20120614 brm rail offset plan v3 - epa wa · brockman iron limited rail infastructure offset plan...

JULY 2012

BROCKMAN IRON PTY LTD

RAIL INFASTRUCTURE PROJECT

OFFSET PLAN

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Brockman Iron Limited

Rail Infastructure Offset Plan

July 2012

i

BROCKMAN IRON PTY LTD

RAIL INFASTRUCTURE PROJECT

OFFSET PLAN

Brockman Iron Limited

Rail Infastructure Offset Plan

July 2012

ii

Document Status

Approved for Issue Rev Author Reviewer/s Date

Name Distributed To Date

A M Morris 13/03/2012

B M Morris T McKenna 16/03/2012 M Morris G Firth (Brockman)

06/06/2012

1 K Critchell 07/06/2012 K Critchell G Firth 07/06/2012

2 K Critchell 14/06/2012 K Critchell G Firth 14/06/2012

ecologia Environment (2012). Reproduction of this report in whole or in part by electronic, mechanical or chemical means including photocopying, recording or by any information storage and retrieval system, in any language, is strictly prohibited without the express approval of Brockman Iron Pty Ltd (Brockman) and/or ecologia Environment.

Restrictions on Use

This report has been prepared specifically for Brockman. Neither the report nor its contents may be referred to or quoted in any statement, study, report, application, prospectus, loan, or other agreement document, without the express approval of Brockman and/or ecologia Environment.

ecologia Environment

1025 Wellington Street

WEST PERTH WA 6005

Phone: 08 9322 1944

Fax: 08 9322 1599

Email: [email protected]

Brockman Iron Pty Ltd

Rail Infrastructure Project Offset Plan

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iii

TABLE OF CONTENTS

1 RAIL INFRASTRUCTURE PROJECT OVERVIEW .....................................................................1

2 PLANNING CONTEXT .........................................................................................................3

2.1 ENVIRONMENTAL SUSTAINABILITY...........................................................................................3

2.2 ENVIRONMENTAL ASSETS.........................................................................................................4

3 KEY IMPACTS ....................................................................................................................7

3.1 FORTESCUE MARSH ..................................................................................................................7

3.2 FORTESCUE VALLEY SAND DUNES ............................................................................................7

4 ENVIRONMENTAL MANAGEMENT ....................................................................................9

4.1 AVOIDANCE AND MITIGATION THROUGH MANAGEMENT ......................................................9

4.2 OFFSET OF RESIDUAL IMPACTS...............................................................................................10

5 PROPOSED OFFSETS ........................................................................................................ 13

5.1 MANAGEMENT OF THE FORTESCUE MARSH ..........................................................................13

5.2 SAND DUNE PEC INVESTIGATIONS..........................................................................................13

5.3 COMMENT TO PRINCIPLES......................................................................................................15

6 REFERENCES.................................................................................................................... 17

TABLES

Table 2.1 – Protected Ecological Communities in the Project Area .........................................................6

Table 5.1 – Proposed Offsets .................................................................................................................14

Table 5.2 – EPA Guidance Statement No. 19 Principles .........................................................................15

APPENDICES

Appendix A DEC Meeting Minutes ........................................................................................................19



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ACRONYMS

Brockman Brockman Iron Pty Ltd

DEC Department of Environment and Conservation

EPA Office of the Environmental Protection Authority

EPBC Environment Protection and Biodiversity Conservation Act 1999

ERA Environmental Risk Assessment

PEC Priority Ecological Community

PEMP Project Environmental Management Plan

PER Public Environmental Review

SRE Short Range Endemic

TEC Threatened Ecological Community



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1 RAIL INFRASTRUCTURE PROJECT OVERVIEW

Brockman Iron Pty Ltd (Brockman), a wholly‐owned subsidiary of Brockman Resources Limited, proposes to develop the Brockman Railway Project (the Project). This rail solution will service the ore transport requirements of the Marillana Iron Ore Project. The Project will connect the Brockman Marillana Iron Ore Mining Project (Ministerial Statement 855, EPBC Assessment 2011/5892) to the existing Fortescue Metals Group (FMG) railway line, which currently transports product from FMG’s Cloudbreak mine to the Herb Elliot Port in Port Hedland in the Pilbara region of Western Australia.

In agreement with FMG, and taking advantage of extra capacity in FMG’s railway system, Brockman can cost‐effectively boost the transport efficiency of its iron ore and reduce greenhouse gas emissions by negating the use of road haulage.

The Project includes a linear load out with conveyor facility and a single line heavy haulage railway with passing loops. It extends from the north‐western boundary of the Marillana mine tenement (M47/1414) where the rail runs parallel to the existing BHP Billiton Iron Ore (BHPBIO) railway, crossing the Fortescue Marsh at its narrowest point, and continuing north for approximately 10 km past the marsh. From this point, it deviates from the BHPBIO railway and heads north‐east through the Chichester Range for 12 km, then continues on its north‐easterly course for another 13 km where it meets the FMG railway, approximately 220 km from Port Hedland.

