appendix a submissions register - metro mining...fly in fly out (fifo). in the eis teleconference...
TRANSCRIPT
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1
Appendix A – Submissions Register
This submissions register identifies the submitter number, the submission reference number, the
relevant section of the EIS that the issue relates to, if applicable, details of the issue and Metro
Mining’s response or cross-reference location to the response within the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
2
Submissions Register
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
1 1.1 Sport and Recreation Services has no concerns with this
project. Noted. No further response to this comment is required.
2 2.1 18 The EIS addresses HICB concerns that were identified in our
comments on the TOR for the EIS. Noted. No further response to this comment is required.
2 2.2 18
The EIS (in section 18) provides detailed information about
the hazardous chemicals and associated risk and risk
controls to be employed on/at the project.
Noted. No further response to this comment is required.
2 2.3 18 Risk associated with natural hazards and hazardous
chemicals are comprehensively addressed. Noted. No further response to this comment is required.
2 2.4 18 Emergency planning has been addressed. Noted. No further response to this comment is required.
2 2.5 18 Off-site risk and impacts on sensitive receptors (from a land
use safety planning perspective) have been addressed. Noted. No further response to this comment is required.
2 2.6 18
Due to the quantities of hazardous chemicals that will be
required to be kept at the project site, a Form 73 (Manifest
Quantity Workplace Notification) to Work Health and
safety Queensland will be required once keeping of the
hazardous chemicals commences.
Noted. Metro Mining notes the need to submit / keep Form 73
(Manifest Quantity Workplace Notification) onsite once the keeping
of hazardous chemicals commences.
2 2.7
HICB would like to thank the proponent for providing clear
and detailed information within the EIS. From our
perspective the information was easy to locate and review.
This EIS is one of the best presented that HICB has
reviewed.
Noted. No further response to this comment is required.
3 3.1
CYSF SUPPORTS the Bauxite Hills Project proposed by
Metro Mining Limited which is currently the subject of
Environmental Impact Statement Public Consultation.
Noted. No further response to this comment is required.
4 4.1
On the basis of my own knowledge and the facts I have
before me, I wholeheartedly support Metro Mining and its
Bauxite Hills Project and wish the company well in its
endeavours.
Noted. No further response to this comment is required.
5 5.1
I am pleased to support Metro Mining and its Bauxite Hills
Project, which offers substantial opportunities and benefits
to the Cook electorate and far North Queensland.
Noted. No further response to this comment is required.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
3
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
6 6.1
The Environmental Impact Statement (EIS) document is
predominately focused on environmental impact and
management, with no detailed comment outlining
strategies in place to manage an incident involving workers
with acute and possibly time critical medical conditions.
Refer to Section 18.2 of the Supplementary Report.
6 6.2
Due to the remote location of the Bauxite Hills Project, the
EIS document states that access to the project will be 100%
Fly in Fly out (FiFo). In the EIS teleconference attended on
31 May 2016, information presented to the attendees was
that no road access was available from the PDR to the
project site, which limits the option of a road response to
an incident, limiting a response to either rotary or fixed
wing aircraft.
Refer to Section 18.2 of the Supplementary Report.
6 6.3 2.7.8.2 and
18.8.3.4
The EIS document (2.7.8.2 and 18.8.3.4) refers to the
Bauxite Hills Project as developing an 'Emergency Response
Plan'. The QAS requests that a copy of this document be
provided to the QAS so that the access strategies and on-
site medical capacity of the project can be reviewed.
Refer to Section 18.2 of the Supplementary Report.
6 6.4
The QAS would like to be formally notified and engaged
regarding the actions proposed by the Department of
Environment and Heritage Protection to mitigate the risks
identified by the QAS. Contact officers to be notified are Mr
Warren Martin, Executive Manager, Torres and Cape Local
Ambulance Service Network on email
[email protected] or telephone 4032
8627 and Ms Rachael Harmston, Town Planner,
Infrastructure and Procurement Branch on email
[email protected] or telephone
3635 3887.
This comment appears to be requesting direct action from EHP to
notify and engage with QAS regarding their proposed actions. As
such, Metro Mining is not able to respond on EHP’s behalf.
However, as noted in Section 18.2 of the Supplementary Report,
Metro Mining will formally notify and engage QAS regarding the
development of the ERP (as discussed in Section 18.8.3.4 of the EIS).
Given the commitment by Metro Mining to consult with QAS no
update to the information included in the EIS is proposed.
7 7.1 The Cairns Chamber of Commerce has pleasure in offering
its support to this very important project. Noted. No further response to this comment is required.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
4
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
8 8.1 16
To ensure local suppliers have full, fair and reasonable
opportunities to tender for procurements (throughout the
life of the project), separate strategies should be developed
to differentiate the project's 'operational' and
'construction' phases.
