revised vegetation and flora management plan … · project—i.e. the wiluna uranium mine—as a...

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REVISED VEGETATION AND FLORA MANAGEMENT PLAN WILUNA URANIUM PROJECT

APRIL 2016

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TABLE OF CONTENTS

1 SUMMARY ..................................................................................................................................................... 3 2 CONTEXT, SCOPE AND RATIONALE ............................................................................................................... 5

2.1 The Proposal.......................................................................................................................................... 5 2.2 Key Environmental Factors ................................................................................................................... 5 2.3 Requirements of the Condition ............................................................................................................. 6 2.4 Rationale for Meeting the Environmental Outcome ............................................................................ 8

2.4.1 Results of Studies Conducted ....................................................................................................... 8 2.4.2 Key Assumptions and Uncertainties ........................................................................................... 10

3 MANAGEMENT APPROACH ......................................................................................................................... 12 3.1 Identification of Monitoring Sites ....................................................................................................... 12 3.2 Timing and Frequency of Baseline Survey and Ongoing Monitoring .................................................. 12 3.3 Monitoring Methods ........................................................................................................................... 13

3.3.1 Management Groups for Inferred GDV and Tecticornia-dominated Communities ................... 13 3.3.2 Management Group 1 Monitoring Methods .............................................................................. 13 3.3.3 Management Group 2 Monitoring Methods .............................................................................. 16 3.3.4 Management Group 3 Monitoring Methods .............................................................................. 17

3.4 Trigger Criteria and Rationale ............................................................................................................. 19 3.5 Trigger Level Actions and Rationale .................................................................................................... 20

4 REPORTING PROVISIONS ............................................................................................................................. 21 4.1 Annual Reporting ................................................................................................................................ 21 4.2 Reporting on Exceedance of Trigger Criteria ...................................................................................... 21

5 ADAPTIVE MANAGEMENT AND REVIEW OF THE VFMP .............................................................................. 22 6 STAKEHOLDER CONSULTATION .................................................................................................................. 23 7 REFERENCES ................................................................................................................................................ 24

TABLE OF TABLES

Table 1: Environmental Criteria for this Plan .......................................................................................................... 3 Table 2: Revision History for this Plan .................................................................................................................... 4 Table 3: Requirements of Condition 6 of Ministerial Statement No. 913 .............................................................. 6 Table 4: Vegetation Units Considered to be Inferred GDV ..................................................................................... 9 Table 5: Inferred GDV Containing Tecticornia and Managed as Tecticornia-dominated Vegetation under this VFMP .................................................................................................................................................................... 10 Table 6: Group 1 Monitoring Methods ................................................................................................................. 14 Table 7: Group 2 Monitoring Methods ................................................................................................................. 16 Table 8: Group 3 Monitoring Methods ................................................................................................................. 18 Table 9: Trigger Criteria for this VFMP ................................................................................................................. 19 Table 10: Trigger Level Actions for this VFMP ...................................................................................................... 20 Table 11: Stakeholders to be Consulted ............................................................................................................... 23

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1 SUMMARY

This Vegetation and Flora Monitoring Plan is submitted:

In accordance with Ministerial Statement No. 913, Condition 6, for the Wiluna Uranium Project by Toro Energy Limited; and

As a component of the Public Environmental Review for the Extension to the Wiluna Uranium Project by Toro Energy Limited (EPA Assessment Number 2002-CMS 14025 and EPBC Reference EPBC 2014/7138).

The environmental criteria for measuring achievement of environmental outcomes, which must be met through implementation of this Vegetation and Flora Monitoring Plan, are presented in Table 1.

Table 1: Environmental Criteria for this Plan

Title of proposal The Wiluna Uranium Mine, comprising:

the Wiluna Uranium Project (currently approved, with conditions); and

the Extension to the Wiluna Uranium Project (currently under assessment at the level of Public Environmental Review).

Proponent Toro Energy Limited

Ministerial Statement number 913

EPA’s environmental objectives for the key environmental factor

Wiluna Uranium Project

The EPA identified flora and vegetation as one of nine key environmental factors relevant to the proposal. The EPA’s environmental objectives for flora and vegetation were stated as:

to maintain the abundance, diversity, geographic distribution and productivity of flora at species and ecosystem levels through the avoidance or management of adverse impacts and improvement in knowledge; and

to protect the environmental values of areas identified as having significant environmental attributes.

Extension to the Wiluna Uranium Project

The EPA identified flora and vegetation as one of nine key environmental factors relevant to the proposal. The EPA’s environmental objective for flora and vegetation was stated as:

to maintain representation, diversity, viability and ecological function at the species, population and community level.

Purpose of this plan This Flora and Vegetation Monitoring Plan is submitted:

to fulfil the requirements of Condition 6 of Ministerial Statement No. 913 – Protection of Tecticornia vegetation and inferred groundwater dependent vegetation located outside the groundwater drawdown area; and

as a component of the Public Environmental Review for the Extension to the Wiluna Uranium Project.

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Environmental outcomes No adverse impact to Tecticornia-dominated vegetation and inferred Groundwater Dependent Vegetation outside the 0.5 metres Relative Level groundwater drawdown contours associated with the Wiluna Uranium Project and the Extension to the Wiluna Uranium Project.

Trigger criteria Inferred Groundwater Dependent Vegetation

1. Stem Water Potential at potential-impact sites exceeding one standard deviation on control charts incorporating data from reference sites.

2. Leaf Water Potential at potential-impact sites exceeding one standard deviation on control charts incorporating data from reference sites (trees only).

3. Calculated Projected Foliar Cover at potential-impact sites exceeding one standard deviation on control charts incorporating data from reference sites (trees only).

Tecticornia-dominated Vegetation

1. Stem Water Potential at potential-impact sites exceeding one standard deviation on control charts incorporating data from reference sites.

Corporate Endorsement

This is a dynamic document that will be updated as new scientific and management information is obtained, particularly as a result of the implementation of the Tecticornia Survey and Research Plan and the Groundwater Dependent Vegetation Research Plan, and in accordance with the adaptive management commitments contained within. For each revision of this Flora and Vegetation Monitoring Plan (Table 2), the duly authorised proponent representative certifies that, to the best of their knowledge, the provisions contained within are true and correct and address the legal requirements of Condition 6 of Ministerial Statement No. 913.

