined and therefore difficult to judge and, as it turned out, to implement. However, as indicated earlier, BGC has now proposed a new offsets package which has the support of local authorities and does generate “net benefit” to the local environment through a package of covenanting for conservation purposes some 120 ha of uncleared bushland owned by BGC (Lot 11 and some of Lot 14), rehabilitating approximately 60 ha of degraded Crown land, and fencing to protect some 100-150 ha of remnant bush from grazing in the Wooroloo Brook catchment.
Other environmental benefits arising from the project include:
The protection in perpetuity of a community of Priority Flora (Hemigenia viscida) on Lot 14 including a 50m buffer around this plant community, a population of trapdoor spiders, and three species of land snail; and
Contribution to increased knowledge on the distribution of trapdoor spiders and land snails on the Darling Scarp.
Public Submission 1 stated that the social benefits listed in Section 2.3 of the PER (Volume 2) relating to the supply of material for the building industry are insignificant as the demand for hard rock supplies would be met by another quarry.
There is no guarantee that the demand for hard rock supplies would necessarily be met by other quarries should the Voyager Quarry cease to operate, as quarries operate under licences issued by the DoE. These
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licences govern the conditions under which the quarry can operate, and approvals to expand the operations to meet the demand would need to be obtained. Given that most existing quarries occur within the metropolitan area, expansion operations resulting in increased truck movements and possibly extended operating hours, would be difficult.
Public Submission 4 and the LAG submission stated that the presence of the existing quarry had not benefited the local community and Public Submission 5 stated that the Lakes Roadhouse is the only local business that benefits from BGC. Public Submission 1, Public Submission 2 and the WBLCDC submission asked which community projects and groups had received support from BGC, when this had occurred and to what value.
As stated in Section 2.3.1 of the PER (Volume 2), BGC has contributed to the local community through the following ways:
funding for community projects;
financial support for community sporting clubs; and
sponsorship of local recreation facilities.
BGC personnel also provide business to the Lakes Roadhouse.
BGC’s Chief Executive Officer, Len Buckeridge, was the national winner of Master Entrepreneur in 2003. In an article presented on Page 23 of The Winning Touch magazine (2003), it was identified that Mr Buckeridge is “an active and significant philanthropist whose support is largely unknown and who does not seek recognition”. Therefore, BGC does not wish to disclose the names of the community projects and groups that it has supported in the past.
Public Submission 2 commented that the employment of people is a social benefit but this submission (along with Public Submissions 4 and 15) stated that jobs would not be lost if the quarry moved to another site.
As indicated in a previous response, there are no other sites available close to the metropolitan area where the market is located. If the Voyager Quarry moved to another site that was further away from the market, its costs of transporting the product would increase thereby reducing its ability to compete in the market place. An uncompetitive quarry may be forced to close and in this situation, personnel would lose their jobs.
2.3.2 State Benefits
The AVES submission and Public Submission 2 commented that statements in Section 2.1.1 of the PER (Volume 2) regarding BGC carrying a substantial cost penalty per tonne contradicted statements in Section 2.3.2 that one of the benefits of the relocation will be the maintenance of low cost supplies of hard rock, as the proposed quarry site is easily accessible and relatively close to the metropolitan area.
Both statements are accurate and do not necessarily contradict one another.
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The statement in Section 2.1.1 of the PER (Volume 2), which states that BGC carries a cost penalty per tonne when compared to other quarry operations located within the metropolitan area, is based on the fact that the Voyager Quarry is located outside the metropolitan area. Hence, the cost for transporting the hard rock to market is more than for other quarry operations that are located within the metropolitan area. Relocating the Voyager Quarry to the adjacent Lot 14 Horton Road will ensure the maintenance of low cost supplies of hard rock to the market.
The LAG submission and Public Submission 4 referred to a statement on Page ES-16 (PER Volume 1), which said that one of the consequences of not proceeding with the proposal was an expansion of quarry operations on the Darling Scarp. These submissions stated that this is not an issue as the quarries on the scarp have excellent rehabilitation programmes.
The Proponent disputes that quarrying on the Darling Scarp is not an issue. Hard rock quarries on the Darling Scarp are highly visible from the coastal plain. The visual impact of the excavation site is a recognised primary concern to the community, as recent media reports testify. The rehabilitation of quarried faces on the Darling Scarp with native vegetation is an expensive activity which has been enforced on these operations.
The AVES submission referred to Section 2.3.2 of the PER (Volume 2) where it was stated that the Project would bring in revenue for the local and State governments and asked for further information about how much is paid and to whom. Public Submission 2 asked what financial benefits the Shire of Northam obtained from the quarry, besides rates and licence fees. Public Submissions 4 and 7 stated that approximately $150 is given to Northam Shire per annum.
The Project would bring in revenue for the local, State and Commonwealth governments in the following ways:
Shire of Northam extractive industries licence fees; Shire of Northam rates; DoE licence fees; DPI truck registration fees; and Payroll taxes.
For reasons of commercial confidence, the Proponent cannot disclose the exact amounts of these fees. However, Table 1 provides an indication of the ranges of fees received for the Project.
Table 1 Ranges of Fees Received for the Project
Type of Fee Recipient of the Fee Approximate Amount or Range Extractive Industries Licence Shire of Northam $150/year
Shire Rates Shire of Northam $1,000 - $2,000
DoE Licence Fees DoE $4,000 - $5,000
Truck Registration Fees DPI Tens of thousands of dollars
Payroll Taxes State and Commonwealth Governments Tens of thousands of dollars
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Other than rates and licence fees, the Shire of Northam does not receive any other financial payments from BGC.
The WBLCDC submission asked whether royalties are paid for hard rock. Public Submission 1 asked to whom the royalties are paid, how much is paid per tonne and whether the royalties paid by BGC are voluntary. The LAG submission, Public Submission 4 and Public Submission 7 stated that BGC does not pay royalties to the State. Public Submission 7 stated that the landowners get royalties, and the DoE gets a flat fee and a percentage of the tonnage.
As the existing quarry is located on privately owned land, royalties are paid to the landowner of Lot 7 Great Southern Highway for the hard rock extracted from the existing quarry pit. The amount of royalties paid for the hard rock has been negotiated between BGC and the landowner and BGC cannot disclose the amount of royalties due to commercial confidence. The royalties are voluntarily paid by BGC.
BGC can confirm that it does not currently pay royalties to the State for the hard rock extracted from the existing quarry, nor does the DoE get a flat fee or a percentage of the tonnage.
2.4 Consequences of Not Proceeding
Public Submission 4 stated that BGC was overstating its importance by claiming that the existing quarry provided 35-40% of the crushed rock required by the building and construction industries in the Perth area, and that the author(s) of this submission had calculated BGC’s market share to be less than 25% unless the quarry’s throughput is twice the amount stipulated on the site’s licence. This statement was also made in the LAG submission.
BGC’s previous DoE licence (Licence No. 5356/6) set a nominal rated throughput of 900,000 tpa. The current licence (Licence No. 5356/8) states the nominal rated throughput as 1,200,000 tpa.
BGC provides approximately 80,000-100,000 tonnes of crushed rock per month, which is a conservative estimate. BGC could supply 10-15% more than this amount if market demand were higher. It is estimated by BGC that the outputs of the other three major hard rock quarries ranges from 60,000 to 70,000 tonnes per month. Based on these estimates, BGC contribute at least 34% of crushed rock to the building and construction industries in the Perth metropolitan area, and according to the Chamber of Commerce and Industry (refer next submission) BGC contributes up to 40%.
The CCI submission stated that the Voyager Quarry currently supplies granite which meets 40% of the crushed rock required by the building and construction industry in the Perth metropolitan region and surrounding areas. The submission also stated that granite is an essential commodity used for road base, concrete and other building materials, that Perth relies heavily on granite and that every effort should be made to ensure that a ready, reliable and economical source of granite is available well into the future. In addition, the submission stated that when securing sources of supply for an essential commodity such as granite, companies should not need to have to mount a special case to support an extractive facility.
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The Proponent agrees with and endorses this submission. It is through BGC’s involvement in the crushed rock industry that prices for building materials are competitive, and this allows affordable housing for the Perth community.
The Wildflower Society (Eastern Hills Branch) submission stated that the proposal needs to be fully subjected to triple bottom line accounting in which economic, environmental and social costs and benefits are given equal weighting.
Triple bottom line accounting is not a requirement of the Environmental Impact Assessment (EIA) (Part IV Division 1) Administrative Procedures 2002. In fact, the Environmental Protection Act 1986specifically constrains the EPA to addressing only environmental, social and pollution prevention issues, and precludes the assessment of economic costs and benefits.
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3 Response to Submissions on the Project Description
3.1 Overview
Public Submission 6 asked why the project is called an Expanded Project when there is no increase in the rate of extraction or water consumption.
As stated in the PER (Volume 1), the proposal is to relocate the Voyager Quarry onto land adjacent to its present location. This is necessary because the hard rock resource that is economically available at the current quarry is running out and will be depleted within five years. In order to maintain an uninterrupted supply of rock to the market, BGC needs to start developing the new quarry before the current quarry is depleted. Therefore, over the next five years, the area of quarry operations will expand as the new quarry is developed – principally by the gradual removal and stockpiling of overburden. Once the new quarry has been developed to the extent that it can operate in its own right, all operations at the current quarry will cease and be relocated to the new quarry.
Hence, the proposal is a relocation project, which for a short time will require increased activity of the existing quarry. However, this increased activity will not increase the rate of rock extraction and supply to the market. The rate of water consumption would be increased during the five year transition period, as water will be required for dust control on the new quarry as well as the existing quarry. Once operations relocate fully to the new quarry, water consumption will reduce back to current levels.
Public Submission 1 asked why BGC didn’t keep digging in a westerly direction from the existing site so that the existing quarry joined the proposed quarry.
There are no plans for BGC to keep digging in a westerly direction from the existing quarry to join the proposed quarry, because the quarries are located on two separate properties. The existing quarry is located on land owned by A.M.B. Holdings Pty Ltd and the proposed quarry is located on land owned by BGC (Australia) Pty Ltd. Under the existing Shire of Northam Extractive Industries By-laws, Clause 2 (b) indicates that the quarry cannot be within 50 m from any boundary of the property unless a special approval is received. Clause 2 (b) of the by-laws states:
“A licence mentioned in sub by-law (1) of this by-law is not required where the proposed creation, or enlargement, of an excavation is: (i) except where the operation is on a commercial basis, for the recovery of any materials for the purpose of road construction or maintenance; (ii) of a volume not greater than 3,000 m3 inclusive of all adjacent excavations which have not been rehabilitated; and (iii) not less than 50 m distant from any boundary of the property or from any public road”.
A discussion with one of the officers from the Shire of Northam confirmed that this clause means that BGC cannot develop the quarry beyond 50 m from the western boundary without approval from the shire.
Public Submission 6 asked if the quarry relocation was necessary because the resource is ending or because the owner of the Voyager Farm did not want to renew the lease.
The quarry relocation is primarily necessary as the existing quarry only contains sufficient economically winnable resources to operate for another five years. The current landowner’s reluctance to allow further development of the quarry on his land is a secondary consideration.
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Public Submission 2 referred to the Executive Summary and asked what is meant by the statement “to minimise the potential for off site noise, dust and light emissions”?
The Proponent is committed to ensuring that the proposed operations at the new quarry do not reduce the amenity of the surrounding residents. The key strategy to minimising the impacts of noise, dust and light emissions is to locate the crushing plant at a depth of approximately 30 m within the proposed quarry pit.
Proposed Rate of Extraction
Public Submission 4, the LAG submission, the AVES submission and the WBLCDC submission stated that for the existing quarry there were discrepancies between the stated daily and annual rates of granite extraction, and between these rates and the quarry’s licensed throughput.
It was stated in Section 3.1 of the PER (Volume 2) that the daily rate of throughput is 6,000-10,000 tonnes/day. BGC has advised that these values are not correct. They represent the maximum daily throughput possible when demand for hard rock is high. A daily throughput of between 3,000-4,000 tonnes/day is a more reliable estimate of normal demand.
Table 2 presents the annual truck loading data for the last three years. This data was obtained from the weighbridge electronic records.
Table 2 Amount of Hard Rock Produced from the Existing Voyager Quarry
Year Amount of Hard Rock (tonnes/annum) 2001 958,550 2002 1,212,345 2003 1,118,923
Based on the above truck-loading data, the average annual throughput for the last three years was 1.1 million tonnes. Previously, BGC had advised the DoE prior to the annual throughput exceeding the value stated in the DoE licence.
BGC’s current DoE licence (Licence No. 5356/8) issued on 27 September 2004 has a nominal rated throughput of 1.2 million tonnes. The licence states that “any increase greater than 10 per cent above the nominal rated throughputs shall not occur unless the licensee has been granted prior approval in accordance with the Environmental Protection Act 1986”.
Proposed Depth of the Pit
The LAG submission stated that it was unclear whether the proposed pit will have a depth of 50 m from above the 10-metre overburden or below it (thereby increasing the depth). The submission also asked whether the floor of the proposed pit would be parallel with the slope or level.
The depth of the proposed pit would be 50 m below the lowest point in the natural ground surface, and this depth includes the overburden layer, which consists of gravel and clay. The floor of the proposed pit
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would be level. However, the land surface increases in elevation to the west and, as such, the western boundary of the pit would be in excess of 75 m deep.
Public Submission 2 queried the proposed depth of the pit being only 50 m when the first 30 m are clay and gravel.
As stated in Section 3.2.1 of the PER (Volume 2), the gravel layer is 1 m thick and clay layer is 10-20 m. Therefore, the maximum thickness of the overburden layer in some areas of the pit is 21 m, but the average thickness of the overburden is 11 m. The proposed depth of the pit is 50 m below the lowest point in the natural ground surface.
The AVES and WBLCDC submissions questioned the lifespan of the proposed quarry, based on the footprint and depth of the existing quarry. Public Submission 5 stated that if current production rates are maintained, then the new pit will be mined out in less than 40 years.
Based on the footprint presented on Figure 1.2 of the PER, the lifespan would have been approximately 44 years based on the current rates of production (1.1 million tonnes/annum). The calculation below provides an explanation of this estimate:
Amount of hard rock = Area of pit x Depth of pit x Density of rock
Where: Area of pit (excluding the area allocated for the location of the processing plant) = 480,000 m2
Depth of pit (excluding the overburden layer or 11 m) = 39 m
Density of the hard rock = 2.6 tonnes/m3
Amount of hard rock = 480,000 x 39 x 2.6 = 48.7 million tonnes
Therefore, Lifespan = 48.7 million tonnes / 1.1 million tonnes/year = 44 years
The diagrams in the PER did not show the full 85 ha of clearing, so BGC has extended the southern edge of the pit so that the total area of clearing for the Project equates to approximately 85 ha. The areas outlined in red on Figure 2 of this document are the areas that will be cleared for the Project. The total area of clearing includes the infrastructure and product stockpile area at the southern end of the proposed pit, the pit and the topsoil stockpiles to the west. The areas allocated for these components of the Project have been calculated by computer mapping software and are listed as follows:
Quarry pit = 58.88 ha;
Infrastructure and product stockpile area within the quarry pit = 24.89 ha; and
Topsoil stockpiles = 1.08 ha.
Therefore, the revised lifespan of the quarry will be 54 years based on the production rate of 1.1 million tonnes/annum. The basis for this estimate is presented in the calculation below.
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Amount of hard rock = Area of pit x Depth of pit x Density of rock
Where: Area of pit (excluding the area allocated for the location of the processing plant) = 588,790 m2
Depth of pit (excluding the overburden layer or 11 m) = 39 m
Density of the hard rock = 2.6 tonnes/m3
Amount of hard rock = 588,790 x 39 x 2.6 = 59.7 million tonnes
Therefore, Lifespan = 59.7 million tonnes / 1.1 million tonnes/year = 54 years
The AVES submission queried the similarity between the existing and proposed rates of extraction given the halving of the blasting frequency (down from weekly to fortnightly) combined with the reduced operating hours of the primary crusher (from the current 21 to 15 hours).
The blasting practices at the existing quarry have recently been reviewed by Orica, who is considered by the DoIR, to be a specialist in the field of blasting management. Blasting occurs on a weekly basis at the existing quarry. Orica will be involved in the blasting management for the proposed quarry and will advise BGC on the frequency of blasting required to maintain rates of production while minimising the impact of ground vibration and airblast. The primary crusher for the proposed quarry will also be much larger than the existing primary crusher and will therefore be capable of achieving the same production rates in a reduced amount of time.
3.2 Construction
Public Submission 4, the WRC submission and the Shire of Mundaring submission requested clarification on the proposed footprint of disturbance as the area of land identified for clearing on Figure 1.3 of the PER equated to approximately 70 ha and the PER stated that 85 ha would be cleared. The LAG submission stated that, based on its calculations, significantly more area would be required for clearing than the 85 ha stated in the PER. Public Submission 2 and the AVES submission asked whether the 85 ha proposed for clearing at the proposed quarry site included land already cleared. The AVES submission also asked whether the area to be cleared for the topsoil stockpiles was included in the 85 ha proposed for clearing.
The areas to be cleared, including the area for the topsoil stockpiles, that were shown on the figures in the PER only equated to approximately 70 ha. The reason why 85 ha was stated was that there was an area set aside as a contingency for the stockpiling of gravel and clay. This area was not shown on the figures because it was not known whether it would be necessary to stockpile gravel or clay on-site. BGC has now decided that all gravel extracted from the pit will be removed off-site and used in the manufacture of various products including asphalt, blocks and bricks. Approximately 20 million tonnes of clay will be extracted from the pit and this material will also be sold as product. There are no plans to stockpile gravel or clay on-site.
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As all studies for the environmental impact assessment were based on the 85 ha of disturbance for the Project, BGC has extended the southern edge of the pit so that the total area of clearing equates to approximately 85 ha. The area outlined in red on Figure 2 of this document represents the footprint boundary that will eventually be cleared for the Project. The total area of clearing includes the infrastructure and product stockpile area at the southern end of the proposed pit, the pit and the topsoil stockpiles to the west (refer to Section 3.1 of this document for the areas allocated for these components).
The area to be cleared includes most of the area cleared in December 2001. This can be seen on Figure 2 of this document, which presents an overlay of the proposed quarry layout onto an aerial photograph of the Project Area taken after the clearing occurred in 2001.
BGC makes a commitment that it will only clear the area defined on Figure 2 of this document for the proposed quarry relocation. BGC cannot comment on the statement by the LAG regarding their calculations that significantly more area would be required for clearing, as the LAG has not produced the calculations. However, based on the calculations provided in Section 3.1 of this document, BGC is confident that the footprint shown on Figure 1 will yield a lifespan of 54 years.
Public Submission 2 asked why the initial licence application to the Shire of Northam requested clearing of 98 ha?
The initial licence application to the Shire of Northam requested clearing of 98 ha, as there was an area set aside for a noise bund, which was located on Lots 11 and 14, Horton Road. However noise modelling conducted for the PER showed that the noise bund was not effective in its original location and size. The site layout for the proposed operations changed during the environmental assessment process, where the site layout was optimised to minimise environmental and social impacts. These improvements included confining all disturbance to Lot 14 and reducing the area required for clearing.
Public Submissions 2 and 5 asked why 85 ha needed to be cleared for the proposed quarry when the infrastructure is being placed in the quarry, whereas the existing quarry footprint is 55 ha and the infrastructure is outside of the quarry. The LAG submission stated that the proposed pit covered almost twice the area of the existing quarry, but the footprint of disturbance for the proposed quarry was only slightly more than one and a half times the size of the existing quarry.
The Project requires that 85 ha be cleared so that it is economically viable, as the Proponent needs to maximise the life of the mine to defray his development costs over time. Although the infrastructure is to be located within the pit for the proposed quarry, the proposed pit is larger than the existing pit, as it will have a much longer life than the existing quarry.
The Shire of Mundaring submission was concerned that the clearing would extend beyond the footprint shown in the PER, resulting in the removal of the vegetation buffer. Public Submission 2 also asked if there was any guarantee that further clearing outside of the designated area would not occur.
BGC are committed to implementing the environmental management plans that have been developed for this Project. The draft Vegetation Management Plan states that the area of disturbance is to be limited to
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that which is essential to the practical operation of the quarry. The Proponent will make an additional commitment that clearing will only be carried out in those areas shown on Figure 1 of this document, which equates to an area of approximately 85 ha.
If the Project is approved, it will be constructed and operated as described and defined in the PER and Response to Submissions. Should the Project be approved, BGC will have to comply with the Ministerial Conditions that are issued, which are likely to include the following condition:
Subject to these conditions, the manner of detailed implementation of the proposal shall conform in substance with that set out in any designs, specifications, plans or other technical material submitted by the proponent to the EPA.
Furthermore, as part of the Offsets Strategy, the Proponent will be placing conservation covenants on the northern section of Lot 14, leaving a 100 m buffer from the pit boundary, and the whole of Lot 11, which will protect these areas from clearing in perpetuity.
The AVES submission and Public Submission 2 stated that the volume of overburden (gravel and clay) appeared to be greater than the volume of granite. Public Submission 2 asked how the removal of 20 m of granite would take 50 years, when the removal of the top 30 m (of gravel and clay) was expected to take five to six years. The AVES submission asked whether the proposed granite quarry was actually a clay or gravel pit. It also asked what guarantees there were that the pit would not grow incrementally.
As stated in Section 3.2.1 of the PER (Volume 2), the total amounts of gravel and clay are expected to be 1-2 Mt and 12 Mt, respectively. Even with the new footprint of the quarry, showing the 85 ha, the amounts of gravel and clay would be the same as the calculations in the PER were based on 85 ha of clearing.
Based on the new footprint, the total amount of hard rock resource present in the proposed quarry pit is estimated to be approximately 59.7 Mt. This is explained in the calculation presented in Section 3.1 of this document. It is expected that the rate of extraction would be approximately 1.1 Mt of hard rock per annum. Based on this rate of extraction, it would take 54 years to extract the hard rock resource.
Clay and gravel are much easier to remove than hard rock and can be removed readily using dozers and scrapers. Therefore, five to six years is a reasonable estimate of the time required to remove the overburden. The quarry will produce clay and gravel, in addition to the hard rock, which are saleable materials. These materials will be sold in response to market demand.
BGC has committed to staying within the confines of the quarry footprint outlined on Figure 1 of this document. Within that footprint, the quarry will be developed in stages as outlined in Figure 3.
Public Submission 2 asked why non-degraded native vegetation would be cleared to stockpile topsoil, and why would it be revegetated.
Topsoil is a valuable resource and would be required for the rehabilitation of disturbances at the existing quarry. As a priority, topsoil would be made available for rehabilitation of off-site areas, particularly for
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the revegetation programme, so that the topsoil can be directly returned to ensure that the viability of the seed bank is maximised. However, should there be a need to stockpile topsoil at the site, the area shown in Figure 1.2 of the PER is set aside for this purpose as a contingency and is included in the 85 ha proposed for clearing.
BGC has also been implementing a seed collection programme for the last two years, where Kimseed Environmental Pty Ltd has been commissioned to collect provenance seed. Seed collection occurred in the following months:
November 2002; December 2002; January2003; February 2003; November 2003; December 2003; January 2004; and February 2004.
To date 53 flora species have been harvested for use in the future rehabilitation programmes or in the revegetation programme.
Public Submission 14 raised concern about the construction activities being conducted for five years in conjunction with the operation of the existing quarry. Public Submission 14 asked for more information about the construction phase, including an assessment of impacts on nearby residents during this time period. The AVES submission requested further information about the noise and dust management that would be implemented whilst waiting for the operation to reach 30 metres below ground. The submission also asked for further information about the fate of the overburden material and how it would be managed.
Clearing and development will be staged as shown in Figure 3 of this document. Construction will only be undertaken at appropriate times to reduce dust emissions and to ensure that noise regulations can be met at the boundary of the residences. Real time wind, noise and visual dust monitoring will be undertaken during the construction period.
The fate of the gravel is that it will be used in the manufacture of various products including asphalt, blocks and bricks. The clay will also be sold as product. There are no plans to stockpile gravel or clay on-site.
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3.3 Operations
3.3.2 Drilling and Blasting
The AVES submission asked for clarification on the proposed drilling method as page ES4 of the Executive Summary (Volume 1) says that conventional drilling will be used, whereas page ES3 says that quieter down hole drilling technology will be used. Public Submission 4 stated that the use of quieter ‘down hole’ drilling technology would be off-set by the quarry’s much closer proximity to the residences.
At the time the PER was written, the Proponent assumed that quieter drilling technology was available. Over the last 12 months, the Proponent has been investigating several different drill rigs to find a rig that has reduced noise emissions. However to date, a drilling rig that has significantly lower noise emissions than conventional drill rigs has not been found.
Public Submission 5 referred to the reduction in the number of blasts from weekly to fortnightly at the existing pit and asked whether the blasts are bigger to enable BGC to maintain the same output of product.
Currently, blasting occurs on a weekly basis at the existing quarry. However, when blasting occurred on a fortnightly basis, there was an increase in the size of the blast to maintain the same output of product.
Public Submission 1 asked whether the frequency of blasting would be increased with the new operation.
Orica will be involved in the management of blasting at the proposed Voyager Quarry and has recommended that to obtain a significant reduction in the airblast and ground vibration emissions, the blasting practices should include:
using SurveyPlus laser control system for the design and markout for the blast; providing drilling plans to the quarry driller; auditing drill holes with boretrack system; designing initiation and loading plans; and blast reporting for evaluation.
By adopting these recommendations, BGC will ensure compliance with the restrictions on blasting, as outlined in the Environmental Protection (Noise) Regulations 1997, which specify that, for blasting carried out between 7am and 6pm on any day not a Sunday or a Public Holiday, the airblast level received on any other premises must not exceed:
125 dB Llinear, peak for any blast; and 120 dB Llinear, peak for nine in any 10 consecutive blasts, regardless of the interval between blasts.
For blasting on Sundays and public holidays between 7am and 6pm the criteria are:
120 dB Llinear, peak for any blast; and 115 dB Llinear, peak for nine in any 10 consecutive blasts, regardless of the interval between blasts.
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3.3.4 Crushing and Screening
Public Submission 5 asked what kind of crushers would be used and how would they be housed, and whether the conveyors would be housed.
The specific details for the new crusher for the proposed operations have not yet been determined, however it would have double to triple the capacity of the existing crusher. The crushers would be housed within a steel-framed building with 3 mm thick corrugated steel sheeting. This structure is similar to the enclosure for the existing primary crusher and has been successful in significantly reducing noise emissions from the crusher.
The conveyors at the proposed quarry would also be housed within a steel-framed structure and corrugated steel sheeting.
Public Submission 2 asked where BGC intends to stockpile the granite dust. The AVES submission asked whether “stockpiles” included bunds and of what material would the bunds consist.
The Proponent would stockpile the granite dust within the proposed quarry pit, in the area allocated for stockpiles [see Figure 1.3 of the PER (Volume 2)]. The term “stockpiles” refers to the storage of resources and products such as:
Topsoil;40 mm ballast – used in the construction of railway foundations; 20 mm – used for the production of concrete and blocks; 14 mm – used for the production of concrete, blocks, asphalt and road sealing; 10 mm – used for the production of concrete, blocks, asphalt and road sealing; 7 mm – used for the production of concrete, blocks, asphalt and road sealing; 5 mm – used for the production of concrete, blocks, asphalt and road sealing; Dust – used for the production of concrete, blocks, asphalt and road sealing; and Roadbase – used in road construction and other foundations.
When the term “stockpiles ” is used within the PER, it does not include bunds. The term “bunds” refers to the earthen embankments that are typically constructed from overburden material (EPA, 1998). Bunds are used for noise attenuation, water diversion and to prevent access to mine pit after abandonment.
3.3.6 Water Usage and Storage
The Conservation Council submission asked for further information about the location of the proposed water storage dam and whether the dam will have an impact on hydrology through its connection to the pit and, possibly, the western stream.
The proposed water storage dam would be located within the proposed pit at a depth of 5 m below ground. Due to the expected nature of the rock at the depth of 5 m, an unlined dam would be expected to leak. However, it would tend to be self-sealing with time and the settlement of clay fines. This self-
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sealing process could be promoted by use of powdered bentonite. Therefore, if the holding dam is designed correctly, it will not have a hydrological connection with the pit or the western stream. In addition, it is in the Proponent’s interest to minimise water loss from the dam.
Public Submission 5 referred to Table ES1 of the Executive Summary (Volume 1) and stated that water usage should increase if the size of the pit increases, yet the table showed that water usage would be kept to the same quantity. This submission also stated that significantly more water should be used for dust suppression as dust is not being adequately contained at the existing quarry.
The relationship between water usage and the size of the quarry pit is not directly proportional. Water from the quarry dam would be used for dust suppression on haul roads and conveyors, stockpile sprinklers and plant wash down. The volume of water required for these activities is dependent on the rate of extraction, and as the rate of extraction for the existing and proposed quarry operations are the same, the water requirements will be the same.
To improve dust management at the existing quarry new machinery with larger carrying capacities has been purchased, thus reducing the number of vehicular movements within the quarry. Details of the types of machinery purchased for the existing quarry are presented in Table 5 of this document. The replacement of new machinery at the existing quarry also included a water truck with a larger water tank. In addition, a new pump and sprinkler system was commissioned in December 2003. The new system has the ability to water stockpiles at short, regular intervals and fill the 45,000 L water truck in 4 minutes compared to more than 20 minutes previously. Due to the reduction in the amount of time required to fill the water truck, the spraying capacity of the water truck for dust suppression has been increased by at least five fold.
Recent inspections by DoIR have elicited many favourable comments, especially in relation to dust control. For example, on 29 January 2004, the Special Inspector for Mines (Ventilation) reported that the dust control for in-pit blasthole drilling, loading and haulage of blasted material, and crushing and screening were “of a high standard” and on 22 September 2004 he reported that “dust control throughout the operations was of a high standard”.
The LAG submission stated that it suspected that the annual requirements of water usage for processing is in excess of 120 million litres and that this excess water is travelling vertically and laterally towards the Wooroloo Brook eastern tributary. The submission also stated that not all process water from stockpiles and transfer points is returned to the holding dam, but that some of it is deliberately channelled into excavated ditches that lead into the eastern tributary of Wooroloo Brook. In addition, the submission stated that the grading of the surface pad does not cause infiltrating water to return to the holding dam.
As stated in Section 3.3.6 of the PER (Volume 2), the average daily water requirements for the existing quarry have been estimated to be 376.6 kL (376,600 L) in summer and 77.4 kL (77,400 L) in winter, which equates to a total annual water usage of approximately 94,250 kL (94.25 million litres). The estimations of average daily water usage calculated by BGC were based on the following:
average number of water cart loads per day;
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average amount of water used by the spray bar;
average amount of time that the stockpile sprinklers are used at a specific pump rate; and
average amount of time that the plant wash down is used at a specific rate.
It is also important to note that BGC differentiated between water usage for winter and summer due to the seasonal variation in water requirement.
Therefore, as BGC has based its water usage calculations on the actual activities undertaken at the existing quarry and the LAG has not provided any breakdowns of the alleged annual water usage of 120 million litres, BGC re-affirms that annual water usage at the existing quarry is approximately 94.25 million litres and refutes the claim made by the LAG.
There is some seepage and runoff water released from the existing quarry to the eastern stream just north of the quarry. The net impact of these releases is to reduce stream flow salinity all year round and increase stream flow in winter. Drainage at the existing site is described in greater detail in Volume 2; Appendix B of this document.
In January 2004, seepage was observed in the stockpile area, downslope of the dam, entering the Eastern Stream. This level of seepage is unusually high and was a result of disturbance to the Quarry Dam wall, below the waterline, incurred during earlier excavation activity. The damage was repaired this summer when the water level in the dam was lower and no visible seepage outflow was recorded at the April 2004 sampling. A seepage collection sump has also been installed in mid-2004 in the northeastern corner of the quarry. Any seepage from the Quarry Dam reaching the northeastern area of the quarry will be intercepted by this sump and pumped back to the Quarry Dam.
3.5 Hours of Operation
Public Submission 4 stated that the hours of operation on Saturdays for the existing quarry is 0700 to 1200, not 0700 to 1300 as indicated in the PER. Public Submissions 2 and 5 stated that the existing quarry was operating outside of the hours of operation stated in the PER.
The record of the hours of operation for Saturdays in Table 3.1 of the PER (Volume 2) is incorrect. BGC previously operated between 0700 to 1200 hrs on Saturday, however the hours of operation at the existing quarry are now:
Quarrying operations: 0800 to 1700 hours Monday to Friday, 0800 to 1200 hours on Saturday;
Primary crusher: 0800 to 2200 hours Monday to Friday, 0800 to 1200 hours on Saturday;
Tertiary crusher and screening plant: 0800 to 0400 hours Monday to Friday, 0800 to 1200 hours on Saturday; and
Sales and Weighbridge: 0600 to 0400 hours Monday to Friday, 0600 to 1200 hours on Saturday.
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Public Submission 2 stated that up till December 2001 the primary crusher operated until 4am, but since then had operated until 10pm. This submission asked where else in and around the metropolitan area is a quarry allowed to work until this time of night, five nights a week. Public Submission 6 asked whether the Proponent had reduced the operating hours for the existing Voyager Quarry voluntarily or after the Shire of Northam changed the licence conditions.
Prior to January 2002, the primary crusher had been operating through to 0400 Monday to Friday. After a meeting with the Shire of Northam, the Proponent voluntarily reduced its hours of operation of the primary crusher to 0700 to 2200 hours. Currently, the operating hours for the primary crusher are 0800 to 2200 hours.
For comparison, the typical operating hours for three other hard rock quarries were obtained as follows:
Pioneer advised that the typical operating hours for its Red Hill Quarry are from 0600 to 1600 hours, Monday to Friday. Sales, involving trucking movements can occur before 0600 hours and continue till around 2000 hours. On some occasions, crushing is conducted on Saturdays.
Boral advised that the typical operating hours for pit quarrying and primary crushing operations at its Maddington Quarry are from 0600 to 1630 hours, Monday to Friday and 0600 to 1430 on Saturday. The tertiary and screening plant operates from 0600 to 1800 hours, Monday to Friday and 0600 to 1430 on Saturday. The sales and weighbridge operates from 0600 to 1700, Monday to Friday and 0600 to 1430 on Saturday.
Readymix Holdings advised that the operating hours for its Gosnells Quarry are 0600 to 1700 hours for quarrying and crushing operations. The hours of operation for weighbridge and sales are 0600 to 1700 hours, Monday to Friday and 0600 to 1200 hours on Saturday. Most of these quarries do not have restrictions on the hours of operation, however the times stated above are the customary hours of operation.
Public Submission 1 asked whether BGC would be providing assurances that their current hours of operation would apply to the proposed quarry. Public Submission 5 asked why the hours of operation for the proposed quarry needed to meet production requirements are not less if the new quarry is supposed to be more efficient.
The hours of operation for the proposed quarry would be the same as those currently employed at the existing quarry. The Proponent will make an additional commitment that they will comply with the hours of operation currently employed at the existing quarry and stated in Section 3.5 of this document.
The hours of operation for the proposed quarry have not been reduced even though the new crusher would have a greater throughput capacity because BGC may be required to increase production to meet higher demand. However, if BGC were able to meet the demand for hard rock within reduced hours of operation, the proposed quarry operations would only operate for as long as required to meet the demand.
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3.7 Environmental Management and Monitoring
3.7.1 Environmental Licensing
Information on the environmental licences held by the existing quarry operations was provided as background information and is not part of the proposal being assessed under the PER. However, a number of submissions raised issues relating to this aspect. These are summarised below.
Public Submission 2 referred to Page ES-2 of the Executive Summary (Volume 1), which stated that the current quarry has operated largely in compliance with licence conditions. The submission asked whether BGC was admitting that it had not been operating within the licence conditions and whether this would be the case for the proposed quarry.
BGC is not admitting that it has not been operating within the licence conditions. BGC believes that it has complied with existing licence conditions and commits to operating within their applicable licence conditions for the proposed quarry operations. Furthermore, BGC is striving to operate to best practice into the future. Recent inspections by DoIR have elicited many favourable comments, especially in relation to dust control. A report by the Special Inspector of Mines (Ventilation) on 22 September 2004 stated that “dust control throughout the operations was of a high standard”. Another report on 29 January 2004 stated that “dust control throughout these activities (in-pit blasthole drilling, loading and haulage of blasted material, and crushing and screening) was of a high standard”.
The LAG submission stated that no impact monitoring of groundwater tables and qualities, or of the Wooroloo Brook, has been undertaken by any regulatory authority or by the quarry management, and requested that this be conducted.
A monitoring programme to characterise the water balance of the existing quarry and impacts on groundwater and surface water near the quarry has been implemented by BGC over the past 12 months. Results of this monitoring are presented in Volume 2; Appendix C of this document.
In relation to the proposed Project, the LAG submission suggested that the licensing conditions should include the following:
All on-site activities should be conducted from 7 am to 6 pm, five days a week. No work should be conducted on the weekends or on public holidays.
Strict blasting conditions in terms of strength, frequency, noise, ground vibration limits, flyrock protection, dust pollution, structural damage to homes and outbuildings, animal (e.g. horse) fright and human traumatisation should be enforced.
The primary crusher must be housed within a noise-absorbing building.
Noise levels must be within EPA noise regulations including due allowances for tonality.
Best practice noise reduction technology and procedures must be implemented.
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Continuous noise monitoring should be undertaken and data be submitted to the DoE for analysis on a monthly basis.
Dust from any quarry site must not cross the quarry boundary at any time.
Failure to control dust crossing the boundary will result in the quarry closure until an effective solution is found and implemented.
Continuous dust pollution monitoring should be mandatory.
Independent assessment of dust pollution monitoring should be provided on a quarterly basis.
Dust generating activities should cease when wind conditions are such as to cause dust to be blown towards residences within 2 km of the site. These activities should only resume once the prevailing wind direction is away from these residences.
An automatic weather station must continuously provide a full record of all aspects of climate.
All weather data to be independently assessed and reported to the DoE on a monthly basis.
Process water to be managed so that no process water enters the Wooroloo Brook.
Holding dam to be lined with membranes sufficient to prevent and seepage to the underlying creek system.
All discharges should be to evaporation dams with impermeable liners.
Evaporative products to be removed and transported off-site.
Batters on all faces of the pit to be cut back to 45 degree slopes above pre-quarrying level of groundwater table.
Cutback batters to be rehabilitated with topsoil and densely planted with high-water consuming trees and shrubs.
Void to be left empty of any kind of fill other than “bland” rock fill.
Salinity in end-mining water-filled void to be continuously and automatically monitored.
Salinity of void-fill lake not to exceed 1,500 ppm TDS at any time.
A rehabilitation bond of $1.5 million must be lodged with the DoE and “topped up” on an annual basis to cover on-going and end-quarrying rehabilitation liabilities.
A programme of tree planting determined at five times the density of annual tree and vegetation clearing must be maintained on an annual basis for the life of the quarry.
Forward tree planting programmes are to be approved by the DoE on an annual basis.
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Mandatory independent monthly monitoring and quarterly reporting of all criteria designated by the DoE.
Failure to comply with monitoring and reporting requirements may result in the closure of the quarry.
Monthly monitoring requirements:
– TDS of quarry void water sump; – TDS of holding dam; – TDS of lines of all piezometer holes; – TDS of all monitoring groundwater bores; – TDS of all farm dams within 2 km of the quarry void; – TDS of all pools and flows within Wooroloo Brook; – Volumes of water discharged to from holding dams to evaporation ponds; – Volumes of salt removed from site; – Monthly standing water levels in all observation bores and piezometer holes; and – Full chemical analysis of the groundwater downstream of the quarry from three selected
piezometer sites.
Daily monitoring requirements:
– Volume of water used from holding dam for dust suppression and washing down of plant;
– Volume of water pumped from pit; – Rate of flow or abstraction from two artesian bores located upstream of holding dam;
and– Rainfall and evaporation.
BGC’s response to the proposed licence conditions are presented in Table 3. This table presents whether BGC agrees or disagrees with the proposed licence conditions for the proposed quarry operation and it also provides the reasons for BGC’s decision.