The Project spans 78.4 km and will be situated within an envelope that covers 8699 ha. The Project will result in a maximum disturbance area corridor up to 200 m wide for an area of 1568 ha. An additional 20 ha may be required for a construction camp adjacent to the corridor. The specific location of the construction camp will not be finalised during the term of this assessment. Total disturbance is 1588 ha. The nominated 200 m width is to allow for construction borrow pits, laydown areas and siding infrastructure throughout the length of rail. It is anticipated that the actual disturbance footprint will be considerably reduced from the nominated 1588 ha once an engineered alignment is designed. Following construction, rehabilitation will be completed on construction disturbance areas, further reducing the long‐term footprint of the Project.

Brockman has undertaken substantial baseline environmental and social investigations to adequately assess the potential risks of the Project and to propose appropriate management strategies for key aspects such as native flora and fauna, ground and surface water, heritage values and the local community.

This Offset Plan documents the environmental impacts associated with the Project, the process by which risks are managed and mitigated and Brockman’s proposed plan to offset residual environmental impacts. This plan has been prepared for the Environmental Protection Authority (EPA) with reference to the Government of Western Australia Environmental Offsets Policy 2011 to address the recommendations outlined in the EPA Guidance Statement No. 19 Environmental Offsets ‐ Biodiversity (EPA, 2008) and Position Statement No. 9 Environmental Offsets (EPA, 2006).



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2 PLANNING CONTEXT

2.1 ENVIRONMENTAL SUSTAINABILITY

Brockman has embraced the EPA’s principles of environmental protection as part of Project engineering and design. The environmental objective of the Project’s design, in order of priority, is to:

• Completely avoid the impact if possible;

• Substitute with a lesser impact;

• Design rehabilitation and engineering solutions to reduce the degree and risk of impact;

• Design operational controls and emergency response around reduction of impact consequences; and

• Provide for environmental offsets for the impact.

This Offset Plan has been developed with regard to the following principles for use of environmental offsets:

• Environmental offsets will only be considered after avoidance and mitigation options have been pursued.

• Environmental offsets are not appropriate for all projects.

• Environmental offsets will be cost‐effective, as well as relevant and proportionate to the significance of the environmental value being impacted.

• Environmental offsets will be based on sound environmental information and knowledge.

• Environmental offsets will be applied within a framework of adaptive management.

• Environmental offsets will be focused on longer term strategic outcomes.

Environmental offsets will be designed to be enduring, enforceable and deliver long‐term strategic outcomes. A flexible approach to the security, management, monitoring and audit of offsets will be adopted to ensure that anticipated environmental outcomes are realised.

Responsibility for monitoring, auditing and compliance with set conditions to nominated agencies is as described in the Environmental Protection Act 1986 (WA) and other State legislation. All environmental offsets that are included as part of a statutory approval will identify the agency responsible for monitoring its implementation, ongoing auditing and legislative basis.

Investigations have been conducted by Brockman for all aspects of the Project to gather baseline data and to determine the types and degree of environmental impacts of the Project. Agreement from relevant agencies was obtained for the investigation methods as part of the proposal’s consultation process.

Significance of impacts was determined as a function of the sensitivity of the receiving environment and the magnitude of the impact. In assessing the significance of environmental impacts potentially resulting from this proposal, Brockman considered the following:

• relevant legislation, standards and guidelines;



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• biological assessments of the Project area;

• the EPA’s Principles of Environmental Protection; and

• input from government and community‐based stakeholders.

Opportunities for impact avoidance and minimisation have been identified and implemented to various degrees as part of the proposal’s design phase. The significant environmental impacts, proposed alternatives and on site management measures are outlined in the following sections.

2.2 ENVIRONMENTAL ASSETS

2.2.1 Fauna

Based on the results of database searches and a review of surveys previously undertaken in the area, the potential fauna of the Proposal Area comprises 37 native and eight introduced mammal species, 170 bird species, 107 reptile species and eight amphibian species. Of this potential fauna, the baseline surveys recorded 21 native and five introduced mammal species, 65 bird species and 45 reptile species. No amphibian species were recorded during the surveys. The species accumulation curves generated from trapping data indicated that the majority of trappable fauna were recorded.

Twenty‐six species of conservation significance have the potential to occur within the Proposal Area (Figure 4.2). Six of these species were recorded during the Level 2 fauna surveys. An additional nine species have a high or medium likelihood of occurrence. Conservation significant fauna recorded during the Level 2 surveys consisted of:

• four individuals of the Australia bustard (DEC Priority 4) from two locations;

• twenty‐five inactive, two possibly active and one active Western pebble‐mouse mound (DEC Priority 4) recorded from rocky spinifex hillslopes and plains within or nearby the Proposal area;

• eight records of Northern Short‐tailed mouse (DEC Priority 4) from two sites;

• two sightings of Grey falcons (DEC Priority 4) were observed from different locations;

• Rainbow bee‐eaters (EPBC Act Migratory) at four different locations within the Proposal Area; and

• six recordings of Bush stone‐curlew (DEC Priority 4) from three locations.

A targeted survey for the Northern quoll was conducted as some suitable denning habitat was identified during initial surveys. The survey failed to identify any primary or secondary evidence of Northern quolls being resident within this habitat.