Refer to Section 16.3 of the Supplementary Report.
8 8.2 16
Further clarification of workforce management, including
local/regional recruitment and employment strategy, is
required.
Refer to Section 16.2 of the Supplementary Report.
8 8.3 16.8.2.1
Further clarification of workforce management, including
recruitment and employment strategies for targeted equal
employment opportunity groups (e.g. women; Aboriginal
and Torres Strait Islander people; people with a disability),
is required. It is noted the proponent has indicated a
commitment to maximising opportunities for the groups
mentioned above; however, the Department of State
Development is seeking some measure to have this
position strengthened, particularly as is provides reference
(under section 16.8.2.1) to other projects in the region that
have strategies promoting an inclusive workforce.
Refer to Section 16.2 of the Supplementary Report.
8 8.4 16.9.1.2,
16.9.1.3
Section 16.9.1.2 states recruitment and management of the
workforce during all phases of the project will largely be
the responsibility of contractors and subcontractors, but in
section 16.9.1.3 it is identified the proponent will advertise
for goods and services in the region.
Refer to Section 16.2 and Section 16.3 of the Supplementary Report.
8 8.5 16
Further clarification is required for the structure and
frequency of performance reporting on social impact
mitigation strategies, including: management
arrangements; commitments; local agreements; and
outcomes achieved.
Refer to Section 16.4 of the Supplementary Report.
9 9.1 1.3.6, Table 1-
11
Project environmental approval requirements, no mention
of waterway barrier works approvals. Refer to Section 3.1 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
5
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
9 9.2 2.6.1 p
Shared port infrastructure with Gulf Alumina: It is noted
that discussions are underway for an option of Metro
Mining and Gulf Alumina to share the port infrastructure
and haulage roads. In consideration of a least impact
option to high value marine plants in this area, it is
Fisheries QLD preference for the existing port
infrastructure and haulage roads to be upgraded and used
by Metro Mining.
The acquisition of Gulf Alumina enables the shared use of the
existing and approved SRBP infrastructure. Section 4 of the SEIS
describes the amended Bauxite Hills Project and how the SRBP
infrastructure will be used to service the Bauxite Hills project.
9 9.3 2.7.6.2
The EIS notes: It is not anticipated that forestry materials
will be required by the project. The exact location and
suitability of the on-site deposits is yet to be determined,
although it is expected that suitable materials can be
sourced from within the project area given the presence of
existing borrow-pits associated with the previous kaolin
mine.
The issue is: While the required extractive materials are
expected to be found within the project area, DAF
(Forestry) notes that the actual location/s of suitable
resources has not been determined. If extractive materials
do have to be sourced from outside the project area then
DAF (Forestry) should be consulted for advice on any
authority that might be required under the Forestry Act
1959.
Refer to Sections 4.3.2 and 4.5.3 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
6
9 9.4 4.5.1.4, 4.5.1.7
Capacity of the soil to support agricultural use.
The findings of the soils assessment indicate that the land
subject to the proposed activity might have limited ability
to be used for cropping and or other agricultural use. If the
Agricultural Land Classification B Class land classification is
incorrect, it is recommended that the proponent provide its
findings to the Department of Science, Information
Technology and Innovation (DSITI) to update the State's
soils data and soils mapping. However, if the Agricultural
Land Classification is correct, DAF's key concern is that
there should be no net loss of the availability or utility of
land for agricultural uses resulting from the project. Land
within the project area likely to be directly impacted
includes 1,422 ha of land identified as Agricultural
Classification B Class land. The availability and utility of this
land to undertake agricultural land uses will be impacted by
the project. This land is classed as being highly suitable for
pastures and may be suitable for cropping with engineering
and/or agronomic improvements. DAF recommends that
the proposed mitigate the impacts on agricultural land
availability.
It is recommended that the proponent be required to:
1. Secure equivalent land for permanently impacted
agricultural land (e.g. final void areas, any contaminated
land, and areas of steep slopes post rehabilitation) for
ensuring that there is no permanent net loss of land
available for agricultural production as a result of the
proposed resource activity, in perpetuity; and
2. Ensure that there is no temporary reduction in land
available for highest order agricultural production as a
result of the proposed resource activity by:
Securing equivalent land for temporarily impacted land
for the purpose of highest-order agricultural production
during the term of the project (i.e. 1,375ha)
Providing an 'uplift measure' to ensure the
development of land for agricultural use in the region.