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Table 3 Justifications for Acceptance or Rejection of Proposed Licence Conditions
Proposed Licence Condition Accept or Reject? Reason for Acceptance or Rejection
All on-site activities should be conducted from 7 am to 6 pm, five days a week. No work should be conducted on the weekends or on public holidays.
Accept that BCG would not conduct any work on Sundays or public holidays.BGC rejects the restrictions on hours of operation during the week and on Saturdays.
The hours of operation proposed by the LAG cannot be accepted, as the proposed hours in the PER are required to maintain the production rate required to meet market demand. These hours of operation include working on Saturday mornings.
Strict blasting conditions in terms of strength, frequency, noise, ground vibration limits, flyrock protection, dust pollution, structural damage to homes and outbuildings, animal (e.g. horse) fright and human traumatisation should be enforced.
Accept that the following blasting conditions could be specified within the licence:
Airblast levels; and Ground vibration levels.
BGC disagrees that blasting conditions relating to frequency, flyrock, dust, structural damage, animal fright and human traumatisation are necessary on the grounds that such conditions are impossible to measure in an objective and quantitative manner. .
The reason why the other conditions cannot be accepted are:
Strength – this is already measured in terms of ground vibration and airblast; Frequency – the frequency of blasting would depend on the demand for hard rock and the need to, comply with ground vibration and airblast limits; Flyrock –this cannot be quantitatively measured, but is being adequately monitored; Dust pollution – dust generation from blasting is inevitable, however BGC would conduct blasting when weather conditions are favourable (i.e. winds are from a westerly direction); Structural damage – a structural survey of neighbouring residences was undertaken in January 2003 to provide a baseline description of the houses and another survey has been arranged for January 2005. Claims that ground vibrations from the proposed quarry have caused structural damage to homes would be evaluated on a case by case basis; Animal fright – this cannot be quantitatively measured in an objective manner; and Human traumatisation – this cannot be quantitatively measured.
The primary crusher must be housed within a noise-absorbing building.
Accept. BGC has already committed to housing the primary crusher within a noise reduction structure.
Noise levels must be within EPA noise regulations including due allowances for tonality.
Accept that noise emissions would meet the Environmental Protection (Noise) Regulations 1997.
BGC has to comply with the Environmental Protection (Noise) Regulations 1997, as this is a standard DoE licence requirement.
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Table 3 (continued)
Proposed Licence Condition Accept or Reject? Reason for Acceptance or Rejection
Best practice noise reduction technology and procedures must be implemented.
BGC will adopt whatever noise reduction technology is necessary to meet the requirements of the Environmental Protection (Noise) Regulations 1997.
BGC are constantly trying to reduce noise and are committed to continual improvement in this aspect of their existing operations. The new quarry has been designed to minimise potential for exceeding the requirements of the Environmental Protection (Noise) Regulations 1997, and noise modelling indicates that the Regulations can be met. Adoption of measures over and above that required to meet the Regulations will impose an unjustifiable cost penalty on operations
Continuous noise monitoring should be undertaken and data be submitted to the DoE for analysis on a monthly basis.
Accept, however BGC proposes to submit noise data on a quarterly basis.
BGC already conduct continuous noise monitoring using noise loggers. Data is already submitted to DoE on a quarterly basis.
Dust from any quarry site must not cross the quarry boundary at any time.
This is not achievable for blasting. Hence it is not an acceptable licence condition.
Dust generated from blasting activities at the quarry is not subject to DoE regulation via licence conditions.
Failure to control dust crossing the boundary will result in the quarry closure until an effective solution is found and implemented.
Whilst it would be BGC’s objective to control dust, this is not an acceptable licence condition for dust generated by blasting.
This condition cannot be accepted because dust from blasting is difficult to control and likely to cross the boundary on occasion.
Continuous dust pollution monitoring should be mandatory.
This is not an acceptable licence condition.
The quarry would implement dust control measures to ensure that dust emissions are minimal. Given that there is no health risk associated with the dust from blasting, continuous dust pollution monitoring is considered to be excessive. However, continuous visual monitoring of dust will be undertaken during the construction period.
Independent assessment of dust pollution monitoring should be provided on a quarterly basis.
This is not an acceptable licence condition.
As there is no justification for conducting continuous monitoring of dust, then this licence condition is not applicable.
Dust generating activities should cease when wind conditions are such as to cause dust to be blown towards residences within 2 km of the site. These activities should only resume once the prevailing wind direction is away from these residences.
This is not an acceptable licence condition.
The quarry would implement dust control measures to ensure that dust emissions are minimal even when wind conditions are strong. Note that most operations in the new quarry will be well below ground level to minimise potential for dust escape.
An automatic weather station must continuously provide a full record of all aspects of climate.
Accept. The noise loggers already measure wind speed and direction. A rain gauge has also been installed to record rainfall.
All weather data to be independently assessed and reported to the DoE on a monthly basis.
Accept, however BGC proposes to submit data on a quarterly basis.
BGC already collects noise, wind speed and direction data and submits it to the DoE on a quarterly basis.
Process water to be managed so that no process water enters the Wooroloo Brook.
This is not an acceptable licence condition, particularly during intense rainfall periods.
Based on groundwater and surface water studies conducted during the preparation of the PER, it is known that water would need to be discharged to the Western Stream, which is a tributary of the Wooroloo Brook. As the water is less saline than the water already present in the stream, and discharge would mainly occur during rainfall runoff, this would not have an adverse effect on the stream water quality.
Holding dam to be lined with membranes sufficient to prevent any seepage to the underlying creek system.
This is not an acceptable licence condition.
The lining of the dam with impervious membranes is an unjustifiable cost impost on the quarry, given that if seepage occurs it is likely to seep into the adjacent quarry pits rather than into the western stream.
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Table 3 (continued)
Proposed Licence Condition Accept or Reject? Reason for Acceptance or Rejection
All discharges should be to evaporation dams with impermeable liners.
This is not an acceptable licence condition.
There is no additional area of land available to construct evaporation ponds of the size required to contain wet season runoff. Managed runoff will not adversely affect stream water quality.
Evaporative products to be removed and transported off-site.
This condition is not applicable As there are no plans to store discharge water within evaporative dams, then this licence condition is not applicable.
Batters on all faces of the pit to be cut back to 45 degree slopes above pre-quarrying level of groundwater table.
This is not an acceptable licence condition.
BGC would ensure that the walls of the final void would be stable, however BGC does not agree that there is a requirement to batter the slopes back to 45 degrees.
Cutback batters to be rehabilitated with topsoil and densely planted with high-water consuming trees and shrubs.
This is not an acceptable licence condition.
The purpose of the DoE licence is for pollution control, and it is not appropriate to put rehabilitation requirements within the licence. The licence condition is not acceptable because the quarry is not located within a visually sensitive location and the final land use has not been determined.
Void to be left empty of any kind of fill other than “bland” rock fill.
This is not an acceptable licence condition.
As the void would not be closed for at least another 50 years, a definite closure option cannot be stated. Within this time, new technologies may arise and other closure options may be available.
Salinity in end-mining water-filled void to be continuously and automatically monitored.
This is not a necessary, nor an acceptable licence condition.
Based on the groundwater studies undertaken during the preparation of the PER, the net effect of the proposed quarry will be that water will flow into the quarry, not out, so groundwater levels and the salinity of local streams will not be adversely affected. Therefore, the salinity of the water within the final void does not require continuous monitoring.
Salinity of void-fill lake not to exceed 1,500 ppm TDS at any time.
This condition is not necessary, nor is it acceptable.
As there is no need to monitor the salinity of the water within the final void, then this licence condition is not applicable.
A rehabilitation bond of $1.5 million must be lodged with the DoE and “topped up” on an annual basis to cover on-going and end-quarrying rehabilitation liabilities.
This is not an acceptable licence condition.
BGC will have internal accounting processes to ensure that funds would be available to ensure that the proposed quarry could be decommissioned and rehabilitated effectively.
A programme of tree planting determined at five times the density of annual tree and vegetation clearing must be maintained on an annual basis for the life of the quarry.
This is not an acceptable, nor a justifiable licence condition.
.BGC has proposed a new offsets package which includes rehabilitation of cleared and degraded Crown land, but also includes covenanting privately owned land and fencing remnant bushland to protect it from grazing.
Forward tree planting programmes are to be approved by the DoE on an annual basis.
This condition as it applies to the new offsets strategy proposed by BGC is acceptable
BGC would ensure that all rehabilitation undertaken on its behalf will meet agreed completion criteria.
Mandatory independent monthly monitoring and quarterly reporting of all criteria designated by the DoE.
This is not an acceptable licence condition.
BGC would comply with the monitoring requirements specified within their DoE licence conditions. Monitoring may be conducted by suitably trained BGC personnel or by technical consultants should an expert be required to conduct the monitoring.
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Table 3 (continued)
Proposed Licence Condition Accept or Reject? Reason for Acceptance or Rejection
Failure to comply with monitoring and reporting requirements may result in the closure of the quarry.
Accept, however a mechanism needs to be established for discretion to be applied to what constitutes failure.
BGC ensures that they would comply with the monitoring and reporting requirements as outlined in their DoE licence and accepts that failure to comply with these licence conditions may result in the temporary closure of the quarry.
3.7.2 Environmental Monitoring
The AVES submission stated that there is no mention as to how the costs associated with independent inspections to ensure compliance will be met or how compliance will be measured. The submission also asked to whom the data would be supplied.
The existing quarry is independently inspected by the DoE and DoIR. In most cases, the main purpose of these inspections is to check whether the quarry is operating in compliance with the licence conditions. The Proponent maintains a separate budget for environmental monitoring at the existing quarry. This practice will be implemented for the proposed quarry and the data collected from monitoring will be submitted to the relevant regulatory authorities.
Public Submission 6 asked whether the proponent agreed that its environmental record to date leaves a lot to be desired?
Whilst BGC admits that it made a mistake by commencing clearing of Lot 14 Horton Road without proper authorisation, BGC does not agree with the statement that its environmental record at the existing quarry to date leaves a lot to be desired. Since start-up in 1991, BGC has operated within its licence conditions and continually sought to minimise adverse effects of operations. This is reflected in the low level of complaints received up to 2001. In recent years, BGC has responded to the increased number of complaints by implementing many improvements aimed at reducing noise, in particular.
The environmental management at the existing quarry is considered by the key regulatory authority for the industry to be very good as highlighted in assessments of the dust management at the existing Voyager Quarry undertaken on 29 January and 22 September 2004 by the Special Inspector of Mines (Ventilation) and Special Inspector of Mines (Occupational Health) from the DoIR. The main purpose of these unannounced occupational health inspections was to review the dust and noise management on the site. The two officers from the DoIR observed in-pit blasthole drilling, loading and hauling of blasted material, and crushing and screening. Based on their observations of these activities, they stated in the Mine Log at the quarry, “Dust control throughout these activities was of a high standard”. Therefore, the submissions that claim that dust management at the current quarry is inadequate do not concur with the independent assessment of the DoIR officers.
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3.7.3 Complaints Register
Public Submission 1 stated that Section 3.7.3 of the PER (Volume 2) outlines complaints to the Shire of Northam and BGC, but not the complaints to other organisations such as the Shire of Mundaring, the Mines Department and the Department of Environmental Protection, and asked that these be sourced for the relevant period and that the true nature of complaints be investigated fully. Public Submission 4 and 5 stated that there had been many more complaints than those identified in the PER but that a lot of residents had been unaware of the correct format in approaching the Shire and the EPA, and complained directly to the quarry.
A request for the complaints record on the existing quarry operations was made to the Shire of Mundaring, DoIR and DoE. No information was received from the Shire of Mundaring. The DoIR did not have records of any formal complaints, as environmental complaints are referred to the DoE. Information received from the DoE was incomplete because complaints were recorded by different officers within the department and it was difficult to compile a complete list. The details of the types of complaints received by the DoE are presented in Table 4 below.
Table 4 Types of Complaints about the Existing Quarry Received by the DoE
(15 December 2001 to 13 January 2003)
Nature of Complaint Number of Times Issues Raised
Noise 6
Dust 0
Light Overspill 0
Ground Vibration 1
Blasting 2
Other Concerns 2
As indicated in the previous response, the DoE records confirm that noise has been the main issue since 2001, and BGC has responded accordingly by implementing many improvements to address this issue (refer Table 5).
Public Submissions 4, 5 and 7 and the LAG submission quoted BGC Asphalt and Quarries’ General Manager as stating that no complaints register was kept at the existing quarry prior to 2000.
The statement about the complaints register made by BGC Asphalt and Quarries’ General Manager was true. Prior to 2000, BGC did not maintain a formal complaints register because few complaints had been made to that time.
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3.7.4 Recent Improvements to BGC’s Operations
Public Submission 14 stated that other improvements are welcome and “we look forward to their implementation and subsequent benefit to us”.
BGC is committed to ensuring that its operations at the Voyager Quarry are socially and environmental acceptable and will implement further improvements where opportunities are identified.
The WBLCDC submission referred to the list of improvements presented on Page ES-3 of the Executive Summary (Volume 1) and stated that they need to be substantiated with the full details of “when, where and how”.
Information on the improvements that have been implemented to date at the existing quarry is presented in Table 5. BGC believes that the table records its commitment to continuous improvement and shows how it has responded to the complaints received in recent years.
Table 5 Improvements Implemented at the Existing Voyager Quarry, 2002-2004
Improvement Details of Improvement Location of Implementation
Date of Implementation
Sealing access road The access road was sealed with bitumen. Existing Voyager Quarry – access road
22 May 2002
Re-sealing access road
The access road was re-sealed to reduce noise caused by tyre friction.
Existing Voyager Quarry – access road
4 January 2003
A new Komatsu WA600-3 wheel loader with a bucket size that is 1.5 times bigger than the existing machine was purchased.
Existing Voyager Quarry – pit
23 April 2002
Two new Komatsu HD785 (85 tonne) dump trucks were purchased to replace the Cat 773B (50 tonne) dump trucks.
Existing Voyager Quarry – pit and primary crusher
3 September 2002
A near-new Komatsu WA600-3 wheel loader was purchased.
Existing Voyager Quarry – pit
19 September 2002
A new feed plate was purchased for the secondary crusher.
Existing Voyager Quarry – secondary crusher
10 October 2002
A near-new Komatsu HD465-3 with a 45,000 L tank to supplement the existing 30,000 L watering truck was purchased.
Existing Voyager Quarry - quarry site
11 November 2002
Replacement of earthmoving machines
A near new Komatsu WA500-3 wheel loader was purchased to replace a Cat 980B wheel loader. All loaders at the existing quarry are new or near new.
Existing Voyager Quarry - pit
20 October 2003
Videotaping blasts All blasts are recorded on video and the video tape is reviewed to ensure that no flyrock has left the site.
Existing Voyager Quarry - pit
21 August 2002
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Table 5 (continued)
Improvement Details of Improvement Location of Implementation
Date of Implementation
Increased monitoring of blasting operations
A monitoring site for the measurement of ground vibration was established at Lot 1 Cable Road. Four blasts were monitored, with all vibration levels below 0.1 mm/s. Airblast levels were between 90 dB and 110 dB.
Existing Voyager Quarry
23 May 2002
Construction of rubber-backed frames and earthen bunds around the primary crusher
Frames were built around the primary crusher and rubber padding was attached to the frames to reduce noise emissions. Earthen bunds were constructed on the north and south sides of the primary crusher.
Existing Voyager Quarry – primary crusher
Frames built on 18 April 2002 Earthen bunds built on 10 May 2002
Modified nightshift activities
Nightshift activities were streamlined by: implementing speed limit restrictions; prohibiting the use of horns (unless in emergencies); limiting sirens to short bursts; and keeping the primary crusher full.
Existing Voyager Quarry – pit and primary crusher
20 March 2002
Reduced operating hours of the primary crusher
The operating hours of the primary crusher were reduced to 0800 to 2200 hours. The hours used to be 0700 to 0400 hours.
Existing Voyager Quarry – primary crusher
10 January 2002
Noise monitoring using data loggers were installed, so that noise emissions could be logged on a 24 hour basis.
Existing Voyager Quarry
2 October 2002
The software on both noise loggers was modified to record noise at preset times.
Existing Voyager Quarry
15 April 2003
Continuous noise monitoring
The wind vane on the noise logger was extended to a height of approximately 18 m above the ground to obtain a better reading of wind speed and direction.
Existing Voyager Quarry
16 April 2003
Reduced noise emissions
Reverse beepers on all machinery changed to a silent type for night time operations.
Existing Voyager Quarry - quarry site
22 January 2004
Reduced light emissions
A lighting survey was undertaken and circuits were modified to ensure that minimum lighting was used for night time activities.
Existing Voyager Quarry - pit and infrastructure areas
24 July 2002
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Table 5 (continued)
Improvement Details of Improvement Location of Implementation
Date of Implementation
BGC issued an internal memo regarding blasting procedures. It included the following instructions:
delay blasting on days when wind is coming from the easterly direction; delay blasting as late as possible until conditions (winds) are favourable; and delay blasting until the next day if conditions are not favourable, however charges cannot be left in the ground over a weekend.
Existing Voyager Quarry – pit
10 February 2003
Altered cut-off time for blasting on Fridays to 1500 hours instead of 1700 hours.
Existing Voyager Quarry – pit
22 July 2003
Revised blasting procedures
BGC commissioned Orica to undertake blasting at the quarry. Blasting practices include:
the use of SurveyPlus laser control system for the design and markout for the blast; provide drilling plans to the quarry driller; audit drill holes with boretrack system; design initiation and loading plans; supply of bulk and initiating explosives; priming, loading and stemming of all blast holes; tying up and initiation of blast; environmental monitors as two locations; and blast reporting for evaluation.
Existing Voyager Quarry – pit
6 April 2004
Change blasting initiation from non-electronic to the electronic IKON system. This gives superior precision for the firing order to reduce airblast and ground vibration.
Existing Voyager Quarry – pit
13 August 2004 Revised blasting procedures (continued)
BGC issued an internal memo for the revised blasting instructions, including:
all blasting to occur between 1300 and 1500 hours; blasting to be planned for a Monday or Tuesday; if winds are easterly to sourtheasterly, then the blast must be delayed to the following day; blast notification needs to be done 24 hours prior to the blast; and if the blast is delayed until Friday with no prospect of favourable conditions, then the blast will be fired at 1500 hours on the Friday.
Existing Voyager Quarry – pit
28 September 2004
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Table 5 (continued)
Improvement Details of Improvement Location of Implementation
Date of Implementation
Total enclosure of the primary crusher to reduce noise emissions was completed.
Existing Voyager Quarry – primary crusher
19 May 2003 Reduced dust emissions
A new pump and sprinkler system was commissioned. The sprinkler system is more efficient as it waters stockpiles at short regular intervals to reduce wastage and runoff from stockpiles.The pump now fills up the water truck five times quicker than the previous pump.
Existing Voyager Quarry – stockpile area
23 December 2003
Revised procedures for trucking movements
BGC issued an internal memo regarding trucking movements. It included the following instructions:
all trucks to have muffled exhausts; the use of engine brakes is banned; and mandatory use of tarpaulins on every load.
Existing Voyager Quarry
29 January 2004
Public Submission 5 referred to the list of improvements, which stated that existing earthmoving machines had been replaced with new, larger machines. The submission stated that if the new machinery is already in place, it could still be heard 2.5 km away, and that it was only common sense that bigger machines generated more noise.
An inventory of the new machinery that has been purchased for the existing Voyager Quarry is presented in Table 6.
Table 6 Inventory of New Machinery Purchased for the Existing Voyager Quarry
New Machinery Machinery Replaced Two new Komatsu WA600-3 wheel loader Cat 988 wheel loader Two new Komatsu HD785 (85 tonne) dump trucks Cat 773B (50 tonne) dump trucks Near-new Komatsu WA500-3 wheel loader Cat 980B wheel loader Near-new Komatsu HD465-3 with a 45,000 L tank Supplement the existing 30,000 L watering truck
The rationale of purchasing the larger earthmoving equipment was that machines with larger carrying capacities would reduce the number of vehicle movements, thus reducing noise and dust emissions. Also, the newer machinery has better noise mitigation technology and is in better condition than old machinery, thereby further reducing noise.
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3.7.5 Environmental Management
The AVES submission asked why BGC has not already prepared an EMS in order that the proposal can be fully evaluated and why there was no commitment to adhere to the appropriate ISO 14000 series that deal with environmental management.
Preparation of an EMS is not a requirement of the impact assessment process because it does not add materially to evaluation of a project in the way that an Environmental Management Plan (EMP) does. An EMS is largely a documented management system by which to implement the EMP. Therefore, BGC has not prepared an EMS because their priority has been to actually undertake environmental management by implementing a number of environmental improvements at the existing quarry. The list of improvements is presented as Table 5 of this document.
BGC has recently created a position at the quarry for a Manager - Quality, Safety and Environmental Systems. This officer commenced work at the Voyager Quarry in May 2004. One of his responsibilities will be to develop an EMS.
3.7.7 Benchmarking of Existing Operations
Public Submission 2 asked why the Toodyay Quarry was not included in the benchmarking exercise.
The Toodyay Quarry was not included in the benchmarking exercise because it has not been in operation for at least the last seven years.
Public Submission 2 referred to Page 15 of the PER and stated that the Shire of Northam and Toodyay are not in the metropolitan area.
As defined by the Metropolitan Region Planning Scheme, the Shire of Northam and Toodyay are not in the Perth metropolitan area. However, the statement in the PER refers to the Perth Metropolitan Region,as defined in the Basic Raw Materials Planning Policy Statement as including the metropolitan area and surrounding areas. Under this definition, both the Shire of Northam and Toodyay are included.
The LAG submission compared the existing quarry with the Pioneer Quarry at Redhill. It stated that Pioneer moved its operation 3 km from the local community and modernised its equipment so that it handled the same volume as BGC, but in only half the time, which allows all operations to be conducted during daylight hours.
BGC views the proposed relocation of the Voyager Quarry as an opportunity to greatly improve its operations by replacing the current processing plant with a new state-of-art plant that would be quieter and require less maintenance than the existing plant. Although the quarry would be relocating closer to existing residences, the new quieter plant would be located 30 m below ground level within the quarry pit. These design changes at the proposed quarry will substantially reduce noise and dust emissions.
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The hours of operation for the proposed quarry have not been reduced, however, if BGC is able to meet the demand for hard rock within reduced hours of operation, the proposed quarrying operations would only operate for as long as required to meet the demand.
Public Submission 1 stated that BGC should be benchmarking and seeking accreditation against recognised and approved industry standards.
BGC has recently created a position at the quarry for a Manager - Quality, Safety and Environmental Systems, and part of the role includes the development an EMS for subsequent accreditation to ISO 14001.
3.8 Decommissioning, Rehabilitation and Closure
Bonds and Provisioning for Rehabilitation
The AVES submission and the WBLCDC submission stated that a sufficient or substantial up-front bond was essential to cover the full estimated cost of rehabilitation/closure at the end of the mine life. The AVES submission asked what concrete measures have been taken to ensure that the State will not be left with a liability and stated that, given the current problems being experienced with old minesites and/or contaminated sites, this matter should have high priority.
The LAG submission stated that the rehabilitation bonds under the Shire of Northam's regulations are unacceptably low and recommended that BGC’s budgeting included the up-front lodging of environmental bonds to cover the estimated full cost of rehabilitation at the end of quarry life and be sufficient for post-quarry monitoring and regulation compliance.
BGC does not consider that up-front bonds are required to cover the cost of closure for the proposed quarry. BGC currently allocate funds for the decommissioning and rehabilitation of the existing quarry in its internal financial accrual process. A letter from PKF Chartered Accountants, dated 17 June 2004, confirms that BGC has made provisions for the rehabilitation of the existing quarry.
In accordance with the Strategic Framework for Mine Closure (ANZMEC and MCA, 2000), BGC would accrue funds for decommissioning and rehabilitation during the life of the proposed quarry. A cost estimate of decommissioning and rehabilitation would be developed from the closure plan and these costs would be reviewed regularly to take into account any increases in the costs of goods/services and inflation. In implementing these steps in its internal financial accrual process, BGC would ensure that the financial provisioning for the closure of the proposed quarry would reflect the real cost of decommissioning and rehabilitation works. Therefore, the State would not be left with a liability.
Public Submission 4 stated that there had never been any consideration or funding put aside for the closure of the existing quarry. Public Submission 2, Public Submission 6 and the AVES submission requested information on the amount of money or bond BGC would be prepared to allocate to site decommissioning, rehabilitation and closure of the proposed quarry if it goes ahead.
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A budget for closure of the proposed quarry has not yet been established. However, as stated in Table 6.1 of the PER (Volume 2), a rehabilitation budget will be established to ensure that there are sufficient funds available to conduct the rehabilitation and monitoring for the proposed quarry. At the very least, BGC will remove all infrastructure, remediate any contaminated areas (in the unlikely event that any exist), render the site safe, and revegetate disturbed areas that are not required for future use. Standard procedure is to establish a budget, allow for inflation over time, calculate an annual accrual cost, and financially accrue that cost until it is required to be spent.
3.8.1 Decommissioning and Rehabilitation of the Existing Quarry Operations
The decommissioning and rehabilitation of the existing quarry operations was provided as background information and is not part of the proposal being assessed under the PER. However, a number of submissions raised issues relating to this aspect. These issues are summarised below.
The AVES, Shire of Mundaring and WBLCDC submissions asked for details on the landowner’s requirements for rehabilitation of the existing quarry operations. Public Submission 4 stated that rehabilitation of the existing quarry operations to the landowner’s requirements was unacceptable and that the site had to be rehabilitated to the satisfaction of the environment. The Shire of Mundaring submission stated that the land should, wherever practical, be revegetated and reinstated upon cessation of the quarry activities, regardless of the intention of the landowner.
BGC does not own the land that the existing quarry is located on and cannot conduct any works on this land without the approval of the landowner. Therefore legally, BGC is not in a position to make any commitments other than to rehabilitate the site to the landowner’s requirements.
Public Submission 4 asked what equipment is to be sold and what equipment will be retained for use at the proposed quarry.
The primary and secondary crushers at the existing quarry would be sold and new state-of-art crushers would be purchased for the proposed quarry. Some of the tertiary crushing equipment which is relatively new, may be retained for the proposed quarry.
All mobile plant equipment used at the existing quarry is replaced on a regular basis to ensure that the fleet is kept up to date. Therefore, some of the vehicles that are used at the existing quarry may also be used at the proposed quarry, as they will be relatively new.
The AVES submission and Public Submission 2 asked whether the removal of stockpiles on decommissioning included the dust stockpile.
The decommissioning of the existing quarry would involve the removal of all stockpiles and this includes the dust stockpile. The fate of the granite dust is yet to be determined, however it is likely that it would be used for a major construction project.
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The LAG submission stated that no viable rehabilitation closure plan for the current quarry void has been identified that will not introduce either toxic or saline effluent from the quarry void directly into the Wooroloo Brook drainage system. The submission stated that the existing void would fill with groundwater post-mining as it has good hydraulic continuity with the Wooroloo Brook drainage system.
Closure options for the existing quarry void were not stated in the PER, as BGC does not own the land that the quarry is located on. BGC cannot decide on the closure options for the existing void because this decision has to be made by the landowner.
BGC will rehabilitate the existing quarry to the landowner’s requirements and subsequently hand over future responsibility for the pit to the landowner.
The WBLCDC submission asked what would happen to water in the decommissioned site and what are the implications to hydrology and water quality to the Wooroloo Brook from the decommissioned site. The WBLCDC submission also asked what ongoing monitoring and revegetation would take place.
Depending on what the landowner decides to do with the decommissioned pit at the existing site, there will be different hydrological scenarios. Based on the current understanding of the water balance for the existing pit, water will seep into the pit at an average rate of approximately 0.3 L/s. If the pit is left empty and runoff water is not deliberately directed into the pit, a small pool of water will form at the base of the pit, but there will be no seepage outflow. There will not be a significant amount of water in the pit because evaporation loss will always be greater than rainfall and seepage inflows. The net salt concentration of combined rainfall and seepage inflow is estimated to be 70 mg/L.
If the pit is backfilled with material and the final level of the new pit base is deeper than the weathered granite layer, then the water that seeps into the pit and direct rainfall will collect in the pit in much the same way as if the pit was left empty. However, the seepage inflow rate may be less than if the pit was not backfilled. This water will not flow out of the pit, as the granite bedrock is impermeable at depth.
If the decommissioned pit is backfilled to above the weathered granite layer, the water that collects in the pit may flow out through the weathered granite, as this material is permeable. This water could travel in the direction of the Wooroloo Brook. This water would be fresh, as it will be derived from rainfall, with a salt concentration of approximately 10 mg/L.
The LAG submission stated that a formal Rehabilitation Agreement between BGC and the owner of Lot 7, with the approval of the DoE/EPA, was needed to ensure that there is a legal commitment to complete rehabilitation to standards acceptable to the DoE. The submission also stated that the Strategic Framework for Mine Closure (ANZMEC, 2000) should be imposed upon the current quarry operations.
It needs to be taken into account that the proposal being assessed by the EPA is for a new quarry on Lot 14. The existing quarry operations on Lot 7 are not being assessed. However, in answer to the question, BGC has not developed a formal rehabilitation agreement with the landowner of Lot 7, but is legally committed to rehabilitate the site to the landowner’s requirements.
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The LAG submission stated that the options for the existing void “are stark” as the options are:
(a) A void-filling lake that will become a saline sinkhole through the processes of evaporation;
(b) Backfilling with garbage or so-called ‘inert’ industrial waste will present the next toxic waste problem after Brookdale; and
(c) Backfilling with rock will not be viable.
Responsibility for final land-use of the existing void rests with the landowner, not BGC. However, BGC does not agree with the statements made by the LAG for the following reasons:
(a) If the void was left open, it could be managed so that it would not become a saline sinkhole. Runoff from nearby catchments could be prevented from entering the void by drainage bunds, and the low volume of groundwater seepage and direct rainfall would evaporate in summer. As a result, the void would be seasonally dry.
(b) If backfilling of the void was undertaken it would not include ‘garbage’ or putrescible wastes, which are wastes that contain organic materials as described in the DoE Landfill Waste Classification and Waste Definitions (1996). Should the option of backfilling be chosen, inert wastes would be selected using the Guidelines for Acceptance of Waste to Landfill (DoE, 2002). Inert wastes are largely non-biodegradable, non-flammable and not chemically reactive (DoE, 1996). Using inert wastes will not result in an incident similar to the one at Brookdale, because Brookdale received industrial and biological wastes. These wastes are unlikely to be acceptable for disposal into the existing quarry void; and
(c) Backfilling with rock and inert building waste could well be economically viable.
3.8.2 Closure and Rehabilitation of the Proposed Quarry Operations
The AVES submission, the WBLCDC submission, Public Submission 2 and Public Submission 5 stated that having a draft closure strategy, rather than a final closure strategy, was not acceptable. Public Submission 2 also asked when the final closure strategy would be presented. The WBLCDC stated that full details and commitments of decommissioning and closure, including rehabilitation, must be presented in this proposal. The Shire of Mundaring submission stated that, since the method and performance of post-closure management will have a bearing on the environmental acceptability of the proposal, it should be assessed properly as part of the PER.
A draft closure strategy was developed and presented in the PER so that it would be circulated to key regulators and stakeholders. These parties were able to provide comment and advice on the draft strategy. The final closure strategy would be presented when the post-mining land use has been decided.
In accordance with the Strategic Framework for Mine Closure (ANZMEC and MCA, 2000), BGC has progressed its closure planning process for the proposed quarry and prepared a preliminary closure plan. This is presented as Volume 2; Appendix D for comment. This preliminary closure plan identifies the
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key objectives for mine closure, which provides direction on the project development and design. Following the decision on the final land use and finalisation of the closure strategy, a closure plan would be developed. Development of the closure plan would occur during the life of the project and be reviewed on a regular basis (e.g. every 3-5 years).
The LAG submission stated that the Strategic Framework for Mine Closure (ANZMEC, 2000) should be imposed upon the proposed quarry operations and that the group endorsed the International Institute for Sustainable Development’s observation that a closure plan should precede any discussion of the aspects of the operation. The submission stated that a closure plan should be developed at the outset of operations to ensure that the decisions made during quarry life are oriented towards this objective.
As stated in Section 3.8.2 of the PER (Volume 2), BGC accepts the need for a closure plan based on the objectives and principles of the Strategic Framework for Mine Closure (ANZMEC and MCA, 2000). Furthermore, BGC is already implementing the concepts outlined in the above guidelines by having prepared a preliminary closure plan. This is presented in Volume 2; Appendix D for review and comment. This preliminary closure plan identifies the key objectives for mine closure, which provides direction on the project development and design. BGC therefore considers that it has demonstrated that it is addressing closure issues as part of quarry development planning.
3.8.3 Void Closure and Rehabilitation
Public Submission 1 stated that the information presented in Table 3.8 of the PER appeared to be qualitative and that there was no information on the methodology for the development of assessment criteria in the options for post-operation quarry use.
The assessment of options for post-operation quarry use presented in Table 3.8 and Figure 3.5 of the PER (Volume 2) was based on a paper prepared by Mallet and Mark (1996) entitled, ‘Key Issues in the Management of Final Voids’. The major objective of the pit completion decision process is to identify information that is required to make sound decisions about the final completion of voids. In general terms, there are three options for pit completion, which are:
Void used for water storage; Void used for waste storage; and Void left empty.
The information required to make an assessment of these three options is presented in Table 7.
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Table 7 Pit Completion Options for the Proposed Voyager Quarry
Pit Completion Options Information Required to Make an Assessment Void used for water storage (filling the void with water passively or actively)
Water balance, surface and groundwater hydrology, acid generation potential, limnology and salinity
Void used for waste storage Available wastes, hydrology, geology/geotechnics, economics and surrounding land use
Void left empty Geotechnical stability, water balance and groundwater hydrology
Therefore, a list of possible options for pit completion can be determined by using the information gathered and assessing the proposed uses on a technical basis. These options are then compared to one another and one may be chosen for further assessment. The option that has been selected should then be assessed in more detail, to see if the pit’s geotechnical stability is suitable for the intended use. Then a cost-benefit analysis should be undertaken. This involves an analysis of the following factors:
Engineering costs; Liability risks; Public image (cost or benefit); Economic benefits; and Regulatory acceptance.
The objective of the cost-benefit analysis process is to determine which pit completion option is cost-effective and acceptable to the government, community and the Proponent.
Public Submission 6 referred to Figure 3.5 and asked whether the “Will water accumulate?” diamond should be connected with the “Water storage option analysis” box.
Yes, the “Will water accumulate?” diamond should be connected to the “Water storage option analysis” box and the line connecting the “Is there likely to be remaining resource in the quarry?” diamond to the “Will water accumulate?” diamond should be removed.
Public Submission 15 stated that it would be ludicrous for the quarry void to remain open and asked what material would be used to partially or fully backfill the void. This submission stated there was concern that the quarry void would become a rubbish dump as well as a dump for all sorts of toxic waste, and asked what would that do to ground water, especially in years to come when water will be even more important as there will be greater shortage.
BGC disagrees that it would be ludicrous for the quarry void to remain open. One of the options for closure is in fact that it be left open and allowed to accumulate water for subsequent use. Such use could be irrigation, recreation, or aquaculture. If it was decided to backfill the pit, then as indicated in a previous response, there are DoE Guidelines for Acceptance of Wastes to Landfill that would be complied with to ensure that no toxic or other inappropriate wastes, and only inert wastes were accepted.
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Also, as indicated in a previous response, BGC will need to seek further approval from regulatory agencies before a final void use strategy can be implemented.
Public Submission 5 stated that the options of the closure of the void are unsuitable and the option of filling the void with non-putrescible waste material was untenable. It stated that no waste should be placed in the void as it would leach into the Wooroloo Brook, which is to be used as a potable drinking water source in 2031.
The pit completion option has not yet been selected. However, should the storage of inert, non-hazardous and non-putrescible waste be considered as an option, a full assessment of the hydrology, geology/geotechnical, economics and surrounding land use would be undertaken. The assessment would determine the lower limit of fractured/weathered bedrock to ensure the waste is confined to the deeper impermeable part of the void.
The Office of Soil and Land Conservation submission requested analysis of the long-term risks of off-site salinisation associated with pit closure.
The risks of off-site salinisation due to pit closure are negligible, as groundwater in the vicinity of the quarry would seep into rather than out of the pit. Water balance studies have shown that the groundwater levels would not rise as a result of the closure of the quarry.
An initial analysis of the potential closure scenarios and impacts on the environment has been completed and these results are presented in the PER. As a final closure option has not yet been selected, it is not possible to confirm at this time what the final option will be. However, the initial analysis presented in the PER indicated that closure is not likely to provide a threat to the environment. For the most likely closure options, groundwater in the vicinity of the quarry would seep into rather than out of the pit and risks of off-site salinisation are low. Further studies will be undertaken when more details of the likely closure option become available.
The LAG submission stated that the suggestion of backfilling the void with barren rock would negate the environmental problem but would not be a viable proposition for BGC. The submission also stated that, if the pit fills with water, the mix of acidic groundwater, oxygen and the non-reactive industrial waste in the pit would cause pollution.
As stated in Section 3.8.3 of the PER (Volume 2), the option of back-filling the void with inert waste rock is an option seriously being considered by the Proponent. The increasing amount of redevelopment taking place is increasing the demand for disposal sites that can take building material, such as bricks, tiles and concrete.
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4 Response to Submission on the Existing Environment
4.1 Climate
Public Submission 1 stated that local weather monitoring needed to be carried out as the sites from which the data used in the PER were sourced (Bickley, Chidlow, Mundaring and Northam) were a considerable distance from the proposed quarry site and have unrepresentative climatic conditions.
These weather data were used to characterise general climatic conditions in the region of the quarry. The weather stations used are the closest Bureau of Meteorology weather stations and, even though they are some distance from the quarry site, they are representative of the majority of general weather conditions in the area. The main factor that is affected by geographical variation between these weather station sites is rainfall. In the studies presented in the PER where rainfall is important (e.g. water balance), a synthetic record generated by the Bureau of Meteorology, which provides a more accurate estimate of rainfall at the site, was used.
A rain gauge and anemometer have been installed at the existing quarry site to characterise local rainfall, windspeed and direction.
4.2 Geology, Landforms and Soils
The WRC submission stated that the land units suggested in the PER did not appear to match the topography of the project area.
The information on land unit used in preparing the PER was obtained from:
Biggs, E.R. and Wilde, S.A. (1980) Geology, Mineral Resources and Hydrogeology of the Darling System, Western Australia. In: Atlas of Natural Resources Darling System, Western Australia. Department of Conservation and Environment, Perth.
However, recently obtained electronic data from the Department of Agriculture indicates that the Pindalup land unit is not present within the Project Area and we would agree with that assessment. The major land units within the Project Area are the Yalanbee and the Cooke land units. The Yalanbee land unit is the Yalanbee subsystem, which is neither Yalanbee 1 nor Yalanbee 2. The description for the Yalanbee subsystem is:
“Residual plateau at the top of the landscape shallowly dissected by Pindalup valleys. Pisolitic gravely, yellowish brown soils that vary in texture from loamy sands to clays, with pockets of pale sands and areas of outcropping laterite” (Department of Agriculture).
Public Submission 1 stated that land systems have been described in general terms, but a site-specific soil/landscape survey has not been conducted. This submission suggested that a soil/landscape survey be conducted at a scale that is suitable for management decisions to be made and that 1:10,000 to 1:50,000 scale surveys were appropriate for intensive land use planning, management plans for small catchments, rural land use planning etc. The survey should include site-specific sampling of soils, soil analysis and should link the soil, vegetation, landscape and geological features at a scale of 1:10,000.
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Public Submission 1 stated that the Churchward and McArthur soil/landscape information utilised in the surface water and vegetation surveys in the PER are not suitable data and these sections of the PER are compromised as a result.
For the purposes of the PER, the available mapping data was considered to be adequate. The main issues in relation to the soils and landscapes are at a catchment scale and therefore this is consistent with the scale of the mapping data used.
Public Submission 1 also stated that the report did not identify the regolith features.
The regolith features are described in the geological section of Volume 2; Appendix C.