2.2.2 Flora and Vegetation

Thirty four vegetation communities were identified in the Proposal Area. No Declared Rare Flora were identified in the Proposal area. Four Priority Flora were identified within the corridor. One additional unconfirmed Priority taxa Tecticornia globulifera (Priority 1) was recorded but required further material for verification. Six species collected in the Proposal Area represent range extensions based on collection records lodged at the WA Herbarium. Six weed species were recorded within the Project Area at 30 locations.



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No declared plants were recorded in the Project Area. However, one plant of *Argemone ochroleuca subsp. ochroleuca which is declared in other districts other than East Pilbara Shire was recorded in the Project Area.

Two Priority Ecological Communities (PEC) are present within the Proposal Area: Fortescue Marsh (Priority 1) and the Fortescue Valley Sand Dunes (Priority 3). A further Priority 1 PEC, Freshwater Clay Pans of the Fortescue Valley lies to the immediate west of the Proposal Area and has the potential to be indirectly impacted by changes to surface hydrology.

The most regionally restricted unit present within the Project Area is Unit 562 (Mosaic of Acacia aneura low woodland in valleys with open low tree steppe of Eucalyptus leucophloia and Triodia wiseana hummock grasslands), of which 1036 km2 has been mapped regionally. This unit comprises 18.9% of the Project Area, occurring as a single band at the point where the corridor turns east.

The corridor intersects some mulga vegetation communities and has the potential to indirectly impact this vegetation by altering the surface hydrology. Similarly, changes to surface hydrology have the potential to alter the Fortescue Marsh. These impacts will be mitigated by adequate consideration of hydrology during design and construction and appropriate placement of culverts.

2.2.3 Short‐Range Endemics

More than 500 invertebrate specimens were collected during the Short‐Range Endemic (SRE) survey, however only 15 individuals represented potential SRE species. These included a single known SRE species (new isopod genus, gen. nov. 2) and four potential SRE species (Succinea sp., Anidiops sp., Eucytops sp. and Aname sp.).

Aname, Anidiops, Eucyrtops and isopod gen. nov. 2 were only present in regional areas and will not be impacted by the Project. Succinea sp. was collected from regional areas as well as within the Proposal Area. Less than 1% of the vegetation association from which Succinea was collected will be impacted; therefore the expected impact is low.

The main outcomes from the SRE survey of the Proposal Area are:

• The land systems, vegetation communities and habitats are likely to support SRE groups but are not restricted to the Proposal Area.

• A total of 31 species were collected during the survey, of which one species was considered a SRE (Isopod gen. nov. 2) and four were considered potential SREs (Aname sp., Anidiops sp., Eucrytops sp. and Succinea sp.).

• The significance of the impact to Aname sp., Succinea sp., Anidiops sp., Eucyrtops sp. and the new isopod genus, was considered negligible as the species were collected from outside the Proposal Area only.

• The significance of the impact to Succinea sp. is considered low as it was collected in regional areas as well as within the Proposal Area. The species was found within Vegetation Association 175, which is widespread across the Pilbara, and less than 1% is expected to be impacted by the Project.



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2.2.4 Environmentally Significant Areas

No Threatened Ecological Communities (TEC) will be impacted by the Project. Two PEC’s cross the Study Corridor envelope, and an additional PEC is located adjacent the Study Corridor. These PEC’s and their predicted impacts are presented in Table 2.1.

Table 2.1 – Protected Ecological Communities in the Project Area

PEC Community Description Priority Percent PEC

within Study

Corridor

Area of PEC (ha) within Study

Corridor

Fortescue Marsh

Fortescue Marsh is on the Fortescue River. Endemic Eremophila species and several to near endemic and new to science Samphires are present. Night Parrot, Bilby and restricted aquatic invertebrates are found in this PEC.

Priority 1 0.3 84.5

Fortescue Valley Sand Dunes

Red linear sand dune communities on the Divide land system at the junction of the Hamersley Range and Fortescue Valley, between the Weeli Wolli Creek and the low hills to the west. A small number are vegetated with Acacia dictyophleba scattered tall shrubs over Crotalaria cunninghamii, Trichodesma zeylanicum var. grandiflorum open shrubland. They are regionally rare, small and fragile and highly susceptible to threatening processes.

Priority 3 5.2 5.1

Freshwater Claypans of the Fortescue Valley

Freshwater claypans downstream of the Fortescue Marsh ‐ Goodiadarrie Hills on Mulga Downs Station. Important for waterbirds, invertebrates and some poorly collected plants. Eriachne spp., Eragrostis spp. grasslands. Unique community, has few Coolabah. Threats include weed invasion, infrastructure corridors, altered hydrological flows, inappropriate fire regimes

Priority 1 0 0



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3 KEY IMPACTS

Key impacts to flora and fauna are anticipated to result from vegetation clearing and construction activities. The key impacts surround Environmentally Sensitive Areas, Priority Ecological Communities and surface water‐dependant communities which will be subject to disturbance, as they contain unique and ecological values, and will be subject to residual impacts which cannot be mitigated.