Metro Mining does not propose to revise the EIS to reflect these
proposed recommendations due to the land not being mapped as an
area of regional interest or as a priority agricultural area; that it is
not a strategic cropping area and therefore the Regional Planning
Interests Act 2014 would not apply to the Project. Given the general
limited depth of topsoil recorded across the site, low nutrient
content of the soils, need for excessive amounts of fertilisers,
variable climatic conditions, provision of irrigation and high
transportation costs given the distance to markets, agricultural uses
of the land are extremely limited and generally not feasible.
Furthermore, the proposed post-mining land use, once
rehabilitation is complete, is to return the land to pre-existing native
vegetation communities.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
7
Approval conditioning:
1. It is recommended that if an approval is made, it be
subject to the proponent ensuring that the equivalent land
for permanently impacted land be maintained as land used
for the highest-order agricultural land use in perpetuity.
The equivalent land for permanently impacted land must
be legally secured by registration of a covenant on the title
of the equivalent land, and evidence of the same proved to
the Chief Executive of the Department of Environment and
Heritage Protection (the Chief Executive) prior to the
commencement of the project. It is recommended that if
an approval is made, it be subject to the proponent
submitting a report annually to the Chief Executive which
details:
yield quantity from the equivalent land
yield quality from the equivalent land
inputs (e.g. water, fertiliser, machinery) to the
equivalent land
any events, whether natural or not, which have
influenced the productive capacity of the equivalent
land.
2. It is recommended that if an approval is made, it be
subject to the proponent ensuring that the equivalent land
for temporarily impacted land be maintained for land used
for the highest-order agricultural land use for the term of
the project. The equivalent land for temporarily impacted
land must be legally secured by registration of a covenant
on the title of the equivalent land, and evidence of the
same proved to the Chief Executive prior to the
commencement of the activity. It is recommended that if
an approval is made, it be subject to the proponent
submitting a report annually to the Chief Executive which
details:
yield quantity from the equivalent land
yield quality from the equivalent land
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
8
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
inputs (e.g. water, fertiliser, machinery) to the
equivalent land
any events, whether natural or not, which have
influenced the productive capacity of the equivalent
land.
3. It is recommended that if an approval is made, it be
subject to the proponent providing an uplift measure to
ensure the development of land suitable to undertake
agriculture on occurs in the region. DAF recommends that
the proponent detail the strategy including the sequence of
actions to ensure that this happens, including proposed
farming arrangements and back up options in case first
instance arrangements fail.
9 9.5 5.10.7.2, Table
5-19
Queensland Offset requirements - direct benefit
management plans, potential offset actions, mangroves: It
has been proposed that mangrove and saltpan disturbance
is to be offset through the funding of sea turtle
conversation. Funding to protect marine turtles is not an
acceptable offset as it does not have a direct benefit to
fisheries resources and habitats which are the subject of
the offset.
Metro Mining commits to further consultation with EHP and DAF as
part of finalising the offsets package for the Project. Refer to Section
6.12 of the Supplementary Report for further details on the
predicted and reduced clearance footprint for environmentally
significant vegetation, taking into account the use of the approved
SRBP MIA, BLF and existing SRBP main haul road, in addition to the
use of the SRBP accommodation and associated facilities.
9 9.6 5.13, Table 5-
21
Commitments terrestrial and aquatic ecology.
All waterway crossings are to be designed with regard to
the State development assessment provisions to maintain
fish passage.
Refer to Section 11.3 of the Supplementary Report.
9 9.7 6.2.5
Fisheries Act 1994 also protects waterways providing for
fish passage. The Fisheries Act 1994 protects waterways
providing for fish passage, waterway barrier works may be
applicable for waterway crossings outside of the mining
lease area to ensure fish passage and connectivity within
waterways.
Metro Mining acknowledges this observation. Refer to Section 3.1.1
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
9
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
9 9.8 6.6.1.4
Hydrological Connectivity - omission of the importance of
hydrological connectivity for fish species and fisheries
resources. Hydrological connectivity is important for a wide
range of commercial, recreations and native fish species to
access feeding, spawning and refuge areas. Waterway
barriers that restrict fish movement can significantly reduce
the long term viability of many Australian native fish
populations. Waterway crossings should be designed with
regards to the state development assessment provisions to
maintain fish passage at all flow regimes. Where waterway
crossing falls outside of the mining lease area a
development approval may be applicable.
Metro Mining will utilise the existing SRBP mail haul road to access
the SRBP MIA. As such the north south haul road proposed for the
Bauxite Hills Project is no longer required.
The relocation of the east-west haul road crosses two un-named
creek lines. These crossings will incorporate culverts that will allow
fish passage upstream and downstream of the crossings as outlined
in Section 3.1.1 of the Supplementary Report.
9 9.9 6.6.2
Marine Species-no recognition that marine plants and fish
species may be affected by the proposed development.