4.3 Surface Water
Public Submission 1 stated that there is a lack of baseline monitoring data for stream conditions and that a detailed land assessment of the site needs to be carried out to determine the soil condition, vegetative cover and annual rainfall, and this needs to be linked to the slope percentage. The submission stated that this information could be used to determine maximum flows, safe grades and safe velocity, in regards to water erosion. The submission also stated that if the baseline data are not available, the quarry should be postponed for 3-5 years to enable data to be collected and analysed.
A significant amount of data is available to characterise existing stream conditions and develop erosion management plans. Studies were undertaken for the original PER document that characterised the existing environment and potential impacts of the proposed quarry. These studies have been further expanded with an expanded monitoring plan undertaken by BGC in 2004. The results of the expanded monitoring is presented in Volume 2; Appendix B.
The erosion management plan presented in the PER has also been refined using the additional information collected by BGC in 2004. Details of the plans to manage erosion are given in Volume 2; Appendix B of the Response to Submissions. In summary, erosion risk will be managed using soil conservation techniques and sediment traps on-site, rain falling in the pit in excess of the mine’s processing requirements will be released from the quarry in a controlled fashion, and the stream receiving this water will be reshaped to accommodate the water without eroding.
Public Submission 1 stated that the data utilised in the surface water assessment was insufficient for the scale of the proposal and that the data presented in Appendix G (pages 3-8,Volume 3) regarding runoff from agricultural ground were not based on any local catchment monitoring. This submission also asked that information be presented on how the ARI drainage capacity benchmark was developed and if it was developed using the meteorological information used by BGC, which is not site specific.
The information used in the surface water assessment was based on modelling and results of available experimental studies. There are no catchment monitoring data at the scale of the proposed quarry in the local area, but there are a number of experimental studies of catchment water balance throughout the general area that were consulted. Details of these studies and the modelling are given in Section 2 of Appendix G of the PER.
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There are also two gauging stations in Wooroloo Brook, operated by the Water and Rivers Commission, that were used to evaluate the impact of the existing and proposed quarry on stream flows and salinity at a larger catchment scale. Details of these studies are given in Section 3 of Volume 2; Appendix B.
Information used for design of channel capacities (rainfall for various average recurrence intervals) is based on information generated for the site location. More detailed information on channel design is given in Volume 2; Appendix B.
Public Submission 1 referred to Page 45 of the PER (Volume 2) and stated that the water balance calculation is useful for determining groundwater recharge rather than surface water movement. It also stated that if the runoff figures are based on rainfall data from Northam, Bickley and Chidlow, then the figures are highly inaccurate.
Much of the information on Page 45 of the PER relates to surface water movement and predicted runoff rates for the area of the proposed quarry are given in Figures 4.8 and 4.9.
Runoff predictions were based on weather data generated for the site by the Bureau of Meteorology, as described in Section 2 of Appendix G of the PER.
The Conservation Council submission referred to a statement made on page 44 of the PER (Volume 2) that compared the area of the proposed quarry and infrastructure (approximately 85 ha) to the area of the Wooroloo Brook catchment (0.32 %) and the wider Swan-Avon catchment. The council submission asked why the relative sizes of the Project Area and the catchments are relevant.
This statement is intended to convey the relative sizes of the two catchments, and hence the likely relative impact that the quarry catchment could have on the wider catchment. Because the quarry is so much smaller than the Wooroloo Brook catchment, any impacts are likely to be small and localised. This point is explored in more detail in Section 3.3 of Volume 2; Appendix B.
The WBLCDC submission and Public Submission 2 stated that the clearing of 85 ha is extremely small compared to the Wooroloo Brook catchment but is a very large amount when compared to the native vegetation left in the catchment. Public Submission 4 and the LAG submission stated that 85 ha is 35-36% of the vegetation protecting the headwaters of the Wooroloo Brook.
While the area of vegetation cleared to construct the quarry may form a substantial component of local vegetation, the clearing will have no adverse impact on salinity in local streams or groundwater, unlike clearing for agriculture. The net effect of the proposed quarry will be that water will flow into the quarry, not out, so groundwater levels and the salinity of local streams will not be adversely affected. Clearing for agriculture, on the other hand, has in the past adversely impacted local stream flow and salinity because excess rainfall previously taken up by native vegetation leaks to the local water table, which is saline, causing a rise in groundwater levels and seepage to low-lying areas and streams. Clearing associated with the development of the quarry will occur in stages and the quarry pit will be rapidly excavated to a depth that allows collection of excess water, thus preventing any impacts on local groundwater levels or stream flow.
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The AVES submission stated that part of the headwaters of the Wooroloo Brook originate within the Project Area and the streams in the area already show problems with salinity and waterlogging. Public Submission 5 stated that a number of properties already have a salinity problem and sections of the Wooroloo Brook are saline. Public Submission 2 stated that the author(s) of this submission had not been told that excess water has been released into the Wooroloo Brook from the current quarry operations and that discharging water into the Wooroloo Brook exacerbated problems of waterlogging that are experienced at their property. Public Submission 1 requested that BGC detail current outflows from the existing quarry to determine if its current operations have induced salinisation within Wooroloo Brook and stated that BGC needed to drill bores to the north of the site as that is where the wastewater overflow to Wooroloo Brook is draining and where all surface drainage from the site ends up.
Current salinity problems in the vicinity of the existing quarry are a result of clearing for agriculture, not the quarry. This point has been discussed in Section 3 of Appendix G of the PER. It is also demonstrated clearly in Figure 6 in Volume 2; Appendix B, where colour aerial photographs of the catchment taken in 1989 confirm that salt scalds and seepage already occurred before development of the quarry.
Surface drainage at the existing quarry and impacts on stream flow in Wooroloo Brook are evaluated in a series of experimental studies and modelling, detailed in Section 3 of Volume 2; Appendix B. These studies show that there is some seepage and runoff water released from the existing quarry to the streams just north of the quarry; the net impact of these releases is to reduce stream flow salinity and increase stream flow, particularly in winter.
The LAG submission stated that it had measured the pH of the waters around the quarry and found they were very acidic in some places and commented that this acidity had not been acknowledged in the PER. Public Submission 1 stated that the data on water quality in the existing sediment ponds presented in the PER were misleading as the water in the ponds was bound to be fresh due to winter rainfall reducing salt loads, and that sampling for water quality in sediment ponds and other areas of the catchment needs to occur over a minimum of three years.
No evidence of low pH has been found in water in the existing quarry area or immediately downstream of the quarry. Additional monitoring has been undertaken this year by BGC. One incidence of low pH was observed in local seepage at a granite outcrop in farmland north of the quarry (monitoring site ET1). This seepage water is due to rising groundwater related to clearing for agriculture and is not related to quarry activities. The low pH is probably due to the groundwater passing through an area containing acid generating materials. Details of monitoring data are given in Volume 2; Appendix B.
Sampling at sites around the quarry and stream flow just north of the quarry is ongoing to further characterise seasonal variability.
The LAG submission stated that the current quarry requires a surface water monitoring programme to establish the degree of damage that it is causing to the Wooroloo Brook groundwater system in Lots 7 and 13.
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A surface-water monitoring program has been in place at the existing quarry since January 2002. Results of the sampling at the time of the PER were presented in Appendix G of the PER. The monitoring program has since been expanded to include a greater number of sites, water quality and water balance parameters and this monitoring is continuing. Results of the expanded monitoring programme are given in Volume 2; Appendix B.
Public Submission 5 stated that the WRC had allocated the Wooroloo Brook to be used as a potable water source in 2031. This was also raised by the Earth submission. The Conservation Council submission asked whether there was a contradiction in the area being a Priority 3 Drinking Water Source Area, but not being in a Proclaimed Groundwater Area.
The status of the area is a matter for the regulatory authorities.
4.4 Groundwater
The Conservation Council asked whether the proponent agreed that Figure 4.10 illustrates how the salinity of groundwater progressively increases from Mundaring Catchment towards the wheatbelt.
Figure 4.10 illustrates a regional trend of increasing salinity from Mundaring Catchment towards the wheatbelt. The groundwater salinity is much more complex in detail, for example there is commonly an increase in salinity downslope within individual catchments, and the degree of clearing for agriculture is also an important factor. The indicated eastward increase is therefore a simplified representation of a general trend.
The LAG submission stated that Lot 7 (downstream of the current quarry) is showing evidence of salt scalds, waterlogging and erosion as the groundwater table is extremely close to the surface for most of the year. The submission stated that the groundwater table at Lot 13 must also be close to the surface.
The water table below the lower-lying parts of Lot 7 is generally within 1 m of the surface during winter, as shown by the monitor bores drilled in May 2004, and monitored weekly since then. The groundwater in Lot 13 is expected to be similarly shallow. The water level in Bore PB9, adjacent to the eastern boundary of Lot 13 was at ground level at the time of census in May 2004.
There are salt scalds and associated eroded patches on Lot 7. These pre-date the construction of the quarry, being evident on aerial photographs taken in February 1989 (Airphoto Series WA 2690(c), Run 11, No. 5211).
Public Submission 1 asked whether there was any evidence that the current quarry is causing groundwater drawdown on neighbouring bores. This submission suggested that baseline groundwater impact trends over 3-5 years are needed for the current operation. The LAG submission stated that hydrogeological data have not been collected to assess and test for artificial recharge of the groundwater table beneath Wooroloo Brook due to the existing operations.
There is no evidence of drawdown in neighbouring bores caused by the existing quarry. The nearest known bores are on Lot 5, about 1 km to the west of the existing quarry. Water levels were measured in
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May 2004 in these bores, and ranged from 311-313 m AHD, over 50 m higher than the water level in the quarry sump at that time, and indeed at about the same elevation as the original ground level of the quarry site. The owner of Lot 5 does report that the two bores which he uses have dried up in summer in recent years, but this may be due to reduced recharge from the lower rainfall experienced in 2001-2002.
Monitoring of water levels north of the quarry shows no evidence of local recharge to Wooroloo Brook. The quarry acts as a groundwater sink rather than as a recharge source.
Public Submission 1 stated that local bore data and recent studies of the area indicated that regional groundwater is brackish to saline and that BGC should establish monitoring bores in the local catchment to determine water depth, quality and movement. The LAG submission stated that it requested BGC to install peizometers for monitoring in early 2002 and had not seen evidence of this being undertaken by BGC.
Two monitoring bores were constructed in March 2003. Eleven monitoring bores were constructed on Lot 7 in May 2004, with water samples being taken from each one and analysed for pH, Electrical Conductivity (EC) and Total Dissolved Solids (TDS).
The water levels are being measured in these 13 bores weekly.
Salinity in these bores ranged from 1,400 mg/L TDS for shallow monitoring bores, and 700-9,500 mg/L TDS for deeper monitoring bores.
Private bores analysed from the May-June 2004 census ranged in salinity from 1,500-5,300 mg/L. Soaks and dams ranged in salinity from 150-4,200 mg/L TDS (calculated from average EC:TDS ratio of 0.57).
The LAG submission stated that the current quarry requires a groundwater monitoring programme to establish the degree of damage that it is causing to the Wooroloo Brook groundwater system in Lots 7 and 13 and the degree of dewatering of local farm aquifers that it is causing.
A groundwater monitoring programme has been established to measure water levels weekly in 13 monitor bores.
A census of all accessible private bores, wells, soaks and spring-fed dams was also made in May-June 2004. Water quality analyses (pH, EC, TDS) have also been undertaken on the monitoring bores and representative private bores.
Public Submission 1 stated that the bore data presented in the PER only represented a single sampling period and did not display groundwater level or quality trends or make provisions for fluctuations of bore depth. Suggestions were made to incorporate analysed drill logs, a minimum data set for characterising groundwater systems and variable data sets for determining if salinisation is likely to occur.
Much additional groundwater information has been collected since the original PER, including the construction and logging of 11 additional monitoring bores, census of private bores, wells, soaks and
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spring-fed dams, surveying of elevation of monitor bores and private bores, wells, soaks and dams, and water quality analyses.
Water levels in monitor bores are being measured weekly.
Public Submission 1 stated that the study does not highlight that any hydrogeological survey has been carried out that may indicate the presence of surface and groundwater barriers (such as dolerite dykes) that prevent water from flowing underground, causing water to evaporate and salts to concentrate on the surface. This submission also asked if geological surveys had been carried out in the area to determine the existence of groundwater carriers within the rock that is to be mined. Concern was raised about the subsurface profiles within the Wooroloo Brook area that have water tables between 10 and 20 m.
Aerial photographs have been interpreted to identify major fault structures and dolerite dyke trends. Surveyed water table elevations have delineated groundwater flow directions and gradients.
Public Submission 5 stated that URS started a water survey on neighbouring properties and a number of properties were not finalised and spring fed dams were not surveyed.
All properties in the vicinity, where access was granted by landholders, were surveyed in May-June 2004. All bores, wells, soaks and spring-fed dams were included. All water-points were measured for EC and water level (where accessible), and subsequently surveyed for position and elevation.
The LAG submission stated that Figure 4.4 of the PER (Volume 2) plotted the location of bores BGC1 and BGC2 incorrectly.
Figure 4.4 of the PER (Volume 2) is annotated as ‘Not to scale. Schematic only’. It does not purport to show the accurate locations of BGC 1 or BGC2.
4.5 Vegetation and Flora
Public Submission 1 asked how “vegetation” and “flora” differ.
Encyclopaedia Britannica Online defines flora as “all species of plants that are found in a particular region, period, or special environment”. The term vegetation refers to “the structure and communal relations of the landscape's plant cover, whether it be forest, grassland, or marsh”. In other words, “flora” is the plant life, and “vegetation” is the way in which this plant life comes together to form a community. A plant community (or vegetation type) is characterised by the structure and composition of the plant life.
Survey Timing and Methodology
The Conservation Council submission asked whether the DoE/WRC had asked for a biological survey of ecological values of the disturbed (bulldozed) area in spring 2002 and 2003, and if this was the case, why the PER was developed without the 2003 information.
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The area to which the Conservation Council submission is referring, is located at the southern end of the original Project Area (see Figure 1.3 of PER Volume 2) and was cleared in December 2001. It was included in the area surveyed by Mattiske Consulting Pty Ltd in January 2002 (summer) and October 2002 (spring). Fifteen of the 249 sample sites established by Mattiske Consulting are located in the disturbed area.
The PER was issued for public review in January 2003, prior to the spring of 2003. The DoE did not specifically ask for a survey of the disturbed area in spring 2003. However, BGC has an agreement with the Shire of Mundaring that the progress of the regeneration of vegetation on Lot 11 will be monitored on an annual basis and a report will be submitted to the Shire of Mundaring.
The Conservation Council submission and Public Submission 2 questioned the timing of the vegetation surveys, saying that the first survey was conducted in mid-summer after one of the driest years on record. The Wildflower Society (Eastern Hills Branch) submission, LAG submission and Public Submission 2 asked why there were only two surveys conducted in the course of a single year as the surveys would not have captured ephemeral plant species. Public Submission 7 asked whether the flora survey should have been conducted over a 12 month period to be accurate. Public Submission 5 asked whether conducting only two field surveys was acceptable practice and stated that more field surveys at different times of the year were needed to give a comprehensive list of species. The AVES submission stated that at least four visits (one in each season) are required to be sufficient.
The EPA Guidance Statement on Terrestrial Flora and Vegetation Surveys for Environmental Impact Assessment in Western Australia (EPA, 2004a) states that if the initial botanical survey is undertaken in non-optimal times such as drought, then supplementary surveys must be taken at optimal times. The initial survey was undertaken in the summer months in response to a request from BGC to undertake this work. At all times, it was intended to undertake a spring survey and this was conducted in October 2002.
Despite the dry conditions, it is still possible to undertake extensive botanical studies in summer months, although it is recognised that annual species are added during the spring months. The vegetation communities are largely defined on the basis of structure and floristics (dominants and indicator species), and the vast majority of the perennial species can be captured during any season.
The data had been collected during several visits to the site and also at multiple sites on the survey area. The context of the data set is also important, as Dr Libby Mattiske has been undertaking similar site-vegetation mapping on a local detailed grid system in nearby and other extensive areas of the Jarrah forest since 1976. Therefore there was a reliance on not only the data collected at the specific site, but also the 24,000 plus sites throughout the southwest forest region that has been collected by Dr Mattiske and her team. The data at the site was based on detailed recordings at the 249 grid sites, observations between sites and on interpretation of the aerial photographs.
It is therefore considered that adequate data were collected through the two surveys to address the vegetation and flora factors identified in the EPA Guidelines for the PER.
The AVES submission stated that there may be undescribed flora on the site, but this may not be known as there were only two surveys conducted.
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A thorough survey of the Project Area has been conducted by an experienced team of botanists and ecologists, and resulted in 223 vascular plant taxa from 42 plant species and 112 genera being recorded. Dr Mattiske has some 29 years of experience in flora and vegetation surveys in the jarrah forest (including local and regional mapping experience) and was assisted by team members who have worked extensively in the eastern and northern jarrah forest areas. This depth of experience reduces the risk of flora species not being collected during the surveys, but it is recognised that additional species are often collected if additional survey work is undertaken. The question, therefore, is what is the risk of other significant flora species (such as Declared Rare [DRF] and Priority Flora) occurring on the site. In the case of the proposed quarry site, the risk is considered to be low because the list of species recorded at the site is representative of the northern jarrah forest in this area, and DRF are not anticipated to occur in the area.
The Conservation Council submission requested further information on the number of field days spent during the October 2002 survey.
The January 2002 field survey comprised seven person days. The October 2002 survey included five person field days.
Public Submission 2 asked whether grasses, lichens, fungi and mosses were surveyed.
Non-vascular plant species were not recorded, as this was not part of the scope of work. Although the Mattiske team has undertaken studies on lichens and mosses in the past, both in the Southwest and other parts of the State, there is very little support for taxonomic work in government or academic circles. In fact, historically, specimens have been sent interstate in some instance for identification confirmation.
The EPA Guidelines for the PER did not specify that a survey of non-vascular plants was required, nor are they normally required for surveys of remnant bush in this region.
Survey Findings
Public Submission 5 referred to page 10 of Appendix B which stated, “Despite searching, no Declared Rare Flora species gazetted under the Wildlife Conservation Act (1950-1980) were located in the survey area during the survey undertaken in 2002”. Public Submission 5 asked how this statement could be made after only two site surveys.
A search of the CALM Declared Rare and Priority Flora database was conducted prior to the field surveys to identify those rare and priority species that have previously been recorded in the area and that could occur within the Project Area. This database search generated a list of four declared rare species, two Priority 1 species, five Priority 2 species, 12 Priority 3 species and 10 Priority 4 species that could occur in the area from Mundaring to Chidlow. This list was used as a guide to the species for which to search during the field surveys, but the survey team also searched for other significant species known to occur in the jarrah forest.
As indicated above, the Project Area has been thoroughly surveyed by an experienced team of botanists and ecologists. This included a spring flora survey that was conducted when many of the flora species at
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the site were flowering. Hemigenia viscida (a Priority 4 species) was recorded in the Project Area, but no Declared Rare Flora or other Priority Flora species were recorded.
The CALM submission on the PER stated that, to the Department’s knowledge, all flora species are well represented in land managed within the conservation reserve system.
The LAG submission, AVES submission and Public Submission 2 stated that there is no flora list in the PER or the appendices. The CALM submission stated that it expected the data for the Hemigenia viscida populations to be supplied to this department.
The omission of the flora list from Appendix B of the PER (which provided the flora and vegetation survey report) was due to a production error. The list is provided as Volume 2; Appendix E of this Proponent’s Response to Submissions.
Data on the Hemigenia viscida populations will be provided to CALM independently, although details were provided in Appendix B of the PER.
Subsequent additional work on Hemigenia viscida highlighted the following:
a) This species had been recorded previously on the eastern edges of the Jarrah forest and in pockets within the Wheatbelt (State Herbarium records, Department of Conservation and Land Management 2002).
b) On Lots 11 and 14 Horton Road the Hemigenia viscida was recorded in the heath communities (G site-vegetation type).
c) Hemigenia viscida was recorded in three “heath community” areas on Lots 11 and 14 Horton Road in January 2002. Subsequent field studies targeting this species increased the number of “heath community” areas, on Lots 11 and 14 Horton Road supporting this species, to four. The four heath communities supporting Hemigenia viscida included two areas of the heath community within the proposed expansion area (with approximately 65 plants and 9 plants respectively) and two heath communities to the west of the proposed Project Area (with approximately 1,612 plants and 20 plants). These numbers were recorded by botanists walking parallel through the heath areas and counting plants on a series of transects within the respective heath areas. Consequently, a substantial number of the plants occur outside the development area (including the plants within the larger population that occurs on the western edge of the proposed Project Area).
d) Additional searches were also undertaken in similar communities outside Lots 11 and 14 Horton Road. As a result of these additional searches in nearby reserves and State Forest, another population of some 110 plants was located south of the Mundaring gravel pit operations off Horton Road (to the west of Lots 11 and 14 Horton Road).
A number of submissions referred to the statement in the PER that there were few larger, mature trees in the proposed Project Area. The WBLCDC submission, Public Submission 5, Public Submission 14 referred to a survey conducted by LAG in March 2003 which recorded a large number of trees with visible hollows. The LAG submission stated this “Survey of Significant Trees Within Lots 11 and 14”
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only found 15 Wandoo trees with hollows, the majority of which were within the footprint of the proposed new quarry.
Mattiske Consulting Pty Ltd (2002) states that tree heights greater than 20 m occurred in less that 6% of the sample sites. At 86% of the sample sites, the maximum tree height was less than 15 m and the average maximum tree height for all sample sites was 12.4 m.
Mattiske Consulting Pty Ltd (2002) also states that only small pockets of vegetation within the survey area could be considered to reach the density of foliage cover required to be defined as a forest (>30% foliage cover of the tree understorey species). The majority of the wooded part of the survey area is either woodland (10–30% foliage cover of the tree overstorey species) or an open woodland (<10% foliage cover of the tree overstorey species).
Public Submission 6 asked whether the Proponent agreed that granite outcrops attract special plant communities as described in Nilkulinsky and Hopper (1999).
The vegetation present within the survey area includes an Open to Closed Heath of Proteaceae-Myrtaceae species that occur on the shallow soils on or surrounding outcrops on the upland and valley systems on the Darling Ranges (site-vegetation type G). This was the only vegetation type within the Project Area that was associated with the granite outcrops. It is recognised in Mattiske Consulting Pty Ltd (2002) that this site-vegetation type tends to be dominated by specific herb and shrub species that reflect the soils and moisture associated with outcrops on the Darling Ranges. It is also recognised that this vegetation type is locally significant, as it is associated with localised outcropping supporting a range of species and taxa including, in this survey area, the Priority 4 species, Hemigenia viscida.
Approximately 16.24 ha of site-vegetation type G occur within the survey area. Of this, approximately 7.46 ha will be disturbed during project development. This disturbance is not considered to be significant, as approximately 8.78 ha of vegetation type within the survey area will not be disturbed. In addition, this vegetation type is well represented in the conservation estate (Heddle, Havel & Loneragan, 1980). The CALM submission on the PER also stated that, to the Department’s knowledge, all flora species recorded in the survey area are well represented in the conservation reserve system.
Public Submission 1 stated that there is a lack of baseline monitoring data presented for vegetation for the current quarry operation and that the loss of flora land already cleared in the proposed Project Area needs to be noted. This submission stated that the vegetation survey data has been prejudiced as it may be unrepresentative of the land already cleared.
Detailed vegetation data is held for similar eastern and northern forest areas and in view of the underlying soil changes, it is feasible to map the pre-disturbance vegetation on this area with some degree of accuracy. Further, as some plants still persisted in the area it was possible to confirm boundaries from some of the persisting plants or fallen trees and shrubs.
The loss of flora during the clearing was noted in Mattiske Consulting Pty Ltd (2002) and the PER.
The Conservation Council submission referred to a statement on Page 52 of the PER (Volume 2) which said, “However, as only sections of the south-west forest region have been mapped at the scale
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of site-vegetation type level, it is not feasible to place percentages on representation”. The submission asked why the proponent has not commissioned this work.
Site vegetation mapping has been undertaken in other areas within the southwest forests but is not available to BGC. It is likely that it would take decades with multiple skilled and trained people to undertake this work over the entire southwest forest region. In addition, there is a question of whether this is the responsibility of any particular proponent or the community to support such a massive undertaking. Further, this mapping would not be a one–off need, as communities or site-vegetation types shift through the landscape as climate changes occur.
The Conservation Council submission requested vegetation statistics for the remaining vegetation type within the catchment defined in Figure 3.1 of Appendix G. The submission also asked why the CALM statistics for the vegetation complexes from October 2002 had not been presented. In addition, the submission asked for the representation level of the vegetation complexes to be presented in the context of the local (15 km) area within the Wooroloo Brook catchment as well as a discussion of the representation of the genetic diversity of the species that may occur within the complexes and between catchments.
Detailed work has not been undertaken at the catchment level, so it is not possible to assess the representation of vegetation complexes or genetic diversity.
The CALM submission stated that, to the Department’s knowledge, all flora species are well represented in land managed within the conservation reserve system. The Conservation Council submission asked for a breakdown of the area of each vegetation type in conservation reserves in the local area.
An assessment of these values in the conservation estate was made during the 1970s for the conservation areas designated by the Forests Department. A summary of this information is presented in “Forest Focus” (Heddle, Havel & Loneragan, 1980). Site-vegetation types have not been mapped for the southwest forest region, and therefore it is not possible to supply accurate data for site-vegetation types.
The Conservation Council submission noted that in Table 4.7 it is claimed that some vegetation types are not restricted in their distribution and asked if it was not the case that vegetation types are used as an indicator of general biodiversity.
As site-vegetation types by their very definition encompass more that vegetation (i.e. include site parameters), there is strong evidence to suggest that these site-vegetation types can be used as surrogates for other biodiversity values.
Fire History
The report on the 2002 flora and vegetation survey (Appendix B, Volume 3) stated that, on the basis of field observations and previous experience in vegetation mapping of the Jarrah forest, the majority of the survey area appeared to have been burnt within the last five years. The Conservation Council submission asked for validating information on the claim.
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The LAG submission and Public Submissions 2, 4, 5 and 14 stated that the Project Area had not been burnt in the past five years. Public Submissions 2 and 4 stated that this had been confirmed with the local fire authorities.
Mattiske Consulting Pty Ltd (2002) states that the majority of the survey area appears to have been burnt within the last five years with the exception of a strip along the southern edge of the survey area and within the Open Forest of Allocasuarina fraseriana-Eucalyptus marginata subsp. thalassica. This suggestion was made based on field observations of low litter load.
Logging History
Public Submission 5 referred to Page 11 of Appendix B, which said that there has been a history of logging in the Project Area. And stated that although the project area has been logged, this is no different to any adjacent bushland or for that matter anywhere in this region. This was also raised by Public Submission 2 and the LAG.
The data presented in Mattiske Consulting Pty Ltd (2002) support the extent of the logging in the survey area and it is noted that many trees had coppiced. The report also notes that the evidence of historical logging is similar to that of logging practices undertaken in the Wundowie, Mundaring and York areas. There is no suggestion in the report that historical logging of the Project Area differentiates it from other parts in the region, but indicates previous disturbance of the site.
4.6 Vertebrate Fauna
2002 Desktop Study and Site Inspection
LAG asked who wrote the “Vertebrate Fauna Study” (Volume 3, Appendix D)?
The Vertebrate Fauna Study presented as Appendix D of the PER (Volume 3), was written by Jan Henry. Ms Henry is the Principal of Ninox Wildlife Consulting and has over 20 years experience in conducting fauna surveys in the Goldfields, Southwest, Pilbara and Kimberley.
The Wildflower Society (Eastern Hills Branch) submission, the AVES submission, Public Submissions 1, 2, 5 and 6 stated that a desktop study and brief site inspection were not sufficient and asked why a field survey that included trapping was not conducted for the PER.
A field fauna survey was conducted in November and December 2002 by Biota Environmental Sciences. This field survey included trapping, where Elliott traps were placed at 8-15 m intervals at four locations within the Project Area. The trapping exercise was undertaken between 25 November and 3 December 2003.
Public Submission 1 asked whether a fauna survey involving trapping and releasing of animals would be appropriate to determine species present, their habitat and population densities.
A fauna survey involving trapping and releasing of animals would be appropriate to determine the species present. Subsequent to the desktop study and site inspection undertaken by Ninox Wildlife Consulting, a
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field survey was conducted by Biota Environmental Sciences. Following consultation with the DoE, it was determined that additional information on the following species was required:
Carnaby’s Black Cockatoo (Calyptorhynchus latirostris);Forest Red-tailed Black Cockatoo (Calyptorhynchus banksii naso); Brush-tailed Phascogale (Phascogale tapoatafa);Western Brush Wallaby (Macropus irma);Carpet Python (Morelia spilota imbricata);Dell’s Skink (Ctenotus delli);Rainbow Bee-eater (Merops ornatus); and Western Grey Kangaroo (Macropus fuliginosus).
Therefore the study conducted by Biota Environmental Sciences included trapping exercises to gather information on these species.
The Conservation Council submission stated that appropriate biological survey work should be conducted over an extended period of time over varying climatic conditions and natural events (fire) for scientifically reliable data. The submission stated that an extended survey is essential to capture the area’s full floristic and ecological diversity.
In ideal circumstances, every fauna and flora survey for impact assessment would be conducted over an extended period of time over varying climatic conditions and cover multiple seasonal phases. However, this is not a realistic expectation and survey effort is aimed at the level of the proposal being considered. In this case, the two flora surveys and the targeted fauna surveys were adequate for assessing the potential impacts to flora and fauna for the project.
Public Submission 6 asked how an assertion on rare and endangered fauna can be made in the absence of a site–specific survey.
A thorough literature review was undertaken to provide a comprehensive list of the fauna species that could potentially occur in the area. The literature review included a search of the CALM rare fauna database and a search of the Western Australian Museum’s records of specimens held in their collections. Conducting database searches is a standard component of fauna studies.
Following consultation with the DoE, it was determined that further investigation on rare, threatened or vulnerable species, as indicated previously. Biota Environmental Sciences has since conducted a site-specific field survey to provide an indication of whether these species are present within the project area.
The DoE (Ecological Systems Branch) submission referred to page 12 of the Executive Summary (Volume 1) and the statement regarding mature habitat trees and suitable hollows for nesting. The submission suggested that the statement was misleading as it was in reference to a limited number of vertebrate species and did not consider small species such as reptiles, small birds and bats.
The statement in the Executive Summary regarding the limited number of large habitat trees generally refers to nesting sites for large fauna and cockatoos. The trees present in the Project Area may provide
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suitable habitat for smaller fauna species. Further investigation into the presence of tree hollows within the Project Area was conducted in December 2003. The results of this survey are presented in Volume 2; Appendix F.
The DoE (Ecological Systems Branch) submission stated that the five species listed under the EPBC Act are tabulated but the text only indicates three.
Based on the literature review undertaken by Ninox Wildlife Consulting, there are five species listed under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) that were predicted to occur in the Project Area. Therefore the text in Section 4.6.1 of the PER, which states that there are three species listed under the EPBC Act, is incorrect and should state five species.
The Birds Australia submission stated that the heathlands may be important habitat for a range of insectivorous and nectarivorous birds. This submission also stated that it is likely that a number of the old Marri trees and Wandoo trees in the area (reported as containing nest hollows), may be important for breeding of several species, including the Forest Red-tailed Black Cockatoo and possibly also Baudin’s Black Cockatoo, both listed as threatened species. Public Submission 4, 6 and 9 also stated that there are hundreds of suitable habitat trees in the Project Area.
The tree hollow survey conducted by R.E. Johnstone and T. Kirkby in December 2003 involved an assessment of tree hollows for nesting cockatoos (i.e. Carnaby’s Black Cockatoo and Forest Red-tailed Black Cockatoo). A total of 163 trees with large hollows were visually inspected for signs of use by cockatoos. Of these, 33 trees with hollows that were considered to be most appropriate for nesting were climbed and inspected more closely. Of the 33 trees that were climbed, three were identified as having hollows that had been used over the past 1-3 years, however none of these hollows were used during the 2003-2004 breeding season. Refer to Volume 2; Appendix F for further information.
2003 Targeted Field Survey – Methodology
The LAG submission asked whether the fauna report prepared by Biota Environmental Services (Biota) is a substitute of the original fauna report prepared by Ninox Wildlife Consulting (Ninox) or whether it was an additional report.
The Biota report (Biota and Johnstone, 2003) is an additional, ‘stand alone’ document, however reference was also made to the report previously compiled by Ninox Wildlife Consulting (2002). The ‘Targeted Fauna’ survey was undertaken by Biota and Johnstone (2003) to satisfy a request by the DoE Ecological Systems Branch for additional information on fauna species of potential significance beyond that provided by the original Ninox Wildlife Consulting (2002) report.
Public Submission 7 asked whether the fauna survey should have been conducted over a 12 month period to be accurate. The AVES submission stated that the study was relevant only to the time of year in which it was undertaken and it only provided an informed guess as to what actually exists in the study area. This was also raised by Public Submissions 2, 7 and 12. The AVES submission stated that the survey would need to cover all seasons to be a complete study.
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The Biota and Johnstone (2003) survey was undertaken in accordance with the requirements of the DEP. This survey was intended only as a targeted assessment of specific species, not all fauna present in the study area. The limitations of the study were clearly identified in Section 2.4 of Biota and Johnstone (2003).
In ideal circumstances, every fauna survey for impact assessment would cover multiple seasonal phases. However, this is usually not a realistic expectation and survey effort is typically geared to the level of the proposal being considered. In this case, the seasonal timing of the work was appropriate for the key species targeted by the survey, particularly Dell’s Skink (Ctenotus delli), Carnaby’s Black Cockatoo (Calyptorhynchus latirostris) and Forest Red-tailed Black Cockatoo (Calyptorhynchus banksii naso).
The LAG submission stated that the field survey took place over nine days which represented 2.5% of the year and asked how assumptions could be made on the fauna of an area by sampling 2.5% of the year. Public Submission 17 stated that 10 days on site cannot be indicative of a proper fauna survey and that such a survey has to be seasonal. Public Submission 11 stated that the season and time of day had not been taken into account during the survey. Public Submission 12 and the LAG submission stated that the survey did not document the weather conditions at the time of the survey.
The Biota and Johnstone (2003) survey totalled eight evenings and 11 days of survey effort. The survey was conducted during periods of suitable weather conditions and with daily timing aimed at achieving the optimum results for the targeted species. This was based on recognized best practice methodology and in some cases the discretion of the individual surveyor. If adverse weather had affected the survey results, this would have been noted in the limitations section of the report.
As discussed above, fauna surveys for impact assessment are set at a practical level relative to the scale of the proposal. Contrary to this submissions, a 10-day survey effort, particularly when the exercise is targeted and not a full inventory, is in fact adequate for the required purpose.
Public Submission 11 referred to the methodology applied to the field fauna survey and asked:
how the 25 inch Elliot traps had been modified in relation to trapping of the Brush-tailed Phascogale;how extensive the “extensive systematic censusing” had been for Carnaby’s Black Cockatoo: how extensive the “extensive visual searches” had been for Dell’s Skink; how were “visual searches” done for herpetofauna.
The Elliot traps used during the survey were modified by CALM in order to prevent Brush-tailed Phascogale escape. The traps were modified by the addition of a small latch, as the Phascogale are capable of opening the trap doors with their long claws.
Censussing for Carnaby’s Black Cockatoo (Calyptorhynchus latirostris) was undertaken by walking systematic transects through the study area and using binoculars and listening for cockatoo calls. All sightings of this species and anecdotal evidence (such as feeding remains) were recorded. A total of 163 trees were visually inspected by binoculars for signs of use by cockatoos and a further 33 trees with large hollows were examined by climbing individual trees and inspecting the hollows.
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Visual searches for Dell’s Skink (Ctenotus delli) and other herpetofauna were conducted in accordance with recognised surveying techniques and guidelines set out within Terrestrial Fauna Surveys for Environmental Impacts Assessment in Western Australia (EPA, 2003) and Terrestrial Biological Surveys as an Element of Biodiversity Protection (EPA, 2002). Survey methods included:
walking transects of suitable habitat throughout the survey area;
raking leaf litter;
checking beneath dead or other fallen wood matter;
searching within crevices and fissures of trees; and
using head torches at night to spot animals on trees or other wood matter.
The surveyors involved were Roy Teale (Biota Environmental Sciences) and Greg Harold (Moloch Fauna Consultants), whose combined experience exceeds 45 years.
Public Submission 17 stated that it appears that the wrong sized traps were used. Public Submission 9 asked how the modified Elliot traps could let a Chuditch escape if the traps were modified to decrease the ease of escape for Phascogales. Public Submission 1 stated that the field survey report needed to detail the survey methodology and expected outcomes of the survey process as the survey methods employed were very limited and not adequate to detect target species.
The trap types and survey methodology used by Biota and Johnstone (2003) was appropriate for the targeted fauna species. The Chuditch (Dasyurus geoffroii) caught within the medium-sized Elliot trap at site VO01 was believed to be a sub-adult in order to have entered the trap. Due to its greater size and weight compared to the Phascogale (Phascogale tapoatafa) (Table 8), it was able to force the door of the trap and escape, as noted in Section 3.4.2 of the report (Biota and Johnstone, 2003).
Table 8 Size and Weight Comparison of the Chuditch and Brush-tailed Phascogale
Chuditch Brush-tailed Phascogale Head and Body Length Head and Body Length
310-400 (350) mm (males) 160-261 (199) mm (males) 260-360 (310) mm (females) 148-223 (181) mm (females) 210-310 (275) mm (females) 160-226 (194) mm (females)
Weight Weight 710-2185 (1310) g (males) 175-311 (231) g (males) 615-1130 (890) g (females) 106-212 (156) g (females)
Source: Stahan (1995)
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Public Submission 1 asked whether BGC had applied CSIRO’s avifauna habitat criteria to the proposed site for the determination of suitable remaining vegetation for common bird species and a range of fauna.
The avifauna habitat criteria developed by CSIRO were not used in the determination of suitable remaining vegetation for common bird species and other fauna. The use of these criteria was not relevant to the targeted fauna survey required by the DoE.
2003 Targeted Field Survey – Findings
The LAG submission stated that the Biota report did not document details of the trapping results. Public Submission 10 queried why the Carnaby’s Cockatoo (threatened species) had been left off the Avifauna Species list if foraging had been noted. Public Submission 1 stated that there was no mention in the Biota report of critical habitat size for any of the species targeted, so there are little reference or benchmarking criteria for any species mentioned.
Details of trapping results were clearing presented in Section 3.3 of the Biota and Johnstone (2003) report. Due to the low number of mammals trapped, the detailed trapping results were omitted (with the exception of the individual record of the captured Chuditch) and were given a general appraisal (see Biota and Johnstone, 2003). These capture records and trapping locations are provided for completeness in Table 9.
Table 9 Details of Mammal Trapping Records for Biota and Johnstone (2003)
Site Species Name Common Name Total Opportunistic Macopus irma Western Brush Wallaby 1
VO01 Trichosurus vulpecula Common Brushtail Possum 2 VO01 Tachyglossus aculeatus Echidna 1 VO01 Dasyurus geoffroii Chuditch 1 VO02 Macropus fulignosus Western Grey Kangaroo 3 VO03 Oryctolagus cuniculus Rabbit 1 VO03 Macropus fulignosus Western Grey Kangaroo 7 VO04 Antechinus flavipes Mardo (Yellow-footed Antechinus) 1 VO07 Vulpes vulpes Red Fox 1 VO07 Trichosurus vulpecula Common Brushtail Possum 1
In respect of the cockatoo foraging recorded, Biota and Johnstone (2003) noted that “…evidence of foraging by either Carnaby’s or Baudin’s Cockatoo was noted…” (emphasis added). The possible presence of Carnaby’s Cockatoo was therefore noted in the report, with a more detailed account of the potential breeding value of the project area provided in Section 3.2.2 of Biota and Johnstone (2003).
In respect of habitat sizes, Section 4.1 of Biota and Johnstone (2003) outlined home range sizes for species of conservation significance. This was evaluated in the context of the size of the Voyager project area. Detailed assessment of nesting hollows and other breeding resources was also provided. This latter
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aspect was supplemented by the more detailed work of Johnstone and Kirkby (2003) presented in Volume 2; Appendix F.