Table 2: Revision History for this Plan

Revision Number

Release Date

Duly Authorised Proponent Representative

Name Position Signature

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2 CONTEXT, SCOPE AND RATIONALE

2.1 The Proposal

Toro Energy Limited (Toro) proposes to develop the Wiluna Uranium Mine (the Project), in the vicinity of Wiluna, Western Australia. Development of the Project will consist of the surface mining of four uranium deposits – Centipede, Lake Way, Millipede and Lake Maitland – and the construction and operation of associated infrastructure and an ore haul road.

The Centipede and Millipede deposits are located 30 km south of Wiluna, near the centre-west margin of the Lake Way playa. The Lake Way deposit is at the northern part of the Lake Way playa and is located 15 km south-east of Wiluna, whereas the Lake Maitland deposit is located approximately 105 km south-east of Wiluna. The operation of the Project will include mining, processing and transport of uranium oxide concentrate to the Western Australian border, prior to road or rail transport to South Australia or the Northern Territory for export.

Environmental approval for mining of the Centipede and Lake Way deposits and construction and operation of ancillary infrastructure – collectively referred to as the Wiluna Uranium Project – was granted in October 2012 by the Western Australian Minister for Environment, and in April 2013 by the Federal Minister for Sustainability, Environment, Water, Population and Communities. This approval was granted following a Public Environmental Review (EPA Assessment Number 1819 and EPBC Reference 2009/5174). Toro has not yet commenced mining of the Centipede or Lake Way deposits.

Toro currently seeks environmental approval for mining of the Millipede deposit, mining of the Lake Maitland deposit and construction and operation of ancillary infrastructure – collectively referred to as the Extension to the Wiluna Uranium Project. This approval is being sought by way of a Public Environmental Review (EPA Assessment Number 2002-CMS 14025 and EPBC Reference EPBC 2014/7138).

2.2 Key Environmental Factors

The Environmental Protection Authority (EPA) identified flora and vegetation as a key environmental factor relevant to the Project. At the time of assessment of the Project, the EPA’s environmental objectives for flora and vegetation were stated as:

For the Wiluna Uranium Project:

- To maintain the abundance, diversity, geographic distribution and productivity of flora at species and ecosystem levels through the avoidance or management of adverse impacts and improvement in knowledge; and

- To protect the environmental values of areas identified as having significant environmental attributes; and

For the Extension to the Wiluna Uranium Project:

- To maintain representation, diversity, viability and ecological function at the species, population and community level.

Clearing and dewatering activities associated with the proposal have the potential to affect flora and vegetation. In particular, Tecticornia-dominated communities and inferred Groundwater Dependent Vegetation (GDV) may be at risk from direct disturbance or groundwater drawdown. In the case of Tecticornia, several specimens collected in the Project area may represent new or novel species, and there is therefore concern that potential impacts of the Project may cause loss of unidentified

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species with very specific, but as yet unknown, habitat requirements based on hydrology, salinity and landform.

Following its assessment of the Wiluna Uranium Project, the EPA concluded that flora and vegetation had been adequately addressed and that the objectives for this key environmental factor could be achieved, provided Toro satisfied Conditions 6, 7 and 8 of Ministerial Statement No. 913. Conditions 7 and 8, i.e. Management of Groundwater Drawdown Impacts and Conservation and Improvement of the Knowledge of Tecticornia species, respectively, will be addressed by other plans in Toro’s Environmental Management System.

During its assessment of the Extension to the Wiluna Uranium Project, the EPA commented that the flora and vegetation monitoring component of the Environmental Management Plan should be consistent with the conditions of Ministerial Statement No. 913. As the assessment has not completed, no ministerial conditions specific to the Extension to the Wiluna Uranium Project exist as yet.

This document, the Vegetation and Flora Monitoring Plan (VFMP), is intended to apply to the Project—i.e. the Wiluna Uranium Mine—as a whole. This VFMP addresses Condition 6 of Ministerial Statement No. 913, relevant to the Wiluna Uranium Project, but also uses the requirements of this Condition as a basis for prescribing monitoring and management actions for the Extension to the Wiluna Uranium Project, as per the EPA’s comment. This VFMP will be implemented prior to ground-disturbing activities associated with the Project.

Importantly, this VFMP is a dynamic document. It will be updated as new scientific and management information is obtained, and in accordance with the adaptive management commitments contained within. In particular, three sets of critical updates are planned:

Following the completion of the assessment of the Extension to the Wiluna Uranium Project, this VFMP will be updated to reflect any new ministerial conditions related to the Project;

As the Tecticornia Survey and Research Plan is implemented, this VFMP will be updated to reflect improvements in ecological and management knowledge of Tecticornia; and

As the Groundwater Dependent Vegetation Research Plan is implemented, this VFMP will be updated to reflect improvements in ecological and management knowledge of inferred GDV.

2.3 Requirements of the Condition

Specifically, this VFMP is submitted in accordance with Ministerial Statement No. 913, Condition 6, for the Project – Protection of Tecticornia vegetation and inferred groundwater dependent vegetation located outside the groundwater drawdown (0.5 metres Relative Level; 0.5 mRL) area. The relationships between the requirements of this condition and the following sections of this VFMP are shown in Table 3.

Table 3: Requirements of Condition 6 of Ministerial Statement No. 913

Requirement Section in this VFMP

6-1 The proponent shall manage the proposal in a manner that ensures there is no adverse impact to Tecticornia-dominated vegetation and inferred groundwater dependent vegetation outside the 0.5 mRL groundwater drawdown contours as defined in Figure 21.

Section 3 defines the intended management approach to achieve the environmental outcome.

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6-2 Prior to ground-disturbing activities, unless otherwise approved by the Chief Executive Officer (CEO), the proponent shall prepare a Vegetation and Flora Monitoring Plan for approval by the CEO on the advice of the Department of Environment and Conservation. The Vegetation and Flora Monitoring Plan shall include:

identification of potential-impact monitoring and control sites;

design of a survey to acquire baseline biotic and environmental data;

definition of health and abundance parameters;

definition of critical correlative environmental parameters, including groundwater drawdown as detailed in Condition 7;

definition of monitoring frequency and timing;

identification of criteria to measure decline in health; and

definition of trigger levels and management responses required should a trigger level be exceeded.

This entire document constitutes the VFMP in response to this condition. Specific sections most relevant to this condition are Sections 3.3, 3.4 and 3.5.