Mangroves and associated marine plants provide important
feeding and nursery habitats for many marine species and
fauna including crustaceans and fish.
Impacts to terrestrial, freshwater and marine ecology are discussed
in Chapter 6, 7 and 8 of the EIS and updates are provided Section 6,
7 and 8 of the Supplementary Report.
9 9.10 6.6.4
Fisheries - commercial and recreational fishing
displacement. Note that any displacement to commercial
or recreational fisheries needs to be considered, and
compensation may be applicable for commercial fisheries
in this area. The Guideline on fisheries adjustment provides
advice for proponents on relevant fisheries adjustment
processes and is available by request from the Department
of Agriculture and Fisheries.
The Project is not considered likely to impact commercial or
recreational fishing activity in the Skardon River and adjacent
waters. Refer to Section 6.5.5 of the EIS which discusses potential
impacts to the various commercial fisheries and recreational fishing
activities in the Skardon River area.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
10
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
9 9.11 6.6.5
Summary of impact to marine ecology - no recognition of
marine plants playing a vital role in Qld's fisheries and the
potential impacts of the project on this aspect of the
development. Clearing of 20.5 ha of mangrove, 0.25 ha of
saltmarsh vegetation and 0.4ha of seagrass has the
potential to impact on Queensland fisheries as an economic
driver. These marine plants provide vital shelter, food and
nursery areas to about 75% of fish species caught in
Queensland, and play an integral role in Queensland's
commercial, recreational and indigenous fisheries.
The use of the existing SRBP MIA, BLF and main haul road, in
addition to the relocation of the east –west BH1 haul road has
removed all of the direct impacts on estuarine wetlands (including
areas of seagrass and mangrove habitat) that were previously
identified in the EIS. It is considered unlikely that the economic
driver of Queensland Fisheries will be impacted. Refer to Section
6.5.5 of the EIS which details the existing commercial and
recreational fishing activities within the Skardon River area. Also
refer to Section 6, 7 and 8 and Appendix D of the Supplementary
Report for updated information on terrestrial and marine ecology.
9 9.12 6.8.2.1, Table
6-15
Assessment against significant impact criteria: three
sawfish species and Speartooth Shark: Fragment an existing
population into two or more populations -does not
recognise that waterway crossings may act to fragment this
population. Waterway crossings to be designed in
consideration of the species present in this location, and
allow for fish passage of the entire range of species,
including sawfish and speartooth shark species. This will
allow for movement of these species between nursery and
feeding areas and reduce the likelihood of the population
becoming fragmented.
The assessments of the impacts to Speartooth shark and Sawfish
spp. are discussed in Sections 8.4.1 and 8.4.2 of the Supplementary
Report.
9 9.13 8.8 References to the Land and Sea "Ranges" is incorrect. The online version of the EIS will be updated to reflect these
amendments.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
11
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
9 9.14 8.8.1.1
Section refers to the Cook Shire Council Pest Management
Plan 2012-16. The proponent should note that the existing
plan is currently being reviewed and will be replaced by the
Cook Shire Biosecurity Plan 2016-2020 in the second half of
2016. Reference should be made to the new plan which will
be written under the new legislation (i.e. Biosecurity Act
2014). The proponent is advised to also refer to the
Regional Biosecurity Strategy for Cape York Peninsula 2016-
20 (out for consultation). The Strategy provides valuable
information including detailed maps and strategic
management for priority species. Suggest that proponent
checks for alignment with the priorities of this Strategy.
The revised Cook Shire Biosecurity Plan 2016-2020 is not yet publicly
available on the Cook Shire Council website
(http://www.cook.qld.gov.au/biosecurity). The Regional Biosecurity
Strategy for Cape York Peninsula 2016-2020 is also not available on
the Cape York Natural Resource Management website
(http://www.capeyorknrm.com.au/project/1657).
These documents will be reviewed and considered by Metro Mining
when available.
10 10.1
Substantial community support exists for the Bauxite Hills
Project. Accordingly, we have pleasure in encouraging all
concerned to facilitate the necessary approvals enabling it
to proceed, so long as Metro meets all necessary
environmental standards. We wish Metro well in its
endeavours and look forward to a long-standing, mutually
beneficial relationship.
Noted. No further response to this comment is required.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
12
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
11 11.1 17.2.4.12,
Figure 17.1
The proponent is proposing to conduct its shipping
operations (barging loading area) outside of the Skardon
River port limits and there is currently no approval for an
extension to the existing port limits or permission to carry
out port activities outside of the port limits.
The proponent should consult closely with Ports North with
regard to use of the Skardon River port, to either:
(a) seek an extension of the Skardon River Port limits in
consultation with Ports North. (Under s274 of Transport
Infrastructure Act 1994, a regulation may define or amend
the limits of a port.