Public Submission 11 stated that a few hundred suitable nesting hollows were estimated to occur on the site rather than just a few, as stated in the Biota report. Public Submission 17 stated that a survey undertaken by LAG showed that there were 696 suitable trees on site that could provide habitat for larger bird species.
An additional field survey was undertaken by Johnstone and Kirkby (2003) to carry out a more detailed assessment of the value of nesting hollows on the site for species of conservation significance (see Volume 2; Appendix F). All significant habitat trees on site possessing hollows were surveyed to assess use and nesting opportunities for Carnaby’s Black Cockatoo, Baudin’s Black Cockatoo and the Forest Red-tailed Black Cockatoo. These tree hollows were also assessed for their use by vertebrates of conservation significance such as the Chuditch and Phascogale. Johnstone and Kirkby (2003) assessed 163 trees of potential value on the site in this context. A subset of 33 of these were measured, climber, checked and mapped. Only three of the trees were identified as having hollows containing evidence of use by cockatoos believed to be the Forest Red-tailed Black Cockatoo. These surveys were undertaken by R. Johnstone and T. Kirkby who have many years experience in this type of survey. Mr Johnstone is considered to be one of the leading ornithologists in Western Australia, has edited books for the Western Australian Museum and is a coordinator of the Cockatoo Care Programme.
Public Submission 10 stated that the site to be cleared is an important habitat for native fauna and that the Carnaby’s Cockatoo feeds on the plants in the area as does the Red-tailed Cockatoo. Public Submission 18 stated that the feeding habits of the Baudin’s Black Cockatoo had not been considered to any satisfactory level other than to mention that there was feeding evidence of the species on the property. Public Submission 2 stated that feeding and roosting areas for Carnaby’s Black Cockatoo, Baudin’s Black Cockatoo and the Forest Red-tailed Black Cockatoo are just as important as nesting areas and that this topic was not mentioned in the Biota report.
Biota and Johnstone (2003) provided an assessment of the utilization of the site by the various cockatoo species appropriate to the level of the project. This was further supplemented by the specifically targeted tree hollow study of Johnstone and Kirkby (2003) (Volume 2; Appendix F). Both studies considered the various values of the site for the cockatoo species, including the breeding, foraging and roosting. The most important aspect of this particular site relates to breeding resources for the species in question. Johnstone and Kirkby (2003) found little or no evidence of breeding use by the species of interest or indeed of trees providing suitable hollows.
Public Submission 1 asked why Black Cockatoos were not considered to be a focal species for remnant vegetation protection. It referred to the map on page 10 of the Biota report and stated that from what is shown, the area already cleared contained the most highly suitable habitat for black cockatoos and the proposed quarry site will remove the rest of the habitat.
The current formal assessment was limited to consideration of the impacts of what is contained in the current relocation proposal. The field surveys of Biota and Johnstone (2003) and Johnstone and Kirkby (2003) were only focused on the area proposed for quarry relocation. It is therefore not possible to make
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any retrospective analysis of the value of the habitats that are already cleared for these species from the available data. The values of the area proposed for quarry relocation for black cockatoos is discussed in the previous responses above.
Public Submission 1 stated that the survey results indicated that foxes were present in the area, but no recommendations were made to reduce the numbers to protect native fauna. It also stated that there were no recommendations on how to enhance the habitat for phascogales, wallabies, carpet pythons, Dell’s skink, bee eaters and kangaroos.
Fox control is undertaken at a regional scale by CALM, including in the locality of the Voyager Quarry relocation. A Fauna Management Plan for the Voyager Quarry has been prepared (see Volume 2; Appendix G) and will be submitted to the relevant government agencies (CALM and DoE) for approval prior to implementation. This plan included management measures addressing pest species and enhancement of habitat for target species at the local scale.
Public Submission 1 stated that there is no recommendation to limit fauna deaths from traffic movement. It suggested that speed of quarry traffic be limited, night movements of vehicles be limited and a driver education programme be implemented.
The Fauna Management Plan (Volume 2; Appendix G) discussed in the previous response contains a work method to minimise fauna deaths, interpretation boards, other signage and driver education recommendations.
Public Submission 11 quoted the Biota report as saying that Dell’s Skink is “likely to be in low numbers” and asked how low these numbers would be.
Limited information is available on the population density, distribution and local occurrence of Dell’s Skink, however studies undertaken in the western Darling Range have been recorded its presence (Worsley Alumina, 1985). Dell’s Skink has also been recorded from Mundaring and 7 km east of Sawyer’s Valley as noted in Section 3.4.2 of Biota and Johnstone (2003). The field survey found that whilst the habitat on site was suitable for Dell’s Skink, the location was possibly too far east for this species. The timing of the survey was within the optimum activity period for this species but no individuals were recorded. The survey followed a long period (some three years) of sub-optimal rainfall and the dry conditions may have contributed to the low population densities, possibly accounting for the lack of individuals recorded throughout the survey.
The LAG submission stated that it believed that Biota’s estimate of a current population of 25-30 Western Grey Kangaroos is low, by a factor of two of more.
The estimate of Western Grey Kangaroo numbers was based on field inspection of regularly used access points surrounding the site. Other field data suggest that the estimate appears to be of the right order with nine Western Grey Kangaroos sighted during diurnal searches and 15 during nocturnal searches.
Public Submissions 9 and 11 stated that there were several spotlighting excursions for Carpet Pythons and asked how many is “several”, at what time the excursions occurred and whether the excursions occurred during times when there was noise and vibrations from the quarry blasting and traffic. Public
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Submission 10 asked why three spotlighting excursions were undertaken to locate a vulnerable species and stated that more would be required during summer. The LAG submission stated that a Carpet Snake was found on a property in 2000, which increases the likelihood of others being on the quarry site.
Three evening spotlighting excursions were undertaken to search for the Carpet Python. No quarry activities, such as blasting or heavy traffic took place during the surveys, as the quarry was not active during the time most appropriate to search for the species (early evening). As noted in Biota and Johnstone (2003), Carpet Python are typically recorded at low densities and are not likely to be present in any abundance with the project area. The findings of the survey support this. A single record of Carpet Python from a nearby property does not alter this assessment for the purposes of the project area currently in question.
4.7 Invertebrate Fauna
The Conservation Council submission asked why it was reasonable to assume that if the distribution of vegetation type is not restricted, then other components of the region’s biodiversity, such as soil microorganisms, will also not be restricted. It also asked why a soil microorganism survey has not been conducted.
The Proponent cannot assume that other components of the region’s biodiversity, such as soil microorganisms, are not restricted based on the fact that the vegetation types are not restricted. Field surveys would need to be undertaken to determine whether certain species are restricted to the Project Area. A soil microorganism survey was not conducted as it was not a requirement of the EPA Guidelines and these surveys are not typically requested by the EPA for projects in this region.
The LAG submission questioned the timing of the land snail survey as the survey report presented as Appendix F (Volume 3) stated that any such survey that is carried out during winter [i.e. July], particularly in the southern part of the State, tends to yield lower numbers of snails than in drier seasons. Public Submission 5 stated that the people who conducted the spider and snail studies said that there was not enough time to conduct a comprehensive study of the area.
The land snail survey was undertaken when the survey team was available to conduct the work. Although it is not ideal to conduct land snail surveys in winter, valuable data can still be obtained from this work. Further land snail survey work has since been conducted in May 2004, as this was a more suitable time for the additional survey work to be undertaken.
With regards to the time allowed for the initial spider and land snail surveys, the Proponent did not place time constraints on the land snail and trapdoor spider survey work. It is understood that the personnel conducting these surveys could only allocate a certain amount of time for this survey work, as they had other work commitments. To gather additional data on land snails and trapdoor spiders to determine the conservation significance of the species already collected within the Project Area, additional survey work has been undertaken and the results are presented in Volume 2; Appendices H and I. The results of the trapdoor spider survey are summarised by URS in Volume 2; Appendix H and the full reports prepared by
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York Main and Trent (2004a and 2004b) and Biota Environmental Sciences are also presented in Volume 2; Appendix H.
Public Submission 10 stated that the PER mostly emphasised the snails and spiders, and commented very little on the species that were to be displaced or killed by the expansion whereas most people give snails and spiders very little thought.
It was a requirement of the EPA Guidelines for this Project to undertake land snail and trapdoor spider surveys, as these species are poorly dispersing. Based on advice received from the DoE, a targeted vertebrate fauna survey of species to be displaced by the Project was undertaken by Biota Environmental Sciences in November - December 2002. A copy of this report was sent to those parties that had made a submission on the PER.
Public Submission 1 asked whether the burrowing method suggests that the unrecorded trapdoor spider is a new sub-species. The DoE (Ecological Systems Branch) submission stated that the significance of the trapdoor spider Gaius sp. is still conjecture. This submission also asked whether the species was the same as Wheatbelt or Goldfields specimens and if the species had been identified in the Darling Range.
Spider taxonomy does not generally accept the concept of sub-species. The Gaius sp. trapdoor spider is likely to be a new species. The Voyager (male) specimen has some morphological affinity with Gaiusspider populations found farther south (i.e. Collie) and may either be the same or a different species (derived from a possibly once continuous population). More morphological comparisons need to be made, such as, comparisons on samples of internal genitalia of females (from Voyager) to spiders from Collie and comparisons of male specimens (from Voyager) to those from Collie to confirm its taxonomy.
The Gaius sp. trapdoor spider is not the same species as specimens found in the Wheatbelt or the Goldfields. A specimen of the Gaius sp. was found south of the quarry (off Brookton Highway) and may represent the southern extent of the known distribution of the species.
The significance of the Gaius sp. is:
Taxonomic – based on the distinctive burrowing behaviour (regarded as a taxonomic character) and some morphology, the species is near the base stock of the two genera Eucyrtops and Gaius.
Biogeographic – the presence of the genus Gaius in the Darling Range suggests the persistence of a relictual stock before the radiation of the genus on the inland plateau in response to more arid conditions.
Further field surveys were undertaken in March and November 2004 to determine the distribution of the Gaius sp. and collect specimens for taxonomic analyses. The results of these surveys are presented in Volume 2; Appendix H.
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The LAG submission asked why further work has not been conducted on the three unnamed and undescribed snails.
An additional land snail survey was undertaken in May 2004, which focussed on the three poorly known and unnamed species found in the 2002 land snail survey (Volume 2; Appendix I). The purpose of this additional work was to survey potential suitable habitats in the Darling Scarp region to gain a better understanding of the geographical distribution of these land snail species.
The survey covered areas within the Project Area and areas within State Forest No. 13. Land snails belonging to the unnamed species of the genus Bothriembryon were found at four of the survey stations. The survey stations were located within the State Forest, on hilltops in the vicinity of Inkpen Road, within the Shire of Northam. These snails appeared to be of the same species as those that were recorded in the Project Area in 2002. The results of the study suggest that this species of Bothriembryon seems to be endemic to this area of the Darling Range and is not conspecific with other species found further south on the Darling Range (Slack-Smith, 2004).
Tiny specimens from the family Punctidae were found at eight survey stations, one within the Project Area and the rest within State Forest. These specimens were considered to be conspecific with those found within the Project Area during the 2002 survey and appear to belong to the genus Westralaoma.This species appears to inhabit a more diverse range of habitats than the Bothriembryon species.
The other unnamed and undescribed species from the genus Luinodiscus, which was found in the Project Area during the 2002 survey, was not found during the recent survey. However, the specimens seem to be the same or closely-related to species that have been found at various localities on the Swan Coastal Plain (Slack-Smith, 2004) (refer to Volume 2; Appendix I).
Public Submission 1 asked how many trapdoor spiders were located in the area already cleared by BGC.
The survey undertaken in 2002 included a search for trapdoor spider burrows in the area cleared by BGC in 2001. Two burrows were located within the area cleared. These were located at Sites B21 and B22. Therefore, assuming that both of these burrows were occupied, there was a maximum of two spiders located in the area cleared by BGC.
The DoE (Ecological Systems Branch) submission asked what studies are being undertaken to determine whether the Gaius sp. occurs at other sites in the Darling Range. The LAG submission asked when BGC would conduct the follow-up trapdoor spider work.
An additional trapdoor spider survey was conducted in March 2004 to determine the population size and distribution of Gaius sp. spiders within Lots 11 and 14, Horton Road. The survey work also included a study of the habitat preferences of this species and a regional survey. A male specimen of the Gaius sp.was also collected in pit traps to allow a taxonomic study to be undertaken and the spider to be named.
The regional survey (refer to Volume 2; Appendix H) covered a broad area occurring between the Project Area and the intersection of Brookton Highway and Beraking Road and was undertaken over four days.
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Searching of the reserves and land vested in the Water and Rivers Commission was also conducted. Some Gaius sp. burrows were identified in the following areas, outside of Lots 11 and 14:
2 burrows were located in the land vested in the Water and Rivers Commission, immediately south of the Project Area;
2 burrows were located in the Avon Location 27937 (Crown land); and
1 burrow located in an area near the Brookton Highway and Beraking Road intersection.
Discussion of findings with Dr John Dell of the EPA Service Unit indicated that the conservation significance of the spider was still unresolved, and that a quicker way of resolving this issue may be to undertake genetic analyses to confirm the spider’s taxonomy.
Subsequently a further survey was conducted in November 2004 to collect specimens for taxonomic work and also search additional sites in the region for more populations of the Gaius sp. spider. Out of 10 sites searched, spiders were found at the Voyager Quarry and the Beraking Pool Road/Brookton Highway intersection. However, a robust population (some 25 spider burrows) was found to occur at this latter site. It is likely that these spiders are the same species as that found at the Voyager Quarry, but it is also likely that they are genetically isolated.
It is proposed to collect a male specimen from the Beraking Pool Road population next autumn and undertake morphological analyses to confirm its taxonomic affinity with the Voyager population.
4.8 Social Setting
In response to a statement made in the Executive Summary (Volume 1) that there are some six residences located within a 2 km radius of the existing Voyager Quarry, Public Submissions 2, 5 and 15 stated that there are many more residences in the affected area. This was also raised in Public Submission 4, which stated that there are 15 residences within 2 km of the proposed quarry and five properties within 1 km of the site. The LAG submission stated that there are 19 residences impacted by the existing quarry.
The LAG submission stated that the existing quarry is located between 1.1 and 2 km from a cluster of homes belonging to the local farming community, and that the proposed quarry would be located much closer to these homes, with the nearest being only 500 m from the blasting faces.
Based on the information presented on Figure 2.1 of the LAG submission, which shows the locations of the nearest residences, there are seven residences within a 2 km radius of the existing Voyager Quarry. Figure 2.1 of the LAG submission also shows that there will be 12 residences within 2 km of the proposed quarry, with the closest residence being approximately 560 m from the western face of the proposed quarry pit.
Public Submission 2 and the AVES submission compared the proposed buffer to the nearest residence of 0.5 km for the Voyager Quarry to the 3 km buffer that Pioneer has. Public Submission 4 stated that
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the Pioneer quarry had to move 2.5 km further from the residents to place a 4.0 km buffer zone between the quarry and the residents.
BGC recognises that the quarry expansion will reduce the width of the existing buffer to the nearest residence to 0.5 km. As indicated in Section 2.1.2 of this document, there are no other sites available and BGC has no option but to expand westward from its existing quarry. However, the new quarry has been designed so that the crusher, screens and stackers are below ground level (approximately 30 m below ground) and will be less of a disturbance than the existing quarry. Construction of the proposed quarry can also be managed to ensure that noise regulations are met and dust is managed appropriately.
4.9 Noise
Many of the public submissions indicated that noise from the existing quarry created problems for local residents. Public Submission 8 stated that noise (drilling, blasting, carting, crushing and trucking) is one of the key problems of the existing quarry. Public Submission 5 stated that the noise could be heard from the crushers, rock drill, the rock breaker and all the moving machinery, and that some residents are recording noise levels of >50 dB on their sound monitors. This submission also stated that some residents are wearing earplugs to enable them to sleep.
BGC acknowledges that the existing quarry operations could have created audible noise at some residences under favourable weather conditions for noise transmission. Studies undertaken of the existing operations show that quarry noise will be audible at many residential locations. The levels of noise at various locations are given in the PER specifically in Appendix H of the PER (Volume 3). The maximum indicated level recorded was 48 dB(A) during the day period.
It is not possible to comment on the levels greater than 50 dB(A) recorded by the residents without detailed information on:
Experience of the tester;
Instrument compliance status;
Instrument setting;
Reported value ie. LA10, LAeq, Lmax, LinPeak etc.; and
Observation comments.
It should be noted that many noises in the environment will exceed 50 dB(A) such as talking, bird calls and traffic, and special care is required when attempting to identify a particular noise source.
It should also be noted that BGC has since fully enclosed the primary crusher and purchased new, quieter equipment in an effort to reduce noise levels from existing operations.
Public Submission 9 indicates that the residents living close to the quarry are already heavily impacted by noise from extraction operations 22 hours per day. The LAG submission stated that the machinery used in quarrying, blasting, rock drills, crushers, conveyors, trucks etc. creates a noise that is very
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offensive and intrusive. Public Submission 3 stated that the constant noise of the crusher is punctuated by the noise of blasting, a sound that varies from annoying to alarming. This submission also stated that one of the reasons why the author(s) have not visited their property for over a year is because of the noise. Public Submission 16 stated that noise is a sensitive issue that needs to be resolved.
In terms of the existing operations, the major source is the primary crusher, which has recently been fully enclosed to substantially reduce noise emissions.
The tertiary crushing system now operates from 0800 to 0400 hours Monday to Friday (20 hours per day) and 0800 to 1200 hours on Saturday.
The relatively noisy pit operations which includes the drill and intermittent rockbreaking operations is a daylight only operation between 0800 and 1700 hours. These initiatives will reduce the current level of noise, however it must be stated that further and more substantial noise reductions will be gained as a result of the proposed relocation.
BGC acknowledges that noise is a major issue that needs to be addressed for the relocation of the Voyager Quarry. To address this issue, a noise study was conducted by Herring Storer Acoustics (HSA) for the PER and the results were provided in Appendix H of the PER (Volume 3). In addition, a supplementary report (Volume 2; Appendix K) was prepared by HSA to:
Verify the reliability of the acoustic model;
Update the acoustic model to include noise from the rockbreaker operations, noise reduction from the enclosure of the primary crusher and noise from product haulage off-site; and
Address the issue of construction noise.
The supplementary report was peer reviewed by Langford Acoustical Services in December 2004. It was considered that the modelling undertaken provided a realistic and practicable assessment of the present and proposed operations and that the predictions derived from the model are considered to be accurate. The full text of the peer review by Langford Acoustical Services is presented in Volume 2; Appendix K following the HSA supplementary report.
Public Submission 1 suggested that BGC carry out regular monitoring and apply recognised criteria to help in the decision making for determining blasting times.
BGC now monitors the wind direction and wind speed at the existing quarry. This data is used by Orica to determine appropriate blasting times. BGC will implement this method at the proposed quarry, and ensure that blasting is conducted under appropriate wind conditions to minimise disturbance to residences. In addition, the DoE has developed a noise monitoring programme which includes meteorological monitoring. The programme will be implemented at the existing quarry once LAG has provided confirmation that the programme is acceptable.
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5 Response to Submissions on Community and Government Consultation
BGC made a commitment in the PER that the company would establish a Community Liaison Group (CLG) to facilitate two-way communication about the site operations. The LAG submission stated that it had proposed that a CLG be set up after the clearing in December 2001 and had presented the concept to BGC but that it had been rejected. The submission stated that BGC became interested in the CLG concept once PER preparation had commenced. The WBLCDC submission stated that the structure of the CLG did not have full community support from key stakeholders (WBLCDC and LAG).
BGC disputes the claim made by the LAG that BGC rejected the concept of the CLG. It also rejects the claim that BGC only became interested in the CLG concept once PER preparation had commenced.
Prior to each meeting BGC sends an email with the minutes from the previous CLG meeting and the agenda for the next meeting. BGC then follows this up with a letter containing the minutes and agenda. These emails and letter are sent to the following key stakeholders:
DoE;
Shire of Northam;
LAG;
WBLCDC; and
other community members who have registered interest.
Therefore, although the WBLCDC and LAG have not, until very recently, supported the CLG, BGC maintains contact with these parties and endeavours to keep them informed of CLG activities.
Public Submission 4 stated that a CLG had been suggested by LAG and a draft terms of reference had also been suggested. The LAG submission stated that LAG, the Shire of Northam and the WBLCDC had set the terms of reference for the CLG. Public Submission 5 stated that the CLG was not working as BGC refused to work out the Terms of Reference for the group and would not appoint an independent chairperson. Public Submission 4 stated that a CLG was “never formed and will never operate satisfactorily whilst BGC refuses to be open and honest with the residents”.
In a letter from the Secretary of the LAG dated 1 July 2002, LAG acknowledges that BGC has recognised the need for ongoing community consultation and does not state that the CLG was suggested by LAG.
A draft terms of reference were presented by the LAG and the WBLCDC at the first CLG meeting on 26 November 2002. Therefore the terms of reference were set by the LAG and WBLCDC only. The terms of reference were discussed at the meeting and BGC was to consider these and report on its decision at the next meeting. At the next CLG meeting on 29 January 2003, BGC reported on its decision and had agreed to accept seven of the nine terms of reference. However, members of the LAG or WBLCDC were not present to record this or negotiate the terms of reference. The LAG has maintained the stance that the CLG will not exist until the terms of reference have been defined and agreed by
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participants, however LAG and the WBLCDC have not attended the CLG meetings to progress setting the terms of reference.
It is not BGC’s intention that Graham Kierath will be the chairperson in perpetuity. However, his involvement was principally to ensure that the meetings were run in a cordial manner. In the CLG meeting held on the 23 April 2003, Mr Kierath offered the role of Secretary to anyone who volunteered. To date, a volunteer to take on the role of Secretary has not been received. In August 2004, BGC advised residents that the CLG would be wound up unless LAG and WBLCDC attended. Therefore, LAG and WBLCDC attended the meeting of 26 September 2004, where BGC invited them to nominate an independent chairperson for the next meeting.
The AVES submission stated that the Executive Summary (Volume 1 of the PER) mentions a CLG but does not mention what the powers of this group would be. The WBLCDC submission stated that terms of reference have not been agreed to, nor how the group will operate.
The objective of the CLG is to enable people to raise issues and concerns about the existing quarry and receive a response from BGC.
The powers of the CLG would mainly involve having access to monitoring information provided to government agencies and having an input to all monitoring procedures.
As stated above, draft terms of reference were presented by the LAG and the WBLCDC at the first CLG meeting on 26 November 2002. Following this meeting, the terms of reference were considered by BGC and the outcome was presented at the next CLG meeting on 29 January 2003. The terms of reference were largely agreed upon by BGC as shown in Table 10.
Table 10 Resolution of Terms of Reference
Number Terms of Reference Proposed by LAG and WBLCDC
Terms of Reference Agreed by BGC
1 CLG operates as an overseeing monitoring body. CLG operates as an overseeing monitoring body. 2 CLG will have monitoring rights (analysis of
which is born (sic) by BGC and the data is (sic) made full available with (sic) the CLG).
CLG will have access to the monitoring information provided by BGC to the government agencies.
3 CLG members have inputs on all monitoring procedures across all disciplines e.g. dust, noise, water monitoring, surface water management, revegetation, clearing.
CLG members have input to all monitoring procedures.
4 The CLG is responsible for the environmental reporting of the operation.
Not agreed, because BGC is the entity that provides the reports and the CLG will have access to these reports.
5 CLG has full access to all monitoring data. Production to be reported to the CLG. 6 Quarterly monthly production reports are made to
the CLG. CLG has reasonable access to all monitoring data.
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Table 10 (continued)
Number Terms of Reference Proposed by LAG and WBLCDC
Terms of Reference Agreed by BGC
7 CLG consulted on any change min (sic) operation procedures of the quarry.
CLG consulted on any substantial change in operation procedures of the quarry.
8 CLG appoints an independent environmental consultant to the Group.
Not agreed, as this does not seem necessary.
9 A quorum shall consist of:
– BGC representative;
– LAG representative;
– LCDC representative;
– DEP representative; and
– Northam Shire Council representative
Not agreed, as it was not acceptable that the meeting could be cancelled because the absence of one person.
The AVES submission asked whether the CLG would apply to the proposed quarry or the existing quarry, and whether it would have the right to inspect the project at any time and to report to the appropriate authorities any deficiencies and/or transgressions. This submission also asked whether the group could implement processes to address the concerns of the public, and whether its decision would be final and available to the public. The submission also stated that if the CLG was formed, it was essential that it be independently chaired (by a person who is not associated with BGC), adequately financed and in charge of its own affairs.
The CLG would apply to the existing and proposed quarries, as the aim of the group is to facilitate communication about the site operations. The CLG meetings would provide a forum for the concerns of the community to be discussed and BGC could consider modifying their environmental management measures or operations to address community concerns.
The CLG would not have the right to inspect the quarry at any time, as the regulatory authorities already conduct inspections of the quarry and it is anticipated that they will continue to conduct inspections of the proposed quarry, if the quarry relocation project is approved. LAG has recommended an independent chairman and BGC are investigating his appointment. Future meetings should now be more productive than past meetings.
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6 Response to Submissions on the Environmental Effects Summary
6.1 Identification of Environmental Effects
Public Submissions 6 and 2 asked why BGC site personnel were involved with the environmental risk assessment and what qualifications they held in this regard.
When conducting risk assessments, it is important to involve site personnel, as they are familiar with the activities that could potentially cause environmental harm. Therefore, it was essential to include BGC site personnel in the environmental risk assessment. However, a trained environmental professional facilitated the workshop that was held with the BGC personnel. The facilitator was able to assist BGC personnel in identifying the environmental risks associated with the activities at the quarry.
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7 Response to Submissions on Environmental Issues and Management
7.1 General
Public Submission 6 stated that BGC should employ an environmental officer.
BGC has employed a Manager - Quality, Safety and Environmental Systems at the existing Voyager Quarry. This officer commenced work at the quarry in May 2004.
The LAG submission stated that environmental and amenity issues that had negatively influenced the project were made to be “inconsequential”.
In the environmental assessment for the Proposed Relocation of the Voyager Quarry, the environmental and amenity issues that were relevant to the project were thoroughly investigated. The issues that negatively affected the Project were presented in the PER and management strategies to minimise the impact were proposed. It was not the intent of the PER to make issues that negatively influenced the Project to be inconsequential, rather the intent was to identify all environmental and amenity issues and propose solutions to manage these impacts.
7.2 Landform and Soils
The Office of Soil and Land Conservation submission stated that, in relation to soil erosion, the proponent has identified the relevant issues, but has not at this stage given much indication as to how it intends to manage those issues and their possible impacts.
Erosion will be managed using industry best practice techniques, including construction of stable drains, to manage surface water flows, using soil conservation techniques to prevent erosion, using settling basins as required to collect sediment, and operating according to an erosion management plan. The erosion management plan that will be used is detailed in Section 2.3 of Volume 2; Appendix B.
The AVES, WRC and WBLCDC submissions referred to page ES-9 of the Executive Summary (Volume 1), which stated that problems with erosion are only likely during the wet months of the year (May to September). These submissions stated that major erosion is far more likely to occur as the result of sudden summer storms and not during the normal wet season.
Public Submission 1 stated that, as the Project Area was on a mid to upper slope with a slope class of 7%, significant earthworks would be required to minimise water movement from the unvegetated slope surrounding the proposed quarry. Public Submission 4 asked what soil conservation techniques would be implemented to manage the erosion risk. The WBLCDC asked how erosion and turbidity would be minimised off-site.
Details of the erosion management plan for the proposed quarry site are given in Section 2.3 of Volume 2; Appendix B and Appendix G of the PER. Potential impacts on erosion and stream flow turbidity are discussed in the PER, and are expected to be limited to the area of the Western Stream when excess, fresh
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water is released from the quarry. It is planned to upgrade this stream so that it can safely accommodate the water released, and no erosion or adverse impacts on the turbidity of stream flow is expected as a result of activities at the proposed quarry. Details of the proposed upgrade to the Western Stream are given in Section 2.3.3 of Volume 2; Appendix B and Appendix G of the PER.
Public Submission 2 asked when the final Soil Management Plan would be released.
The erosion management plan is provided in Section 2.3.3 and Figure 11 of Volume 2; Appendix B.
7.3 Surface Water
Existing Situation
The existing quarry operation is not part of the proposal being assessed under the PER but a number of submissions raised issues relating to current surface water impacts and management. These are presented below.
The WBLCDC submission asked whether the sealing of the access road to the existing quarry had changed the water use for dust suppression, and if a large amount of water is unused, whether it would be discharged to the Wooroloo Brook
Sealing the access road has reduced the volume of water used for dust suppression, but dust suppression within the quarry and on the stockpiles still has a major water requirement.
Water in excess of processing and quarry requirements is released to the Eastern Stream, which is in the headwaters of Wooroloo Brook.
Public Submission 4 stated that there is no evidence to show that the existing quarry has not contributed to the salinity of Wooroloo Brook. Public Submission 5 stated that the property to the north of the proposed Project Area has salt starting in the paddocks that are closest to the quarry. This submission stated that, since 1991, the salt level in their dam has increased despite planting hundreds of trees on the property. This submission also stated that salt scalds have appeared in some areas of their property. Public Submission 1 stated that aerial photos clearly showed downstream degradation from the current operation, caused by the release of quarry water.
Studies undertaken for the PER and subsequently have indicated that the net effect of the existing quarry is to reduce salinity in the Eastern Stream near the quarry. Salts scalds to the north of the quarry are a result of rising groundwater caused by clearing for agriculture and are not caused by activities at the existing quarry. This is discussed in the PER and in Volume 2; Appendix B of the Response to Submissions.
The area of discolouration at the north eastern corner of the existing quarry, evident on aerial photos, is partially a result of seepage from the quarry area and partially an existing feature of the area. Seepage water discharged from the quarry is sourced from the Quarry Dam and rainfall and percolates through the
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compacted gravel base that the quarry area is constructed on. This water typically has a salinity of around 1,000 mg/L TDS or less. The discolouration evident on the aerial photography is a result of changed vegetation and possibly iron staining and is not a saline scald.
Historical aerial photography of the area (Figure 6 in Volume 2; Appendix B) shows that there was seepage in the area of the stain prior to construction of the quarry. This was groundwater discharge as a result of clearing for agriculture, and probably still contributes to the current stain.
The Wildflower Society (Eastern Hills Branch) submission referred to Section 7.3 of the PER (Volume 2), which stated that the discharge from the current quarry operations increased streamflow and lowered the salinity levels in the streams near the quarry. The submission asked for recorded and independently evaluated data from the existing operations to support the statement that the pit-harvested water has improved downstream salinity levels.
URS has undertaken a number of observations of stream flow that confirms the models predictions. These results were discussed in the PER documents and further observations and analysis is given in Section 3 of Volume 2; Appendix B.
Public Submission 1 stated that as there are no data presented prior to 1991, there is no evidence that agriculture has contributed to local degradation issues.
A substantial amount of information has been collected that confirms the impact of agriculture on stream flow. Transects along the streams near the quarry, conducted by URS in July 2002, clearly demonstrate that saline inflows from salt scalds and saline seepage areas in the agricultural areas are the main contributor to stream salinity.
Salinity in the Quarry Dam, which is likely to be the main source of water released from the existing quarry to the streams, and in stream flow adjacent to the quarry and above the saline seepage areas, averages about 1,000 mg/L TDS, which is less than salinity of stream flow in the vicinity of saline seepage areas (typically 2,000-4,000 mg/L TDS).
The effect of clearing for agriculture on groundwater levels and land and stream flow salinisation is well documented in the literature (see, for example: Water and Rivers Commission, 2000; Agriculture Western Australia, 2000). Saline seepage areas north of the quarry exhibit characteristics typical of an environment where saline groundwater levels have risen as a result of clearing for agriculture.
Aerial photography taken in 1989, prior to development of the quarry, also shows seepage in the area of the quarry; this seepage was caused by clearing for agriculture. This photography is shown in Figure 6 in Volume 2; Appendix B.
Monitoring data collected by BGC and discussion on the extent of salinity in the quarry area and impacts of the existing and proposed quarry on stream flow and salinity are given in Appendix G of the PER and Volume 2; Appendix B, Section 3, of the Response to Submissions.
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The LAG submission stated that salinisation of creeklines due to agriculture had already begun to occur in patches prior to quarrying, but salt scalds and land degradation already evident in the downstream area of the quarry may be as a result of BGC poor water management practices. The LAG submission stated that the current quarry produces discharges that introduce excessive salt loads into the Wooroloo Brook during year-round flows.
Review of historical photography for the area (flown in 1989) shows clearly that salinisation was already well advanced in the streamlines through and north of the quarry area prior to construction of the quarry (see Figure 6 in Volume 2; Appendix B). As is discussed in Appendix G of the PER and in further detail in Volume 2; Appendix B to the Response to Submissions, the quarry’s net impact has been to reduce the salinity of stream flow and increase the volume of stream flows in winter in the streams just north of the quarry. Neither of these effects would cause increased salinisation of the streams and in fact may have reduced salinity for some distance downstream.
Surface Water Studies Conducted for the PER
The Wildflower Society (Eastern Hills Branch) submission asked for the reference to the data source for Figures 4.1a, 4.1b, 4.2a and 4.2b presented in Appendix G (Volume 3) and the years for which the data were recorded. It also asked where the stream salinity flow data was obtained from and when it was obtained.
The results presented in Figures 4-1 and 4-2 are predicted using the modelling techniques and assumptions detailed in Appendix G of the PER. Results given in Figure 4-1 are annual totals, projected into the future assuming average weather conditions and changing quarry operational phases. Results given in Figure 4-2 are average monthly values for a range of catchment conditions and quarry phases.
The Conservation Council submission referred to page 2-1 of Appendix G (Volume 3) and asked if the SWAT modelling was two-dimensional and thus unable to cope with residual salt in the unsaturated zone.
The SWAT model was used to predict runoff and the catchment water balance, not groundwater flows nor the amount of salt in the unsaturated zone.
The Conservation Council submission referred to Table 4.1 of Appendix G (Volume 3) and asked:
if the table should be titled “Predicted Water Balance for the Proposed Project Area” to reflect the total area affected and the predominantly two-dimensional nature of the modelling;
The analysis relates to the pit, not the project area (which is larger than the pit) so the title is correct.
why there is no rainfall inflow shown for the forested area prior to development;
Rainfall inflows for the ‘Prior to development (forest)’ scenario was not included in Table 4-1, but is 100% of inflows for the forested area prior to development.
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in relation to the amount of inflow during construction, if the Proponent expects less rain than normal to fall in the Project Area during the construction phase;
The pit area increases in size over time during construction. The amount of rainfall inflow is calculated based on the size of the pit, so increases during the construction period.
if a water balance model could be broken down further as there is not enough detail on the water balance during an environmentally sensitive phase of pit construction;
Table 4-1 of the PER shows the range of variation likely in the major water balance components during construction and details are discussed separately. The main potential impacts on the environment relate to seepage of water into/out of the pit and release of excess fresh water to local streams. A detailed analysis of hydrogeology related to the seepage inflow/outflow components of the water balance for the pit, including change during construction period is given in Section 2 of Appendix G of the PER. Effects of release of fresh water to local streams is discussed in Section 4-4 of Appendix G of the PER.
why there were no allowances for “runoff” and “process water” in relation to the outflow.
No runoff water from outside the pit area will enter the pit; runoff generated within the pit from rainfall is captured under the “rainfall” inflow. Process water is sourced from rainfall-runoff water collecting with in the pit, so is not a separate inflow.
The Conservation Council submission referred to Table 4.2 of Appendix G (Volume 3) and asked:
if the table should be titled “Predicted Salt Balance for the Proposed Project Area” instead of “…for the Pit”;
The analysis relates to the pit, not the project area (which is larger than the pit) so the title is correct.
why the table assumes that the only salt inflow will come from salt in the rainfall and disregarded the residual salt mobilisation into the groundwater;
Salt mobilisation is included in the seepage inflow.
why no salt tonnages are listed under outflows prior to development (forest) and during construction;
All outflows in Table 4-2 are shown as percentage; tonnages can be calculated as required by multiplying percentage by total inflows.
how seven tonnes of salt deposited annually can reach the forested area without rainfall as the table showed no rainfall inflow to the area of the proposed pit prior to development (forest);
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Rainfall inflows for the Prior to development (forest) scenario was not included in Table 4-1, but is 100% of inflows for the forested area prior to development.
why less salt (three to six tonnes) would be deposited by rainfall during construction (years 0-5) than before construction (seven tonnes) and after construction (six tonnes);
The amount of salt sourced from rainfall that reports to the pit varies depending on the pit area, so is lower during the early stages of construction when the pit area is smaller. Some salt may also be retained on surfaces throughout the pit area and removed in product taken from the site – the range of 6-7 t of salt is an estimate of the variation in the amount of salt reporting to the pit during operation. The value of 7 t prior to development is the total rainfall inflow over the pit area, and is shown for comparison only.
if the Proponent agreed that 6-7 tonnes of salt annually would be removed from its property and be transferred to the other properties in the Wooroloo Brook Catchment by releasing water accumulated into the pit;
The predicted amount of salt released from the quarry is shown in Figure 4-1 of Appendix G of the PER. This figure shows an increase of 5 t/year during operation, compared with the existing situation (note that this salt is released at concentrations significantly lower than currently exists in local streams, as shown in Figure 4-2). After closure, the amount of salt export from the quarry is predicted to drop to 0; the remainder of salt in local stream flow is sourced from agricultural areas.
if the Proponent accepted that salt in the groundwater that had accumulated in the pit would be unlikely to cross the boundaries of the Proponent’s property in streamflow if the quarry were not approved; and
The water balance study has demonstrated that evaporation will greatly exceed the combined seepage and rainfall inflow, and so there will be no resultant streamflow originating from the quarry.
why there was no allowance for “runoff” and “process water” in relation to the outflow.
No runoff water from outside the pit area will enter the pit; runoff generated within the pit from rainfall is captured under the “rainfall” inflow. Process water is sourced from rainfall-runoff water collecting with in the pit, so is not a separate inflow.
The Conservation Council submission referred to Figure 4.1 of Appendix G (Volume 3) and asked if the predicted variation in annual salt load took into account extra sources of salt such as salt leached from stockpiles and soil downstream from the quarry. This submission also asked how the quantities of water and salt referred to in Figure 4.1 relate to the quantities of water and salt in Tables 4.1 and 4.2, respectively.
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The analysis considered salt issues related to the stockpiles (i.e. accumulation and removal off-site) and leaching of salt into local streams (i.e. as a result of rising water tables caused by clearing for agriculture). The information in Figure 4-1 is an extension of the data in Tables 4-1 and 4-2.
In relation to Figure 4.2 of Appendix G (Volume 3), the Conservation Council submission asked if an additional curve for ‘pre-quarry’ (forest) would be useful.
An additional curve for a pre-quarry’ (forest) scenario has been added; the revised data is shown in Figure 8 in Volume 2; Appendix B.
Proposed Water Usage and Disposal
The LAG submission stated that the proposed quarry should not be located in the uppermost catchment basin of the Wooroloo Brook as it will be a high water-usage operation. Public Submission 11 stated that the use of water of any quality or quantity in this area, which is affected by salinity, is not sustainable. It also stated that the use of any sort of water just to reduce dust is unacceptable.
Modelling of average monthly stream flow for the catchment, presented in Section 3 of Volume 2; Appendix B of the Response to Submissions, indicates that the proposed quarry will in fact increase flows of water with low salinity in Wooroloo Brook near the quarry, compared with the existing catchment condition.
The Wildflower Society (Eastern Hills Branch) submission asked what are the proportions of water that will be used for processing versus water that will have a low enough salinity that it can be released to the reconstructed western stream.
The predicted proportions of water from the pit used for processing and water released to local streams is shown in Table 4-1 of Appendix G of the PER.
The Office of Soil and Land Conservation submission requested further information on the likely quantities and duration of release of stored water from the quarry into the drainage line flowing into Wooroloo Brook.