PEC’s are not explicitly provided for in legislation or EPA position statement No 9 (2006), and as such are not considered a ‘critical asset’. However, Brockman recognises the environmental attributes and ecological values of the PEC and, through this Offset Plan, is committed to ensuring a net beneficial environmental outcome for the Project. Brockman considers the impact to the PEC to be ‘Modification’, as per the DEC Definitions, Categories and Criteria for Threatened and Priority Ecological Communities (2010), which states:

“Modification: changes to some or all of ecological processes (including abiotic processes such as hydrology), species composition and community structure as a direct or indirect result of human activities. The level of damage involved could be ameliorated naturally or by human intervention.”

3.1 FORTESCUE MARSH

3.1.1 Environmentally Significant Values

The Fortescue Marsh provides important feeding, roosting and breeding habitat during times of flood to a large number of waterbirds from across Australia. Whilst the Fortescue Marsh is currently part of pastoral leases and not designated for conservation, there is an agreement in place by the State Government for parts of the Fortescue Marsh area to be excluded from the Pastoral lease renewal for a public purpose (as per s143 6(d) of the Land Administration Act (1997)) and to formally reserve the land as a conservation reserve. There is also the potential for this area to be listed as a RAMSAR wetland in the future. It is estimated that up to 88 ha of the 108,262 ha Fortescue Marsh PEC will be impacted by the Project.

3.2 FORTESCUE VALLEY SAND DUNES

3.2.1 Environmentally Significant Values

The Fortescue Valley Sand Dune PEC is regionally rare, small, fragile and highly susceptible to threatening processes. It is estimated that up to 15 ha of the 194 ha Sand Dune PEC will be impacted by the Project.



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4 ENVIRONMENTAL MANAGEMENT

In reference to the environmental objectives of the Project design, Brockman has implemented the following environmental management strategies.

4.1 AVOIDANCE AND MITIGATION THROUGH MANAGEMENT

Brockman has embraced the concept of sustainable development as part of the engineering and design phases of this Project. Brockman has evaluated the key social, environmental and economic impacts of the proposal. The Project endeavours to provide positive social benefits wherever feasible and reduce any environmental impacts to as low as reasonably practicable.

Impact avoidance and reduction opportunities that are being implemented include:

• engineering and design of infrastructure to avoid significant impacts where possible and ensure maintenance of surface water flows; and

• progressive rehabilitation of the construction footprint as soon as practicable.

Where impacts are unavoidable, Brockman seeks to:

• prevent impacts to species of conservation significance; and

• reduce waste and emissions to levels as low as are practicable.

Considerations of alternative designs aligned with the approach of sustainable development are discussed in the following sections.

4.1.1 Alternative Options

Brockman initially proposed three alternative railway corridor options to the EPA and DEC for consideration. Following consultation and the completion of further feasibility studies, the Project has been refined to one definitive corridor.

Issues influencing the design alignment of the Project include:

• land accessibility on other land owner tenements;

• biological factors, including flora, vertebrate fauna and invertebrate fauna;

• Environmentally Sensitive Areas;

• heritage issues; and

• maximising efficiency of operations.

4.1.2 Mitigation

The proposal has been designed to avoid, where practicable, serious or irreversible damage to the environment. This includes ceasing all further feasibility studies on alternative railway options that would have greater impacts on the Fortescue Marsh and the proposed conservation estate.

Further, the Project will not create significant additional impact to the area as it crosses the Fortescue Marsh at it narrowest point, adjacent to the existing BHPBIO railway. It then continues



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parallel to the BHPBIO railway for approximately 10 km past the Fortescue Marsh where it forks north east. Due to its location and the surrounding vegetation at the Marsh (Mulga woodlands of up to 6 m in height), the Project is also envisaged to have a very low visibility to tourists visiting the area.

The following considerations are specific to the Fortescue Marsh and underlie Project planning and construction practices:

• Disturbance of the Marsh is to be kept to a minimum and only in areas approved for work.

• All in‐flowing and out‐flowing creeks and streams are to be preserved, with culverts and drainage structures installed wherever necessary.

• Appropriate scientific studies will be commissioned to monitor water quality and other aspects of possible impact on the Marsh by proposed works.

• Brockman commits to the long‐term preservation of the marsh by working with the local Native Title claimant group (M.I.B.) and relevant external organisations to develop, implement and enforce a comprehensive Cultural Heritage Management Plan.

• The prevention of groundwater pollution and contamination will be achieved through appropriate waste management practices.

• Removal of non‐essential infrastructure and rehabilitation of the disturbed ground to final land use requirements will be carried out upon completion of construction.

In consultation with the DEC, Brockman propose to develop an Environmental Management Plan for the construction of the Project.

4.1.3 Predicted Outcomes

The management measures described above show that the Project can meet the EPA’s objectives for vegetation and flora as follows:

• The Project has been designed to avoid significant locations. Clearing of native vegetation will be kept to a practical minimum. Progressive rehabilitation will reduce exposed areas and restore habitat for native fauna and flora. Control programmes for weed and feral animals will be implemented.

• Vegetation communities impacted by the Project are generally widely distributed in the region. Where the project does intersect regionally restricted vegetation units, impacts to the vegetation units are less than 7% by area. The regional extent of these communities will not be significantly affected by the clearance footprint of the Project. The Project will implement measures to identify and control invasive weed species.