Extension of the Skardon River Port limit would require an
amendment to the Transport Infrastructure (Ports)
Regulation. (This is the Department of Transport and Main
Roads' preferred course of action) or
(b) seek an approval to carry out port activities outside the
current Skardon River port limits under s274 of the
Transport Infrastructure Act 1994. (The Governor-in-
Council may decide that port activities of a substantial
nature may be carried on at a place that is not a port
managed by a port authority, the State or a local
government).
The EIS should clearly indicate which approach the
proponent wishes to take and consult closely and regularly
with Ports North to progress this issue.
There is no longer a requirement to extend the port limits given the
relocation of the port area. Refer to 3.1.5 and 17.2 of the
Supplementary Report.
11 11.2 17.6.3.3
In the second paragraph "Navigational Aids", it states that
"the navigational channel will be charted by MSQ and the
RHM and checked regularly, particularly following the wet
season and extreme weather events".
Refer to Section 17.3 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
13
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
11 11.3 17.9, Table 17-
16
The 11th item states that "Navigation channel will be
charted and checked regularly, particularly following the
wet season and extreme weather events". To clarify
responsibility for surveying the channel, this commitment
should more clearly state annual surveying will take place,
at the proponent's expense, e.g. "the channel offshore of
the mouth of Skardon River will be hydrographically
surveyed by MSQ at the end of each wet season at the
proponent's expense "
Refer to Section 17.4 of the Supplementary Report.
11 11.4 Appendix M
"the channel offshore of the mouth of Skardon River should
be hydrographically surveyed (at the end of the wet
season)." To clarify responsibility for surveying the channel,
this commitment should more clearly state annual
surveying will take place, at the proponent's expense, e.g.
"the channel offshore of the mouth of Skardon River will be
hydrographically surveyed by MSQ at the end of each wet
season at the proponent's expense "
Refer to Section 17.3 of the Supplementary Report.
12 12.1
Recently draft guidance material for Bushfire hazard has
been developed in support of the State Planning Policy in
the form of a draft model code (attached). The draft model
code has been developed to meet QFES operational needs
and adopt key recommendations for bushfire mitigation.
The code is currently in consultation with peak bodies and
key industry groups. In support of this process, please
consider relevant sections of the draft model code as a
guide to address SPP requirements for bushfire hazard.
Refer to Section 18.3 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
14
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
12 12.2
Although the mining component is exempt from the State
Planning Policy the proponent should consider relevant
sections of the draft model code to assist in mitigating
against the adverse effects of bushfire. A number of
management and mitigation measures that are identified
by the EIS are addressed in the draft model code such as
firebreaks, design and siting of buildings, access, and water
supply. In particular mitigation measures should be
implemented in the development of the accommodation
camp. PSBA advises that a bushfire site assessment should
be conducted to determine the level of bushfire affecting
the site and this in turn will guide adherence requirements
against the draft model code.
Refer to Section 18.3 of the Supplementary Report.
13 13.1 2.2.3, 6.6.1,
7.6.2
Listed threatened marine species - Please provide further
evidence to support the conclusion that the proposed 1:10
year sediment pond design will be sufficient to avoid
sediment-laden runoff entering the Skardon River from the
Mine Infrastructure Area (MIA).
The Department notes the sediment ponds in the MIA are
within 100 m of the Skardon River and the EIS notes the
sediment ponds are expected to overflow. The Department
also notes that the mine site will not be operational during
the wet season and will be effectively understaffed during
this time.
Since the release of the EIS, Metro Mining has completed a
successful takeover of Gulf Alumina’s assets, including the existing
and proposed infrastructure for the SRBP, and proposed
operations. The MIA and sediment ponds originally proposed for the
Project are no longer required, and the comments relating to this
area are no longer relevant.
The acquisition of the SRBP enables the use of the approved
infrastructure at the port area. The sediment ponds approved for
the SRBP will be used for the MIA.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
15
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.2
6.5.2, 7.6.3,
7.13.2,
Appendix B3
(Section 3.3)
Seagrass - Dugong - Please calculate the amount of
seagrass habitats (in hectares) that have the potential to be
impacted by the construction and operation of the Barge
Loading Facility (BLF) and vessel activities on the Skardon
River.
Please update the relevant sections of Chapter 7 to identify
the potential impact to seagrass habitats from the
proposed action.
The Department notes there have been seven benthic
habitat surveys undertaken from the Skardon River (Table
6-3, Table 7-6 and Appendix B3) and the EIS discusses the
results of these surveys. The EIS also includes Figure 6-4
and Figure 7-10 which highlights seagrass habitats near the
proposed BLF. The Department considers seagrass habitats
are important habitat for the migratory Dugong which is
known to occur in the Skardon River.