Predicted quantities of water released to the local streams is shown in Table 4-1 and Figure 4-1 of Appendix G of the PER. A description of proposed water releases is given in Appendix G of the PER and more details of the design of the reshaped stream section into which water will be released is given in Section 3.4.4 of Volume 2; Appendix B.
Public Submission 1 stated that evaporation and rainfall rates should be monitored to ensure that the holding capacity of the dams is suitable and the water run off is managed seasonally.
Rainfall and storage water balances have been monitored at the site in 2004 and runoff is actively managed. Suitable evaporation data can be sourced from the Bureau of Meteorology.
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Public Submission 1 asked what the criteria were for releasing water into the Wooroloo Brook. The Shire of Mundaring submission stated that the PER identifies the water quality criteria for salinity and turbidity for the release of water to the environment, but asked for additional information about the level of treatment to achieve these criteria. Public Submission 2 asked what tests would be conducted on the water prior to release and who will conduct the tests. This submission also asked what qualifications the person conducting the tests will have and what records will be kept.
Details of release criteria and monitoring are given in Appendix G of the PER. Additional information on erosion and stormwater management is given in Volume 2; Appendix B.
The Conservation Council submission referred to page 5-3 of Appendix G (Volume 3) and asked what happens to the stored water that is released after it leaves the Proponent’s property. It also asked whether the proponent agreed that it would have no control over this water and its environmental effects once it leaves the property.
As stated in Appendix G of the PER, this water will increase the quantity and reduce the salt level of flow in the local steams. A more detailed evaluation of the downstream impact of the releases is also given in Volume 2; Appendix B. There will be no adverse impact on the environment nor water users downstream of the quarry as water released will have a low salt load and low turbidity. The amount of water released will be small in the context of existing flows in Wooroloo Brook, and increased flows will be noticeable for only 2-4 km downstream of the quarry.
Public Submission 2 asked what would happen to the water if it were unsuitable for release.
Management processes for water that is unsuitable for release are detailed in Appendix G of the PER. In essence, water of unsuitable quality will not be released.
Proposed Reconstruction of the Western Stream
The Wildflower Society (Eastern Hills Branch) referred to Section 7.3 of the PER (Volume 2) which stated, “The downstream receiving channel (i.e. the “western stream” in Figure 4.7) will be reconstructed to accommodate the release flow and to more closely match the downstream receiving channel” and asked what the physical plan looked like for the reconstruction. The Shire of Mundaring submission also requested additional information about the method of drainage reconstruction.
Details of the stream reconstruction are given in Section 3.4.4 of Volume 2; Appendix B.
The Conservation Council asked whether the proposed modifications to the western stream contradict the EPA guidelines as to the integrity, functions and environmental values of the western stream. The Shire of Mundaring submission stated that the western stream needed extensive revegetation and to be fenced to ensure that water quality and erosion impacts are adequately managed.
The reconstruction will aim to stabilise the existing stream and allow it to safely receive water released from the quarry while retaining its current land use (grazing).
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Water and Salt Balances
The Conservation Council asked whether clearing of the Project Area will add 150,000 m3 of runoff water into the catchment.
Clearing and construction of the quarry will lead to an increase in fresh water released into local streams. The amounts of release vary over time and are detailed in Appendix G of the PER.
The WRC submission asked what depth the salt stores occur in the soil profile and what will happen to the salt during clearing, mining and closure.
The salt is likely to be concentrated in the soil profile below the root zone of vegetation and above the granite bedrock, between 2 and 13 m deep. The gravelly material in this layer, containing the salt, will be removed from the quarry as product and little of this salt will enter the pit or local streams.
Public Submission 1 asked what the net effect of the proposed quarry and the Shire of Mundaring’s gravel quarry was on the catchment water balance and groundwater salinity. It suggested that a hydrological study taking into account the combined effect of both of these operations should be conducted.
The effect of cumulative land use change on stream flow and water quality in local streams and the Wooroloo Brook catchment, but not the Shire’s quarry in particular, has been considered as there will be no cumulative impacts from the two quarries. The Shire of Mundaring’s quarry is located in a different catchment to BGC’s proposed quarry and water from the area enters Wooroloo Brook some 10-15 km downstream. Evaluation of the impact of BGC’s proposed quarry on stream flow and water quality downstream indicates effects will only be noticeably within 2-4 km of the quarry. Water from the Shire of Mundaring’s quarry enters Wooroloo Brook further downstream, so there will be no cumulate impact of the two quarries on flows in Wooroloo Brook.
Public Submission 1 asked how assessments would be made of the amount of water already existing in the catchment. It also asked that, if this is a desktop water balance equation based on rainfall data from outside the site, how BGC can be certain of down-stream conditions.
The methods used in the water balance modelling are detailed in Appendix G of the PER. Rainfall data generated by the Bureau of Meteorology for the site itself were used in the analysis.
The Conservation Council submission referred to page 2 of the Executive Summary and asked if the proponent implied that salt in streamflow comes from runoff water mixing with saline seepages at ground surface.
The Conservation Council submission referred to page 2 of the Executive Summary (Volume 1) and asked if the total amount of salt carried by the catchment would increase the pre-quarry salt levels. This submission also asked if the PER implied that most of the salt in streamflow comes from runoff water mixing at the ground surface with saline seepages and if the Proponent agreed that most salt in
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streamflow leaving the local catchment is not necessarily sourced by runoff mixing with saline seepage but by salt located in the soil profile and mobilized by rising groundwater levels.
BGC is not sure to what these comments relate to, as there is no reference to salt in stream flow on Page 2 of the Executive Summary of the PER. Appendix G of the PER discusses salinity levels and likely sources of salt in stream flow for the existing situation and after development of the proposed quarry. Most salt in stream flow north of the quarry area is sourced from saline groundwater discharging to stream lines and low-lying areas.
The Conservation Council submission referred to page 5-3 of Appendix G (Volume 3) and asked what physical mechanism leads to salt accumulation if there is no water flow over summer and where in the catchment and the soil profile would the salt accumulate. This submission also asked how runoff could be simultaneously high to avoid salt flushing and low to avoid erosion.
It is not sure to what this comment relates to, as there is no reference to salt accumulation on Page 5-3 of Appendix G of the PER. Salt is discharged to stream lines and low-lying areas as a result of high groundwater levels. Salt can accumulate in the near surface profile when evaporation is greater than the discharge rate or in dams and ponds that are not flushed. This salt can be later flushed with stream flow resulting from rainfall.
It is not sure to what part of the PER the second question relates and the meaning of the question is unclear, but discharge from the proposed quarry will be released in such a way as to ensure there will be no flushing of accumulated salt (i.e. water will be released only after natural flows have occurred in the streams north of the quarry) and so there will be no erosion.
The Conservation Council submission referred to page 101 in the PER (Volume 2) which stated, “The first regular release from the quarry will not occur until some streamflow has occurred in the stream from natural flow processes. This is to avoid flushing any salt that has accumulated over summer”. The submission asked what extra salt could accumulate over summer to be flushed later from the system if there has been no water to supply or mobilize the salt. The submission also asked if the discharge water would add more salt to the salt load and the salt store of the Wooroloo Brook catchment.
Salt can accumulate or concentrate as a result of evaporative concentration from pools, dams and low-lying areas.
The net effect of the water released from the proposed quarry will be to reduce the salinity of stream flows in local streams, as discussed in Appendix G of the PER.
The Conservation Council submission asked whether up to eight tonnes of salt from the project would be removed annually and transferred to other properties of the Wooroloo Brook catchment in the released groundwater.
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The amount of salt in stream flow near the proposed quarry during the construction and operational phases is predicted to increase marginally compared with the existing situation, but stream salinity is predicted to decrease (see Appendix G of the PER). After closure, salt export from the quarry area is likely to fall to near zero.
Effects on Catchment Salinity and Salinisation
The WBLCDC submission opposed the statement made in the Executive Summary (Volume 1, Page 10) that the proposed quarry would not contribute to local catchment salinisation and stated that the quarry would contribute to the salinity of Wooroloo Brook. The AVES submission and Public Submission 11 stated concern that the proposed clearing would aggravate the salinity and waterlogging of streams. Public Submission 10 stated that land clearing causes and contributes to salinity and that the streams in the region already exhibit problem of salinity. The submission also stated that it is essential to stop any further clearing of native bush.
Existing stream flow in the area of the proposed quarry already has elevated salinities as a result of rising groundwater caused by clearing for agriculture. The proposed quarry will not exacerbate salinity in local streams and will, in fact, lead to a reduction in stream flow salinity during winter. The information used to form this conclusion is detailed in Appendix G of the PER and expanded in Section 3.2 of Volume 2; Appendix B.
Public Submission 1 stated that the surface water report seemed to be concerned with on-site water but did not take into account off-site impacts. The submission also stated that releasing of water from the site would not be acceptable until a detailed catchment survey is carried out and ongoing monitoring is in place. The WRC submission asked that the downstream impacts be quantified, including the potential impacts to surface water and land salinisation, and how these would be managed.
Section 3.3.3 of Volume 2; Appendix B evaluates the impacts of the quarry on the broader Wooroloo Brook catchment. This study concluded that impacts of water released from the quarry were not likely to extend more than 2-4 km downstream, which is a small proportion of the Wooroloo Brook catchment.
More detailed monitoring has been undertaken at the existing and proposed quarry sites and detailed erosion and water management plans have been prepared – details are given in Volume 2; Appendix B.
The Office of Soil and Land Conservation submission stated that the Commissioner of Soil and Land Conservation had previously issued BGC with a Soil Conservation Notice due to concern about the likelihood of secondary salinity occurring as a result of the clearing and subsequent development of the site. The submission requested that some analysis be undertaken on the risks of on-site or off-site salinity occurring due to clearing and site development.
The WBLCDC submission asked what the effect would be of clearing of 30% of the native remnant vegetation in the sub-catchment (ie upstream of the western and eastern streams). The Conservation Council submission stated that the PER asserts that “clearing for agriculture” has led to increased water salinity and greater risk of land salinisation in the Wooroloo Brook Catchment. It asked why
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clearing for the quarry will not lead to increased water salinity and greater risk of land salinisation. The submission also stated that clearing should not be allowed in a catchment where hydrogeological thresholds have been breached and that no further clearing should be allowed until the proponent has demonstrated that significant repair to the catchment has occurred.
Impacts of clearing on and off-site salinity associated with the proposed quarry are dealt with in Appendix G of the PER. Clearing and pit excavation will occur in a phased manner over a period of 10-12 years, so there will not be substantial additional recharge to groundwater as a result of clearing vegetation. Once the pit is established, there is not expected to be any outflow to groundwater from the pit and water collecting in the pit from rainfall and seepage inflows will be managed as detailed in Appendix G of the PER. Salt contained in the existing soil profile will be removed from site in saleable product. As such, there will not be any on- or off-site salinisation issues associated with the proposed quarry.
The Wildflower Society (Eastern Hills Branch) submission asked how salty drainage waters filtering through the salt-bearing rocks and sub-soils in the pit and stockpiles would be separated from less salinised run-off waters from buildings. It also asked whether all the water harvested from the salt-bearing overburden stockpiles and the pit floor would be used as process water, and what would happen if the volume of “salty water” exceeds the requirements or storage capacity.
Salt and water in the pit area will be managed as detailed in Appendix G of the PER. Salt contained in the existing soil profile will be removed from site in saleable product, so will not enter the pit water. The pit water balance analysis given in Appendix G of the PER accounted for all salt and water inflows and outflows and concluded that water in excess of processing requirements will be fresh and can be safely released to the environment. The process area and sump will be located below ground level, so there will be adequate temporary storage capacity and no possibility of an accidental release to the environment.
Public Submission 1 asked if saline groundwater quantities exceed the requirements for dust suppression, how will the on and offsite impacts be managed for the removal of this water?
Management systems will be established to deal with situations where water of an unacceptable quality for release to the environment accumulates in the pit; these systems are detailed in Appendix G of the PER.
The Office of Soil and Land Conservation submission requested information on the effect of increased discharge on the downstream environment. Public Submission 1 stated that the impacts on the local catchment from current and proposed quarry activities needed greater investigation, particularly related to increase in salinity. The Conservation Council submission asked whether the proposed quarry would contribute to salinisation as a result of the water release programme, depending on how the water affects the water table in the catchment.
Additional analysis of the impacts of the existing and proposed quarries on the broader Wooroloo Brook catchment is given in Section 3.3.3 of Volume 2; Appendix B. This study and Appendix G of the PER concludes that there will be no adverse impacts on downstream salinity.
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The Conservation Council submission and Public Submission 4 referred to Page ES-10 in the Executive Summary (Volume 1), which stated “The proposed quarry will increase streamflow in the local catchment. This increased streamflow is not likely to have an adverse effect on the downstream environment …”. Public Submission 4 referred to the use of the term “likely” and asked for a more definite statement. The Conservation Council submission stated that increased streamflow, especially during the summer months and outside of the Proponent’s property, has the potential to mobilize salt from the unsaturated zone and increase water salinity and land salinisation downstream from the quarry as the discharge water percolates to the water table through unsaturated soils.
Additional analysis of the impacts of the existing and proposed quarries on the broader Wooroloo Brook catchment (Section 3 of Volume 2; Appendix B) confirms that there will be no adverse impacts of water release or increased stream flow on the downstream environment.
Any water releases from the quarry during summer will only occur after heavy rainfall events and only after stream flow from the general catchment has moved downstream, thus ensuring that the quarry water release does not mobilise salt from the wider catchment.
Public Submission 4 referred to Page ES-10 of the Executive Summary (Volume 1) which stated, “Streamflows in the local catchment are then likely to return to near the levels that occurred prior to the development of either of the quarries”. This submission questioned the use of the term “likely” and asked for a more definite statement. It also asked what would happen to the environment during the 50 years of altered water flow and stated that it may be Perth’s proposed drinking water for the year 2030.
The use of the term “likely” is appropriate in this context, as predictions 50 years into the future contain uncertainties. Effects of some important uncertainties and potential changes over 50 years (e.g. increased salinisation as a result of rising groundwater caused by clearing for agriculture) are discussed in Appendix G of the PER. The effect of the quarry on Wooroloo Brook has been investigated and shown to be minimal, both during operation and after the quarry closes (see Section 3.3.3 of Volume 2; Appendix B).
The Conservation Council submission referred to Page ES-20 of the Executive Summary (Volume 1) where it predicted that there would be an increase in runoff, and asked whether this runoff would have the potential to increase the salt content of the groundwater as the runoff water percolates through the upper salt-laden unsaturated soils.
Additional analysis provided in Section 3.3.1 of Volume 2; Appendix B confirms that there will be no increase in the salt content of groundwater in streams near the quarry.
The Conservation Council submission referred to Page ES-20 in the Executive Summary (Volume 1), which stated, “The controlled release should, on average, reduce streamflow salinity downstream of the quarry”. The submission asked how the Proponent could guarantee reduced streamflow salinity downstream if it has no control over the environmental management of the downstream portion of the Wooroloo Brook Catchment. It also asked what right the proponent had to impose, or risk imposing,
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land degradation problems on adjacent landholders. The AVES submission stated that there is no guarantee that the less saline water discharged from the mine site would adequately compensate for the increased salinity that would occur from the land clearing. Public Submission 1 also questioned the suggestion that the proposed quarry would decrease stream salinity.
Appendix G of the PER and subsequent analysis in Sections 2 and 3 of Volume 2; Appendix B of the Response to Submission clearly demonstrates why the proposed quarry will lead to reduced stream flow salinities and states the assumptions and methods used in drawing those conclusions. The proponent does not guarantee to reduce downstream salinities, but does state that operation of the proposed quarry, including clearing of vegetation to develop the quarry and release of excess water from the quarry, will not adversely impact on the downstream environment nor cause land degradation problems for downstream landholders.
Public Submission 1 asked if BGC intended to set up a catchment monitoring system to look at stream water levels and groundwater levels in valley floor locations off-site, where the quarry drainage will end up. The submission stated that visual monitoring and hand sampling is not an acceptable monitoring method to determine off-site impacts.
An enhanced monitoring program has been established that will characterise stream flow and groundwater levels near and downstream of the existing and proposed quarry. This monitoring programme and results to date is detailed in Volume 2; Appendix B.
Surface Water Management Plan
Public Submission 1 asked for further information on sump management. This submission also asked how it will manage surface water runoff from watering the quarry site with 376.6 kL/day of saline groundwater (Table 3.2). The Conservation Council submission asked how the Proponent would prevent residual salt being leached from the topsoil stockpiles.
Appendix G of the PER details management of pit water quality and salt accumulation. There will be no salt in stockpiles on-site – the salt will be removed in product sold. Salinity levels of water in the sump will remain low as a result of dilution from rainfall directly over the pit.
The WRC submission asked what contingencies are proposed for special events such as storms, leaks and where monitoring detects/shows potential problems.
Appendix G of the PER and Volume 2; Appendix B of the Response to Submissions details stormwater and erosion management procedures for the range of problems that may be encountered during operation of the mine, including water quality that is of too poor quality to be released to the environment and the occurrence of intense rainfall events.
The WBLCDC submission stated that the Surface Water Management Plan (Appendix I) must include the establishment of arrays of observation monitoring bores across the valley downstream (to northern property boundary) from the quarry to assess any changes/movements in water chemistry and salinity
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impacts from the proposal. This submission also stated that the bores should be monitored appropriately with the data made available to the public.
A total of 13 monitoring bores have been established at eight sites in the valley downstream from the quarry. Water samples have been taken from all these bores, and water-levels are being recorded weekly.
The Conservation Council submission stated that the Surface Water Management Plan should:
address downstream flows outside of the immediate Project Area because increased downstream flows will increase the amount of salt released into the downstream groundwater system;
allow for the removal of water from the sump in the pit by means other than the release into the catchment, such as by tanker or by evaporation; and
address the “potential shifting of the salinity problem off-site to other landholders and to the environment downstream from the Project Site”.
Various options for water management at the proposed quarry have been evaluated and the plans presented offer the best solution, both in terms of minimising impacts on the environment and for operational efficiency of the quarry. As clearly stated in Appendix G of the PER and Volume 2; Appendix B, no adverse impacts on the downstream environment will occur as a result of release of excess water from the quarry to the environment.
The WBLCDC submission suggested that the Surface Water Management Plan be assessed and endorsed by the Shire of Northam, Shire of Mundaring and other relevant State agencies prior to the commencement of any works at the site. The Shire of Mundaring submission also stated that the plan should be endorsed by the Shires of Mundaring and Northam and relevant State Government agencies, such as DoE, Water and Rivers Commission and Department of Conservation and Land Management prior to clearing of vegetation or work commencing at the site.
Appropriate regulatory approvals will be received before commencing construction of the quarry and associated surface water structures.
Public Submission 2 asked when the final Surface Water Management Plan would be released.
Details of proposed surface water and erosion management procedures are given in Appendix G of the PER and Volume 2; Appendix B.
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7.4 Groundwater
Current Situation
The existing quarry operation is not part of the proposal being assessed under the PER but the LAG submission provided comment on a number of aspects relating to current groundwater impacts and management.
The LAG submission stated that the current quarry is likely to have depleted the aquifer beneath Horton Hill by a 20-45 m vertical fall in the groundwater table level. The submission stated that this has caused farms dependent on groundwater to lose freshwater recharge as well as 20 m of hydraulic head due to the reversal of the hydraulic gradient from west to east towards the current quarry. The submission also stated that continual mining would cause farm dams to go dry and saline.
The deepest water level encountered in the census in May 2004, before any winter rainfall had occurred was 15 m, in the bore on Lot 5. Clearly, therefore, levels cannot have fallen by 20-45 m.
There is no evidence of drawdown caused by the current quarry, or of a regional reversal of gradient towards the quarry.
The only farm dams which could potentially be affected by the quarry are those downgradient, on Lot 13. The quarry could contribute to an improvement in quality in these dams by release of low-salinity surface runoff. The quarry will not cause any rise in groundwater levels which could contribute to further salinity rises in farm dams.
The LAG submission stated that it appeared to be possible that current quarry dewatering is already dewatering the Helena Valley catchment groundwater, which is only 500 m south of the quarry. LAG believes that an area in excess of 180 ha has been dewatered.
There is no evidence of dewatering of groundwater in the Helena Catchment. The only known boreholes upgradient of the existing quarry are two bores south of the holding dams, both of which flow continuously at the surface.
The LAG submission stated that the fracture zones (Horton Hill Structural Zone) are the main conduits of groundwater migration beneath the Wooroloo Brook drainage systems and that these zones might be the reason that dewatering of the Horton Hill farm aquifers has been so laterally and vertically extensive. The submission stated that a groundwater recharge mound is likely to be present beneath the processing operation during summer and possibly winter and the perceived groundwater recharge area may explain why pit dewatering has not lowered groundwater levels in the area but depleted them elsewhere. It was stated that Figures 3.8 to 3.11 of the LAG submission illustrated that recharge from rainfall contributing to the Horton Hill aquifer is flowing away from the resident farms, down a dewatering induced hydraulic gradient towards the existing quarry.
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There is no evidence of reduced groundwater levels in the Horton Hill area as a result of quarrying, nor of any recharge mound downgradient of the quarry. Figures 3.8 to 3.11 of the LAG submission are conjectural and are not supported by any factual information.
Artificial recharge mechanisms attributable to current quarrying and processing operations were identified in the LAG submission as direct process water discharge to Wooroloo Brook and recharge by process water management. The submission also stated that the burial of 3 ha of the eastern tributary of Wooroloo Brook with stockpiled aggregate and road base would result in direct groundwater recharge to the brook.
There is no evidence of recharge or groundwater mounding beneath Wooroloo Brook, as a result of the current quarrying operations.
The LAG submission stated that the current quarry discharge rates are calculated to be double natural flows and pose a threat to increasing the rate of groundwater rise beneath the Wooroloo Brook.
Groundwater levels at the end of summer 2004, downgradient of the existing quarry, were within 1 m of the surface along the line of the tributaries of Wooroloo Brook, so significant additional recharge from surface flows is not feasible.
Deeper aquifer levels, above granite bedrock, generally have higher hydraulic heads than the water table. The water table is thus maintained by upward flow from the deeper aquifer level, rather than by recharge from surface flow.
There is no evidence of groundwater rise beneath Wooroloo Brook from the current quarry operations.
The LAG submission stated that the current quarry holding dam discharges process water to the Wooroloo Brook all year round and this has not been measured. This could be a major source of recharge to the Wooroloo Brook and contribute to a rising groundwater table.
There has been some discharge in the past from the holding dam to Wooroloo Brook, but there is no evidence of a rise in groundwater level from this source.
Measurement of variation in water levels in the holding dam, when the quarry has been out of operation over long weekends during the early part of 2004, has indicated a net an inflow to the holding dam ranging from 2.7-4.7 L/s.
The LAG submission stated that there are two artesian bores located at the existing quarry which contribute water to the groundwater table beneath Wooroloo Brook.
The aggregate flow from the two artesian bores is very small – measured at 0.30 L/s on 7 January and 0.24 L/s on 11 April 2004. Much of this is probably evapotranspired from the vegetation growing on the south side of the holding dam, with any remainder seeping into the holding dam.
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The LAG submission stated that URS said that the existing dam was lined, but BGC Asphalt and Quarries’ General Manager told some members of LAG that the dam was not lined.
The dam is reported to be clay-lined, and about 8 m deep.
The LAG submission stated that there were multiple fracture zones visible in the upper 10-15 m of the quarry would have acted as water flows channels prior to quarrying. The submission stated that the channels will resume function when the quarry fills up with water post-quarrying, further illustrating that hydraulic continuity exists between the pit and Wooroloo Brook.
The quarry void will not fill up with water after quarrying is completed, as evaporation will exceed groundwater and surface water inflows. The void will largely remain dry.
The LAG submission stated that a 1 mm recharge would cause 0.5 to 1 m rise in the groundwater table and that a detailed programme of fact finding and gathering of baseline data with detailed quantification of the impact is required to determine the effects of existing operations on the local groundwater table.
There is no evidence of groundwater rise due to quarrying, and the quarry acts as a groundwater sink rather than a source of recharge. Eleven additional monitor bores were constructed in May 2004, and a census of private bores, wells, soaks and spring-fed dams was undertaken in May-June 2004.
Proposed Pit Dewatering and Predicted Groundwater Drawdown
Public Submission 1 requested information on the dewatering rates from the current and proposed pits. The LAG submission stated that there is a possibility that hydrological modelling of the proposed quarry has underestimated rates of seepage into the quarry and that discharge rates have been calculated to be quadruple those attributable to natural flows.
All seepage into the quarry is diverted into the quarry sump. Inflow rates to the sump have been measured peridodically between March 2002 and April 2004 and have ranged from 0-0.7 L/s, with an average of 0.37 L/s. This is essentially identical to the rate quoted in the PER, which was used in the water balance modelling reported in that document. The proposed pit is likely to have a lower inflow rate, since it will be bounded to the east by the existing quarry, where the water table has locally been lowered.
The LAG submission stated that the proposed quarry would discharge saline water into the Wooroloo Brook for eight months of the year, causing groundwater levels to rise. It stated that the long-term flow volumes would introduce large volumes of salt to the Wooroloo Brook.
The water discharged from the quarry will be much less saline than the current water quality in Wooroloo Brook, and will therefore tend to improve the water quality in the brook.
Groundwater levels will not rise as a result of discharge from the quarry. Groundwater levels are already close to the surface, and are maintained by upward hydraulic pressure from deeper groundwater.
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The WRC submission asked what the shape of the cone of groundwater drawdown would be during clearing, mining and closure, and how the cone of groundwater drawdown would affect run-off.
Any cone of groundwater drawdown due to mining will be highly irregular. The permeability of the weathered and fresh granite is generally very low. In June 2004, the groundwater level, as shown by the in-quarry sump, was about 259 m AHD. At the same time, groundwater levels in artesian bores AB1 and AB2, upstream from the holding dam, were above casing top at 304.8 m AHD. Water levels in MB2S and MB2D, about 150 m northeast of the edge of the quarry, were at about 295 m AHD.
Drawdown will be propagated preferentially along any major fracture zones. There are two fracture zones, trending WNW and passing through the quarry. Theoretically, any detectable drawdown effect, assuming worst case hydraulic conditions, would be unlikely to extend beyond 1 km from the quarry, and would be limited to a narrow zone along the line of fracture. Apart from these fracture zones, drawdown effects are unlikely to extend further than 100 m from the quarry.
The Wildflower Society (Eastern Hills Branch) submission referred to the Executive Summary (Volume 1, Page 10) and PER (Volume 2, Page 96, Paragraph 1) and asked for further information on the lateral and vertical extents of the fracture zones from the edge of the proposed pit.
There is a WNW fracture extending across the new quarry site. The depth of this is not known, but the intensity of fracturing will decrease with depth, and fractures would be expected to be closed below a depth of 50-60 m. The lateral extent of the fracture can be traced on air photographs for at least 2 km.
The Conservation Council submission asked whether rising groundwater levels are expected in the remaining area of Lot 14 as a result of the proposed Project.
Groundwater levels are not expected to rise in the remainder of Lot 14 as a result of the proposed Project. The quarry will act as a groundwater sink rather than as a recharge source.
Public Submission 1 asked how wastewater would be managed if dewatering of the pit is greater than the holding capacity of the proposed dam. This submission also raised concern about the location of any overflow from the holding dam and suggested that the capacity of the holding dam needed to be accurately calculated. Public Submission 1 suggested building sealed holding dams and overflow dams to ensure that no overflow entered Wooroloo Brook or onto neighbouring properties.
The submission’s reference to wastewater is inferred to mean excess groundwater seepage in the context given. The amount of groundwater inflow to the pit will be small, and will not exceed the holding capacity of the proposed dam. Any overflow will be contained within the pit.
The LAG submission stated that a viable rehabilitation solution for the drawdown effect of quarry dewatering on the surrounding environment had not been provided and that a full study assessing the cone of dewatering (drawdown) around the existing quarry is required to assess the future impacts that current and proposed mining will have on sub-catchment water tables. The submission stated that the extensive pumping tests and related hydrogeological programmes need immediate implementation to
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assess the extent of current and future quarry dewatering upon local aquifers. The programmes should include monitoring of process water usage and farm aquifer dewatering.
A survey of all farm bores and dams was completed in May and June 2004, and water levels are being recorded in 13 groundwater monitoring bores weekly.
The LAG submission stated that the proposed quarry faces would allow groundwater from the Horton Hill to be drained away, “such that the aquifer will never ever be able to recover its historical hydraulic head or its former volume”.
There is no evidence of reduced groundwater levels in private bores due to the current quarry operations. Any drawdown effects are likely to be confined to 100 m from the quarry, except along major fractures, where any detectable effect could possibly extend to a distance of 1 km, but would be limited to a narrow zone.
Potential Impacts of Groundwater Drawdown on Vegetation
Four submissions identified issues relating to the potential for impact on vegetation due to groundwater drawdown. These issues are outlined below, and have also been included in Section 7.5 of this document.
The AVES submission stated that the group had received professional advice that suggested that a steep-sided pit will cause the water table at the sides of the pit to drop substantially and that this will initiate vegetation loss for a considerable distance from the sides of the pit. The Wildflower Society (Eastern Hills Branch) also asked what the potential impacts would be of changed soil moisture profile on the remnant plant communities near the new pit.
Vegetation dependent on groundwater might be affected within 100 m of the pit. Groundwater dependent vegetation occurring along narrow WNW fracture zones could be affected up to 1 km away. However, most of the vegetation tends to rely on seasonal water. Therefore, it is more reliant on rainfall than groundwater levels, and is most unlikely to be affected by groundwater drawdown.
The Wildflower Society (Eastern Hills Branch) referred to the Executive Summary (Volume 1, Page 10) and PER (Volume 2, Page 96, Paragraph 1) and asked for further information on the lateral and vertical extents of the fracture zones from the edge of the proposed pit and the anticipated long term impact of the fracture zones on the moisture retention capacity of the soils and sub-soils supporting remnant vegetation communities.
The fracture zones extend at least 2 km from the proposed pit, but would certainly be unaffected beyond 1 km. The depth of the fracture zones is unknown, but they will decrease in fracture intensity with depth, and would be expected to be closed below 50-60 m depth.
The Conservation Council submission asked whether a fall in the groundwater level immediately adjacent to the quarry would have a negative impact on the remaining vegetation, including Heath
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community 5 of Hemigenia viscida, and stated that this needed to be addressed in the Groundwater Management Plan.
It is expected that the Hemigenia viscida plants within the Project Area tend to rely on seasonal water near the shallow outcropping areas. Therefore, this species is more reliant on rainfall than groundwater levels, and is most unlikely to be affected by groundwater drawdown.
Public Submission 2 asked how the proponent would overcome the problem of vegetation death due to the lowering of the groundwater table around the rim of the pit.
The Proponent does not expect any vegetation deaths due to the lowering of groundwater levels as most of the vegetation tends to rely on seasonal water. Therefore, it is more reliant on rainfall than groundwater levels.
Potential Impacts on Local Water Supplies
Public Submission 1 referred to a statement in Section 7.3.3, which stated, “groundwater in the vicinity of the quarry will seep into, rather than out of, the pit” and asked whether this indicated that the pit would be responsible for domestic bore drawdown in the local catchment.
There are no existing domestic bores likely to be affected by the proposed quarry. Groundwater levels will, in general, only be affected within 100 m of the quarry, and up to 1 km along major WNW fracture zones.
The WRC submission, Public Submission 7 and Public Submission 15 asked how a reduction in groundwater levels would affect other users in the area. Public Submission 5 stated that the decrease in groundwater levels near the proposed quarry is a real concern for the neighbouring properties as they are not on scheme water and are dependent on the groundwater for crops, livestock and household use. The LAG submission stated that the quantity of groundwater used by the current quarry has caused a serious depletion of the groundwater aquifers that the local farming community relies upon as its sole source of water, and that the proposed quarry has the potential to deplete the farm aquifer completely during the life of the quarry.
There is no evidence that the existing quarry has affected other groundwater users in the area, nor is it likely that the proposed new quarry will affect any existing bores.
Public Submission 4 stated that there is a possibility that the poor groundwater yields to bores and high salinity have been exacerbated by the existing quarry. This submission asked whether the advancement of the proposed project would reduce the bore water and whether BGC would be held liable if this was to occur. This submission also stated that residents might lose their livelihood through the dewatering of the Horton aquifer.
There is no evidence that the existing quarry has affected the yields of any existing domestic bores. The quarry would, if anything, tend to reduce salinity resulting from agricultural clearing, by locally reducing water levels.
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Public Submission 7 referred to page 9 of the Executive Summary (Volume 1) and asked if the clearing of trees would cause the water table to drop.
Clearing would tend to increase recharge to groundwater from rainfall, and hence tend to cause a rise in groundwater level.
The author(s) of Public Submission 5 stated that there was concern about the loss of their groundwater from blasting. This submission also stated that the WRC had been consulted and that it could neither confirm that the loss of groundwater could occur, nor that it wouldn’t occur and queried whether it was best to err on the side of caution.
All existing domestic bores are too far away from the quarry to be affected by blasting.
Potential Impacts on Catchment Salinity and Salinisation
The Conservation Council asked whether the proposed quarry is situated in a groundwater recharge area, which was an area that was traditionally not cleared to ensure better groundwater quality down-catchment.
The proposed quarry is located in the catchment where groundwater is probably subject to recharge. The area of the quarry is insignificant in this respect, however, in the context of the total catchment area.
Public Submission 1 expressed concern that the off-site impacts from surface water runoff and groundwater movement would be greater than the impacts at the quarry site. It also expressed concern about the position of the quarry within the catchment and the salinity of the groundwater in the surrounding catchments.
No significant offsite impacts on groundwater are expected. The quality of surface water in the catchment is likely to be improved, because of release of surface runoff of much lower salinity than the existing creeks.
Adjacent catchments should not be affected.
The LAG submission stated that geological fracturing has controlled the location of regional draining channels and that the fractures transmitting water into the groundwater system have direct relevance to the risks of further salinisation of the Wooroloo Brook by quarrying processes. The submission stated that increased salinisation due to the water management practices at the current quarry will migrate downstream and spread laterally, affecting farms distant from the source of the salinisation, putting Wooroloo Brook at significant risk, and threatening the economic viability of farms and their ecosystems.
The salinisation has been caused by clearing for agriculture, and pre-dates the existence of the quarry. The current quarry will, if anything, have counteracted salinisation to a minor extent, by locally lowering groundwater levels.
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The Conservation Council submission referred to Page ES-22 of the Executive Summary (Volume 1) which stated “Quarry dewatering operations will lower the level of groundwater in the Project Area. This will offset any soil salinisation which is normally caused by rising groundwater levels”. The submission asked what is meant by “offset any soil salinisation”, as the Project Area is in a forested recharge area with a deep watertable and salinisation through rising groundwater levels is unlikely. The submission also asked that, since there would be no soils remaining in the Project Area to become salinised after stripping of overburden, why the proponent needed to offset soil salinisation by lowering the groundwater level.
Agreed. Soil salinisation due to rising groundwater levels would not be likely in this area.
The LAG submission stated that the current quarry already poses unsolvable and irreversible salinisation and degradation problems post–quarrying as the void will fill with groundwater and evaporation will cause it to become saline. The submission stated that the outcomes of this would be a direct stream of saline water into Wooroloo Brook and a risk of groundwater pollution downstream if the pit backfill is not barren rock.
Evaporation in the post-quarrying void will exceed groundwater and surface water inflows, and will largely remain dry.
No saline water will be discharged into Wooroloo Brook.
Groundwater Management Plan
The Conservation Council stated that the Groundwater Management Plan should:
address downstream flows outside of the immediate Project Area;
allow for the removal of water from the sump in the pit by means other than the release into the catchment, such as by tanker or by evaporation; and
address the potential shifting of the salinity problem off-site to other landholders and to the environment downstream from the Project Site.
The management of downstream flows from the proposed quarry operations have been addressed in the surface water management plan, which is presented in Volume 2; Appendix B.
Public Submission 5 stated that independent monitoring of groundwater is required as there is concern for the existing groundwater and proposed water use in the quarry expansion.
Results of groundwater monitoring at the proposed quarry will be submitted to the DoE on a regular basis and the DoE will also conduct inspections of the proposed quarry. Therefore, the Proponent believes that independent monitoring of groundwater is not required.
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Public Submission 2 asked when the final Groundwater Management Plan would be released.
As stated in the PER, the Proponent has made a commitment to finalising the Groundwater Management Plan after considering the comments received during the public review period and in consultation with the regulators. The final draft of the plan will be submitted to the DoE for review and finalised following the receipt of their comments. The final Groundwater Management Plan will not be re-circulated in the public arena, however it will be available from BGC, should a request be made to BGC Quarries.
7.5 Vegetation and Flora
Vegetation Clearing Conducted in December 2001
The vegetation clearing that was undertaken in December 2001 was raised in a number of submissions, which also questioned BGC’s ignorance of the law. This was raised by the AVES submission, the WBLCDC submission, the Wildflower Society (Eastern Hills Branch) submission, Public Submission 2 and Public Submission 4. The AVES submission stated that part of the land already cleared goes beyond the area intended for the proposal and asked why this area was cleared if it was not needed for the proposal.
The proposed Project Area for quarry development encompasses most of the area cleared in December 2001 (Figure 2). Since the clearing occurred, further work was conducted to refine the project layout to take into account a range of environmental, social and economic factors and this resulted in the exclusion of development on Lot 11, on which a small portion of the clearing occurred. BGC has made an agreement with the Shire of Mundaring that the progress of the regeneration of vegetation on Lot 11 will be monitored on an annual basis and a report will be submitted to the Shire of Mundaring.
Public Submission 11 stated that the area already cleared should be immediately revegetated as close as possible to the original species. Public Submission 6 stated that the area already cleared should be revegetated to demonstrate that BGC can successfully rehabilitate land, and that the Shire of Mundaring, CALM and WRC should be invited to determine whether the rehabilitation has been successful.
The cleared area has been revegetating naturally subsequent to the clearing. A deed has been created between BGC and the Shire of Mundaring whereby annual monitoring will be undertaken to assess the regeneration process and this will be reported to the Shire of Mundaring. The survey will record structure, health and species diversity of disturbed and intact vegetation to allow for comparison. The monitoring will be undertaken for a minimum of five years or a period sufficient to demonstrate that the disturbed vegetation is progressing toward a stable and self-regenerating system.
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Potential Impacts of Proposed Vegetation Clearing
Public Submission 1 asked why 85 ha of native vegetation would be cleared when a significant amount had already been cleared.
The area of vegetation cleared in 2001 was 16 ha and is not of sufficient size to accommodate the proposed development.
Public Submission 2, Public Submission 5, Public Submission 10, the AVES submission and the LAG submission stated that the clearing of 85 ha is unacceptable in the Shire of Northam as the shire is already overcleared and below the required threshold of 30% of the pre-clearing vegetation type. The AVES submission asked what is the percentage of the remaining vegetation type that the proposed 85 ha represents in the Shire of Northam. Public Submission 6 asked why should any wandoo be cleared since this vegetation-type is surely below the 30% threshold level by now.
Approximately 16.4% (23,272 ha) of the Shire of Northam comprises native vegetation. The proposed area of clearing (85 ha) represents 0.37% of the remaining native vegetation.
BGC has committed to implementing an offsets strategy to replace some of the local botanical values that will be reduced through the proposed vegetation clearing. The strategy comprises three elements including the rehabilitation of some 60 ha of gravel pits and degraded Crown land in the vicinity of the quarry; the fencing of some 100-150 ha of remnant bush on the Wooroloo prison farm; and the covenanting for conservation of some 120 ha of uncleared bushland on privately owned land The benefits of implementing the proposed strategy are expected to include assistance in catchment management issues, the re-establishment of biodiversity values, and the establishment of corridors and linkages for native fauna movement between areas of remnant vegetation.
Public Submission 2 referred to the Biota report and asked why it stated that an additional 10 ha were required for clearing.