6-3 Prior to ground-disturbing activities, unless otherwise approved by the CEO, the proponent shall implement the approved Vegetation and Flora Monitoring Plan required by Condition 6-2 and any approved revisions, until advised by the CEO that implementation of the Vegetation and Flora Monitoring Plan can cease.

Section 2.2 and Section 3 stipulate that this VFMP will be implemented prior to ground-disturbing activities associated with the Project.

6-4 Should results of monitoring from the implementation of the Vegetation and Flora Monitoring Plan required by Condition 6-2 indicate a decline in the plant health compared with the control sites, the proponent shall take immediate corrective actions to protect Tecticornia-dominated vegetation and groundwater dependent vegetation in response to monitoring results, and shall provide a report to the CEO within 21 days of the decline being identified, which:

1. describes the decline; 2. provides information which allows determination of the

likely cause of the decline; and 3. proposes actions and associated timelines to remediate

the decline in plant health compared with control sites.

Section 3.5 prescribes the Trigger Level Actions to be implemented in the event that a Trigger Criterion is met. One of the Trigger Level Actions is to initiate the reporting process required by this condition.

6-5 Should the decline in plant health compared with the control sites identified in Condition 6-2 be determined by the CEO to be caused by activities undertaken in implementing the proposal, the proponent shall implement the actions identified in Condition 6-4(3) until the CEO determines that the actions can cease.

Section 3.5 prescribes the Trigger Level Actions to be implemented in the event that a Trigger Criterion is met. One of the Trigger Level Actions is to implement the actions required by this condition.

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6-6 Prior to ground-disturbing activities, unless otherwise approved by the CEO, the proponent shall prepare a Groundwater Dependent Vegetation Research Plan for approval by the CEO on advice of the DPaW to investigate the environmental water requirements of groundwater dependent vegetation units potentially impacted by the proposal. The Groundwater Dependent Vegetation Research Plan shall include a monitoring plan.

Not addressed by this VFMP.

6-7 Prior to ground-disturbing activities, unless otherwise approved by the CEO, the proponent shall implement the approved Groundwater Dependent Vegetation Research Plan required by Condition 6-6 until otherwise advised by the CEO that implementation of the Groundwater Dependent Vegetation Research Plan can cease.


6-8 The proponent shall annually submit the results of monitoring required by Conditions 6-2 and 6-6, in the compliance assessment report required by Condition 4-6.

Section 4 prescribes the reporting requirements for the VFMP, in accordance with this condition.

6-9 The proponent shall take into account the findings of the Groundwater Dependent Vegetation Research Plan required by condition 6-6 when developing trigger values for Condition 7-1(1).


Note: 1. Figure 2 of Ministerial Statement No. 913, covering the Wiluna Mining Project, indicates the groundwater drawdown contours for the Centipede mining area, Lake Way mining area and West Creek borefield area. For the Extension to the Wiluna Mining Project, to which this VFMP also applies, groundwater drawdown contours are indicated in the Public Environmental Review documentation. 2. Now the Department of Parks and Wildlife (DPaW), and referenced as such throughout this VFMP.

2.4 Rationale for Meeting the Environmental Outcome

The results of baseline surveys, targeted surveys and other assessments (Section 2.4.1), as well as a number of assumptions and uncertainties (Section 2.4.2), have been used to inform the management approach for this VFMP (Section 3). The management approach for this VFMP includes Trigger Criteria, set at levels that will provide advance warning of a situation that may compromise the environmental outcomes sought by the Project (for rationale, see Section 3.4). Each trigger also has a corresponding management response, or Trigger Level Action, which will be implemented in the event a trigger level is exceeded (for rationale, see Section 3.5).

2.4.1 Results of Studies Conducted

Flora and vegetation studies, conducted for the Project since 2007, have included desktop reviews, baseline surveys, targeted flora surveys and peer reviews (e.g. Outback Ecology, 2009, Outback Ecology, 2007, ecologia, 2015a, ecologia, 2015d, Outback Ecology, 2009, Niche, 2011, Niche, 2014, ecologia, 2016b, ecologia, 2016a, ecologia, 2015b, Actis, 2012). The broad groups of vegetation found included playa vegetation, fringing vegetation, dune vegetation, plains vegetation, calcrete vegetation and claypan vegetation. Vegetation condition in the region is generally good, although mining and cattle grazing activities have impacted on vegetation communities.


A number of Tecticornia species have been identified in the Project area, both inside and outside the Project footprint, and may be impacted by development of the Project (Environmental Protection Authority, 2012). Some of these species are widespread, but a considerable number of specimens from field surveys could not be identified as known species within the existing knowledge of

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Tecticornia and are likely to represent some new or novel species (Shepherd, 2015). There is concern that these potentially new species could be of conservation significance, with very specific, but as yet unknown, habitat preferences based on hydrology, salinity and landform (Environmental Protection Authority, 2012).

Inferred Groundwater-dependent Vegetation

A number of vegetation units in the Project area have been inferred as being Groundwater Dependent Vegetation (GDV; Niche, 2014, Niche, 2011). For a brief discussion of the meaning of the term ‘inferred’ in this context, refer to Section 2.4.2.2.

Terrestrial GDV is typically encountered as part of a groundwater dependent ecosystem, dependent on surface expressions of groundwater or on subsurface groundwater (Eamus et al., 2006). The inferred GDV in the Project area would fall into the latter group. Given this dependency, dewatering activities associated with the Project have the potential to impact inferred GDV.

Inferred GDV is located within the boundaries of the Centipede, Millipede and Lake Way deposits, and within the boundaries of the West Creek borefield (Table 4). Original determinations of inferred GDV in the Project Area also included some vegetation units characterised by the presence of Tecticornia (Table 5); this VFMP therefore addresses their management under the broader Tecticornia-dominated vegetation category (Section 2.4.1.1, and see also Section 2.4.2.1), and they are not considered in the management approach for inferred GDV.

Table 4: Vegetation Units Considered to be Inferred GDV

Vegetation Unit1 Location Inferred Groundwater Preference2

Clay Plains Eucalyptus camaldulensis Open Woodland over Acacia spp.