However, the Department notes that Table 7-47
acknowledges the area of direct estimated disturbance on
seagrass communities is yet to be confirmed as “Detailed
surveys for the presence of seagrass within the proposed
footprint will be undertaken during the final design phase.”
Hence, the EIS does not provide an estimated amount of
seagrass habitat to be potentially impacted.
The Department notes that Appendix B3 contains mapping
of seagrass habitats in the Skardon River dated March 2015
(Figure 3.2). The Department considers this map would be
useful to include in the EIS and assist in the calculation of
the amount of seagrass habitats that have the potential to
be impacted by the proposed action.
The Supplementary Report includes the new information obtained
during the seagrass surveys undertaken in the Skardon River (refer
to Figure 7-1) in the vicinity of the infrastructure disturbance
footprint of the cyclone mooring area and the originally proposed
BLF and RoRo - refer Section 7.3. Table 7-47 and Table 5-18 of the
EIS identifies the significant residual impacts from the Project
requiring offsets, which have been significantly reduced. This table
has been updated and is provided in Section 6.12 refer specifically to
Table 6-11) of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
16
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.3 7.8.1
Water Mouse - Please amend Table 7-15 to note the Water
Mouse as having the ‘Potential’ to occur. The EIS notes that
surveys for the Water Mouse were not carried out.
However, suitable mangrove and saltpan habitat occurs on
the margins of the Project Area. The EIS states 20.5 ha of
mangrove and 0.25 ha of saltpan vegetation will be cleared
for the barge loading area. Please provide an assessment of
the likely impacts to the Water Mouse, its habitat and the
proposed management and mitigation measures to
minimise the impact to this species.
Under the system Metro Mining has adopted (as with most EIS
assessments), species considered with 'potential' to occur are not
considered under the significant impact guidelines. Metro Mining
also notes comment 13.7 from the Department itself which states
'The Department considers species assessed against the significant
impact criteria should be categorised as no less than ‘Likely’ to
occur.'
Recent surveys for Water Mouse have been carried out in mangrove
areas proposed to be impacted by the Project.
Refer to Section 8.2.5 of the Supplementary Report for the results of
the targeted Water Mouse surveys.
Following the collocation of the BLF and RoRo to the approved SRBP
port area and the use of the existing SRBP main haul road to service
the Bauxite Hills Project, no mangrove habitat is anticipated to be
disturbed in addition to that already approved for the SRBP.
13 13.4 7.8.1, 7.12
Northern Quoll - Please provide further discussion to
support the conclusion that the Northern Quoll only has
the ‘Potential’ to occur in the Project Area. The Department
considers the Northern Quoll is ‘Likely’ to occur as the EIS
notes that foraging habitat (eucalypt woodlands) for the
Northern Quoll occurs on the project site and the species
has a large foraging range.
Refer to Section 8.2.3 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
17
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.5 7.8.1, 7.13.2,
7.16
Red Goshawk, Masked Owl and Bare-rumped Sheathtail bat
- Please provide hollow-bearing tree habitat mapping for
the Project Area and calculate the amount of hollow-
bearing tree habitat (in ha) to be directly impacted by the
project. Please discuss and provide case studies (where
relevant) to demonstrate the effectiveness of selectively
felling hollow-bearing trees prior to general clearing for use
within rehabilitation areas as a mitigation measure. Please
update the relevant sections of Chapter 7 to identify the
potential direct impact of the project to hollow-bearing
tree habitat from project activities. Please update the
Commitments Table (Table 7-50) to include a commitment
to monitor and assess this mitigation measure throughout
the rehabilitation lifetime.
The Department notes that hollow-bearing trees are
important habitat for several listed threatened species,
particularly the Red Goshawk (for prey species), Masked
Owl (for nesting) and the Bare-rumped Sheathtail Bat (for
nesting). The EIS notes the commitment to selectively fell
large, hollow-bearing trees prior to general clearing for use
within rehabilitation areas to provide immediate breeding
and nesting habitat. The Department considers the
monitoring and assessment of this mitigation measure
would be useful to determine its effectiveness for use in
other mining rehabilitation actions in the area.
Further detail of the likelihood of the species occurring in the Project
area is presented in Sections 8.2.1, 8.2.2 and 8.2.4 of the
Supplementary Report. This updated assessment reaffirms the
position that these three species are not known or likely to occur at
the site. Consequently, Metro Mining does not propose to
undertake hollow bearing tree mapping.