The proposed site layout defined in Figure 1.2 of PER (Volume 2) equates to approximately 75 ha. This did not include allowance for the development of clay and gravel stockpiles that would be required if these materials are not sold, used for backfilling the existing quarry or otherwise removed from site. BGC has now confirmed that areas for overburden stockpiles are not required and the pit area has been expanded to include the total 85 ha of clearing (Figure 1 of this document). The reference in the Biota report (2003) to the additional 10 ha of clearing was related to Table 3.5 in that report, which indicated that the impact area was 76.03 ha based on the outline shown in Figure 1.2 of the PER (Volume 2). As the proposed area of clearing is 85 ha, the authors of the Biota report wanted to qualify that the results shown in Table 3.5 did not include the full 85 ha. Therefore, only 85 ha will be cleared for the Project.
Public Submission 6 referred to a statement in the Executive Summary, which said that there is no site-vegetation type present that is not represented in the wider conservation estate. It asked whether this type of argument is illogical, as it means that nothing that exists elsewhere is worth conserving.
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This statement was made to provide perspective on the conservation values and degree of protection in place for the site-vegetation types within the Project Area. This does not remove the need to minimise clearing and to protect the remnant vegetation that will remain within the site.
The LAG submission stated that the clearing would remove 36% of the remnant vegetation protecting Wooroloo Brook and pose a serious threat of enhancing the salinity and current land degradation of Wooroloo Brook. The Conservation Council submission stated that the proposal would lead to the clearing of 25% of the remaining native vegetation in the catchment defined in Figure 3.1 of Appendix G and asked why this percentage of clearing would be acceptable from a biodiversity perspective.
It is difficult to confirm the accuracy of the above statements without reference to a figure or map. Based on our calculations of the area of uncleared vegetation shown in Figure 3.1 of Appendix G in the PER, there is approximately 12,839 ha of remnant vegetation in the catchment, and the proposed clearing of 85 ha would represent less than 1% of the vegetation in the catchment. In addition, our studies of the surface and groundwater regime and potential impacts of the quarry show that the quarry does not pose a threat of enhancing the salinity of Wooroloo Brook. To the contrary, the BGC proposal is likely to reduce the salinity of the brook, particularly in its upper reaches. Furthermore, BGC propose a new offset strategy which will protect remnant bushland and rehabilitate degraded and cleared Crown land, much of which occurs within the Wooroloo Brook catchment.
The Conservation Council submission referred to Page 19 of Appendix B where it stated, “… all vegetation complexes exceed the 10.0% on the total areas in reserves”. The submission asked why this is considered acceptable when the EPA’s Position Statement on the Environmental Protection of Native Vegetation in Western Australia states that below 30% of the original area, a vegetation complex will decline at an exponential rate.
The Bush Forever report states that the target for vegetation complexes is >10%, however 30% is used at a national strategy level. These levels are targets only and not a legal requirement.
The Conservation Council submission stated that the proposal does not meet the requirements of the EPA’s Position Statement on the Environmental Protection of Native Vegetation in Western Australia. It asked for information to be presented that indicates a comparison of development options to avoid disturbing native vegetation.
The EPA Position Statement on the Environmental Protection of Native Vegetation in Western Australia sets down the EPA’s view on land clearing in agricultural areas of the State. The EPA’s view is that any disturbance of native vegetation is not the preferred option. However, the decision on whether areas should be cleared or not depends on local and regional representation, adequacy of that representation and also the adequacy and acceptability of the offset/mitigation measures for a project. As there are no site-vegetation types in the proposed Project Area that are not represented in the conservation estate, and CALM has stated that all flora species recorded in the survey area are well represented in the conservation reserve system, the proposal meets the requirements of the EPA Position Statement.
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An evaluation of the options to locate the Project in cleared areas is presented in Section 2.1.2 of this document. This determined that the relocation of the quarry to Lot 14 is the only available option.
The Conservation Council submission also stated that this proposal, if implemented, would place WA in breach of the objectives of the Natural Heritage Trust of Australia Act 1997, Section 10, which states:
“The Primary Objective of the National Vegetation Initiative is to reverse the long-term decline in the extent and quality of Australia’s native vegetation cover by:
a) Conserving remnant native vegetation; and
b) Conserving Australia’s biodiversity; and
c) Restoring, by means of revegetation, the environmental values and productive capacity of Australia’s degraded land and water.”
No comment.
The Conservation Council submission stated that the proposal was at variance with the Government’s biodiversity and conservation policy initiatives. It asked how the proposal would meet the no net loss of native vegetation requirement.
BGC accepts that its original revegetation proposal presented in the PER was difficult to judge and implement. However, BGC has since engaged the services of Mr Frank Batini to develop a feasible offsets strategy that meets the EPA’s requirement for generating a “net benefit” to the environment. As can be seen from his report (Volume 2; Appendix J) Mr Batini has obtained the support of many local authorities for his recommended strategy and BGC is now in a position to make a much firmer commitment than it was able to in the PER.
The Conservation Council submission stated that the proponent should meet the terms of the criteria developed by Safstrom and Craig (1996) as landholders wishing to clear agricultural zoned land are required to meet these criteria.
The criteria referred to this submission were developed for agricultural areas (Wheatbelt and coastal areas) and are not applied on a regular basis.
Public Submission 2 asked what guarantees there were that the vegetation north of the Great Southern Highway that is within the water catchment of the Goldfields Water Supply would not be encroached upon, damaged, destroyed or polluted as a result of the operations.
Clearing of vegetation will be restricted to the footprint of the proposed quarry operations and associated infrastructure, as outlined in Figure 1 of this document. No clearing of vegetation will occur outside of this footprint which occurs on land owned by BGC. There will not be any off-site impacts to vegetation due to the Project.
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The AVES submission stated that it is common practice to use topsoil for revegetation, but it would deteriorate badly if left for a long period as the seed bank degenerates. The submission asked how this stockpile will fit in with the need to re-contour the land.
It is well recognised that topsoil viability reduces if stockpiled for a long period of time. To prevent or minimise the loss of soil viability, the topsoil stockpiles would be seeded with native species. The topsoil would be used to rehabilitate disturbances within the proposed quarry area and/or the existing quarry. The topsoil is respread after contouring of the land. Once the topsoil has been fully utilised, the footprint of the stockpile(s) would also be contoured and rehabilitated.
Potential Impacts on Hemigenia viscida
Public Submission 1 asked how many Hemigenia viscida plants were estimated to be lost in the clearing undertaken in December 2001. This submission also asked whether Hemigenia viscida is immune to dieback and what measures would be taken to prevent the spread of dieback to these plants, if they are not immune to dieback.
The December 2001 clearing resulted in minor disturbance to Hemigenia viscida populations H9 and H10, so it is unlikely that many plants of this species were lost due to the clearing.
It is unknown whether Hemigenia viscida is immune to dieback, but CALM has tested Hemigenia exilisand found it to be resistant to Phytophthora cinnamomi (dieback). Hemigenia viscida in heath community H5 are not at risk, as the spread of dieback will be prevented through the implementation of the Dieback and Vegetation Management Plans. Further, dieback does not occur in the vicinity of the heath community H5.
The WBLCDC submission referred to Page ES-12 of the Executive Summary (Volume 1), which stated, “However, the conservation status of this species [Hemigenia viscida] has been downgraded to Priority 4 (Rare Taxa) on the State DRF and PF List and it is reasonable to assume that its classification under the EPBC Act will be reviewed in due course.” The WBLCDC submission stated that this does not change BGC’s legal obligations under the Act in relation to this species, including the need to seek Federal approval if impacts are significant.
It is unlikely that Hemigenia viscida would be placed on the DRF list if clearing for the Proposal was carried out, as most of these plants within the Project Area (approximately 95%) were recorded in one heath community (heath community H5), which is protected from clearing and other project disturbances by a 50 m buffer. In addition, this species is known to occur elsewhere in the State (on the eastern edge of the Jarrah forest and in pockets in the Wheatbelt region) (Mattiske Consulting Pty Ltd, 2002).
This issue was also discussed in Section 1.7.2 of the PER (Volume 2). This section of the PER states that, under the EPBC Act, an action requires approval from the Federal Environment Minister if the action has, will have, or is likely to have a significant impact on a Matter of National Environmental Significance. The proposed quarry relocation was referred to Environment Australia (now the Department of Environment and Heritage) on 22 February 2002 due to the potential for impacts on
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Hemigenia viscida and a number of vertebrate fauna species. Environment Australia subsequently advised that the proposal is not a “controlled action”. Therefore, approval is not required under the EPBC Act.
Public Submission 2 asked whether Hemigenia viscida would be placed on the Declared Rare Flora list if clearing for the proposal were carried out. The LAG submission raised a similar issue.
Priority 4 species are defined by CALM as “taxa which have been adequately surveyed and which, whilst being rare (in Australia) are not currently threatened by any identifiable factors”. It is unlikely that Hemigenia viscida would be placed on the DRF list if clearing for the proposal was carried out as almost 95% of the plants of this species within the survey were recorded in one heath community (community H5), which will be protected from clearing and other project disturbances by a 50 m buffer. In addition, this species is known to occur elsewhere in the State (on the eastern edge of the jarrah forest and in pockets in the Wheatbelt region) (Mattiske Consulting Pty Ltd, 2002).
The Wildflower Society submission stated that it welcomed the protection of 95% of the Priority 4 Hemigenia viscida population on the site, and that the society believed the buffer zone is essential to the population’s protection. Public Submission 1 asked whether the 50 m buffer for the protection of the heath community 5 is acceptable to stop the effects of water erosion, dust, flyrock, saline water and future weed invasion. The submission also asked of what the buffer would comprise.
The buffer will comprise undisturbed native vegetation and will be sufficiently wide to prevent or minimise any impacts on Hemigenia viscida from project development.
Public Submission 1 stated that Hemigenia viscida would be threatened by ongoing clearing and isolation and stated that BGC should provide a specific and comprehensive management plan for this species.
It is unlikely that Hemigenia viscida within the survey area will be adversely impacted as BGC has made a commitment to restrict clearing of this species to approximately 5% of the population known to occur in the Project Area. In addition, a commitment has been made to maintain a 50 m buffer around heath community H5 (which contains 95% of the known population of this species within the survey area) during all phases of the Project. This buffer zone, along with the vegetation in other parts of the Project Area, will be managed in accordance with the Vegetation and Dieback Management Plans developed for the Project.
The Conservation Council submission referred to Page 99 of the PER (Volume 2) which stated “Accordingly, groundwater levels downstream will not rise as a result of the quarry and may even fall in a small area immediately adjacent to the quarry”. The submission asked whether a fall in the groundwater level immediately adjacent to the quarry would have a negative impact on the remaining vegetation, including Heath community 5 of Hemigenia viscida.
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It is expected that the Hemigenia viscida plants within the Project Area tend to rely on seasonal water near the shallow outcropping areas. Therefore, this species is more reliant on rainfall than groundwater levels, and is most unlikely to be affected by groundwater drawdown.
Dieback
The LAG submission referred to a recommendation in the Dieback Assessment presented as Appendix C (Volume 3). The submission stated that LAG disagreed with the suggested location of the clean down station, which was proposed to be 400 m west of the existing quarry entrance.
BGC does not intend to construct a clean down station at the proposed location of 400 m west of the existing quarry entrance. A clean down station will not be constructed for the Project, as BGC will not be disturbing the dieback-infested area.
The LAG submission stated that BGC has not implemented the first two recommendations from the Dieback Assessment even though it was conducted in December 2001. The submission asked why BGC had not already prevented access to the diseased area and signposted it in order to arrest the spread of Jarrah Dieback. The submission also stated that the PER does not make any commitment to do anything about the dieback-infested areas before the commencement of work on its proposed quarry.
The first two recommendations of the Dieback Assessment undertaken in December 2001 involved the elimination of uncontrolled access around the dieback infested area and erecting signage educating riders of the disease status of the area. Access to the dieback infested area was blocked within a week of a follow-up dieback survey conducted on 28 May 2003. The dieback survey confirmed that dieback had not spread since the initial assessment in 2001. Signage informing people of the status of the disease in the zone has subsequently been erected in October 2004.
Vegetation and Dieback Management Plans
The CALM and Wildflower Society submissions stated that the Vegetation and Dieback Management Plans should clearly outline the objectives and outcomes. The CALM submission also stated that a description of how certain actions would be implemented should also be included.
The next draft of the Vegetation and Dieback Management Plans will be provided to CALM and the DoE for comment and finalised after receiving their comments. As finalisation of the plans is covered by proponent commitments, the final versions of the plans will be provided to the DoE audit branch for sign-off. In reviewing these plans, the DoE auditor will consider the requirements of the EPA.
Public Submission 1 asked what the fire management strategy is for the remaining remnant vegetation, particularly in regards to the protection of rare flora.
The risk of wildfires will be minimised through careful use and management of plant and equipment in the Project Area. Any fires that occur naturally or accidentally will be managed in accordance with the site’s emergency response plan.
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Public Submission 2 asked when the final Vegetation and Dieback Management Plans would be released.
As stated in the PER, the Proponent has made a commitment to finalising the Vegetation and Dieback Management Plans after considering the comments received during the public review period and in consultation with the regulators. The final draft of the plans will be submitted to CALM and DoE for review and finalised following the receipt of their comments. The final Vegetation and Dieback Management Plans will not be re-circulated in the public arena, however they will be available from BGC, should a request be made to BGC Quarries.
The Wildflower Society submission stated that the plan should be approved by the CALM. The CALM submission advised that the department would provide further comment following further stakeholder consultation. The CALM submission also stated that the redrafted plans should be reviewed to the requirements of the EPA, prior to project commencement.
The next draft of the Vegetation Management Plan will be provided to CALM and the DoE for comment and finalised after receiving their comments.
7.6 Vertebrate Fauna
Trees as Fauna Habitat
Public Submission 2 stated that the statement in the PER that there are few suitable breeding hollows in the Project Area is incorrect as there are hundreds of breeding hollows in the area. The AVES submission stated that the group recognised that there is not a significant number of trees available for nesting of large birds but there is a significant number of trees present with hollows available for small birds and reptiles. The AVES submission suggested that these smaller nesting sites have the potential for larger birds to utilise them in future but will not be available if they are destroyed during the expansion procedures.
Additional survey work was conducted to identify significant habitat trees with suitable hollows for the targeted species (see Volume 2; Appendix G). Whilst Johnstone and Kirkby (2003) identified both small bird and mammal nesting within some of the surveyed trees, the primary focus was still on fauna of conservation significance (primarily Black Cockatoos, Phascogales and Chuditch). Only three of the 163 trees considered by Johnstone and Kirkby (2003) proved to have potential use for the targeted fauna, confirming the initial assessment of Biota and Johnstone (2003). None of these hollows were confirmed as supporting current activity by the species of interest.
The LAG submission stated that there are “some 700 trees on the site that appear to offer appropriate hollows for nesting on account of their height, their hollows, and so on”.
In order to ascertain the validity of the LAG statement that there are “some 700 trees on site that appear to offer appropriate hollows for nesting on account of their height, their hollows and so on”, the criteria used
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by the LAG in order to assess significant habitat trees on site would need to be reviewed. As outlined in the previous response, detailed field studies by specialists indicated that only three trees on site had the potential to provide breeding resources for species of conservation significance.
The Earth submission stated that, at worst, the clearing of natural hollows displaces the hundreds of species who depend on them and that the fauna report did not recommend a sufficient number of hollows to be placed outside the area to be cleared for use of obligate hollow-nesters.
A recommendation was made in Section 4.4 of Biota and Johnstone (2003) to erect 6-10 nesting boxes. As part of the Fauna Management Plan (Volume 2; Appendix G), the uses of nesting boxes erected within uncleared areas would be monitored. This would allow for the future augmentation of nesting boxes, if warranted.
Public Submission 11 referred to page 6 (Recommendations – Biota report) which stated, “Wherever possible, hollow-bearing trees should be left undisturbed”, and queried in what situation would this be possible and what guidelines do you use for saving a habitat tree.
A working method is included in the Fauna Management Plan (Volume 2; Appendix G) detailing the guidelines for retaining habitat trees. Prior to habitat clearance, any trees to be retained would be tagged and recorded, marked with high visibility tape at eye level or above on the main stem. All site staff associated with the clearance works would be briefed on the procedures for marking and retaining any significant habitat trees. It is anticipated that only larger trees, such as the three identified by Johnstone and Kirkby (2003), would be subject to this procedure.
The AVES submission asked how many species of bats are using the Wandoo spouts? It also asked how many Boobook, Barking or Barn Owls are using hollows in trees and whether Black Cockatoos are using any spouts or hollows?
As no bat species of conservation significance are likely to occur in the quarry area, there were no bat species amongst the taxa required to be targeted by survey by the DoE Ecological Systems Branch (Biota and Johnstone, 2003). There are therefore no records of bat species utilising Wandoo spouts on site. Hollows with recorded use by Black Cockatoos and Boobook Owls were discussed in the results section of Johnstone and Kirkby (2003) (Volume 2; Appendix F). It should be noted that evidence of hollows being utilised by cockatoos was recorded outside of the proposed development footprint, adjacent to the site boundaries to the north and southwest (Johnstone and Kirkby, 2003).
The AVES submission and Public Submissions 2, 9, 11, 14 and 18 stated that the use of nesting boxes to off-set the reduction of natural nest hollows had not yet been proved effective.
It was clearly recognised in Biota and Johnstone (2003) that the use of nesting boxes is still in development as a management technique. It is, however, the most appropriate and direct management response to address the issue of potential nest site loss. Without trials of this management approach, there will be no data to evaluate its success and usefulness in a management context.
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Impacts
The Birds Australia submission stated concern about the loss of a large area of habitat that is regionally important for a range of bird species that are uncommon or declining in the wheatbelt region and as a potential feeding habitat for a number of nationally endangered bird-life. The submission expressed concern for the loss of habitat for regionally uncommon species such as Carnaby’s Cockatoo, a species listed as Endangered under the federal EPBC Act and under the state Wildlife Conservation Act. It stated that food sources include banksias, eucalypts, hakeas and grevilleas occur in the project area and that this habitat is an important regional foraging site in a diminishing matrix of fragmented native vegetation.
The significance of the site to Carnaby’s Cockatoo has been addressed in detail in Section 4.6 of this document, Biota and Johnstone (2003) and Johnstone and Kirkby (2003) (Volume 2; Appendix F). The available data indicate that the site is of little significance to this species at either a population or taxon level. There will be local loss of avifauna habitat associated with clearing works. However, the site is situated in a context of somewhat fragmented, but relatively extensive, remnant vegetation (see Figure 8.1).
The Birds Australia submission stated that it encouraged the retention of this native habitat, particularly the heathland and wandoo woodland. The submission stated that wandoo bushland type represents an important remnant of a regionally declining habitat and contains a suite of bushland-dependent species unlikely to occur post-clearing. It was stated that the key threatened species likely to be impacted, particularly through the loss of Wandoo woodland, include the Western Shrike-tit, Rufous Tree Creeper and Western Yellow Robin. The submission also stated that the retention of the area is necessary in maintaining the regional connectivity of populations and buffering against long term species loss.
None of the species noted above were considered to have been sufficiently at risk by the DoE Ecological Systems branch to need targeted fauna survey assessment. These were therefore not considered by Biota and Johnstone (2003) and Johnstone and Kirkby (2003), although only one, the Western Yellow Robin was documented as occurring on the site.
Public Submission 10 referred to the Field Guide to the Birds of Australia (page 314) and stated that food dispersion due to the clearing of native vegetation means that the birds cannot supply enough food for their young, resulting in population decline.
The target avifauna species of conservation significance surveyed by Biota and Johnstone (2003) (Carnaby’s Cockatoo, Baudins Cockatoo and the Forest Red-tailed Black Cockatoo) are wide range foragers utilising diverse food sources. It is accepted that reduction in foraging area will result in population decline of other more sedentary bird species that are not of elevated conservation status.
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Public Submission 6 referred to page 15 of the Executive Summary (Volume 1) and queried why BGC believed that ‘reducing the likelihood...of significant impact on threatened or migratory species’ was an adequate response in relation to environmental safety when ‘certainty’ is required.
The survey undertaken by Johnstone and Kirkby (2003) confirmed that there is a lack of suitable habitat trees for threatened species, where only three of the 163 trees considered by Johnstone and Kirkby (2003) proved to have potential use for cockatoos.
The Conservation Council submission stated that a population of Numbats was released in the Mundaring catchment area in 1997 and 1998, and the habitat range of the species is expected to encroach on the proposal area. The submission asked what the conservation status of the Numbat is and why the proposal should be allowed to potentially impact their conservation status.
The conservation status of the Numbat is Schedule 1 (vulnerable) under the Wildlife Conservation Act 1950-1979. The home range for both sexes ranges from 25 to 50 ha, however dispersal movements of more than 15 km have been recorded (Strahan, 1995). There is no evidence to suggest that the re-introduced Numbat population at Mundaring has reached the proposed quarry site. This therefore has no bearing on the proposal and the quarry relocation would not alter the conservation status of this species even if re-introduced animals were present.
Public Submission 18 stated concern that various fauna had been identified as being endangered or vulnerable under the EPBC Act 1999 and that the Proponent is meant to identify its actions under the Act as well as abiding by WA State Government’s legislature and procedures.
The proponent has met its obligations under these acts by completing targeted fauna surveys to assess the presence of any listed species (Biota and Johnstone, 2003; Johnstone and Kirkby, 2003). These studies indicated that there are no species listed under these acts that require further statutory clearances in respect of the proposed relocation.
Public Submission 18 stated concern for the lack of attention paid to the endangered and threatened fauna habitat. The Earth submission stated that there is a lack of attention given to protecting the CALM Priority 3 Phascogales from the proposed quarry expansion and loss of habitat if clearing proceeded. Public Submission 2 stated that if the Chuditch was threatened with extinction, then knowing that this species occurs in the area should be sufficient reason to disallow any further clearing.
Biota and Johnstone (2003) and Johnstone and Kirkby (2003) completed targeted fauna surveys of the proposed quarry site specifically seeking evidence of threatened fauna use. This included the Phascogale and the Chuditch. No evidence of Phascogale use of the subject land was recorded. A single Chuditch was recorded during the survey, but as noted in Biota and Johnstone (2003), the area to be cleared for the quarry would represent a small percentage of the home range of this individual. The quarry would therefore not result in any changes to conservation status for these species.
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Public Submission 6 referred to paragraph 7 on page 12 of the Executive Summary (Volume 1) and queried what BGC proposes to do about the less mobile species such as lizards, snakes, small marsupials and insects that are less mobile than the larger species such as the Chuditch.
Management procedures addressing less mobile fauna during clearing and construction works are addressed in the Fauna Management Plan (Volume 2; Appendix G).
Public Submission 16 asked where mobile fauna would move to?
Mobile fauna are likely to move to vegetated areas adjacent to the project area. These areas include land to the south, southwest, and east of the proposed quarry. As stated in Section 2.8 of Appendix D of the PER (Volume 3), the vegetation on the western boundary of Lot 11 is Wandoo woodland and this continues through to the land where the Mundaring Shire gravel pit is located. Therefore the vegetation within Lot 11 and the Mundaring Shire land provide areas for mobile fauna to move to. There are also opportunities for fauna to move to State forest to the southwest of the project area.
Public Submission 1 stated that the current impacts on target species due to existing quarry activities, such as blasting, have not been adequately described. The AVES submission stated that the continual blasting would inevitably have a deleterious effect on fauna, particularly at breeding time.
There are many studies that show that animals readily habituate to non-threatening noises. The difficulty experienced by airport authorities in keeping seagulls away from runways is a classic example.
Public Submission 9 stated that the quarry extension would create a pool of water inaccessible to wildlife yet contribute to explosions of mosquito and feral bee populations that would compete for nest hollows.
A number of mosquito species found in WA breed on the surface of stagnant and permanent freshwater pools. Appropriate management of any water bodies that may develop due to quarrying works may be implemented depending on the level of the mosquito problem. This will largely be determined as an occupational health and safety issue for the quarry workforce.
Feral bees are already present in the site area. A number of hollows suitable for Cockatoo nesting were occupied by feral bees at the time of the additional tree hollow survey conducted by Johnstone and Kirkby (2003). Section 4.6 of the Fauna Management Plan (Volume 2; Appendix G) details control methods for feral bees and this will for an adjunct to any trials of nesting boxes as part of cockatoo management.
Public Submission 9 stated that the kangaroo populations will be unbalanced by 50 years of quarrying and this will cause problems to nearby properties. The AVES submission stated that if animals move into other areas following clearing of the Project Area, the habitats already occupied by other animals will be defended and as a result cause the death of one animal. The DoE (Ecological Systems Branch) submission stated that the example of reducing impact on poorly dispersing species such as the Honey Possum is a poor example when the Honey Possum had not been recorded within the Project Area.
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The kangaroo population has already shown adaptive behaviour regarding historical disturbance due to quarrying operations already occurring on the site. As the kangaroo population within the survey area is not contained, and appears to already be utilising surrounding land, any additional kangaroo displacement may be incremental rather than the development of an entirely new behaviour and movement pattern. The estimates of kangaroo numbers do not suggest an especially large population is currently resident within the quarry area.
Recommendations from the Targeted Vertebrate Fauna Survey Report
Four submissions commented on the recommendations made in the targeted vertebrate fauna report prepared by Biota (2003). These comments are provided below.
The Earth submission stated that Recommendation 1 of the Biota report is inadequate and did not address the following:
a) The decline in cockatoo nesting opportunities and general number of cockatoos.
b) Cockatoos are ‘protected’ birds both federally and by State Legislation.
c) The overall clearing impacts of other clearing in the area.
d) The lack of evidence demonstrating that cockatoos use the hollows at all.
e) The findings by the CSIRO that nesting boxes can have an adverse effect on native fauna for a number of reasons.
f) The high level of doubt that cockatoos would live in artificial boxes or any hollows near the quarry pit.
The Earth submission stated that the recommendations are extremely limited and did not discuss the enhancement of remaining habitat, protection and relocation of species threatened with habitat destruction.
The specific aim of the Biota and Johnstone (2003) report was to identify the suitability of habitat on site, nesting opportunities and presence of a number of targeted Threatened fauna species. This included species of Black Cockatoo that may utilise the survey area for breeding and foraging. A full appraisal of overall impacts of other clearing in the area was outside the scope of the targeted study. This was specifically noted in the limitations section of Biota and Johnstone (2003).
Contrary to the above submission, Sections 1.1 and 3.4.1 of Biota and Johnstone (2003) note that Carnaby’s Cockatoo is a Schedule 1 protected species and the Forest Red-tailed Cockatoo is a Priority 3 species. The reasons for this elevated conservation status, including nest site decline, were also discussed.
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In response to (d) of the Earth Submission above, the additional tree hollow survey of Johnstone and Kirkby (2003) largely confirmed the initial assessment of Biota and Johnstone (2003) that the site contained very few suitable breeding hollows for black cockatoos.
Artificial boxes are discussed further in Response 4.1 - 4.6 above. The Water Corporation Cockatoo Care programme has had some successful results with Carnaby’s Cockatoo nesting within artificial box trials in the wheatbelt region of WA (Water Corporation Cockatoo Care Programme, 2004).
Public Submission 1 stated that there is no recommendation for relocating fauna to suitable habitats when further clearing is carried out.
Prior to the commencement of the clearing activities, a trapping and survey exercise to cage trap and relocate threatened fauna will be undertaken as outlined in the Fauna Management Plan (see Section 3.4.1 of Volume 2; Appendix G).
In relation to Recommendation 2 in the Biota report, Public Submission 11 asked when the fauna habitat in rehabilitated areas would be enhanced with logs and suitable debris as 50 years time will be too late, and Public Submission 14 stated that the ability of logs and debris to be used for fauna habitat may be lessened as felled timber was removed after the land clearing in 2001.
Methods to provide habitat reconstruction for fauna are included in the Fauna Management Plan (Volume 2; Appendix G). The use of cleared timber to create microhabitats is a standard management procedure and could be a viable option to be employed within the project area. Retaining logs from felled mature or senescent trees can offer immediate and provisional future habitat for local ground fauna.
The LAG submission asked what commitments BGC is going to make based on the information presented in the Biota report.
These recommendations are addressed in the Fauna Management Plan for the Voyager Quarry relocation area (Volume 2; Appendix G). The plan will be submitted to the relevant government agencies (CALM and DoE) for approval prior to implementation. This plan included management measures addressing pest species and enhancement of habitat for target species at the local scale.
Fauna Management Plan
The CALM and the Wildflower Society submissions stated that the Fauna Management Plan should clearly outline the objectives and outcomes. The CALM submission also stated that a description of how certain actions will be implemented should also be included.
The Fauna Management Plan sets out the timing, responsibility and objectives of the planned management actions. This provides details of management procedures and allow for implementation to be auditable.
Public Submission 2 asked when the final Fauna Management Plan would be released. The CALM submission advised that the department would provide further comment following further stakeholder
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consultation. The CALM submission also stated that the redrafted plan should be reviewed to the requirements of the EPA, prior to project commencement.
The Fauna Management Plan is currently in a draft state. It will be submitted to the relevant agencies for approval prior to the commencement of any clearing activities on site.
7.7 Invertebrate Fauna
The WBLCDC and AVES submissions stated that the discovery of the Gaius sp. is significant and the percentage to be affected is also a concern. The LAG submission stated that it would be irresponsible to commence quarrying before this new Gaius species is fully documented, lest it become extinct or endangered as a result of BGC’s quarrying activities. The DoE (Ecological Systems Branch) submission stated the trapdoor spider was an unresolved situation.
BGC recognised that the trapdoor spider issues was unresolved and therefore commissioned Professor York Main to undertake further investigation during March 2004. The objective of these studies was to:
1. Determine the population size and distribution in lots 11 and 14 of Gaius sp. spiders and to describe their habitat preferences.
2. Collect male specimens and thereby assist with diagnosis of species and confirm generic placement.
3. Conduct a comprehensive survey outside the above location to ascertain whether the species has a wider geographic occurrence in adjacent land and on sites with similar habitat and topographic position within the Darling Range southward from the above location.
4. Identify a suitable relocation site for some spiders within the quarry footprint.
Professor York Main’s reports and a summary of findings and recommendations are presented in Volume 2; Appendix H.
The conclusions from the summary report are presented below.
The core population (containing approximately 79 burrows) is located within the proposed quarry relocation area. The long-term persistence of the other spiders within the vicinity of this area may be dependent on this core population. Main (1987) noted that Anidiops villosus (Rainbow)(=Gaius villosus Rainbow) can persist in remnant bush provided about 20 matriarchs (reproductive age females), representing about 25% of a given subpopulation, are present in a group of closely aggregated clusters and with additional aggregations (of similar representative age structure) scattered in proximity in continuous bush. Thus, extrapolating from other studies and considering the disparate distribution of low density clusters of the Gaius sp. in lots 11 and 14 outside the dense aggregation in the proposed Voyager Quarry relocation area (and that minimal size of reproductive
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females is not known), it is unlikely that the population of Gaius sp. will be able to persist in the long-term if this “core” population is destroyed.
Should the quarry relocation proceed, approximately 46 burrows will not be disturbed on the remaining areas of lots 11 and 14. Whilst these spiders are likely to survive in the short- to medium-term, their long-term persistence without the core population providing regular recruits is questionable.
The Gaius sp. spider population is likely to be highly sensitive to fire because the species does not make a soil plug at the burrow entrance. Therefore, fire management should be a critical component of any land management plan for lots 11 and 14.
The male specimen of Gaius sp. spider from Lot 14 differs morphologically from other male specimens of Gaius spider populations that have been found to the east of the Avon.
The Gaius sp. population from lots 11 and 14 appears to be the northern extent of the southerly distribution of Gaius spider populations. The Voyager (male) specimen does have some morphological affinity with “southern” spiders. The Voyager species may be either the same or a different species (derived from a possibly once continuous population) as the species farther south. More morphological comparisons need to be made. For example, comparisons on samples of internal genitalia of females and comparisons of additional male specimens (from Voyager) and Collie need to be made. The specific status is still not conclusive.
The Gaius sp. spider has been found in low numbers on land adjacent to lots 11 and 14, and in an area near the intersection of Brookton Highway and Beraking Pool Road.
Whilst trapdoor spiders can be readily translocated into artificial accommodation such as flower pots of soil maintained in a laboratory, translocation of large populations in the field has not yet been attempted and the likely success of such translocation is unknown.
The recommendations from the summary report are as follows:
If the proposed quarry proceeds, fire management strategies should be implemented to protect the remaining spiders, as the Gaius sp. is likely to be sensitive to fire.
Given the uncertainty of long-term survival of the spider in this area if the quarry relocation proceeds, further investigation is desirable to locate a dense population within the conservation estate nearby so that there is confidence that the Gaius sp. will persist in the long-term.
Professor York Main’s reports were provided to Dr John Dell of the EPA Service Unit for review. Subsequent discussion of findings with Dr Dell indicated that the conservation significance of the spider was still unresolved, and that a quicker way of resolving this issue may be to undertake genetic analyses to confirm the spider’s taxonomy.
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Subsequently a further survey was conducted in November 2004 to collect specimens for genetic analysis and also search additional sites in the region for more populations of spider. There was a total of 10 sites searched and spiders were found at the Voyager Quarry and the Beraking Pool Road/Brookton Highway intersection. However, a robust population (some 25 spider burrows) was found to occur at this latter site. It is likely that these spiders are the same species as that found at the Voyager Quarry, but it is also likely that they are genetically isolated.
It is proposed to collect a male specimen from the Beraking Pool Road population next autumn and undertake morphological analyses to confirm its taxonomic affinity with the Voyager population. In the meantime, specimens of females have been collected.
Assuming that the taxonomic analyses confirm that both populations contain the same species of spider, and given that some 30% of the approximate Voyager population will remain undisturbed (although their potential for long term survival is unknown), it is considered that the risk of the species becoming extinct is now much less than previously.
The WBLCDC submission stated that a successful method of spider relocation was necessary before development proceeds. The DoE (Ecological Systems Branch) submission asked about the previous success of trapdoor spider translocation.
Professor York Main has considered the issue of spider relocation and provided recommendations on the scope of work required in the event that such an exercise is undertaken. At present, the only areas available for translocation are Lot 11, undisturbed parts of Lot 14 and the Beraking Pool Road/Brookton Highway site. The requirements for translocation of the Gaius sp. from Lot 14 at a population level would involve:
identification of a suitable habitat for the translocation of spiders;
excavation and removal of the specimens, which is a labour intensive process;
establishment of artificial burrows at the new site; and
implementation of a monitoring programme for the first three years, then at 10 and 20 years.
There has been one published example of a successful translocation of an individual trapdoor spider (an adult Idiosoma sigillatum) (Prince, 2003). In this relocation, the spider had been dislodged in a Nedlands garden and was translocated to bushland at the CALM Wildlife Research Station at Woodvale. The spider became established in a burrow provided for it, and over a few days it made a door and attached a fan of twigs, which is characteristic for the species. It was recorded to be still alive and active two years after translocation.
Public Submission 1 stated that if the trapdoor spiders that are found in the area which is not cleared require more than that area to maintain viable breeding populations, their ability to do this would be hampered by the proposed quarry.
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The area required for persistence of a trapdoor spider species varies according to the following factors:
Life history strategy (longevity, reproductive phenology and behaviour, dispersal capability); Topography; Soil type; Vegetation type; Burrowing and foraging behaviour; and Availability of prey.
In a study undertaken by Main (1987), it has been demonstrated that populations of certain trapdoor spiders can persists in remnant bushland in the Wheatbelt of Western Australia. It was suggested that approximately 25 ha of favourable habitat with a surrounding buffer area is adequate to maintain a viable population of Gaius villosus at least in the short-term.
The habitat for the Gaius sp. trapdoor spiders in Lot 11 and the northern area in Lot 14 will not be disturbed by BGC.
The LAG submission stated that URS changed the meaning and intent of the trapdoor spider report by inserting two sentences in the Conclusions without Professor Barbara York Main’s approval.
URS did not intentionally change the meaning of the trapdoor spider report entitled ‘Survey of Trapdoor Spiders Occurring in Avon Location 1881, Lots 11 & 14, Including an Area for Proposed Relocation of the Voyager Quarry’ and presented as Appendix E of the PER (Volume 3). Professor York Main has accepted that based on the information in her report, the changes made by URS were reasonable and were done in good faith.
The Shire of Mundaring submission requested clarification on the classification of the invertebrate fauna species identified at the site, i.e. if they are rare, endangered or protected by some form of legislation. The WBLCDC submission asked what the impact to the land snail population would be outside the proposed quarry footprint.
The invertebrate fauna species identified within the Project Area are not classified as rare, or specially protected under the Wildlife Conservation Act 1950 or the EPBC Act. The trapdoor spider found in the Project Area appears to be a new species. Examination of a male specimen collected in March 2004 shows that while it shares some similarities with specimens collected from Collie, Tambellup and Esperance, it does have markedly different palpal structures to these specimens.
The three land snail species found in the Project Area in 2002 are undescribed and poorly known specimens belonging to three different families of snail. Further survey work conducted by the Western Australian Museum (Ms Slack-Smith) in May 2004, has found that two of the snails inhabit other parts of the Darling Range, and that the third appears to be very closely related to a species which is common on the Swan Coastal Plain. The land snails were found in Lot 11 and on the northern part of Lot 14, which will not be disturbed by BGC and therefore are not at risk from the quarry relocation. The Western Australian Museum report on the findings of the May 2004 survey is presented in Volume 2; Appendix I.
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The LAG submission highlighted a statement made in the land snail report, which stated that in absence of comparable surveys on land snails on the Darling Range, no valid evaluation of snail fauna in the project area could be made. It asked why the recommendation from the Land Snail Study to conduct further investigation in adjacent areas was not mentioned in the PER. Public Submission 8 stated that the Land Snail Study found three species of snail that were of scientific interest and environmental importance but that the PER disregarded all of the recommendations of the Land Snail Study.
As indicated in the previous response, the recommendations of the land snail report presented as Appendix F of the PER (Volume 3) were implemented in May 2004. The results of this survey are presented in Volume 2; Appendix I.
The LAG submission stated that the “Environmental Issues and Management” section of the PER (Volume 2) said that there was an impoverished molluscan fauna within the survey area. The submission questioned this statement as the researcher neither said nor implied that the population is impoverished or rich, and that if the snail population is impoverished, then BGC should make heroic conservation efforts to sustain and/or increase that population. The WBLCDC submission referred to page 13 of the Executive Summary (Volume 1) and asked what condition the molluscan population would be in once the development begins if it is already impoverished.
The statement in the PER referring to “an impoverished molluscan fauna” was taken from Section 4.0 of the land snail report presented as Appendix F of the PER (Volume 3). The land snail report states “Few species of terrestrial snails were recorded from this survey, even though the fieldwork was conducted over two days by four people (two with extensive experience in such work). This low level of diversity of native species appears to indicate an impoverished molluscan fauna in this part of the Darling Range”. It is the intent of the author of the land snail report that the word “impoverished” means that there is a sparse molluscan fauna is sparse.
According to the land snail report, the sparse molluscan fauna population could be related to the low level of available calcium in the granitic and lateritic rocks and soils in the area. Other environmental factors that might contribute to the sparse population are the low and unpredictable rainfall, generally low humidity and wide temperature range.
Of the few populations of Bothriembryon species, which have been detected on the Darling Range over a period of many years, high population densities have never been recorded. However, the persistence of these populations indicates that these snails, at seemingly low density, are still sufficiently abundant to find one another, mate and reproduce often enough to maintain the population.
As little is known about the requirements of the land snail species and the ways in which they interact with their physical or biotic environment, there is little that BGC can do to sustain or increase the population.
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Once the Project commences, the land snails located within the immediate Project Area will be lost from the local land snail population. However, as indicated in the report prepared by Ms Slack-Smith (2004), the species will survive on in Lot 11 and undisturbed parts of Lot 14 and their survival is not at risk.
The LAG submission stated that the Draft Fauna Management Plan did not include any management measures for the trapdoor spiders or the land snails.
Advice received from the invertebrate fauna specialists indicated that the following management measures could be undertaken to minimise the impact on trapdoor spiders and land snails.
Ensure that the footprint of disturbance is limited to that which is essential to the practical operations of the quarry;
Prevent disturbance in areas that are not proposed to be cleared;
Ensure that all vehicles remain on designated tracks. No off-road driving is permitted;
Ensure that natural drainage is maintained in areas that are not proposed to be cleared; and
Ensure that introduced plant or animal species do not establish within the Project Area or Lot 11.