West Creek Borefield Brackish

Clay Plains Melaleuca interioris Low Forest B


Claypan Frankenia spp. Dwarf Scrub Lake Way Saline

Creekline E. camaldulensis Woodland West Creek Borefield Brackish

Drainage line E. camaldulensis Woodland


Fringing M. xerophila Forest Centipede, Millipede, Lake Way Brackish

Salt lake Frankenia spp. Dwarf Scrub Lake Way Saline

Notes: 1. As per Niche (2014, 2011) 2. As per RPS Aquaterra (2010a, 2010b)

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Table 5: Inferred GDV Containing Tecticornia and Managed as Tecticornia-dominated Vegetation under this VFMP

Vegetation Unit Location Inferred Groundwater Preference2

Claypan Tecticornia spp. Heath and Dwarf Scrub

Millipede, Lake Way Saline

Salt lake Tecticornia spp. Heath and Dwarf Scrub

Centipede, Millipede, Lake Way, Lake Maitland

Saline

Notes: 1. As per Niche (2014, 2011) 2. As per RPS Aquaterra (2010a, 2010b)

2.4.2 Key Assumptions and Uncertainties


Surveys across Millipede and Lake Maitland, in mining and non-mining areas, were conducted in order to further define Tecticornia communities and identify any species of conservation significance (ecologia, 2015c, ecologia, 2015d). Sixteen Tecticornia-dominated communities were identified, with some degree of similarity among the communities found across each lake system, and most taxa recorded during the surveys were abundant. Subsequent identifications of the Tecticornia specimens collected, however, identified uncertainties regarding their taxonomy and therefore questioned the overall delineation of Tecticornia-dominated communities in the Project area (Shepherd, 2015).

The uncertainty surrounding survey results for Tecticornia-dominated vegetation in the Project area means that the most precautionary approach for managing Tecticornia-dominated communities in the Project area is to treat them as a single group (ecologia, 2016b). This version of the VFMP reflects this, prescribing only general monitoring locations, monitoring methods and management actions. Following the implementation of the Tecticornia Survey and Research Plan, a higher degree of resolution of Tecticornia-dominated vegetation communities is expected, and it will be possible to update this VFMP with more specific management information.

In particular, the implementation of the Tecticornia Survey and Research Plan is planned to identify optimal monitoring methods for direct incorporation into this VFMP. As noted by the EPA, measuring plant health is challenging for salt lake communities. Tecticornia and other salt lake species are adapted to extreme conditions, and traditional measures of plant and vegetation health, such as leaf area index, are not appropriate for plants with such reduced morphology and sparse vegetation. Additionally, the adaptation of these species to extreme conditions means that they may be resilient to impacts for some time, and decline in health may not have a linear relationship with the degree of impact.

Monitoring of Tecticornia-dominated communities must take into account that a decline in plant health can be caused by a combination of factors, and isolating the causal factors influencing plant health requires the establishment of multiple analogous, i.e. control, monitoring sites. To adequately address this requirement, this VFMP provisions for consultation with appropriate experts when identifying specific monitoring locations and protocols in future revisions (Section 6).

Inferred Groundwater-dependent Vegetation

Although botanical assessments in the Project area identified the presence of vegetation that has potential to be groundwater dependent (Niche, 2014, Niche, 2011), no direct assessment was conducted to develop an understanding of the environmental water requirements of these

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vegetation units or their degree of dependency on groundwater. They are therefore ‘inferred’ to be GDV, based on criteria defined by Eamus et al. (2006):

The groundwater or capillary fringe above the water table is likely to be within the rooting depth of any of the vegetation;

A proportion of the vegetation remains green and is likely to be physiologically active during extended dry periods;

The vegetation associated with the subsurface groundwater is different, in terms of species composition and phenology, to the surrounding vegetation; and

The annual use of water by vegetation is considered to be significantly greater than the annual rainfall.

The most precautionary approach for managing inferred GDV in the Project area is to proceed with monitoring these vegetation units in a manner consistent with monitoring for known GVD. This version of the VFMP reflects this, prescribing only general monitoring locations, monitoring methods and management actions. Following the implementation of the Groundwater Dependent Vegetation Research Plan, a better understanding of the environmental water requirements of inferred GDV units is expected, and it will be possible to update the VFMP with more specific management information.

As with Tecticornia-dominated communities, monitoring of inferred GDV must take into account that a decline in plant health can be caused by a combination of factors. For inferred GDV, for example, groundwater drawdown may potentially exacerbate the impacts of drought. In addition, different monitoring techniques will be required for claypan vegetation units, i.e. with low, sparse and reduced foliage, compared to other vegetation units that are dominated by trees or medium shrubs. Monitoring times may also differ between these vegetation communities, to detect changes in vegetation health due to the impacts of the proposal.

As with Tecticornia-dominated communities, and isolating the causal factors influencing plant health in inferred GDV requires the establishment of multiple analogous, i.e. control, monitoring sites. To adequately address this requirement, and to address the uncertainties associated with effective monitoring of claypan vegetation units described in the preceding paragraph, this VFMP provisions for consultation with appropriate experts when identifying specific monitoring locations and protocols in future revisions (Section 6).

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3 MANAGEMENT APPROACH

In accordance with Condition 6 of Ministerial Statement No. 913, this VFMP prescribes an ongoing monitoring programme for Tecticornia-dominated vegetation and inferred GDV in the Project area. As discussed previously, this VFMP is a live document and will be updated as new information becomes available; accordingly, the design of the monitoring programme is indicative at present, but will be finalised in future revisions of this VFMP. Updates to the monitoring programme will be informed by the implementation of the Tecticornia Survey and Research Plan and Groundwater Dependent Vegetation Research Plan, and future revisions of this VFMP will be submitted to the EPA for approval prior to ground-disturbing activities.

3.1 Identification of Monitoring Sites

The monitoring programme will use a Before-After-Control-Impact (BACI) design to determine the locations of monitoring sites. A combination of potential-impact monitoring and control monitoring sites will be chosen for each vegetation unit; in the case of Tecticornia-dominated communities, these vegetation units will be refined via the Tecticornia Survey and Research Plan. The number and location of sites will be finalised in consultation with relevant stakeholders (Section 6), and will be informed by the implementation of the Tecticornia Survey and Research Plan and the Groundwater Dependent Vegetation Research Plan. The number and location of monitoring sites will reflect:

Stratification between potential-impact and control areas for each major area associated with the Project;

Identification of inferred GDV communities inside and outside the 0.5 mRL groundwater drawdown areas;

Identification of Tecticornia-dominated communities inside and outside the 0.5 mRL groundwater drawdown areas;

Proximity to existing groundwater bores; and

Practical constraints such as road access, future accessibility, proposed clearing areas and safety.