• Flora species impacted by the Project are distributed within the region. The Project has been designed to avoid populations of significant species where possible. Botanical surveys conducted for the Project has improved knowledge of vegetation and flora in the region.

4.2 OFFSET OF RESIDUAL IMPACTS

It is considered by Brockman that the steps taken to implement the hierarchy of environmental objectives results in residual impacts being confined to the clearing and associated removal of habitat within the PEC’s. As such, the significant residual environmental impact addressed by this



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offset plan is the clearing of up to 88 ha of native vegetation within the Fortescue Marsh PEC unit and 15 ha within the Fortescue Valley Sand Dune PEC unit.



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5 PROPOSED OFFSETS

This plan details Brockman’s offset for the clearing of native vegetation. The objective of the proposed offset is to directly counterbalance the impact, and it is considered by Brockman that the offsets will achieve a net environmental benefit.

5.1 MANAGEMENT OF THE FORTESCUE MARSH

In recognition of the conservation importance of the Fortescue Marsh to the State of Western Australia and Commonwealth of Australia (including the potential for this area to be listed as a RAMSAR wetland in the future and the associated conservation significant fauna values associated with the Marsh), Brockman has already committed a total of $400,000 to DEC Fortescue Marsh conservation initiatives to offset its proposed Marillana Iron Ore Project.

To offset the Rail Project, Brockman proposes to provide an additional $250,000 to a DEC trust fund, as part of a state and federal initiative to protect conservation listed flora and fauna species. Brockman will contribute a total of $50,000 per annum for five years from commencement of operation. The intent of size and timing of this contribution can assist with the transition of the Marsh into a conservation reserve from 2015.

Brockman also recognises that the location of its Marillana Iron Ore and Rail Projects lends itself to supporting DEC conservation programmes, particularly those being conducted on the southern boundary of the Marsh.

To help facilitate the conservation initiatives, Brockman will, as far as latent capacity dictates, provide in‐kind support to DEC or contracted staff engaged in undertaking the conservation initiatives by way of providing:

• accommodation and meals at the Marillana mine site as required;

• vacant seats on charter flights from Perth to the Project for the research project personnel; and

• communications, transportation and health and safety support where necessary.

Brockman will extend this support to the DEC for the Life of Mine.

5.2 SAND DUNE PEC INVESTIGATIONS

In recognition of the conservation importance of the Sand Dune PEC to the State of Western Australia, Brockman has already committed a total of $100,000 as part of the offset package for the Marillana Iron Ore Project. The intent of this offset is to increase the knowledge base of the Sand Dune PEC unit.

Of the $250,000 commitment for the Rail Project, Brockman proposes that $50,000 is spent undertaking further investigations into the Sand Dune PEC. The scope of the investigations will be determined in consultation with the DEC.

Should the scope of work be completed within the budget committed, any remaining funds (to the maximum commitment value) that are insufficient to undertake further investigations shall be donated to a mutually agreed (between Brockman and DEC) conservation trust, fund, programme or project.



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Table 5.1 – Proposed Offsets

Residual Environmental Impacts Asset Values Offset Direct or Contributing?

Maximum Monetary

Commitment Value (AUD)

Provide additional funding towards a DEC trust fund for the management of the Fortescue Marsh and related initiatives in the Pilbara region of Western Australia.

Contributing $200,000

Total clearing of up to 1588ha. Clearing of up to 88 ha of native vegetation within Fortescue Marsh PEC. Clearing of up to 15 ha of Sand Dune PEC.

PEC containing high ecological values. Asset contains environmental attributes associated with supporting environmental values such as Conservation Significant Fauna.

Provide additional funding to the DEC trust fund to undertake further environmental investigations of the sand dune community, which may include regional investigations.

Contributing $50,000



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5.3 COMMENT TO PRINCIPLES

In developing the offset package, Brockman has considered the EPA Principles for formulating an environmental offset package, outlined in EPA Guidance Statement No. 19 Environmental Offsets ‐ Biodiversity (EPA, 2008). Table 5.2 demonstrates how these principles have been considered by Brockman.

Table 5.2 – EPA Guidance Statement No. 19 Principles

Principles Comment

A. Environmental offsets should only be considered after all other reasonable attempts to mitigate adverse impacts have been exhausted

Brockman has undertaken steps to achieve avoidance and mitigation. A summary of this is included in Section 4.

B.

An environmental offset package should address both direct offsets and contributing offsets.

Brockman’s Offset Plan includes contributing offsets which are considered appropriate to the scale and intensity of the residual impacts, and consider the regional context and values associated with the impacts.

C.

Environmental offsets should ideally be ‘like for like or better’.

Brockman’s Offset package will have a net environmental gain for the Weld Range. The offsets relate specifically to the Weld Range environmental values and attributes, and to the current and future impacts being experienced by this environment.

D.

Positive environmental offset ratios should apply where risk of failure is apparent.

Offsets shall achieve a net environmental benefit.

E.

Environmental offsets must entail a robust and consistent assessment process.