7.8 Local and Regional Biodiversity Conservation
The CALM submission stated that the clearing of 85 ha of native vegetation would have some impact on biodiversity values but that this loss could be mitigated to some extent by the commitments given by BGC in the PER. The WBLCDC submission stated that the claim that there will be no biodiversity loss contradicts statements in the PER that there will be a loss of species.
The WBLCDC is not correct when they stated that the PER claimed that there will be a loss of species. In Section 6.2 of the PER (Volume 2), it stated that there would be no loss of regional biodiversity values or flora and fauna species as the vegetation associations to be cleared are well represented within the conservation estate and the vertebrate fauna are widespread in distribution. However it was recognised in Section 6.2 of the PER (Volume 2) that there would be a localised reduction of some biodiversity values as a result of the clearing of native vegetation. It also stated that there would not be a loss of “regional biodiversity”.
The Proponent agrees with the statement in the CALM submission, which says that the impact on biodiversity values could be mitigated by the commitment to rehabilitate land within the Wooroloo Brook Catchment as compensation for the disturbance of 85 ha of vegetation on Lot 14. As indicated, BGC has now proposed a new offsets strategy which has been designed to generate a “net benefit” to the environment in accordance with the EPA’s preliminary Position Statement on environmental offsets.
Public Submission 6 referred to Page ES-13 of the Executive Summary (Volume 1), which stated, “Clearing of vegetation within the Project Area will result in the localised loss of habitat for vertebrate
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and invertebrate fauna”. The submission asked whether the Proponent claims that localised loss of habitat does not result in localised loss of biodiversity.
The Proponent does not agree that the statement in the Executive Summary (Volume 1) referring to the localised loss of habitat for vertebrate and invertebrate fauna will result in localised loss of biodiversity. The National Strategy for the Conservation of Australia’s Biological Diversity (ANZECC, 1996) defines biodiversity on three levels:
genetic diversity – the variety of genetic information contained in all of the individual plants, animals and microorganisms that inhabit the earth; species diversity – the variety of species on earth; and ecosystem diversity – the variety of habitats, biotic communities and ecological processes.
Based on these definitions of the three levels of biodiversity, the localised loss of habitat will not result in the loss of genetic, species or ecosystem diversity as the vegetation associations to be cleared are well represented within the conservation estate and the vertebrate fauna are widespread in distribution.
The Wildflower Society (Eastern Hills Branch) submission asked for references to support that degraded areas in the Wooroloo Brook catchment can be restored to intact bushland status.
Revegetation that is undertaken as part of the offsets package will not restore the degraded areas to “intact bushland”, but it will offset the reduction of biodiversity values that will occur as a result of the clearing of native vegetation for the Project.
Revegetation in the Wooroloo Brook catchment has been undertaken at the Wooroloo Prison South. Sinclair Knight Merz developed a tree planting programme for the proposed Wooroloo Prison South, which was prepared for the Ministry of Justice (SKM, 1998). The proposed Wooroloo Prison South involved the clearing of 11.5 ha of remnant Jarrah woodland. However, this was to be offset by the planting of approximately 11.2 ha of native vegetation around the proposed prison site. A planting prescription and maintenance programme was prepared to maximise the success of the planting programme. In June 2004, the prison maintenance officer indicated that the establishment of trees (woodlots) has been extremely successful, and this was attributed to the nutrients from the prison wastewater treatment plant.
Public Submission 2 stated that the revegetation in other tributary catchments, even if it was downstream, would not stop an increase in salinity and waterlogging that is already present along this section of Wooroloo Brook. The LAG submission stated the proposed revegetation scheme is unlikely to inhibit groundwater tables from rising. The Wildflower Society submission stated that rehabilitating 170 ha in the Wooroloo Brook Catchment will benefit salinity and water management in the catchment, but would not address the loss of intact, long-established native vegetation as a result of clearing for the quarry. The CALM submission stated that the loss of biodiversity values from the clearing of 85 ha cannot be replaced in the short to medium term by replanting 170 ha of disturbed land, and that it was not clear whether this could be achieved in the long term.
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The objective of the original Revegetation Strategy was to replace some of the local biodiversity values that will be reduced as a result of clearing approximately 85 ha of vegetation within the Project Area. As part of the Response to Submissions process, an offsets package has been developed and involves the rehabilitation of approximately 60 ha of degraded Crown land in the vicinity of the quarry, and protection in perpetuity of up to 420 ha of existing remnant bushland within the catchment. This would contribute to the salinity management within the catchment.
The Proponent agrees with CALM when it states that biodiversity values cannot be replaced in the short- to medium-term by the implementation of the Revegetation Strategy as originally proposed, but the Proponent is confident that its proposed new offsets strategy will result in some long term benefits to local biodiversity values.
The WBLCDC submission asked what evidence there is to show that the 2:1 ratio (170 ha) of revegetation would be effective. The Wildflower Society (Eastern Hills Branch) submission asked why the wider community should accept that 85 ha of intact bushland should be given up for a compensation of parcels of bushland of unknown quality and location.
There is evidence available from Alcoa’s rehabilitation operations in the Darling Scarp, that revegetation is possible. A 2:1 ratio was offered in recognition that it provided a reasonable buffer to ensure that the 85 ha of vegetation lost from Lot 14 would be replaced elsewhere in the catchment. The Preliminary EPA Environmental Offsets Position Statement (No. 9) (2004b) states that “positive offset ratios should be used where ‘critical assets’ are adversely impacted, or where there is a risk that the offset will not succeed over the long-term. That is, the size of the offset to impact ratio should be larger than 1:1 and be proportional to both the importance of the environmental asset being impacted, and the likelihood that the offset is unlikely to achieve a ‘net environmental benefit’ outcome”. Therefore, the 2:1 ratio meets the requirement of the EPA Position Statement.
Note that the Proponent has now proposed a new offsets strategy which has been developed to generate a “net benefit” to the environment. This offsets package will rehabilitate some 60 ha of degraded Crown land in the vicinity of the quarry, and will protect in perpetuity up to 420 ha of existing remnant bushland within the catchment.
The wider Perth community should accept the loss of 85 ha of remnant bushland in return for both BGC’s offset package and maintenance of a competitive raw materials market in the metropolitan area.
The AVES submission asked why options for revegetation had not already been determined and what if the investigation shows that there are no options available for revegetation. This submission also asked that, if only private land available, what would happen if the land owners won’t sell their properties.
BGC endorses the above comment because that is precisely what has transpired. Difficulty has been encountered in identifying suitable parcels of land for rehabilitation. It is for this reason that BGC engaged the services of Mr Frank Batini to develop an offsets package that was both feasible and supported by local authorities. This package is based largely on rehabilitating or protecting degraded
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Crown land being managed by various local and government authorities. Letters of support have been received from these authorities and CALM has indicated willingness to undertake the revegetation work under contract to BGC.
Public Submission 6 asked whether the proponent could indicate the location of cleared Crown land on Figure ES2.
The nearest is a small area of cleared Crown land located on Reserve 36125, located on the western side of Horton Road. This reserve is labelled on Figure ES2 of the PER (Volume 1). This cleared area, which is shown on Figure ES3 of the PER (Volume 1), is a Shire of Mundaring gravel pit.
The WBLCDC submission, LAG submission, AVES submission, Public Submission 1, Public Submission 4, the CALM submission and the Shire of Mundaring submission requested more information on the following aspects of the proposed revegetation programme:
where the revegetation would occur (including whether cleared areas would be revegetated or just “disturbed areas”, and proximity to the quarry);
the method of revegetation (including whether it would be a plantation);
the timing of the revegetation;
the standard of revegetation (species selection);
responsibility for managing and monitoring the revegetated areas; and
methods for protecting the revegetated areas in the long-term (such as conservation covenants).
Note that the revegetation strategy presented in the PER has now been replaced by the Proponent’s new offsets package described previously in this document. Volume 2; Appendix J addresses the above questions in greater detail. In summary, the rehabilitation strategy for each individual parcel of land will differ according to its condition and current use. Implementation of the offsets package will commence immediately on receipt of approval to proceed and rehabilitation of cleared sites will occur in advance of clearing for the project. It is BGC’s preference to contract CALM to undertake all revegetation works and CALM has indicated a willingness to do so. Assuming that BGC reaches agreement with CALM, then CALM would manage and monitor the rehabilitated areas to the standard specified in their guidelines. Some of the areas will be protected by covenants and BGC will investigate opportunities to covenant all rehabilitation and protected areas.
A number of suggestions and comments were made in relation to the proposed revegetation strategy, as follows:
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Objectives and Outcomes – The CALM submission stated that the revegetation strategy should clearly outline the objectives and outcomes. The objective should be supported by specific strategies and quantitative success criteria.
Location - The WBLCDC submission stated that the revegetation should occur in the immediate catchment area to offset the loss of vegetation. The Shire of Mundaring submission stated that the revegetation should be concentrated within the White Gum Gully sub-catchment to achieve local catchment management benefits, as the project is located within this sub-catchment. Public Submission 1 questioned the location of the revegetation projects in the Shire of Northam as the downstream impacts of the current mining operations are felt by catchment located in the Shire of Mundaring. The AVES submission stated that it is not possible to return cleared land to its natural state especially if there is a large weed or pasture burden.
Timing - The Wildflower Society submission stated that the proponent should be committed to the production of a revegetation strategy before commencing the quarry development. Public Submission 4 stated that the revegetation should be conducted beforehand because it will take many years of growth to compensate the loss of 85 ha. The AVES submission stated that the proposal to complete the revegetation by the time the existing operations cease was unacceptable because the cessation of the existing operations is flexible. The WBLCDC submission stated that there should be continuous infilling for the life of the proposal (50 years).
Type of Revegetation - The CALM submission stated that the proposed revegetation strategy requires a stated objective of rehabilitating the disturbed land in order to provide a habitat that mimics the floristic structure and diversity of nearby native vegetation to the fullest extent possible to maximise the biodiversity outcomes. The Wildflower Society submission stated that the revegetation would only be worthwhile if it mimics the floristic structure and diversity of the nearby native vegetation, and that this should be an EPA condition for the proposal. The WBLCDC submission stated that the revegetated sites would not have the same diversity of plant species as intact bushland nor attain the same health and quality. It stated that the revegetation project would only achieve 20-25 species because of the lack of availability of seedlings or seed. The Wildflower Society submission stated that plantation planting would not be adequate.
Provision of Fauna Habitat – The Birds Australia submission stated that high-quality rehabilitation will have some role in providing feeding habitat for local bird species. Public Submission 5 stated that it would take a long time for the revegetated areas to be able to support the wildlife that will be displaced as a result of the clearing.
Management of Revegetated Areas - The WBLCDC submission suggested that BGC make a commitment to a continual maintenance programme for the revegetated sites that included setbacks due to drought, fire, pestilence and weeds. The WBLCDC submission also suggested that BGC make a commitment for the long term fencing of the revegetated areas and that effort be made to fencing off remnants in the immediate catchment to equal at least the same area to be cleared (85 ha) to offset cleared and biodiversity loss.
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Protection of Revegetated Areas - The Wildflower Society and AVES submissions stated that the revegetation areas should be protected by conservation covenants.
The WBLCDC submission stated that a complete revegetation strategy should be prepared and endorsed by the Shires of Northam and Mundaring, relevant State agencies and landowners (if revegetation is to occur on private land) prior to any further vegetation clearing works commencing at the site. This was also suggested by the Shire of Mundaring. The CALM submission advised that the department would provide further comment on the revegetation strategy following further stakeholder consultation and that strategy should be reviewed to the requirements of the EPA, prior to project commencement.
BGC acknowledges the above submissions and believes that its new offsets package addresses them adequately (refer to Volume 2; Appendix J).
The Wildflower Society submission stated that, in addition to rehabilitating land, BGC should either buy and donate 85 ha of good quality native vegetation to the conservation estate or contribute to a fund aimed at raising funds from industry to buy up land to add to the conservation estate. This submission stated that the vegetation should have some or all of the following:
Threatened Ecological Communities; Declared Rare Flora; Priority Flora; significant native vegetation; fauna habitat; and/or biodiversity value.
BGC commits to placing a conservation covenant on Lot 11 (approximately 65 ha) and the uncleared land remaining in Lot 14 (some 112 ha) and manage this land for wildlife protection.
7.9 Greenhouse Gas Emissions
Public Submission 6 referred to a statement on Page 119 of the PER (Volume 2) that said “Preliminary discussions indicate that approximately 170 ha of native vegetation outside the Project Area will be revegetated to provide a significant net carbon sink in the long term”. The submission asked whether the proposed revegetation was to compensate for the loss of native vegetation or to get some carbon credits.
The purpose of revegetating approximately 170 ha of native vegetation outside of the Project Area is to off-set the proposed clearing of 85 ha and maintain biodiversity values within the catchment. It was not the Proponent’s intention to obtain carbon credits by implementing the revegetation strategy.
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Public Submission 6 asked why the haulage of quarry material and the truck movements (>200 truck movements per day) was not considered in terms of greenhouse emissions.
The haulage of quarry material was not included in the calculation of greenhouse gas emissions presented in Section 7.9.3 of the PER (Volume 2) as only emissions from within the site were considered to be relevant. Also, the haulage of the quarry material is undertaken by a combination of trucks owned by BGC, subcontractors and other parties. It should also be noted that not all BGC trucks from BGC Transport, a subsidiary of BGC (Australia) Pty Ltd, take material to BGC sites. Only approximately 16% of the BGC trucks take material from the existing quarry to BGC sites. The greenhouse gas emission attributed to the haulage of quarry material for BGC purposes from the existing quarry is estimated to be approximately 1,557 tpa CO2. Diesel fuel consumption for the proposed quarry is expected to increase by approximately 10%, which would mean that approximately 1,713 tpa CO2 would result from the haulage of the quarry material for the new project.
7.10 Dust
Current Situation
The existing quarry operation is not part of the proposal being assessed under the PER but a number of submissions raised issues relating to current dust impacts and management. These are presented below.
Many of the public submissions indicated that dust from the existing quarry created problems for local residents. The LAG submission stated that there is “continual fallout of dust that descends on our homes each day, polluting both outside and inside”. The submission stated that strong gusty winds carry the airborne dust from the existing quarry to the neighbouring properties and that, apart from health problems, the dust has caused additional cleaning.
The LAG submission stated that vehicular movement, even on sealed roads, is a problem and that sprinklers at the existing quarry are not controlling dust.
Public Submission 2 stated that trucks leaving the quarry do so in ‘swirls of dust’ and that dust from the visible granite stockpile regularly covers the author(s) property both inside and outside the house. Public Submission 3 stated that the author (s) had hardly gone to their property for over a year due to issues including dust. Dust blown from the existing quarry necessitates frequent cleaning of surrounding households and that clothes cannot be safely left out to dry in windy conditions.
Public Submission 2 and 4 stated that the current dust suppression measures are totally inadequate as the prevailing winds remove dust from stockpiles, as does the movement of the machinery on site. Public Submission 5 stated that the strong easterlies blow dust throughout the surrounding properties before and after blasting and also from stockpiles and moving machinery. The submission also stated that the valley (residential area) is quite often in a dust haze. Public Submission 7 stated that dust
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from the existing quarry currently blows down through the valley. Public Submission 14 stated that the size of the current quarry made it impossible to control dust.
The LAG submission stated that the logistics of keeping 85 ha wet enough day and night, seven days a week to prevent dust generation, has not been addressed.
Public Submission 8 also stated that one of the key problems with the existing quarry was dust and that complaints had been made to the Shire, DoE and the local Minister. Public Submission 16 stated that letters had been written to BGC Management and the Northam Shire stating their concern for dust emissions from the quarry at certain times of the year. The submission asked that the sensitive issue of increased dust pollution be investigated so that the proposed project can operate without further impacting the residents and causing BGC further problems. The DoE (Licensing Branch) submission stated that the dust generated during blasting was subjected to community complaint.
BGC acknowledges that dust from blasting has on occasion been blown across its boundary onto neighbouring properties. However, BGC rejects the assertions that this is a regular and frequent occurrence. It occurs in situations when the weekend is approaching and because regulations forbid explosives being left unattended in the ground when the quarry is closed, they must be detonated under less than optimal wind conditions. This has occurred on only three or four occasions out of 30-34 blasts conducted each year. Normally, and in accordance with its blasting management plan, BGC waits until optimum wind conditions are prevailing before conducting the blast.
BGC also acknowledges that there have been occasions when strong easterly winds have been prevalent that dust has lifted off its stockpiles, or been generated by moving machinery. However, as dust in quarries is a major occupational health and safety concern for the workforce, remedial action is taken quickly to protect the workforce. On such occasions, the dust source is immediately damped down and dust rarely crosses the quarry boundary.
Dust is therefore also a major concern to BGC, and BGC is continually looking for ways to control its generation and escape. In recent years, BGC have implemented a number of initiatives to improve dust management. New machinery with larger carrying capacities has been purchased, thus reducing the number of vehicular movements within the quarry. Details of the types of machinery purchased for the existing quarry are presented in Table 5 of this document. The replacement of new machinery at the existing quarry also included a water truck with a larger water tank. In addition, a new pump and sprinkler system was commissioned in December 2003. The new system has the ability to water stockpiles at short, regular intervals and fill the 45,000 L water truck in 4 minutes compared to more than 20 minutes previously. Due to the reduction in the amount of time required to fill the water truck, the spraying capacity of the water truck for dust suppression has been increased by at least five times.
Assessments of the dust management at the existing Voyager Quarry were undertaken on 29 January and 22 September 2004 by the Special Inspector of Mines (Ventilation) and Special Inspector of Mines (Occupational Health) from the DoIR. The main purpose of the unannounced inspection was to review the dust and noise management on the site. The two officers from the DoIR observed in-pit blasthole
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drilling, loading and hauling of blasted material, and crushing and screening. Based on their observations of these activities, they stated in the Mine Log at the Voyager Quarry, “dust control throughout these activities was of a high standard”.
The DoE (Licensing Branch) submission stated that the removal of the vegetation buffer between the existing quarry and local residences in 2001 has increased the issue of dust fallout from current quarrying activities.
BGC acknowledges that it has received more complaints regarding its operations since the clearing conducted in 2001 resulted in the removal of approximately 16.5 ha of the 266 ha of native vegetation in Lots 11 and 14 to the west of the existing quarry. As shown on Figure 1.3 of the PER (Volume 2), the area of clearing is located at the southern end of the existing quarry and is between 125 and 235 m in width. This figure also illustrates the significant amount of remaining native vegetation on the western boundary of the existing quarry operation. BGC consider it unlikely that the clearing would result in dust from its operations affecting nearby residents. However, it is possible that the residents located to the west of the cleared area have experienced dust lift-off from the cleared area during easterly winds. This area has now revegetated naturally and dust lift-off from Lot 14 should now be minimal.
The DoE (Licensing Branch) submission referred to statements made in Section 7.10 of the PER (Volume 2) that ‘The current DoE licence specifies that visible dust should not leave the boundary of the premises’. The submission stated that this statement was incorrect and that the PER was probably referring to conditions A1 to A7 which contain specific measures for dust control and states, as a standard, that no visible dust should cross the premises boundary, with the implication that no dust crosses the boundary with respect to the specific activity.
BGC agrees that the statements made in Section 7.10 of the PER relating to the DoE licence conditions, were referring to conditions A1 to A7 which imply that no dust should cross the boundary with respect to specific activities conducted at the quarry. Perhaps the PER should have stated that dust “generated by licensed activities” will not cross the boundary of the site.
The activities that were specified under Conditions A1 to A7 of the DoE licence for the existing quarry are listed below to provide clarification on this issue:
A1: relates to wetting aggregate materials from the quarry prior to loading the material into trucks;
A2: relates to sealing all trafficked areas except haul roads with road base;
A3: relates to wetting all trafficked areas including haul roads;
A4: relates to water sprays on the feed point to the primary crusher;
A5(a) and A5(b): relate to installing skirts on hoppers and water sprays at all transfer points from the conveyor to sizing screens;
A6: relates to wetting all materials stockpiles as necessary; and
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A7: relates to routine maintenance and housekeeping practices.
The current DoE licence (Licence No. 5356/8) for the existing quarry was issued on 27 September 2004 and it contains similar conditions.
The DoE (Licensing Branch) submission also stated that the Environmental Protection Regulations (1987) relate to crushing and screening and not to blasting as the regulations do not specify quarrying as a licensable activity.
BGC agrees with the DoE clarification that the licence conditions only apply to screening and crushing operations, and confirms that dust from its blasting operations is not regulated.
The LAG submission asked why the PER referred to the NEPM guidelines for ambient air quality when these were not designed for measuring site boundary information. This issue was also raised by the Wildflower Society (Eastern Hills Branch) submission.
The reference to the NEPM Guidelines for ambient air quality in the PER was purely to indicate that these are the only standards available and that they are not applicable to site boundary monitoring activities.
The LAG submission stated that no boundary dust monitoring has been carried out at the existing quarry.
BGC accepts that no dust monitoring instrumentation has been established at its boundary to the existing quarry, but rejects the implication that no monitoring is undertaken. Visual monitoring of dust is by far the easiest and quickest way to obtain feedback that emissions are occurring, and respond to them. As indicated in a previous response, dust control is a key management activity at the quarry.
The LAG submission stated that the present quarry is not meeting the appropriate criteria for dust.
As indicated in a previous response, there are no criteria for environmental dust. The only criteria available apply to Occupational Health standards at the work site.
The Wildflower Society (Eastern Hills Branch) submission also asked how the data from the current particulate dust load from the existing quarry are extracted from any regional dust load monitoring station.
The particulate dust load for the existing quarry cannot be extracted from regional dust load monitoring station.
Proposed Project
The following submissions relate to the effects of the proposed project which is the subject of the PER.
The LAG submission stated that dust would reduce the amenity of the area for living, farming or other activities by reducing visibility, damaging or soiling materials, damaging vegetation or interfering with
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normal agricultural activities. The LAG submission also stated that silica dust, although not toxic in most forms if ingested, would settle on locally grown fruit such as wine grapes and may influence the quality of the final product. The LAG submission also referred to Section 7.10 of the PER (Volume 2), which stated that dust generation would be highest during blasting activities. The submission stated that this is not correct as dust is generated equally or more by general quarrying operations. The LAG submission also stated that dust resulting from clearing activities would be impossible to control and that staging the clearing would not have any effect because once the vegetation is removed, the topsoil will be prone to erosion due to vehicular movement and wind.
Public Submission 7 stated that if the expansion went ahead, the dust levels would increase due to increased machinery movement, clearing and mining. Public Submission 3 stated that BGC cannot control the dust that the wind causes to erupt from the pit due to the ‘Venturi Effect’ lifting the dust out of the quarry. Public Submission 4 stated that dust suppression has not been dealt with adequately and that this was required before the mine moved closer to residences and increases health concerns.
BGC recognises that dust is a major concern to neighbouring residents as well as an occupational health concern for its workforce. BGC believes that the new site will enable it to better control operational dust because stockpiles and crushing equipment will be placed below groundwater level and a buffer of trees will be maintained at ground level to further reduce wind induced dust lift-off. This design initiative together with the continued application of other standard dust management techniques, (e.g. water sprays, sprinkler etc.) will ensure that operational dust can be controlled better than has at times been possible at the existing quarry due to its exposed nature.
BGC also recognise that clearing and overburden removal activities required to develop the quarry, has the potential to generate dust and reduce amenity for neighbouring residents. To control dust emissions during this construction phase of the Project, BGC propose to:
Develop the quarry in five stages (refer Figure 3).
Only clear the minimum area required at any one time for removal of topsoil and overburden.
Undertake these activities only under favourable weather conditions – principally during the wetter months or under westerly or northerly winds.
Ensure that dust control mechanisms (spray and tanker trucks) are implemented where and when required.
Undertake continuous visual monitoring of dust at the boundary during these activities and stop work if unfavourable wind conditions cause dust to lift-off in the direction of residences.
Establish a phone link to the construction manager for nearby residents.
Keep residents informed of when activities are likely to occur.
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Ensure that no large bare expanses of soil and overburden are left exposed over the dry summer period.
Given the above commitments, BGC believe that the quarry can be developed in an acceptable manner and that by only undertaking construction during favourable conditions, dust can be controlled to avoid adverse amenity effects on adjacent residents
When the proposed quarry has been established, the existing quarry would no longer be in operation, and therefore there will not be an overall increase in machinery movement. Also, subsequent to the decommissioning of the existing quarry, the stockpiles will be removed and there will not be a source of dust generation.
BGC will implement the following dust management measures at the proposed quarry:
Watering the haul roads. Watering of benches and pit floors. Watering of stockpiles using automatic sprinklers. Watering of shot-rock in the pit before it is loaded and hauled to the crushing plant. Using wet drilling practices for the quarrying operations. Using water sprays throughout the plant and at all transfer points. Watering and covering loads when transporting material off-site. Implementing speed restrictions within the quarry. Enclosure of the primary crusher within a steel-framed building with 3 mm thick corrugated steel sheeting.Housing of the conveyor within a steel-framed structure with corrugated steel sheeting.
Health Concerns
The DoE (Licensing Branch) submission stated that health concerns had been raised by residents but that occupation health monitoring on the site did not reveal any specific health problem development due to the nature of the product mined. However, the submission indicated that the DoE felt that BGC had not adequately addressed the residents’ concerns.
Public Submission 2, 3, 8 and 14 stated that the residents of the area were concerned about health problems due to dust, particularly in relation to any potential for the dust to cause silicosis. The LAG submission also stated that a number of residents are asthmatic and any increase in natural airborne pollutants will exacerbate their condition.
The LAG submission stated that there was no evidence in the PER of the silica type, content and particle size of the dust produced by the operation. Public Submission 7 also stated that no testing of the actual dust emissions or health effects of the dust had occurred. Public Submission 5 stated that the dust blown onto houses had been analysed and the silica content was 82%. This submission stated that this was a major health concern and may cause problems in 10 or 20 years time.
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As indicated in the DoE submission, BGC undertakes occupational health monitoring of its workforce at the quarry in accordance with DoIR requirements. No specific health problems have arisen in the workforce, nor are any anticipated given the dosimeter results obtained to date. Therefore, BGC did see a need to address this issue in the PER. However, to address the above submissions, BGC tried to engage Dr Peter DiMarco, an independent specialist in Health Risk Assessment (HRA), to determine the health risk posed to the residents from its existing and proposed operations. However, the LAG were not comfortable with Dr DiMarco reporting directly to BGC and asked that he be engaged by, and report directly to the EPA. BGC agreed to this request, the EPA engaged Dr DiMarco and his report will be available through the EPA.
Dust Management
The DoIR submission stated that public safety and associated issues such as dust were adequately addressed in the PER.
BGC acknowledges this submission.
The Wildflower Society (Eastern Hills Branch) submission queried how the dust loads of the new operation can be monitored and dealt with if there is an absence of actual data of site boundary measurements on current particulate loads from the existing operation.
As indicated in a previous response, the existing situation bears very little resemblance to the proposed project which has been designed to minimise potential for dust emissions. Dust will be monitored visually at the new quarry location as before. However, BGC intend to install dust monitoring instruments at their boundary closest to residents to collect evidence of their compliance with their licence conditions. It should be noted that the Voyager Quarry is not the only source of dust in the neighbourhood. In summer, Horton Road, which occurs between the quarry and most residences, is a major source of dust, as are some of the fields when they are being worked.
The LAG submission referred to Section 7.10.4 of the PER (Volume 1) that stated a number of dust management strategies, and stated that there are many problems with these, as follows:
The existing vegetation is inadequate, and reducing the buffer by half is going to worsen the problem;
The windbreak will only affect the wind at ground level and once the wind has picked up the dust, the vegetation will only assist in lifting the dust higher by deflecting it upwards;
Water sprays cannot prevent dust from blasting as the dust is expelled in the atmosphere at supersonic speeds;
Blasting under favourable wind conditions is not effective as the quarry is surrounded by residences;
Visually monitoring dust and dust suppression techniques have not worked at the existing quarry.
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Using sprinkler systems is not currently effective and covered conveyor systems are currently not in use. The current plans are not extensive enough to show this detail; and
The sealing of the access road is ineffective, as Great Southern Highway shows dust up to many centimetres thick.
BGC believes that operational dust can be controlled much more easily at the new quarry site than at the existing quarry.
The LAG submission stated that the Pioneer quarry at Herne Hill had additional dust control measures that had not been proposed by BGC, as follows:
Enclosure of all crushing plants and conveyors;
Mechanical filtration of exhausted air from the plant; and
Stripping of overburden is kept to a minimum and will be progressive as the quarry develops. The retention of existing vegetation will be retained for as long as possible to minimise generation of fugitive dust.
BGC proposed to implement all of the above measures at the new plant.
Public Submission 2 asked when the final Dust Management Plan would be released.
As stated in the PER, the Proponent has made a commitment to finalising the Dust Management Plan after considering the comments received during the public review period and in consultation with the regulators. The final draft of the plan will be submitted to DoE for review and finalised following the receipt of their comments. The final Dust Management Plan will not be re-circulated in the public arena, however they will be available from BGC, should a request be made to BGC Quarries.
7.11 Noise
Current Situation
The existing quarry operation is not part of the proposal being assessed under the PER but a number of submissions raised issues relating to current noise impacts and management. These are presented below.
Many of the public submissions indicated that noise from the existing quarry created problems for local residents (see Section 4.9 of this document). In addition, Public Submission 5 stated that the existing quarry noise had become noticeably louder since the clearing of approximately 16 ha in December 2001. The LAG submission also stated that noise and dust had became increasingly intolerable since the vegetation clearing in December 2001.
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The DoE (Licensing Branch) submission stated that the department understood that residents feel that they are unreasonably impacted by noise only in the early morning and evenings when background noise levels are much lower than during daylight hours. The submission also stated that residents claim that noise from the current quarry has been more significant since clearing was undertaken in 2001. They also stated that they were unable to verify whether this is the case, but that it appeared to be logical that this could be the case.
The clearing of vegetation in 2001 should have had negligible effect on the maximum noise level propagation to neighbours to the west of the quarry. This is due to the fact that maximum noise propagation at any site occurs under downwind conditions which effectively bypasses any barrier effect of a treed area. Under calm conditions, noise levels at the nearest western neighbours are around 24 dB(A) with no tree effects and possibly 21 dB(A) with tree effect. It is therefore possible that under calm conditions, only residences located to the west of the existing quarry may be hearing the noise of current operations more clearly since the vegetation was cleared in 2001. Both monitoring by BGC and noise modelling conducted by HSA confirms that maximum noise levels at the nearest residence to the west do not exceed 30 dB(A).
The DoE (Environmental Regulations Division) submission stated that the modelling of the current operations shows the possibility of non-compliance. The submission requested information on what measures would be undertaken for the current operation to achieve compliance. It acknowledged that the existing primary crusher is currently being enclosed and that this will result in a reduction in the overall levels received by the residents, at least for the day-time scenario.
Modelling of the existing quarry operations for the PER indicates potential exceedances of the Environmental Protection (Noise) Regulations 1997 assigned levels at residential locations north, east and south of the quarry, under certain atmospheric conditions and at certain times.
During the day and evening, it was the primary crusher that was the dominant source of this noise. The crusher has since been fully enclosed to reduce emission levels by 7 dB(A) from this source. The significant contributors to potential night time exceedances are mobile equipment and the tertiary crusher. It is impracticable to significantly reduce noise from these sources, any further.
Hence, whilst daytime noise levels have been significantly reduced to meet regulatory requirements, it is still likely that night time operations may exceed regulatory requirements at times. The only practicable way that this can be resolved is to move the quarry to the new location.
Noise Monitoring and Modelling Conducted for the PER
Public Submission 11 asked who is conducting the noise monitoring, when is it being conducted and how is it being conducted.
Public Submission 1 stated that BGC had installed data loggers for recording noise, but had not installed a weather station to determine common wind direction and speed.
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As stated in Section 3.7.2 of the PER (Volume 2), BGC commissioned two data loggers in September 2002. These record noise onto digital tapes on a continual basis and also record wind speed and direction. The data are archived for reference.
Public Submission 5, Public Submission 7 and the LAG submission questioned the location of BGC’s noise data loggers and weather station, as they are positioned in bushland. The LAG submission suggested that the monitoring station located to the north should be moved 50 m to the east, which would place it on clear ground and it would have line of sight to the quarry (source of noise). The move would also bring it in direct line with the residence of Dibble/Milech.
A noise monitoring programme is being developed by the DoE and the locations of the monitoring stations are specified in this programme. Currently, the DoE is waiting to receive written feedback from LAG.
Public Submissions 5, 7 and 16 stated that rain was received on 1 November 2002 and asked how the noise assessment conducted on 1-2 November could be accurate. The LAG submission stated that the humidity reading for the period that noise monitoring was undertaken was not mentioned. The submission referred to the Pioneer Public Environmental Review where Herring Storer stated that humidity has a significant effect on sound propagation.
The LAG submission stated that the wind direction for 1 November 2002 that was quoted by Herring Storer Acoustics was incorrect. The submission stated that this information was probably taken from the BGC monitoring station, which recorded calm wind and direction prevailed from the SW. The LAG data stated wind WSW and a wind speed of approximately 10 kph. The LAG submission stated that the area has its own “micro-climates” and temperature inversions are common. The submission stated that these phenomena increase sound propagation and there are elevated sound levels at more distant residences.
The noise assessment of 1 November was made by HSA. The wind speed and directions were from personal observations. There was no rain recorded on this occasion. The temperature ranged from 10 to 9°C during the night period measurements, with wind varying from gusting southerly to very light south west over the night. Humidity was not measured, however it would have been relatively high, if rain was in the area. The higher the humidity, the better the propagation of noise, therefore on the night of 1 November, downwind noise propagation would have been close to the worst case scenario.
The LAG submission referred to Page 12 of the Noise and Vibration Assessment report (Appendix H) and stated that the first paragraph should state that the existing quarry operations exceed the EPA noise regulations at four residences.
The referred paragraph states that exceedances may occur at 4 residences. It is assumed the LAG submission is intimating this should read exceedances “do” occur instead of “may”. There are no measured levels that show the regulatory assigned levels are exceeded at the residences. The levels are predicted based on nearfield recordings and computer modelling. The maximum levels predicted are dependant on downwind propagation and the occurrence of a positive temperature gradient.
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The LAG asked whether the reduced tree buffer and prevailing wind conditions were taken into account for the noise impact assessment.
The noise impact assessment (modelling of propagation) assumed no tree cover, hence the results can be considered on the ‘high side’ (ie. conservative).
The DoE (Environmental Regulations Division) submission stated that there was no mention of the meteorological parameters used for the modelling of the worst-case (down-wind/temperature inversion) conditions used in the noise modelling. The submission also asked for further information on whether the worst-case meteorological parameters used in the modelling followed the default value defined in the EPA’s “Draft Guidance for the Assessment of Environmental Factors No. 8, Environmental Noise”.
The atmospheric conditions presented in Table 11 were used in the predictive modelling in accordance with the “Draft Guidance for the Assessment of Environmental Factors No. 8, Environmental Noise”.
Table 11 Atmospheric Conditions Used in the Predictive Modelling
Day & Evening Scenario Night Scenario Wind Speed 4m/s 3m/s Wind Direction Downwind Downwind Temperature 20°C 15°C Humidity 50% 50% Pasquil Stability Factor B E
Public Submission 5 asked how a project with a proposed life of 50 years could be based on two days of field work. Public Submission 16 stated that it was important to have acoustic data collected over a 12 month period. Public Submission 1 stated that noise level trends should be presented from 1991 from periods of 24 hour operation and when conditions enable noise to be carried in a westerly direction.
The DoE (Environmental Regulations Division) submission questioned the accuracy of the ambient noise levels presented in Table 4.9 of the PER (Volume 2). The submission stated that the night-time levels were unusually high for a rural area of this type but that the LA90 values for daytime seemed realistic if a breeze was present.
Noise immissions of the existing operations were measured and modelled in order to predict the resultant levels from the proposed operations. The existing operations were also modelled in order to obtain verification measurements and better define the level of accuracy of the model. More or longer term monitoring will have little if any bearing on this process. The data presented in Table 4.9 of the PER are likely to be accurate. However this data is no longer traceable with respect to the prevailing conditions of the time of measurements and more recent data such as the monitoring results in Appendix H of the PER
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(Sub-Appendix F) should be referred. This data indicates ambient noise can drop to as low as 20 dB(A) during the early hours of the morning.
The DoE (Environmental Regulations Division) stated that additional data are needed to support the assumption that masking by noise generated by wind in the trees occurs and consequently that tonality is not present. The submission also stated that this requires source ranked immission spectral data to isolate the individual sources and their potential to exceed, and spectral data for noise generated by wind in the trees.
The LAG submission referred to Appendix H (Volume 3), which stated that adjustments for tonality, modulation and impulsiveness were not made. The submission stated that the type of machinery in use by the quarry warrants at least two levels of adjustment to be applied, up to the maximum adjustment of 10 dB. The submission stated that the rock drills, crushers and rock breakers are tonal and modulated, and the loading of large rock fragments into the dump trucks and crushers is impulsive.
The judgement of wind noise and tonality comes from field observations, which are more accurate than predictive modelling. The field data was used to help assess the results of predictive modelling. The existing quarry noise immissions are considered tonal under calm or light wind conditions and adjustments have been made accordingly. There is no indication of modulation or impulsiveness based on the observations made.
The DoE (Environmental Regulations Division) submission stated that it did not seem that the rockbreaker had been included in the modelling of the existing or new operations, and asked for additional information on the use of this piece of machinery. This submission also stated that road trucks are not included in the sound power list and are assumed to not be included in the modelling, even though despatch of materials is listed as part of the night-time operations. The submission stated that the exclusion of the road trucks must be justified or included in the modelling.
Neither the rockbreaker, nor the road truck operations within the mine site were included in the previous model. The rockbreaker was not considered a significant source of noise due to its limited time on site (only 3 periods of 1 week each per year). However, both trucking operations and the rockbreaker are now included in the revised modelling and the results are presented in the HSA supplementary report (Appendix K).
The supplementary report presents a new model which incorporates the above additional noise sources and the full enclosure of the primary crusher. Results of the revised modelling for existing operations at the Voyager Quarry showed that noise levels remain the same or similar to those modelled in the PER. This is because the additional noise sources from the intermittent rockbreaker and the continuous truck operations are balanced out by the much reduced noise levels now emanating from the enclosed primary crusher.
The DoE (Environmental Regulations Division) submission stated that, for the transition operations, it was not clear at what depth below ground level the new operations were modelled. The submission stated that it was unclear what sources were used and their distribution in the new quarry area. The
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submission also stated that, as the topsoil layer extends to a depth of 1 m (nominally where construction activities cease), modelling of the operations at this ground level should be provided, as well as for further transitional depths.
Secondary crushing and screening were modelled at –30 m, crusher tip head at –25 m and haul path at varying heights between the tip head and quarry. The scenarios of topsoil and overburden removal have been remodelled on the basis that it is only the topsoil removal that may be included in construction noise activities as defined in the Regulations. Note that it is no longer proposed to construct noise attenuation bunds (refer to HSA supplementary report (Volume 2; Appendix K)). Also note that the depth of topsoil and non-saleable overburden (subsoil) at the proposed quarry site varies between 1-5 m in depth. Therefore construction noise has been modelled at the average depth of 3 m.
The DoE (Environmental Regulations Division) submission stated the proposed operation should be re-modelled to represent worst-case conditions. The submission suggested that noise mitigation measures be identified and included in the re-modelled proposal and suitable commitments made to ensure these are implemented.
The proposed quarry operation has been re-modelled to represent worst-case conditions. Refer to HSA supplementary report (Volume 2; Appendix K). To ensure worst case conditions were modelled for the proposed new operations, the revised model did not include the noise measurements for the existing primary crusher after it was fully enclosed.
As stated in Section 3.2.3 of the PER (Volume 2), the proposed primary crusher will be constructed within the quarry pit. However, it will also be housed within a structure to minimise noise. The enclosure will be similar to the enclosure for the existing primary crusher, comprising a steel-framed building with corrugated steel sheeting. Modelling results presented in Appendix K show that once operations reach the –20 m depth below ground level, exceedance of noise regulations at the boundary are most unlikely even under worst case conditions. However, above –20 m depth, the potential for exceedance increases and operations will require management in this zone when worst case conditions occur to ensure compliance with noise regulations.