3.2 Timing and Frequency of Baseline Survey and Ongoing Monitoring

Following the identification of monitoring sites, an initial survey will be conducted in order to acquire baseline biotic and environmental data. In accordance with BACI design principles, this will take place prior to ground-disturbing activities. Ideally, but depending on feasibility, additional baseline surveys will be conducted prior to ground-disturbance in order to obtain an extended baseline dataset. Subsequent to this baseline survey, monitoring will be repeated on an annual basis. The baseline and subsequent monitoring surveys will nominally be scheduled to occur in May, but timing may be adjusted depending on rainfall.

In addition to the scheduled surveys, ad hoc surveys may be performed following significant rainfall events. Monitoring inferred GDV communities as soon as they are accessible following significant rainfall is desirable because, as noted by the EPA, their degree of recovery after drought conditions may be a key measure of whether impacts due to groundwater drawdown are occurring (whereas other vegetation units would not necessarily be as reactive to rainfall).

The timing and frequency of monitoring will be finalised in consultation with relevant stakeholders (Section 6). Although the incorporation of additional rainfall-dependent surveys into the monitoring programme will be considered, the lack of rainfall reliability in the Project area means that the core monitoring commitment will consist of the annual monitoring as described above.

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3.3 Monitoring Methods

3.3.1 Management Groups for Inferred GDV and Tecticornia-dominated Communities

For the purposes of documenting the management approach in this VFMP, inferred GDV and Tecticornia-dominated vegetation communities have been categorised into three management groups. These are:

Group 1, comprising units of inferred GDV dominated by trees and medium shrubs:

- Clay Plains Eucalyptus camaldulensis Open Woodland over Acacia spp.; - Clay Plains Melaleuca interioris Low Forest B; - Creekline E. camaldulensis Woodland; - Drainage Line E. camaldulensis Woodland; and - Fringing M. xerophila Forest;

Group 2, comprising units of low, shrubby inferred GDV on claypans and salt lakes:

- Claypan Frankenia spp. Dwarf Scrub; and - Salt lake Frankenia spp. Dwarf Scrub; and

Group 3, comprising all Tecticornia-dominated communities, which will be further refined as a result of the implementation of the Tecticornia Survey and Research Plan.

3.3.2 Management Group 1 Monitoring Methods

Each monitoring site will consist of a permanent, 2500 m2 quadrat containing permanent sample trees. Ten sample trees per quadrat will be selected randomly – either E. camaldulensis, M. interioris or M. xerophila, according to vegetation unit – and marked with a metal tag and fence dropper. Quadrats will be positioned to provide good spatial representation of the potential impact area, where significant stands of inferred GDV exist; however, at locations where there are too few trees in the permanent quadrats, trees adjacent to the quadrats will be selected.

Each sample tree will be subjected to a range of qualitative and quantitative assessments, including a visual health assessment, plant characterisation, projected foliar cover (PFC) and leaf and stem water potentials (LWP and SWP; Table 6). In addition, for each annual monitoring period, data for critical correlative parameters will be collected from authoritative sources (Table 6). These data will be included in analyses and reporting.

Optionally, a Landscape Function Analysis (LFA) assessment may be completed at each monitoring site. The LFA method is used to describe landscape type, characterise landscape organisation and assess soil surface condition (Tongway and Hindley, 2004). This method derives a number of indices for site stability, infiltration and nutrient cycling, from data in the aforementioned three categories, to assess how well an ecosystem functions from a biophysical perspective. Sites are characterised according to their topographic location, soils, slope, vegetation type, land use and state of the soil surface.

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Table 6: Group 1 Monitoring Methods

Method Type Method Description and Definitions Summary of Variables and Units

Plant characterisation

Tree height, diameter at breast height over bark (DBHOB) and age class will be determined for each sample tree. This method will allow the size of each sample tree to be compared temporally and provide quantitative measures to complement visual assessment measures.

Per quadrat, for each of ten sample trees

Tree height (m)

DBHOB – 130 cm above ground (cm)

Age class (UNITS)

Visual health assessment

Sample trees will be visually assessed based on a conceptual model of the symptoms of decline due to water stress and indicators of recovery as conditions improve (Souter et al., 2010). The assessment will incorporate the following:

crown extent and density;

epicormic growth, new tip growth, reproduction, leaf die-off and presence of mistletoe; and

bark condition.

Crown extent and density scores are based on a scale from 0 to 7, which corresponds to both descriptive and percentage divisions. A rating of 0 corresponds to a tree with no leaves and a rating of 7 corresponds to a tree where the canopy is completely foliated and the foliage is at maximum density. A score of 4 represents a tree with medium canopy foliation and medium foliage density.

Epicormic growth, new tip growth, reproduction, leaf die-off and mistletoe presence are all scored based on a scale from 0 to 3. A rating of 0 corresponds to the effect being absent and a rating of 3 corresponds to the effect being abundant. All variables are scored on the visibility of the effect throughout the assessable crown.

Bark condition is assessed on the main stem(s) and lower branches, on a scale from 0 to 4. A rating of 0 corresponds to a tree with intact bark, ratings of 1, 2 and 3 correspond to the extent of bark cracks (i.e. minor, moderate and extensive) and a rating of 4 corresponds to no bark (e.g. a long-term dead tree).


Crown extent (0-7 scale)

Crown density (0-7 scale)

Epicormic growth (0-3 scale)

New tip growth (0-3 scale)

Reproduction (0-3 scale)

Leaf die-off (0-3 scale)

Mistletoe presence (0-3 scale)

Bark condition (0-4 scale)

LWP and SWP LWP and SWP measurements will be taken using a pressure chamber instrument. Measurement of LWP and SWP is a scientifically robust method for providing an in situ indication of plant water status (O'Grady et al., 2002, Turner, 1988); however, careful interpretation of results is necessary due to the potential for disequilibrium to occur between pre-dawn leaf and soil water potentials in some situations.

Per quadrat, for each of five sample trees

LWP (Bar; two replicates) *

SWP (Bar; two replicates) *

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At each monitoring site, two excised shoots (two to ten leaves) will be sampled from the mid-canopy of five of the ten permanent sample trees one to two hours before dawn. Shoots will be immediately sealed in an airtight plastic bag and kept chilled in an icebox until their water potentials can be measured with a pressure chamber instrument (e.g. Model 1505D or 1000, PMS Instrument Company).