Brockman has commissioned environmental studies along the rail corridor and within the greater region. Ongoing consultation and approvals management with local, state and federal government agencies, non‐government organisations, pastoral land owners and traditional land owners has assisted Brockman in determining the potential environmental and social impacts of the Project.

F.

Environmental offsets must meet all statutory requirements.

Brockman has considered and adhered to, and shall continue to consider and adhere to, the statutory requirements of Project EIA and statutory approvals. Brockman has engaged key stakeholders in developing this Offset Plan, including the DEC, to ensure its suitability and consistency with state environmental objectives and policy.

G.

Environmental offsets must be clearly defined, transparent and enforceable.

Offsets have been clearly defined (See Table 4.1)

H.

Environmental offset must ensure a long lasting benefit.

Offsets ensure long lasting benefit, as they are influential to increasing knowledge around mine closure and rehabilitation techniques. The offsets also increase the long term ecological functions of Weld Range through regional rehabilitation by way of feral control and destocking.



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6 REFERENCES

Australian Standards (2009) AS NZS ISO 31000‐2009 Risk management ‐ Principles and guidelines

DEC (2010) Definitions, Categories and Criteria for Threatened and Priority Ecological Communities

EPA (2008) Guidance Statement No. 19 Environmental Offsets – Biodiversity

EPA (2006) Position Statement No. 9 Environmental Offsets

Government of Western Australia (2011) WA Environmental Offsets Policy



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APPENDIX A DEC MEETING MINUTES

1025 WELLINGTON STREET WEST PERTH WA 6005 • PH: 9322 1944 • FAX: 9322 1599 • ACN 088 821 425 • ABN 63 088 821 425 www.ecologia.com.au

Page 1 of 3

Brockman Resources Limited Marillana Iron Ore Project 22 September 2011 Location: OEPA, Perth Present: Amy Oud (Environmental Protection Authority)

Glenn Firth (Brockman Resources) Paul Bartlett (Brockman Resources) Marc Morris (ecologia Environment)

EPA MEETING MINUTES PROPOSED PROJECT CHANGES

Brockman sought audience with the EPA to present proposed changes to the Marillana Iron Ore Project, and determine the approvals strategy required to implement the changes. The meeting was subsequent to, and informed by, the meeting between Brockman and the DEC (02/09/2011), at which potential impacts, development constraints and offsets were discussed.

Agenda

Speaker Discussion Summary

Introduction of Attendees and Meeting Agenda

GF

Introduces Paul and Marc to Amy.

Outlines the intention of the meeting; to discuss proposed changes to the Project and identify the approvals pathways.

Project Changes GF

Outlines the increase in Project footprint from 2985 ha to ~3500 ha and how the number has been achieved.

Outlines the boundary of clearing activities within M47/1414 is still south of the existing BHP rail and weeli-wolli creek.

Changes to water modelling.

AO Inquires that set back from weeli-wolli creek will be maintained as per MS855 condition 6-1. Updated water modelling to be presented with 45C. Confirmed by GF.

GF Inquires that increased footprint is within scope of 45C process. Confirmed by AO.

Rail Infrastructure PB Describes changes around moving rail loading infrastructure north of the BHP Rail, as shown on figure 1.

Impact to Sand Dunes GF What constitutes an adverse effect in the context of impacting part of the dune community?


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Agenda


AO Intent of condition 5-1 is to ensure dunes are not impacted by the proposal.

GF Brockman have discussed with DEC (summary attached) removing some of the dune system to allow for streamlined engineering solution for a load out facility north of the BHP rail. DEC consider this acceptable if appropriate offset can be provided. DEC preference is to have streamlined engineering over messy rail infrastructure networks which will fragment the landscape.

AO It is good that the DEC have been consulted, as EPA seeks their technical advice on impacts.

MM DEC very in touch with the condition of the dune system and understand that the dunes are already degraded and weed infested at the point of proposed impact. Greater value in providing offset towards reducing fragmentation and protecting the dunes which are in good condition, particularly those south east of the project. Existing land-uses are not going to change, and cattle and weeds are likely to continue to degrade the dunes at the Project.

Section 45 C & 46 Processes AO Section 46 would be required to remove PEC condition 5-1. Can be done concurrent with 45C approval if desired.

GF What if the rail load out was removed from the Mine approval process and integrated into the Rail Project EIA, set at API (OEPA2011/000097-1), which is scheduled to be submitted next year for assessment? Could that eliminate the need for Section 46 change?

AO May be possible. May still be conjecture around MS condition 5-1.

GF Brockman will remove rail loading from the scope of 45C and include it in the API, which will allow rigour of EIA to look at impacts, offsets etc. This will remove rail entirely from the scope of MS 855.

AO Deems this to be an acceptable approach.

GF Camp relocation will be off M47/1414 and includes an airstrip.

AO Not an issue.


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Agenda


GF Intending to undertake VCP process for camp and airstrip, what is EPA advice?

AO Would prefer integration into 45C, which will allow for better internal administration and auditing.

Conclusions GF No issue with Brockman pursuing a Section 45C process to undertake the changes as described, including revised footprints and relocation of camp and addition of airstrip.

Brockman will remove the rail from the scope of the Mine Project and present the Loading infrastructure and impacts to PEC in the API for assessment.