The LAG submission stated that, in Appendix B of the Noise Impact Assessment (Volume 3 - Appendix H), Figure 01 is the first of many computer models that is showing incorrect sound propagation analysis. The submission stated that, at the westerly tip of the blue <65, halfway through the 60-65 dB contour, the LAG monitor picked up readings of 90 dB. It also stated that the indication that the cut off for noise propagation being the ridge alongside Horton Road to the west is inaccurate, as readings taken at the Pederick residence has exceeded 55 dB.
The suggestion is that the predicted noise levels are incorrect based on measurements made by LAG. It is not known what units of measure, meter settings or any other parameters LAG have used to obtain a level of “90 dB” at a point that appears to be around 500m from a point central in the minesite. Perhaps it was a blast noise and linear peak levels that were recorded. To achieve a level of 90 dB(A) one would have to be within 20 metres of a machine.
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The ridge is not a cut-off point for noise propagation but the ridge provides a barrier effect which reduces noise from the minesite more than if the ridge were not there which is evident by the compressed noise level contours. To achieve a level of 55 dB(A) at a distance greater than 2 km due to minesite noise is only possible if the measurements were linear peak levels of blast noise. The reported level of 55 dB at the Pederick residence is not in units that are normal environmental units i.e. an LA10 value would be 55 dB however the reported overall level would normally be written as 55 dB(A). The absence of the ‘A’ weighting designation normally indicates a linear recording which is significantly higher than an A weighted value and could easily be 55 dB. If the value was an LA10 value of 55 dB(A) it is suggested the noise was not the result of quarry noise but other sources such as wildlife or road traffic
Impacts
Public Submission 4 referred to the Executive Summary (Volume 1) which stated, “No construction of the new quarry will occur at night”, and asked for a definition of the “day time” operations.
Daytime operations are 0700 to 1900 hours Monday to Saturday, as defined by the Environmental Protection (Noise) Regulations 1997.
Public Submissions 4 and 5 and the LAG submission stated that moving the quarry 750 m to the west would increase noise impacts and that locating infrastructure 30 m below ground would do little to alleviate the noise. Public Submission 7 stated that if the new expansion was approved, the mining of weathered granite would increase noise and the valley acts as an amphitheatre. The CCI stated that noise from the current quarry comes from ground level, however at the proposed quarry, it would be coming from 30 m below ground, which would reduce the noise levels. The DoIR submission stated that public safety issues relating to blast noise appear to have been adequately addressed in the PER.
BGC concurs with the CCI assessment. Operating the fixed plant and equipment at a –30 m RL is acoustically similar to building a 30 m high barrier around the operations. The noise emissions will be less than for the existing operations and accordingly any impacts will also be lower. If the barriers were only on one to threes sides an “amphitheatre effect” would occur in the direction of the open side however this will not be the case at the proposed new quarry where operations will not only be at least 30 m below ground, but also below a 5 m tree buffer on all sides.
The DoE (Environmental Regulations Division) submission stated that there was not enough information to show that the transition operation can be managed to comply with the Environmental Protection (Noise) Regulations 1997. The submission stated that a commitment be made that measures will be carried out and subsequent verification will be undertaken to show that compliance with the Noise Regulations can be achieved under worst-case conditions before the proposed quarry commences.
The transition operations include new and existing operations. Any new operations will be managed to comply with the regulatory immission criteria. However, it needs to be recognised that the existing operations may not comply under certain worst case wind conditions. Therefore BGC may on occasion
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also need to manage their existing operations to ensure total compliance with the regulatory immission criteria during the transition phase of the development. This requirement will be most infrequent.
The DoE (Environmental Regulations Division) submission stated that the noise impacts of the construction and operation activities should be considered separately. The submission stated that the removal of overburden in the form of topsoil could possibly be regarded as construction if the removed material is used in the construction of a bund. It stated that the extraction and sale of the subsequent layers of gravel and clay could not be considered as construction noise and must be considered as the on-going operation of the quarry, and that the noise emanating from this must comply with the Noise Regulations.
The LAG submission referred to Appendix H (Volume 3), which stated the transition operations would result in slightly elevated noise levels and that it is classified as “construction noise”. The submission stated that the clause in the Regulations was not designed to cover such a long-term land clearing project.
Potential noise impacts from construction and operation of the new quarry have now been considered separately in the revised modelling presented by HSA in Volume 2; Appendix K. As indicated at the beginning of this report, BGC have reconsidered their construction plan for the new quarry, and now no longer propose to construct noise attenuation bunds or clear the quarry in one operation. Instead the quarry will be developed in 6 stages or zones in a series of smaller and more manageable operations over the next 50 years. Topsoil removal activities will only occur during the wet months of the year in order to minimise potential for fugitive dust. Construction noise is exempt from noise regulations, but this activity will now only occur over a 4-5 month period once every 2-5 years.
Subsequent overburden removal within the zone under development will be managed by placing real-time noise monitors at the boundary closest to sensitive premises and in the event that noise levels approach exceedance levels, either reducing the number of earthmoving machines in operation (from 3 scrapers to one), or ceasing operations altogether.
HSA (Volume 2; Appendix K) have modelled noise levels under worst case downwind conditions from five locations inside each zone to identify which wind directions have the greatest potential to exceed regulations at the nearest residence to the zone under development. When coupled with weather forecasts, this information will be used to plan day-to-day overburden removal operations ahead of time in an effort to manage noise levels at the premises most at risk.
The AVES submission referred to Page ES-23 of the Executive Summary (Volume 1), which stated, “Noise will primarily be managed by locating the plant site within the proposed quarry pit (approximately 30 m below ground surface) and housing the primary crusher (if required)”. The submission asked why the primary crusher will be housed “if required”.
The primary crusher is the major noise source at the quarry. Predictive modelling indicates that the relocated crusher will be below the regulatory assigned level at noise sensitive premises. The reference to housing the crusher housed if required is a statement meant to address the fact that should the predictive
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modelling be wrong then there are still alternatives to reduce emission level by enclosing the crusher. However, BGC proposes to house the new primary within a steel-framed building with corrugated steel sheeting. This structure is similar to the enclosure for the existing primary crusher.
The DoE (Environmental Regulations Division) submission stated that the primary crusher is likely to generate noise that contains modulation characteristics as it is a jaw crusher. The submission stated that there has not been assessment to show that the noise from the crusher has lost this characteristic when received at the residences. It also stated that if the modulation characteristics are still present in the noise when received at the residences, it would attract a +5 dB adjustment as specified in the Noise Regulations.
All observations by noise specialists, HSA, indicate that the primary crusher noise does not have modulating characteristics. The existing primary crusher, which has undergone noise control treatment (enclosure) is inaudible at neighbouring residences with respect to day and evening background noise. Further, the new primary crusher will have noise immission levels that are at least 5 dB(A) below the assigned levels.
Public Submission 8 stated that the PER did not address the effect of quarry noise on livestock production, nuisance for humans or noise as a health hazard that causes sleep deprivation. The LAG submission asked for further information on the effect of mining noise on livestock.
Noise from the relocated mining operations will be less than the existing operations. Noise immission levels will comply with the Environmental Protection (Noise) Regulations 1997. The quarry noise immission levels from the relocated quarry, in general, will be less than existing background noise due to the existing quarry, road traffic, wildlife, aircraft and local residentially generated noise.
Public Submission 1 asked whether BGC would be providing any assurances that the current restriction on machinery use and creation of noise would apply to the proposed quarry.
BGC proposes to house the new primary within a steel-framed building with corrugated steel sheeting and will also operate machinery to comply with the Environmental Protection (Noise) Regulations 1997.
The current operating hours are implemented to ensure that existing equipment is restricted during the night time period. The proposed operations will ensure noise level compliance at all hours hence there should be no need for restrictions, however BGC will make an additional commitment that they will comply with the hours of operation currently employed at the existing quarry and stated in Section 3.5 of this document.
Noise Management Plan
Public Submission 2 asked when the Noise Management Plan would be released.
As stated in the PER, the Proponent has made a commitment to finalising the Noise Management Plan after considering the comments received during the public review period and in consultation with the regulators. The final draft of the plan will be submitted to the DoE for review and finalised following the
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receipt of comments from the DoE. The final Noise Management Plan will not be re-circulated in the public arena, however it will be available from BGC, should a request be made to BGC Quarries
However, the Noise Management Plan will focus on noise control during the overburden removal stage of works (3-20 m below ground level on average). Whilst overburden may occur to –30 m depth, modelling shows that once operations reach –20 m depth, the potential for exceedance of noise regulations is low.
As indicated in a previous response, the key components of the Noise Management Plan are:
a. Develop the quarry in six sequential stages or zones over the life of the proposal. Topsoil removal in each zone to be completed within one “wet season”; overburden removal to be conducted only under favourable conditions for minimising fugitive dust and potential for exceedance of noise levels;
b. Predict and monitor wind and weather conditions for occurrence of potential unfavourable conditions for the zone under development, and only operate under favourable weather conditions;
c. Continuously monitor noise and dust levels at the boundary closest to sensitive receptors and when either reaches levels considered close to being unacceptable, either reduce the amount of earthmoving equipment in operation, or if necessary cease operations altogether; and
d. Establish direct communication link between residents and the construction contractor for notification of planned operations.
7.12 Ground Vibration and Airblast
Public Submissions 7 and 15 stated that the actual blasting practices conducted by the existing operations were not consistent with the information presented in the PER (which states that blasting is conducted approximately once every fortnight). Public Submission 7 stated that blasting occurred on 31 January and 6 February 2003, i.e. six days apart.
The statement in the PER was based on the usual blasting practice undertaken at the quarry at the time that the PER was released. Currently, blasting occurs weekly at the existing quarry.
The LAG submission stated that the noise monitoring performed by ABT was not conducted using the correct methodology as the ground vibration transducer was attached to a small rock, which was barely buried within the ground.
It is normal practice to drive a metal stake into the ground to allow attachment of a magnetic transducer. If the LAG submission is correct in stating that the ground vibration transducer was attached to a small rock, then it is likely that the ground borne vibration would be overstated due to excessive movement of the small rock.
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Public Submission 4 referred to paragraph 4 on page 7 of the Executive Summary (Volume 1) and asked if the Australian Standard 2187.2-1993 recommendation that vibration be <10 mm/s for houses are for surface or below ground levels.
The Australian Standard 2187.2-1993 recommendation that vibration be <10 mm/s for houses refers to surface levels. This is so that it reflects the amplitude of vibration that would be sensed or felt within a dwelling.
Public Submission 4 quoted the Herring Storer Acoustics finding that ground vibration levels of around 3.4 mm/s can be expected at the nearest residence following blasting at the proposed quarry based on Maximum Instantaneous Charges (MICs) of around 130 kg, and asked what guarantee is there that BGC will use those MICs. This was also raised by the AVES submission.
Blasts will be monitored at two locations by Orica to ensure that blasts do not exceed 10 mm/s (Australian Standard 2187.2-1993). A blasting impact assessment undertaken by SRK Consulting in October 2004 (Volume 2; Appendix L) resulted in the development of a Vibration and Overpressure Monitoring Plan. One of the objectives of the plan is to reduce the potential for non-compliance with respect to blast impact and licence requirements and the plan contains procedures for achieving this objective.
The LAG submission stated that the vibration and airblast data in Volume 3 (Appendix H) only provides data from 1993 to 1995 and that data from 1990 to 1993 are missing, but that the data had to be collected as a condition of the site’s DoE licence.
BGC does not have vibration or airblast monitoring records prior to 1993. It should be noted that the existing Voyager Quarry did not become fully operational until 1991.
The LAG submission referred to Appendix H (Volume 3), which stated that the airblast level would be at the upper end of the 9 out of 10 weekday criteria. The submission stated that it is not fair and reasonable to be so close to what is a maximum limit.
The predicted airblast levels presented in the PER were based on actual airblast levels recorded at the existing quarry prior to Orica becoming involved in the blasting management at the quarry.
Advice provided by Orica indicated that airblast is one of the easiest things to manage in a blast by designing the blast properly. It has implemented the following blasting procedures for managing airblast and ground vibration:
Use laser profiling to accurately record the rock face;
Input the data into a model to optimise the burden and determine the optimum drilling pattern. The model will provide a drilling design that minimises the risk of excessive airblast, ground vibration and flyrock;
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Use a bore tracking device to ensure that the actual drill hole follows the design blasthole. The drillers that are used by Orica are required to drill within 2 of the design blasthole, otherwise the driller is required to re-drill the hole; and
Use Orica’s i-kon Digital Energy Control system for the programming and firing of detonators. This system can be used to reduce the blast-induced vibrations and airblast. Blast frequencies can also be adjusted so that the range is not damage-causing (> 25 Hz).
Therefore, through implementing the above blasting management procedures, airblast levels at the proposed quarry are expected to be less than those predicted in the PER.
Furthermore, a blasting impact assessment undertaken by an expert geotechnical engineer from SRK Consulting (Volume 2; Appendix L), confirmed that the levels of “anticipated air overpressure at the Voyager Quarry are judged to be incapable of causing damage to adjacent residents”.
Public Submission 4 referred to the Executive Summary (Volume 1), which indicated that the study by Herring Storer Acoustics has shown that blasting can be managed to comply with comfort criteria. The submission asked what the comfort criteria were and if the comment indicated that there will be exceedences. This submission stated that airblasts can shake houses without structural damage but can dislodge contents by vibration.
The reference to comfort criteria relates to airblast, where the Australian Standard 2187.2-1993 indicates that a limit of 120 dB is commonly used. The statement in the Executive Summary (Volume 1) does not mean that there will be exceedances because the limit of 120 dB is consistent with the Environmental Protection (Noise) Regulations. The regulations state that airblast levels from daytime blasting must not exceed 125 dB for any single blast or 120 dB for nine in any 10 consecutive blasts. Therefore, if the airblast levels are within the comfort criteria, then the blast will also be within the regulatory limits.
The DoE (Environmental Regulations Branch) submission stated that there was variability in the vibration levels during the early stages of the existing operation and that, given the variability of these blasts, there is a high possibility of exceedance of the DoE limits at the proposed quarry.
As Orica will be in charge of blasting management at the proposed quarry and BGC will implement the Vibration and Monitoring Plan developed by SRK Consulting (Volume 2; Appendix L), there will be reduced variability in the vibration levels during the early stages of the proposed operations. Orica has advised that the blasting undertaken during the development phase of the operations will involve the use of smaller charges than for the production phase. The possibility of exceedance of the DoE limits for ground vibration would be very low, even during the development phase if Orica manage the blasting.
The LAG submission referred to a structural survey conducted by McDowall Affleck Pty Ltd that was commissioned by BGC and conducted at 16 residences. The submission stated that the damage reported is of a type and degree not likely to be found in comparable residences that are not influenced by the stresses generated by the drilling and blasting of a quarry.
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The structural survey conducted by McDowall Affleck Pty Ltd recorded the cracking observed for houses and outside structures. The survey was conducted to provide baseline results which claims of damage due to ground vibration at the proposed quarry can be evaluated.
The report provided by McDowall Affleck did not involve any interpretation of the results. Further investigations involving soil testing and inspections of the footings and foundations for the houses would be required to determine whether the cracks recorded in the survey are attributed to the drilling and blasting at the existing quarry. Therefore, without further information provided by qualified structural engineers, BGC cannot respond to the statement, “the damage reported is of a type and degree not likely to be found in comparable residences that are not influenced by the stresses generated by the drilling and blasting of a quarry”.
Another structural survey of the residences is planned for January 2005.
The LAG submission stated that the structural survey conducted by McDowall Affleck Pty Ltd was incomplete and until the omissions have been rectified, there are a lack of baseline data.
The omissions that LAG referred to in their submission relate to the fact that the water tank on the Brady property was not inspected and Priestley did not receive a copy of the report. The survey was undertaken by Mr C. Durrant of McDowall Affleck. In undertaking this survey, Mr Durrant was accompanied by the property owner or a neighbour during the inspection of the houses and outside structures. As this was the method that was employed at all properties, it is likely that the water tank on the Brady property was not inspected because it was not highlighted to Mr Durant. Extensive baseline data has been collected for all other properties.
In terms of the delivery of the reports to the property owners, BGC were responsible for distributing the structural reports to the property owners. A report for the Priestley property was provided to them in February 2003 and another copy was provided to Mr Priestley on 12 November 2004.
Public Submission 5 stated that six residences have had structural engineering surveys completed, that their homes are damaged and that evidence of this is present within the Structural Engineers’ report requested by the Shire of Northam. This submission stated that it would appear that this acknowledges the potential for significant impacts to occur.
In January 2003, BGC commissioned a structural survey of 16 residences adjacent to the Voyager Quarry. The report presents the findings on the structural integrity of the houses and outside structures. The observations were based on visual inspections and did not involve an investigation of possible soil effects.
The report recorded cracking on exterior and interior features on the properties, however the report does not state the cause of the cracking nor does it acknowledge that there is potential for significant impacts to occur.
The AVES submission stated that there is no available information on the cumulative effects of continuous blasting on the environment or surrounding buildings and residences. The submission
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requested that data be acquired to demonstrate that cumulative blasting would not cause future environmental problems.
Advice received from Orica about the impacts of ground vibration indicates that a well-constructed house with the correct foundation and footings would not suffer from the cumulative impacts of blasting. According to the Australian Standard 2187.2-1993, the ground vibration limit for houses and low-rise residential buildings is 10 mm/s. If the ground vibration is below this level, then damage to houses is likely to be negligible.
BGC has engaged an independent expert in blasting to assess the potential for cumulative blasting to damage residential structures. This report is presented in Volume 2; Appendix L of the document.
Public Submission 11 stated that blasting can affect fauna within several hundred metres of the blasting site and that the blasting damages structures and water bodies, particularly within the seismic zone that the current quarry is located in. The LAG submission also asked for further information on the effect of blasting on livestock.
To our knowledge, the effects of blasting on fauna and livestock have not been researched. However, personal observations indicate that both fauna and livestock can be startled by a sudden loud noise. It is likely that fauna will respond in much the same way as humans do.
The AVES and LAG submissions stated that the wall between the existing pit and proposed pit may fracture as a result of continual blasting and asked why there is no evidence in the PER that this is known or catered for. The LAG submission also raised concern about geotechnical stability and stated that geotechnical consultants should be employed to determine how ground vibrations are transferred through fracture zones transecting Horton Hill and how they affect homes in the area.
The wall between the proposed and existing pits will be at least 30 m wide and under the blasting conditions employed by Orica, the wall will be stable.
Based on the results of the blast impact assessment undertaken in October 2004 by SRK Consulting (Volume 2; Appendix L), it is anticipated that geological structures will not result in amplification of vibration. The interpreted existence and location of the Horton Hill Structure Zone shown on Figure 3.7 of the LAG submission running WNW cannot be confirmed without undertaking a detailed geological drilling programme. However, independent expert advice received by SRK Consulting stated that ground vibration that is transmitted across dominant geological structures will be attenuated more than those that are parallel. Also, the transmission of ground vibration is dependent on the nature of the material, because if the material is less competent (i.e. weathered or fractured), then ground vibration attenuation is greater. Therefore, if the Horton Hill Structure Zone interpreted by the LAG is present and consists of weathered material, then vibration would be attenuated to the WNW of the quarry. If the zone is present and it consists of competent material, then vibration attenuation will be less.
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The LAG submission stated that the existing quarry faces are extensively fractured, “so much so that fracturing had at the time of mapping very strongly controlled nearly every development blast face”. It also stated that these fracture extend well beyond the quarry towards local residences.
If the LAG are correct in their statement that there is fracturing beyond the quarry towards the residences, then ground vibration will be attenuated and will not be amplified towards residences. The blast impact assessment report (Volume 2; Appendix L) states that “less competent (i.e. more weathered and fractured) materials can be expected to cause blast induced vibration to decay more rapidly with distance from the blast”.
Management and Monitoring
The AVES submission stated that even though the study has shown that blasting can be managed to comply within comfort criteria, there is no evidence that this will be the key objective.
The key objective for the blasting management plan is to ensure that the airblast and ground vibration levels are below the regulatory levels.
Public Submission 5 stated that the monitoring stations are not located in areas where monitoring would be more appropriate, such as residences close to the proposed quarry rather than 1.5 km west of the existing quarry. Public Submission 5 stated that the monitoring of vibration is not adequate and should be conducted on each person’s property for every blast as the houses are either shaken or covered in a cloud of dust.
A monitoring station has been positioned approximately 500-600 m to the west of the existing quarry to replicate the distance to the nearest residence for the proposed quarry scenario. This monitoring began in 2002 and data has been collected for almost two years. The results that have been collected indicate that the levels are well below the ground vibration regulatory limits, ranging from 0.7 to 4.0 mm/s (see Table 7-1 of Volume 2; Appendix L).
As the results from the monitoring indicate that there is no exceedance of the limits at the site boundary, there is no justification for monitors to be placed on every resident’s property. However, in agreement with some of the residents, BGC has monitored ground vibration on these properties.
The DoE (Environmental Regulations Branch) submission stated that blasts are controllable as lower charge masses may be used and asked that the Draft Airblast and Ground Vibration Management Plan include information on how the impacts of blasting will be managed to ensure that vibration from blasting does not exceed DoE limits. The submission also asked that the management plan address how the airblast impacts are to be managed.
A report was developed by a geotechnical engineer who is an expert in the assessment of blasting impacts and blast induced vibration (Volume 2; Appendix L). This report also contains an Air Overpressure and Ground Vibration Monitoring Plan in Appendix A of the report. This plan contains the procedures for
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blasting practices at the proposed quarry and is designed to manage airblast and ground vibration so that the regulatory limits are not exceeded.
Public Submission 2 asked when the final Airblast and Ground Vibration Management Plan would be released
A Vibration and Monitoring Plan has been developed by an expert geotechnical engineer from SRK Consulting. This plan is presented in Volume 2; Appendix L.
7.13 Flyrock
Public Submission 2 stated that flyrock has been a big and dangerous problem in the past, with large pieces landing considerably more than 100 m from the pit, and queried the risk to homes, people and domestic animals.
There will not be a problem with flyrock at the proposed quarry because Orica would develop a blasting management plan for the Project that will ensure the following:
correct Maximum Instantaneous Charges (MICs) are used; the burden spacing is adequate; and the drilling pattern is more open and the holes are straight.
Implementing the management measures in the blasting management plan will ensure that flyrock will not occur. The Proponent has made a commitment in Section 7.13.4 of the PER (Volume 2) that it would monitor every blast over a 12-month period to ensure that flyrock is contained within the site boundaries. The risk to homes, people and domestic animals will be very low because BGC would implement good blasting management measures and is committed to ensuring that flyrock does not leave the site boundaries.
Public Submissions 2, 4 and 5 referred to paragraph 1 on page 8 of the Executive Summary (Volume 1) and queried the ability of the cameras to capture the flight and full extent of flyrock distances.
The cameras capture each blast and flyrock does not occur. It is evident from the videotapes that the rock that is blasted remains in the pit. The way that blasts are managed at the existing Voyager Quarry, flyrock does not occur. The camera would certainly be able to capture rocks being thrown some distance from the quarry.
Public Submissions 4, 5 and 14, as well as the LAG submission, stated that the new operation would be unable to contain flyrock when blasting on the surface rock occurs as the surface quartz is weathered and “shale-like” and therefore highly unpredictable in its trajectory during blasting.
A blasting management plan has been developed by a geotechnical engineer who specialises in the assessment of the impacts of blasting. This plan is presented as Volume 2; Appendix L. The
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implementation of the management plan would ensure that flyrock is contained within the confines of the site boundary.
Public Submission 4 referred to paragraph 9 on page 7 of the Executive Summary (Volume 1) and asked what the new techniques were that prevented flyrock occurring.
The improved blasting practices that have been implemented at the existing quarry to prevent flyrock from occurring are presented in Section 7.13.3 of the PER (Volume 2). These included:
ensuring that the burden spacing, which is the distance between the rows of blastholes parallel to the major free face, was adequate; decreasing the amount of explosives used for blasting the same amount of rock; improving drilling practices by opening up the pattern and drilling straighter holes; ensuring that an effective stemming column of suitable height was placed into the blasthole after the main explosives charge; and improvements in the manufacturer’s products.
The DOIR submission stated that public safety and associated issues such as flyrock appear to have been adequately addressed in the PER.
The Proponent agrees and acknowledges this statement.
7.14 Site Access and Transport
The LAG submission stated that there are 140-200 trucks a day used at the existing quarry. The Earth submission stated that approximately 300 trucks currently leave the existing site each day causing numerous social problems for local and wider-spread residents. This submission also stated that the current movement of traffic causes increased risk of accidents. Public Submission 11 stated that the heavy road trains on Great Eastern Highway degrade the surface.
Table 12 shows the number of truck movements for the different size classes over the last four years. Based on this data, there are approximately 239 truck movements per day at the existing quarry. This includes truck movements to and from the quarry, which demonstrates that the claim made in the Earth submission that there are 300 trucks leaving the quarry each day is incorrect. Therefore, there are only 120 trucks “leaving the quarry” each day.
The current traffic movement on Great Southern Highway and Great Eastern Highway is not directly attributable to BGC’s operations. BGC has undertaken surveys by stationing a person at the quarry front gate and recording the vehicle type and number of vehicles on two occasions in consecutive years. It was observed that the traffic was dominated by public traffic, including heavy traffic not associated with BGC’s operations. Therefore, it is not valid to attribute the increased risk of accidents to BGC’s truck movements.
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Table 12 Average Number of Daily Truck Movements for the Existing Quarry (2001 – 2004)
Year 6 Wheeler (Capacity of 14 t)
Semi-Trailer (Capacity of 25 t)
Truck and Dog (Capacity of 40 t)
Road Train(Capacity of 50 t)
Total Daily Truck
Movements
2001 70 53 70 24 2172002 84 63 84 28 2592003 83 63 83 28 2572004 72 54 72 24 222
Average 77.38 58.12 77.39 25.82 238.75
Public Submission 10 stated that the number of trucks (200/day) is unacceptable for fauna and humans in the area.
BGC has not recorded any accidents involving fauna or humans since operations commenced at the Voyager Quarry. Therefore, it is not reasonable to claim that the truck movements associated with BGC’s operations are “unacceptable to fauna and humans in the area”.
The AVES submission stated that with the wetting of the loads, this increases the load on the truck and reduces the payload. They asked whether this would mean that there are more truck movements or whether there will be overloading.
BGC sprays the load with water prior to the transportation of products from the quarry to reduce dust. The wetting of the payloads increases the load by less than 1%, which means that the amount of water added does not overload the trucks. Therefore, there is not requirement to have increased truck movements, nor are BGC’s trucks overloaded.
Public Submission 1 stated that transport routes are a concern and data should be presented on the volume of truck traffic from the current quarry site and whether this has increased or decreased over the life of the quarry. Public Submission 2 also requested truck movements to and from the quarry per week.
Truck movement data for the last four years from the existing quarry are presented in Table 12. This data suggests that the average daily truck movements has remained quite steady over the last four years, ranging from 217 to 259 truck movements per day. BGC’s records show that the demand for hard rock over the last three years has been particularly high, resulting in around the 1 to 1.1 million tonnes per year. In forecasting the market demand for hard rock, it is expected that the demand will taper off over the next few years. Therefore, the number of truck movements for the next few years are expected to be the same.
Based on a 5.5-day week for the operation of the quarry, there would be an average of 1,313 truck movements to and from the quarry per week.
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Public Submission 1 asked for further information on the expected truck traffic from the proposed quarry site and suggested that these data be presented to the Department of Planning and Infrastructure to assess the acceptability of truck volume. In addition, this submission stated that there should be a guarantee that the main access road to the quarry will be from Great Southern Highway, not Horton Road.
The number of truck movements to and from the quarry is dependent on the volume of hard rock produced. As the annual throughput for the proposed quarry will be the same as that for the existing quarry, it is expected that the number of truck movements will also be the same.
BGC has made a commitment that access to the proposed quarry will be from Great Southern Highway, as is currently the case.
7.15 Visual Amenity
Public Submission 4 referred to the Executive Summary (Volume 1) where it stated that “there is no direct line of sight between these residences and the existing quarry, nor will there be for the new quarry”. The submission stated that properties to the north and east have line of sight to the existing quarry and the proposed mine site. Public Submission 2 also stated that the proposed quarry site is visible from their property.
It is possible that the existing quarry is visible from the property due north of the quarry (i.e. residence B), although exactly what ‘property’ refers to is not defined. If from anywhere on the ‘overall property’, this is likely to be so, as there are a number of vantage points from which to observe surrounding properties and adjacent landscapes. However, if it is the ‘residence’ this is different.
The residence lies on the 290 m contour. Between the residence and the existing quarry the contours rise to 300 m contour with a high knoll or point of 305-310 m. The furthest side of the existing quarry (i.e. the southern side) cuts back to the 330 m contour. Given this topographic setting/positioning, while it may be true (subject to field verification) that a small portion of the quarry is visible (the southern quarry side) it is highly improbable that the major quarry working is visually accessible from ground height. An upper storey viewing point may make some difference, but there is no reference to the property being other than a single storey structure.
Visual accessibility from Residence C does appear highly unlikely on the basis of the topography, and particularly in combination with the vegetation cover in the vicinity of the residence.
All other properties are unseen and cannot have visual accessibility to the quarry site, existing or proposed – pronounced ridges separate them and form separate viewsheds.
The proposed mine site presents more of an issue to Residence B, and in theory Residence C perhaps – but on the basis of contours only. The proposed quarry cuts back to the 360 m contour at one point. This
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may be visible from Residence B, but will require accurate plotting to establish whether this is so. The same applies to Residence C.
However, against this it is vital to take account of existing vegetation cover that is dense, extensive and permanent. The practical effect of this vegetation is to create substantial ‘foreground closure’ (visual screen), particularly in the case of Residence C and cannot be excluded from the assessment. Foreground vegetation is highly effective in creating a visual buffer and rendering distance landscape ‘unseen’. This definitely applies to Residence C and could easily be introduced to provide screening for Residence B.
Public Submission 4 stated that the pit wall of the proposed quarry would look as unsightly as the plant and equipment, and queried the visual impact of the stockpiles. The submission also stated that distance is not a solution to visual impact.
It is true that the western wall of the proposed quarry pit wall could look unsightly. Without specific treatment it will, and it will be visually dominant in the visual catchment within which it is located, but this visual catchment is relatively confined.
Landscape treatment to soften the eventual remaining landscape feature that is created and left behind can be achieved. It will require forward planning and design of the final quarry wall. This could include sufficient batters and final benches to allow establishment of vegetation as part of a quarry closure plan.
Public Submission 4 referred to the Executive Summary (Volume 1) where it stated, “However there is a vegetation buffer in close proximity to the viewing point, which is likely to obscure the visibility of the proposed project”. This submission questioned the use of the term “likely” and asked for a more definite statement.
As mentioned above, providing substantial vegetation screening as part of the overall development and management plan can provide very effective ‘foreground closure’ to render otherwise visible elements in the foreground, mid-ground or back-ground landscape entirely invisible. The wording should be changed to omit ‘likely’ and as confirmed commitment to provide such screening, according to the satisfaction of all parties, should be given.
The AVES submission stated that the lighting type should have already been decided.
Lighting is a key factor in visibility of night-time operations. Current lighting technology allows for extremely low impact solutions both in terms of mitigating ‘direct light spill’ and ‘general light-glow’. It would be better to defer final decisions on lighting technology until closer to operational start-up, but in the meantime to commit to the application of appropriate new lighting technologies in order to minimise light impacts.
BGC has already demonstrated that it is committed to minimising lighting impacts, as a lighting survey of the existing quarry was undertaken n July 2002 and circuits were modified to ensure that minimum lighting was used for night-time activities.
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Public Submissions 2 stated that the existing quarry produced night glow and that if the proposed quarry were allowed to operate at night, then the actual lights would be visible. Public Submission 4 stated that night glow has detrimental effects on livestock and interferes with this submitter’s hobby of astronomy.
The above comments apply. In short, lighting technology has improved substantially in recent years, and light glow and light spill can be minimised in a most effective manner. A commitment to this effect was made in the PER.
Public Submission 3 stated that it did not believe the light will not be a problem, especially during the early years of the project where overhead lighting will have light overspill. It stated that the problem would be worse with a closer and larger quarry. Public Submission 4 stated that even though the actual lights will eventually be below ground level, the light will be reflected back upwards “by the reflective nature of the granite”.
The above comments apply. Radiant light, light glow and light reflection has a great deal to do with the light ‘wave-length’ being omitted from the light source in use. Current technology allows more opportunity than previously to minimise reflected light and light glow, and with proper advice it is possible to reduce all lighting issues to a substantial degree.
Public Submission 2 asked when the final Visual Impact Management Plan would be released.
As stated in the PER, the Proponent has made a commitment to finalising the Visual Impact Management Plan after considering the comments received during the public review period and in consultation with the regulators. The final draft of the plan will be submitted to DoE for review and finalised following the receipt of their comments. The final Visual Impact Management Plan will not be re-circulated in the public arena. However, they will be available from BGC, should a request be made to BGC Quarries.
7.16 Aboriginal Heritage
The DIA submission stated that it had reviewed the Aboriginal heritage reports for the project and that BGC had addressed the Aboriginal Heritage Act in undertaking heritage surveys. The department stated that if any cultural material is unearthed during the excavation and construction phase of the development, all work should cease, and the DIA should be notified.
Should any cultural material be unearthed during the construction and operational phases of the proposed Project, work will cease and the Department of Indigenous Affairs (DIA) will be notified.
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8 References
Agriculture Western Australia (2000) Salinity at a Glance. Farmnote No. 08/2000. Department of Agriculture, WA.
Australian and New Zealand Minerals and Energy Council (1996) National Strategy for the Conservation of Australia’s Biological Diversity. Department of Environment, Sport and Territories, Canberra.
Australian and New Zealand Minerals and Energy Council and Minerals Council of Australia (2000) Strategic Framework for Mine Closure. ANZMEC and MCA, ACT.
Biota and Johnstone, R.E. & C. (2003) Voyager Quarry Extension – Targeted Fauna Survey. Unpublished report prepared for BGC Quarries, January 2003.
Department of Environment (1996) Landfill Waste Classification and Waste Definitions 1996 (as amended). Department of Environment, Perth.
Department of Environment (2002) Guidelines for Acceptance of Solid Waste to Landfill. Department of Environment, Perth.
Department of Resources Development (1980) Resource Protection Plan- Basic Raw Materials. Report of the Darling Escarpment Aggregate Resources Committee.
Environmental Protection Agency (1995) Best Practice Environmental Management in Mining - Rehabilitation and Revegetation. The Environmental Protection Agency, ACT.
Environmental Protection Agency (1998) Best Practice Environmental Management in Mining – Noise, Vibration and Airblast Control. The Environmental Protection Agency, ACT.
Environmental Protection Authority (2002) Terrestrial Biological Surveys as an Element of Biodiversity Protection. Position Statement No. 3, March 2002.
Environmental Protection Authority (2003) Guidance for the Assessment of Environmental Factors, Terrestrial Fauna Surveys for Environmental Impact Assessment in Western Australia. Draft Guidance Statement No. 56, February 2003.
Environmental Protection Authority (2004a) Guidance for the Assessment of Environmental Factors, Terrestrial Flora and Vegetation Surveys for Environmental Impact Assessment in Western Australia. Guidance Statement No. 51, June 2004.
Environmental Protection Authority (2004b) Environmental Offsets. Position Statement No. 9.Environmental Protection Authority, July 2004.
Heddle, E.M., Havel, J.J. and Loneragan, O.W. (1980a) Focus on Northern Jarrah Forest Conservation and Recreation Areas. In: Forest Focus No. 22.
Johnstone, R.E. and Kirkby, T. (2003) Assessment of Tree Hollow Resources and Obligate Hollow Nesting Birds at Voyager Quarry Site, The Lakes, Mundaring, Western Australia. Unpublished report for BGC Quarries.
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Landvision (1996) Managing the Basic Raw Materials of Perth and the Outer Metropolitan Region. Report prepared for the Extractive Industries Committee of the Chamber of Commerce and Industry of Western Australia, April 1996.
Main, B.Y. (1987) Persistence of invertebrates in small areas: Case studies of trapdoor spiders in Western Australia. Chapter 3, pp. 29-39 in ‘Nature Conservation: The role of remnants of native vegetation’. (Editors: Saunders, Arnold, Burbidge and Hopkins). Surrey Beatty & Sons, Chipping Norton, NSW.
Mallet, C.W. and Mark, M.R. (1996) Key Issues in the Management of Final Voids. In: Post-Mining Land Stability and Design Workshop Proceedings. Brisbane, Queensland. Ed. by L.C. Bell and R.W. McLean. Australian Centre for Minesite Rehabilitation and Research, Brisbane, Queensland: 93-105.
Mattiske Consulting Pty Ltd (2002) Flora and Vegetation on Avon Loc 1881 – Lots 11 and 14 Horton Road, The Lakes – Mundaring. Unpublished report prepared for BGC Quarries, November 2002.
Ninox Wildlife Consulting (2002) The Vertebrate Fauna of Avon Loc 1881 Lots 11 and 14 Horton Road The Lakes – Mundaring. Unpublished report prepared for BGC Quarries, July 2002.
Prince, R.I.T (2003) Successful translocation of a mature female ridge-back trapdoor spider (Idiopidae: Idiosoma sigillatum). The Western Australian Naturalist. 24(2) 10-103.
Shire of Northam (1999) Eastern Slopes Planning Precinct of the Local Rural Strategy. Shire of Northam, WA.
Sinclair Knight Merz (1998) Wooroloo Prison South – Tree Planting Program. Prepared for the Ministry of Justice, August 1998.
Slack-Smith, S.M. (2004) Report on a Survey of Terrestrial Molluscs for BGC Quarries on Areas within a Proposed Expansion of the Voyager Quarry and of Nearby Areas of the Darling Range, WA. Reportprepared for BGC Quarries, June 2004.
Stahan, R. (1995) The Mammals of Australia. Australian Museum/ Reed Books, Australia.
Survey and Mapping Group Pty Ltd (1987) Basic Raw Materials Resource Protection Strategy, Perth Metropolitan Region. Prepared for the State Planning Commission, November 1987.
Western Australian Planning Commission (2000) Statement of Planning Policy No. 10 – Basic Raw Materials.
Worsley Alumina Pty Ltd (1985) Worsley Alumina Project: Flora and Fauna Studies, Phase Two.Confidential report prepared for Worsley Alumina.
Water Corporation Cockatoo Care Programme (2004) www.watercorporation.com.au/cockatoocare
Water and Rivers Commission (2000) Salinity. Water Facts 15. Water and Rivers Commission, WA.
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York Main, B. and Trent, S.W. (2004a) A Further Survey Including Demography of the Trapdoor Spider Gaius sp. Occurring in Avon Location 1881, Lots 11 and 14 and Adjacent Land Holdings. Unpublished report prepared for BGC Quarries, May 2004.
York Main, B. and Trent, S.W. (2004b) Survey for the Trapdoor Spider “Voyager” Gaius sp. in Nearby Regional Areas to Avon Location 1881, Lots 11 and 14. Unpublished report prepared for BGC Quarries, May 2004.
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9 Limitations
URS Australia Pty Ltd (URS) has prepared this report for the use of BGC (Australia) Pty Ltd in accordance with the usual care and thoroughness of the consulting profession. It is based on generally accepted practices and standards at the time it was prepared. No other warranty, expressed or implied, is made as to the professional advice included in this report. It is prepared in accordance with the scope of work and for the purpose outlined in the Proposal dated 4 December 2003.
The methodology adopted and sources of information used by URS are outlined in this report. URS has made no independent verification of this information beyond the agreed scope of works and URS assumes no responsibility for any inaccuracies or omissions. No indications were found during our investigations that information contained in this report as provided to URS was false.
This report was prepared between December 2003 and December 2004 and is based on the information reviewed at the time of preparation. URS disclaims responsibility for any changes that may have occurred after this time.
This report should be read in full. No responsibility is accepted for use of any part of this report in any other context or for any other purpose or by third parties. This report does not purport to give legal advice. Legal advice can only be given by qualified legal practitioners.