PFC PFC will be determined for individual trees and across transects. PFC is related to canopy density, which is often related to plant stress (as the shedding of the leaf canopy is one of the first physiological responses to water stress; Souter et al., 2010).

For assessing the PFC within the canopy of individual trees at each monitoring site, permanent photo monitoring points will be installed underneath the ten permanent sample trees and marked with a star picket. When monitoring each point, a 12 megapixel digital camera will be locked onto a tripod with the camera looking skywards. A surface level, or bubble level, will be used to ensure the camera image sensor is horizontal.

Images will be analysed to estimate a PFC following MacFarlane et al. (2007b, 2007a). Following two or more monitoring events, the data obtained from the images will be used to identify temporal changes in PFC.

PFC will also be visually estimated by the assessor. This will allow additional validation of the PFC data calculated from the images, and will result in observations useful in interpreting any temporal changes in PFC.


Calculated PFC (%) *

Estimated PFC (%)

Critical correlative environmental parameters

For each monitoring site, data for critical correlative environmental parameters will be obtained for the monitoring period. Critical correlative environmental parameters are considered to be:

total rainfall since last monitoring (Bureau of Meteorology);

groundwater conductivity (at nearest monitoring bore; Toro); and

groundwater level (at nearest monitoring bore; Toro).

For whole Project area

Rainfall (mm)

Per quadrat

Groundwater conductivity (µS/cm)

Groundwater level (mBGL)

Note: * Designated trigger criterion under this VFMP

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Each monitoring site will consist of a permanent, 200 m2 quadrat containing permanent sample plants of inferred GDV-species. Ten sample plants per quadrat will be selected randomly – e.g. Frankenia spp. – and marked with a metal tag and fence dropper. Quadrats will be positioned to provide good spatial representation of the potential impact area, where significant groups of inferred GDV exist. In addition to a permanent quadrat, each monitoring site will consist of five 20 m-long replicate line-intercept transects.

Cover of inferred GDV will be assessed for each quadrat and intercept transect, and each sample plant will be subjected to a plant health assessment and measurement of SWP (Table 7). In addition, for each annual monitoring period, data for critical correlative parameters will be collected from authoritative sources (Table 7). These data will be included in analyses and reporting.

Optionally, LFA assessments may be conducted at each monitoring site. For additional information on LFA, refer to Section 3.3.2.



Cover The percentage cover of inferred GDV within the quadrat will be visually estimated. Along each line-intercept transect the start and end point of each intercepting individual of inferred GDV will be recorded, as well as its height.

Per quadrat

Cover of inferred GDV species (%)

For each of five line-intersect transects

Length of intercept with each individual of inferred GDV (cm)

Height of each intersecting individual of inferred GDV (cm)

Plant health assessment

For each sample plant, a permanent photo point will be installed and marked with a star picket. A 12 megapixel digital camera will be used to take a side-on photograph of the plant. From each photograph, the health of each plant will be assessed visually based on the percentage of branches with tip browning (e.g. as per Fortescue, 2013, Astron, 2011).

A health score of 1 to 3 will be assigned as a result of the assessment. A score of 1 corresponds with a plant in poor health, with 75-100% browning, a score of 2 corresponds with a plant in moderate health, with 25-75% browning, and a score of 3 corresponds with a plant in good health, with 0-25% browning.

Per quadrat, for each of ten sample plants

Tip browning extent (1-3 scale)

SWP SWP measurements will be taken using a pressure chamber instrument. Measurement of SWP is a scientifically robust method for providing an in situ indication of plant water status (O'Grady et al., 2002, Turner, 1988); however, careful interpretation of results is necessary due to the

Per quadrat, for each of five sample plants


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potential for disequilibrium to occur between pre-dawn stem and soil water potentials in some situations.

At each monitoring site, two excised shoots (two to ten leaves) will be sampled from five of the ten permanent sample plants one to two hours before dawn. Shoots will be immediately sealed in an airtight plastic bag and kept chilled in an icebox until their water potentials can be measured with a pressure chamber instrument (e.g. Model 1505D or 1000, PMS Instrument Company).







Rainfall (mm)

Per quadrat





Each monitoring site will consist of a permanent, 200 m2 quadrat containing permanent Tecticornia spp. sample plants. Ten Tecticornia spp. sample plants per quadrat will be selected randomly and marked with a metal tag and fence dropper. Quadrats will be positioned to provide good spatial representation of the potential impact area, where significant groups of Tecticornia spp. exist. In addition to a permanent quadrat, each monitoring site will consist of five 20 m-long replicate line-intercept transects.

Cover of Tecticornia spp. will be assessed for each quadrat and intercept transect, and each sample plant will be subjected to a plant health assessment and measurement of SWP (Table 8). In addition, for each annual monitoring period, data for critical correlative parameters will be collected from authoritative sources (Table 8). These data will be included in analyses and reporting.

Optionally, LFA assessments may be conducted at each monitoring site. For additional information on LFA, refer to Section 3.3.2.

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Cover The percentage cover of Tecticornia spp. within the quadrat will be visually estimated. Along each line-intercept transect the start and end point of each intercepting individual of Tecticornia spp. will be recorded, as well as its height.

Per quadrat

Cover of inferred GDV species (%)

For each of five line-intersect transects

Length of intercept with each individual of inferred GDV (cm)

Height of each intersecting individual of inferred GDV (cm)

Plant health assessment

For each sample plant, a permanent photo point will be installed and marked with a star picket. A 12 megapixel digital camera will be used to take a side-on photograph of the plant. From each photograph, the health of each plant will be assessed visually based on the percentage of branches with tip browning (e.g. as per Fortescue, 2013, Astron, 2011).

A health score of 1 to 3 will be assigned as a result of the assessment. A score of 1 corresponds with a plant in poor health, with 75-100% browning, a score of 2 corresponds with a plant in moderate health, with 25-75% browning, and a score of 3 corresponds with a plant in good health, with 0-25% browning.

Per quadrat, for each of ten sample plants

Tip browning extent (1-3 scale)

SWP SWP measurements will be taken using a pressure chamber instrument. Measurement of SWP is a scientifically robust method for providing an in situ indication of plant water status (O'Grady et al., 2002, Turner, 1988); however, careful interpretation of results is necessary due to the potential for disequilibrium to occur between pre-dawn stem and soil water potentials in some situations.