AO No issue with proposed changes and all are within the scope of 45C process.

Confirms rail loading infrastructure to be assessed with API.

Best regards, Marc Morris Environmental Advisor 26 September 2011

Address: Level 1, 117 Stirling Highway Nedlands WA 6009 Posta; Address: PO Box 141 Nedlands WA 6909 Phone: +61 8 9389 3000 Fax: +61 8 9389 3033 E-mail: [email protected] Web: www.brockman.com.au Page 1 of 6 ABN: 73 009 372 150

DISCUSSION NOTES RE: DEC MEETING

SUBJECT: CHANGES TO MARILLANA IRON ORE PROJECT (MS 855)

DATE: 02 September 2011

LOCATION: DEC EMB Kensington

ATTENDEES: Glenn Firth (BRM), Marc Morris (ecologia), Murray Baker (DEC), Nicholas Woolfrey (DEC), Stephen Van Leeuwen (DEC)

Introduction Brockman Iron Pty Ltd (Brockman), a 100%-owned subsidiary of Brockman Resources, owns the proposed Marillana Iron Ore Project (the Project) located approximately 100 km north-west of the township of Newman. The project lies within M47/1414; a mining lease that is some 8700 ha in area. The project was assessed under Part IV of the Western Australian Environmental Protection Act 1986. The level of assessment for the proposal was set at Public Environmental Review (PER) with a 4 week public review period, which occurred between 10th May and 8th June 2010. The Project was conditionally approved under Ministerial Statement 855 which was released on 8th February 2011. Purpose of this Discussion Paper The PER presented the Project based on conceptual designs representative of the project at that stage of development (predominantly at Prefeasibility Level, with a Definitive Feasibility Study commenced). Since the PER was approved, Brockman has been working to finalise the Bankable Feasibility Study (at ±10% accuracy) and in the process, has refined the project design and also identified a number of opportunities to increase the value of the project without substantially increasing impact on sensitive environmental receptors. The purpose of this paper is to inform the Environmental Protection Authority (EPA) of the proposed changes to the design of the Project and re-commence dialogue to determine what, if any, environmental approvals are required to permit those changes in line with the current project development schedule and existing Ministerial Statement conditions. Also included in this paper, and directly relevant to the proposed changes, is as summary of a recent meeting held with the WA Department of Environment and Conservation (DEC). The proposed changes and their potential impacts on environmental receptors were discussed. Following EPA’s review of the information in this paper, Brockman seeks an informal meeting with key staff in EPA to discuss options going forward around a similar format to a pre-referral meeting. Summary of Approved Project and Proposed Changes The proposal has slightly increased in scale from 750 Million tonnes (Mt) iron ore to 1065 Mt (owing to a LOM extension of 5 years) with roughly the same size of processing facility and mining footprint. Associated infrastructure has been re-configured. The proposal continues to develop the project using traditional open pit mining methods of excavating, load and haul, still producing 17-

CHANGES TO MARILLANA IRON ORE PROJECT (MS 855)

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19 Mt of beneficiated ore per annum as presented in the PER. The location of the various project components as presented in the approved PER is shown in figures below (original footprint and vegetation map) however the project refinements now present a likely layout of the project as shown in Figure 1. Table 1 lists the key characteristics of the proposal (taken from Schedule 1 of MS 855) with proposed likely changes that have come out of the refined studies during development of the BFS. Table 1: Summary of Key Proposal Characteristics

Element Description (approved PER) Likely Changes (since PER) General Proposed Commencement 2012 No change Project Life Span 20 years 25 years of operation Area of Disturbance 2985 hectares (ha) 3500 hectares (ha) Mining Total Pit Area 1648 ha 1780 ha Waste Rock Disposal 587 ha above ground plus in-pit storage 221 ha external storage plus in-pit storage Fines Reject Storage 247 ha above ground plus in-pit storage 340 ha above ground plus in-pit storage Dewatering 120 Gigalitres over the life of the mine May slightly increase above this volume. Dewatering Rate Peak dewatering of up to 32 Megalitres/day May slightly increase above this volume. Dewater Disposal • Use on site for processing, dust

suppression and use at accommodation camp;

• Managed Aquifer Recharge; • Infiltration ponds; and • No dewater discharge to any creekline.

There is a possibility that only a little if any excess water will result in the project water balance which is currently being refined.

Infrastructure Processing Requirements Crushing, screening and wet gravity

beneficiation No change

Workforce Accommodation

On-site accommodation camp Possibility of relocation off-tenement, to an adjacent Miscellaneous Licence area

Water Supply • Pit dewatering; • Off-take agreements where possible;

and • On or off-tenement bores where

necessary.

No change

Power Source On-site diesel-NG/LNG duel fuel generators.

No change


FIGURE 1 Current project footprint being proposed Note: the preferred rail spur alignment north of the existing BHPB rail line is not shown but is discussed in this paper


Summary of Implications of Changes Brockman has assessed the likely implications of the changes with respect to anticipated approvals requirements. These implications would need to be discussed with EPA to confirm our understandings and set a course that provides EPA with sufficient information to process approvals required for the changes. The summary below covers the points for discussion with EPA on new potential environmental impacts that would not have been assessed in the approved PER:

1. Project Lifespan – increased reserves allow for an extra five years of operational life. Positives include longer employment opportunities, regional economic benefits, and additional State royalties. Negatives include the possibility of utilising more water resources (see point 6) and a larger footprint of disturbance (see point 2).