Notwithstanding, Metro Mining will still undertake selective clearing
of hollow bearing trees for rehabilitation use.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
18
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.6 7.8.1 and 7.12
Chocolate Tea Tree Orchid, Black-footed Tree-Rat (north
Queensland) - Please provide suitable habitat mapping for
the species identified (known and likely to occur) in the
Project Area. These maps should include an overlay of the
proposed mining infrastructure layout to illustrate where
there will be an impact on suitable habitat. Please provide
the total amounts of suitable habitat (in ha) for the Black-
footed Tree-rat:
o in the entire Project Area; and
o to be directly and indirectly impacted by the project.
Please update Chapter 7 to assist in the assessment of
impacts of the project on the species and the identification
of potential offsets.
The EIS states that the Black-footed Tree-rat is ‘Known’ to
occur in the Project Area. The Black-footed Tree-rat was
listed at the time of the referral decision and therefore an
offset may be required for habitat clearance.
The information for the Black-Footed Tree Rat is included in Section
8.4.4.3 of the Supplementary Report. The Project requires the
clearing 1,507 ha of Darwin Stringybark woodland (RE3.5.2). This
habitat remains widespread in the surrounding region with a further
44,280 ha located within a 20 km radius of the Project area. Given
the general lack of records and the abundance of this habitat in the
wider landscape no significant residual impacts have been predicted
for this species and therefore no offsets are required. The species
will be part of the Project-specific Significant Species Management
Plan (refer Section 8.4.3.3 of the Supplementary Report).
Updated discussion on the Chocolate Tea Tree Orchid is provided in
Section 8.4.3.1 of the Supplementary Report.
13 13.7
6.5.4, 7.8.2,
Appendix B3
(Section 4.2.2)
Migratory Species - Please review the consistency of the
‘Likelihood of occurrence’ of all migratory species in
individual EIS chapters, between EIS chapters and EIS
appendices. The Department considers species assessed
against the significant impact criteria should be categorised
as no less than ‘Likely’ to occur (Table 7-19). For example,
the Loggerhead Turtle, Dugong and Giant Manta Ray.
In the EIS, Dugong was listed as being ‘likely’ to occur this has since
been updated to 'known’ based on a single record in the Skardon
River (refer to Section 7.6.4.2, 7.8.1, 8.4.3.7 and 8.6.2.1 of the
Supplementary Report).
Giant Manta Ray remains 'unlikely to occur.' Metro Mining has
assumed DotEE were referring to Coastal Manta Ray as this species
was assessed under the significant impact guidelines as per Table 6-
20 and Table 7-43 of the EIS. This species was previously assessed as
potential to occur and has been elevated to ‘likely to occur’, albeit as
a transient species through the offshore transhipment area.
Loggerhead Turtle remains at 'potential to occur' and the significant
impact assessment for this species included at Table 7-19 of the EIS
may be ignored in accordance with DotEE’s comment that species
assessed against the significant impact criteria should be categorised
as no less than ‘likely’ to occur.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
19
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.8 6, 7, Appendix
B3
Pristis pristis - Please update Chapter 6 and Chapter 7 to
ensure consistency in the naming of Pristis pristis:
o Section 6.5.4 (Table 6-5) and Section 6.8.2 of the EIS
notes the common name of species as the Largetooth
Sawfish.
o Section 7.8.2 of the EIS notes the common name of the
species as both the Freshwater Sawfish and Largetooth
Sawfish.
o Section 4.2.2 (Table 4.2) and Section 4.3.3 of Appendix
B3 notes the common name of the species as the
Largetooth Sawfish.
It is noted that both common names are used on the species
webpage on DotEE's own Species Profile and Threats Database.
Metro Mining have adopted Largetooth Sawfish for use in the
Supplementary Report as on the approved Conservation Advice for
the species.
13 13.9 7.9.1
Palm Cockatoo - Please remove the impact assessment for
the Palm Cockatoo.
The Department notes the Palm Cockatoo was listed as
‘Vulnerable’ under the EPBC Act on 31 October 2015. The
Controlled Action decision for this project was 18
September 2016. The Department notes that the EIS makes
reference to this and that the ‘species is not required to be
assessed’.
The significant impact assessment for Palm Cockatoo included in
Section 7.9.1 of the EIS may be ignored in line with DotEE’s
comment that “the Palm Cockatoo was listed as ‘Vulnerable’ under
the EPBC Act on 31 October 2015. The Controlled Action decision for
this project was 18 September 2016. The Department notes that the
EIS makes reference to this and that the ‘species is not required to
be assessed’.