At each monitoring site, two excised shoots (two to ten leaves) will be sampled from five of the ten permanent sample plants one to two hours before dawn. Shoots will be immediately sealed in an airtight plastic bag and kept chilled in an icebox until their water potentials can be measured with a pressure chamber instrument (e.g. Model 1505D or 1000, PMS Instrument Company).

Per quadrat, for each of five sample plants






Rainfall (mm)

Per quadrat



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3.4 Trigger Criteria and Rationale

Trigger Criteria designated in this VFMP have been chosen to reflect the expected responses of inferred GDV and Tecticornia-dominated vegetation to impacts of groundwater drawdown, based on basic principles of plant ecophysiology and ecohydrology (Table 9). It is expected that further stakeholder consultation (Section 6), the implementation of the Tecticornia Survey and Research Plan and the implementation of the Groundwater Dependent Vegetation Research Plan will yield additional information; potentially, this may warrant changes to these trigger criteria or their associated levels.

Levels associated with Trigger Criteria in this VFMP have been chosen based on the application of control charts to identify trends in monitoring data that may indicate changes taking place within potential-impact sites in comparison to control sites (Morrison, 2008, Anderson and Thompson, 2004). Control charts contain a centre line value (which represents the mean value), an upper control limit and a lower control limit (Morrison, 2008). In the absence of significant impacts, parameters are expected to fall within the control limits.

The application of control charts is becoming a common method for interpreting trends in environmental monitoring data, particularly when triggers for management responses are required. Control charts can incorporate univariate or multivariate data, are relatively easy to interpret and can be updated as additional data become available (Morrison, 2008).

Table 9: Trigger Criteria for this VFMP

Trigger Criterion Rationale Trigger Level

LWP (Group 1) Measurement of LWP is a scientifically robust method for providing an in situ indication of plant water status (O'Grady et al., 2002, Turner, 1988).

Management response as per Table 10 is required in the event of sample trees at potential-impact sites exceeding one standard deviation in LWP (where control charts also incorporate data from control monitoring sites).

Calculated PFC (Group 1)

PFC is related to canopy density, which is often related to plant stress (as the shedding of the leaf canopy is one of the first physiological responses to water stress; Souter et al., 2010).

Management response as per Table 10 is required in the event of sample trees at potential-impact sites exceeding one standard deviation in calculated PFC (where control charts also incorporate data from control monitoring sites).

SWP (Groups 1, 2 and 3)

Measurement of SWP is a scientifically robust method for providing an in situ indication of plant water status (O'Grady et al., 2002, Turner, 1988).

Management response as per Table 10 is required in the event of exceedance of sample trees (Group 1) or sample plants (Groups 2 and 3) at potential-impact sites exceeding one standard deviation in in SWP (where control charts also incorporate data from control monitoring sites).

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3.5 Trigger Level Actions and Rationale

Trigger Level Actions designated in this version of the VFMP have been chosen to reflect the requirements of Ministerial Statement No. 913, Condition 6 (Table 10). It is important to note that there are limited data regarding the ecophysiology and ecohydrology of inferred GDV and Tecticornia-dominated communities in the Project Area, and this represents a limitation for the assignment of appropriate Trigger Level Actions at present.

The implementation of the Tecticornia Survey and Research Plan and the Groundwater Dependent Vegetation Research Plan will address knowledge gaps in these areas, and are therefore expected to result in new information relevant to the choice of Trigger Level Actions. Further, the assessment of the Extension to the Wiluna Uranium Project is not yet complete, and may have a bearing on the conditions of the Project (and therefore the provisions of this VFMP). Accordingly, Trigger Level Actions will be reviewed and updated, if necessary, based on the outcomes of these processes.

Table 10: Trigger Level Actions for this VFMP

Trigger Criterion Trigger Level Action

LWP (Group 1 only) 1. Immediately, review vegetation monitoring data to confirm that the Trigger Criterion has been met.

2. If (1) confirms that the Trigger Criterion has been met, immediately review critical correlative environmental parameter monitoring data to assess possible causes of the vegetation change confirmed in (1).

3. Within 21 days of confirmation of the Trigger Criterion being met – i.e. the outcome of (1) – provision to the CEO of an assessment report. This will document the outcomes of (1) and (2), and will:

describe the decline in detail;

provide information allowing determination of the likely cause of the decline, including identification of assumptions and data gaps; and

if the decline is identified as likely to be the result of Project-related impacts, propose actions and associated timelines to remediate the decline in plant health compared with control sites.

4. Following direction from the CEO, implement any required actions based on (3) until the CEO determines that the actions can cease.

Calculated PFC (Group 1 only)

SWP (Groups 1, 2 and 3)

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4 REPORTING PROVISIONS

4.1 Annual Reporting

The environmental outcome will be reported, against Trigger Criteria Levels (Table 9), for the 12-month period preceding each monitoring annual survey by 30 June each year in an annual report. In the event that trigger criteria were exceeded during the reporting period, the annual report will include a description of the effectiveness of Trigger Level Actions that have been implemented, in addition to the standard analysis of trends. The annual reporting requirement is in addition to any reporting required for exceedance of Trigger Levels (Section 4.2).

4.2 Reporting on Exceedance of Trigger Criteria

In the event of exceedance of any Trigger Level Criterion, Toro will notify the EPA in writing within 21 days. This process is detailed as Trigger Level Action 3 (Table 10).

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5 ADAPTIVE MANAGEMENT AND REVIEW OF THE VFMP

Each annual report will provide information on the current status of inferred GDV and Tecticornia-dominated communities in relation to the Project and, in doing so, may identify knowledge gaps or deficiencies that reduce the effectiveness of the VFMP. In these cases, each annual report will document recommendations, if any, for improvement of the VFMP, its management approach and its Trigger Criteria, Levels and Actions. If recommendations are developed, it will trigger review of the VFMP in light of the recommendations and allow for issue of an updated version of the VFMP in consultation with relevant stakeholders (Section 6).

In particular, this adaptive management process will be responsive to the outcomes of the implementation of the Tecticornia Survey and Research Plan and the Groundwater Dependent Vegetation Research Plan. Other information that may support the review of this VFMP may be gained as a result of:

Implementation of the Groundwater Drawdown Monitoring and Management Plan for the Project;

General improvement in knowledge and understanding of ecophysiology and ecohydrology of groundwater dependent vegetation in Western Australia;

Changes to the nature of activities associated with the Project; and/or

Responses to Trigger Level Actions not having the desired or anticipated outcomes.