2. Area of Disturbance – an increase of some 500 ha on that originally proposed in the PER. Efforts have been made to confine disturbances to within original footprint bounded by Weeli Wolli Creek to the east), the BHPB rail line (to the north) and Brockman tenement boundaries (west and south). There are no sensitive environmental receptors within the confines of this larger footprint. There is potential for the rail alignment and load-out facility to be relocated north of the BHPB rail line and impact on the smallest and most degraded of the on-tenement sand dune vegetation communities (PEC 6 and 7). This has implications on Ministerial Statement condition 855:M5.1.

3. Total Pit Area – There has been an increase in iron ore reserves and an improved metallurgical understanding allowing a lower cut-off grade to be used. These improvements have only slightly increased the total footprint but the change is more due to an improved mining and mine waste disposal strategy. The final pit area at closure (below natural ground level but above the natural groundwater table – as agreed in the PER for backfilling) is likely to be around 1130 ha of the 1780 ha total mine area.

4. Waste Rock Disposal – overall, a smaller ex-pit footprint has resulted from the refined project design with more mine waste to be placed back into the open pit footprint. The area of in-pit waste dumps above natural ground level will be some 650 ha.

5. Fines Reject Storage – The footprint of the FRS1 has increase from 247 ha to 340 ha following front end engineering design studies and processing refinement.

6. Dewatering and Dewatering Rate – The numbers for the project water balance are still being developed with the aim to confirm the volumes of dewatering and rates of use as originally proposed in the PER. Early data indicate that a water surplus is unlikely and therefore management of excess via Managed Aquifer Recharge may not be required. If slight increases in demand result, the groundwater impact models will be re-worked to determine any changes in drawdown rates, cone of depression and natural recharge rates.

7. Workforce Accommodation – There is a possibility that the accommodation camp and associated infrastructure originally proposed in the PER may be moved off the project tenement to an adjoining Miscellaneous Lease approximately 6 km to the west of the western tenement boundary. The footprint of the camp, waste water treatment facility and


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landfill will not change from that originally proposed (i.e., approximately 30 ha). Flora, vegetation and habitat surveys have been completed for these areas which indicate the environmental qualities of the alternative location is typical of those surveyed within the project tenement.

From this summary, Brockman identifies the key project changes as:

• The overall increase in project footprint; • The possible impact to a PEC sand dune community; and • The possible increase in water abstraction rates and volume.

These points are suggested as the topics for discussion with EPA when Brockman can further present the details behind the changes, the existing environmental data for the changes and further proposals to demonstrate that the overall changes to the project are not substantial. Outcomes from the Meeting with DEC Environmental Management Branch on 02/09/2011 A meeting was held on Friday 2nd September 2011 between Glenn Firth (Brockman), Marc Morris (ecologia) and DEC representatives Stephen Van Leeuwen and Murray Baker. The project changes presented above were discussed to obtain any early indications from DEC that the proposed changes were unmanageable or unacceptable. Overall, DEC did not foresee any of the changes as being material or causing a significant increase in environmental impact. A summary of their comments is presented below:

1. Increased Project Lifespan – DEC not concerned with this change.

2. Increased Area of Disturbance – DEC acknowledged the efforts to keep the disturbance footprint within the confines the existing footprint and boundaries stating that they do not see the increase as a concern to existing environmental qualities. When presented with the proposed change of rail alignment and load-out facility north of the BHPB rail line through the mapped sand dune vegetation communities (PEC 6 and 7), DEC commented that the impact would not be environmentally adverse, given the stock and weed damage existing on that dune already, and would endorse that change provided that the following recommendations were agreed upon: - an additional Environmental Offset be agreed between DEC and Brockman; and - efforts should be made to align both the rail spur line and load-out facility so that the

single degraded sand dune be removed in preference to fragmenting the 2-3 mapped communities and the dune itself.

When asked on DEC’s opinion on any implications of this change on Ministerial Statement condition 855:M5.1, DEC believed that the very small loss of the heavily degraded dune was not substantial or adverse (compared to the alternative of fragmenting the communities) and overall, was manageable and acceptable to DEC with an additional Offset in place. It was their opinion that there was a greater value in achieving the best engineering solution for the rail in this limited area, especially given that additional rail infrastructure may adjoin this spur in the future as part of FMG expansion projects, and that a resulting spaghetti of infrastructure would have a greater impact.

3. Increased Total Pit Area – DEC not concerned with this change.


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4. Decrease in Waste Rock Disposal – DEC happier with a reduced footprint ex-pit.

5. Fines Reject Storage – DEC not concerned with this change. |

6. Dewatering and Dewatering Rate – DEC not concerned with this change provided that any changes are manageable and the re-worked groundwater impact models indicate no impact to the Fortescue March ESA.

7. Workforce Accommodation – DEC not concerned with this change.



July 2012

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