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6 STAKEHOLDER CONSULTATION

Consistent with the EPA’s expectations for this VFMP to align with the principles of environmental impact assessment, Toro intends to consult with relevant stakeholders in the process of further developing this VFMP. This will occur prior to the VFMP being submitted to the EPA for final approval, which in turn will occur prior to ground-disturbing activities for the Project (in accordance with Condition 6 of Ministerial Statement No. 913.

This section provides a summary of consultation that is intended to occur (Table 11). Comments and feedback obtained during the consultation process will be addressed in subsequent revisions of this VFMP. In the case of significant comments, each revision of the VFMP will contain a summary of the comments and how they have been addressed.

Table 11: Stakeholders to be Consulted

Person Affiliation

Bindy Datson Actis Environmental

Tim Colmer University of Western Australia

Kelly Shepherd Department of Parks and Wildlife

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7 REFERENCES

ACTIS 2012. Tecticornia review: Wiluna uranium project. Unpublished report for Toro Energy Limited.

ANDERSON, M. J. & THOMPSON, A. A. 2004. Multivariate control charts for ecological and environmental monitoring. Ecological Applications, 14, 1921-1935.

ASTRON 2011. Christmas Creek Vegetation Health Monitoring and Management Program Baseline Report. Unpublished report prepaered by Astron Environmental Servi ces for Fortescue Metals Group Ltd.

EAMUS, D., HATTON, T., COOK, P. & COLVIN, C. 2006. Ecohydrology: Vegetation Function, Water and Resource Management, Clayton, Australia, CSIRO Publishing.

ECOLOGIA 2015a. Assessment of Tecticornia associated with Lake Way and Lake Maitland. Report by ecologia Environment for Toro Energy Limited.

ECOLOGIA 2015b. Extension to the Wiluna Uranium Project Flora and Vegetation Consolidation and Conservation Assessment. Unpublished report for Toro Energy Limited.

ECOLOGIA 2015c. Extension to the Wiluna Uranium Project Vegetation Mapping Conolidation and Conservation Assessment. Unpublished report for Toro Energy Limited.

ECOLOGIA 2015d. Millipede to Lake Maitland Haul Road Level 2 flora and vegetation assessment. Report by ecologia Environment for Toro Energy Limited.

ECOLOGIA 2016a. Extension to the Wiluna Uranium Project Response to EPA Submissions Tecticornia Groundwater Dependency. Unpublished report for Toro Energy Limited.

ECOLOGIA 2016b. Extension to the Wiluna Uranium Project: Cumulative Impact Assessment. Unpublished report prepared for Toro Energy Limited.

ENVIRONMENTAL PROTECTION AUTHORITY 2012. Report and recommendations of the Environmental Protection Authority on the Wiluna Uranium Project, Toro Energy Limited.

FORTESCUE 2013. Vegetation Health Monitoring and Management Plan - Cloudbreak Life of Mine Expansion Project (CB-PL-EN-0019). Fortescue Metals Group Limited.

MACFARLANE, C., ARNDT, S. K., LIVESLEY, S. J., EDGAR, A. C., WHITE, D. A., ADAMS, M. A. & EAMUS, D. 2007a. Estimation of leaf area index in eucalypt forest with vertical foliage, using cover and fullframe fisheye photography. Forest Ecology and Management, 242, 756–763.

MACFARLANE, C., HOFFMAN, M., EAMUS, D., KERP, N., HIGGINSON, S., MCMURTIE, R. & ADAMS, M. A. 2007b. Estimation of leaf area index in eucalypt forest using digital photography. Agricultural and Forest Meteorology, 143, 176–188.

MORRISON, L. W. 2008. The use of control charts to interpret environmental monitoring data. Natural Areas Journal, 28, 66-73.

NICHE 2011. Assessment of the Flora and Vegetation at the Toro Energy Wiluna Uranium Project: Lake Way, Centipede and West Creek Borefield. Unpublished report for Toro Energy Limited.: Niche Environmental Services.

NICHE 2014. Assessment of the Flora and Vegetation at the Toro Energy Wiluna Uranium Project: Millipede Project Area, unpublished report by Niche Environmental Services for Toro Energy Ltd. Niche Environmental Services.

O'GRADY, A., EAMUS, D., COOK, P., LAMONTAGNE, S., KELLEY, G. & HUTLEY, L. 2002. Tree Water Use and Sources of Transpired Water in Riparian Vegetation along the Daly River, Northern Territory. Report to Environment Australia as part of the Healthy Rivers Program.

OUTBACK ECOLOGY 2007. Lake Way and Centipede Baseline Vegetation and Flora Survey, Unpublished report for Toro Energy Ltd.: Outback Ecological Services.

OUTBACK ECOLOGY 2009. Lake Maitland: Baseline Vegetation and Flora Surveys - May and November 2007 and May 2009, Unpublished report for Mega Uranium Ltd. Outback Ecological Services.

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OUTBACK ECOLOGY 2009. Lake Maitland Baseline Vegetation and Flora Surveys - May and November 2007 and May 2009. Unpublished report for Mega Uranium Ltd.

RPS AQUATERRA 2010a. Lake Way Groundwater Impact Assessment. Unpublished report prepared for Toro Energy Limited.

RPS AQUATERRA 2010b. West Creek Water Supply Groundwater Modelling. Unpublished report (1134/C/104a) prepared for Toro Energy Limited.

SHEPHERD, K. A. 2015. Identification of Tecticornia voucher specimens for Toro Energy Ltd. Report on identifications of Tecticornia specimens collected by ecologia/Engenium for Toro Energy Ltd. 9 June 2015.

SOUTER, N. J., CUNNINGHAM, S., LITTLE, S., WALLACE, T., MCCARTHY, B. & HENDERSON, M. 2010. Evaluation of a visual assessment method for tree condition of eucalypt floodplain forests. Ecological Management & Restoration, 11, 210-214.

TONGWAY, D. J. & HINDLEY, N. L. 2004. Lanscape Function Analysis: Procedures for Moinitoring and Assessing Landscapes with Special Reference to Minesites and Rangelands. Canberra ACT: CSIRO Sustainable Ecosystems.

TURNER, N. C. 1988. Measurement of plant water status by the pressure chamber technique. Irrigation Science, 9, 289-308.

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