13 13.10 7.9.2
Whimbrel and Common Sandpiper - Please update Chapter
7 to consider EPBC Act Policy Statement 3.2.1 – Industry
guidelines for avoiding, assessing and mitigating impacts on
EPBC Act listed migratory shorebird species (2015) and how
the proposed action is not inconsistent with actions
outlined this document. The Department notes this
document applies to two shorebird species identified in the
EIS:
o Whimbrel (Numenius phaeopus)
o Common Sandpiper (Actitis hypoleucos)
The EPBC Act Policy Statement can be found on the
Department’s website at:
www.environment.gov.au/epbc/publications/shorebirds-
guidelines.
Refer to Section 8.3.1.1 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
20
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.11 7.10.2
Listed threatened marine turtle species - Please update
Chapter 7 to include a discussion on how the proposed
measures to avoid, mitigate and manage impacts on listed
threatened marine turtles are consistent with recovery
actions in the National Recovery Plan for Marine Turtles
(2003). The Department notes the EIS mentions the
recovery plan for marine turtles in Australia, however, the
EIS Terms of Reference states “The Assessment
Documentation must discuss how the proposed action is
not inconsistent with any relevant recovery plan for listed
threatened species and communities.”
Refer to Section 8.4.3.1 of the Supplementary Report.
13 13.12
7.10.2, 7.16,
Appendix B3
(Section 4.3.1)
Flatback Turtle, Hawksbill Turtle, Olive Ridley Turtle - Please
identify and discuss the proposed measures to avoid,
mitigate and manage consequential impacts on marine
turtle nesting beaches during critical nesting and hatching
periods. Please make reference in this discussion as to how
additional measures are consistent with recovery actions in
the National Recovery Plan for Marine Turtles (2003).
Please update the Commitments Table (Table 7-50) to
demonstrate how consequential impacts on marine turtle
nesting beaches during critical nesting and hatching periods
will be avoided, mitigated and managed. Appendix B3
states that there is listed threatened marine turtle nesting
beaches located approximately 10 km downstream of the
proposed action. The Department notes that the beaches
will not be traversed during construction or operation of
the mine. However, the Department considers that there
are likely to be consequential impacts of the proposed
action on turtle nesting beaches as a result of the work
force visiting the area for recreation.
The Project itself will have no impact on the beach to the west of the
Project area. Metro Mining will communicate the importance of the
turtle nesting areas and critical nesting times to its workforce and
establish educational and operational measures (i.e. no 4WD on the
beach) to protect the values of the beach.
An assessment of the Project’s potential impacts to turtles against
the recovery plan is included at Section 8.4.2.1 of the
Supplementary Report.
In addition, as part of the Project offsets strategy investigations into
supporting Mapoon Land and Sea Rangers are being carried out.
This includes supporting activities such as removing/cleaning up
marine debris known to endanger marine species such as marine
turtles (e.g. discarded fishnets) and feral animal control, particularly
feral pigs which are well known to predate marine turtle nests.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
21
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.13 7.10.2
Sawfish species and Speartooth Shark - Please update
Chapter 7 to consider the recovery actions contained in the
Sawfish and River Sharks Multispecies Recovery Plan (2015)
and how the proposed action is not inconsistent with these
actions.
The Recovery Plan was approved by the Minister and
applies to the following species:
o Largetooth Sawfish (Pristis pristis)
o Green Sawfish (Pristis zijsron)
o Dwarf Sawfish (Pristis clavata)
o Speartooth Shark (Glyphis glyphis)
o Northern River Shark (Glyphis garricki)
Refer to Section 8.4.2.2 of the Supplementary Report.
13 13.14
7.10.2,
Appendix B3
(Section 4.4.1)
Speartooth Shark - Please complete a separate impact
assessment for the Speartooth Shark against the ‘Critically
Endangered’ significant impact criteria in the Significant
impact guidelines 1.1 Environment Protection and
Biodiversity Conservation Act 1999.
Refer to Section 8.4.1 of the Supplementary Report.
13 13.15 6.11, 7.10.1,
7.14, 7.16
Listed Threatened and Migratory Species - Please confirm
the distance of the safety exclusion zone around the pile
driving works during the construction of the Barge Loading
Facility. The Department notes inconsistencies in the
distance quoted in the EIS:
o Table 6-22 quotes a commitment to employ a 500 m
safety exclusion zone.
o Section 7.10.1 quotes a 1000 m safety exclusion zone
will be established.
o Table 7-49 quotes a safety zone will be established at
1000 m prior to piling activity.
o Table 7-50 quotes a commitment to employ a 500 m
safety exclusion zone.
The use of the approved SRBP MIA and BLF removes the need for pile driving activities associated with the originally proposed Bauxite Hills BLF. No additional piles will be required for the BLF to those already approved for the SRBP.
Pile driving will still be necessary to construct the cyclone moorings.
A 500 m safety exclusion zone will be implemented during the
placement of these piles. Refer to Section 7.2.1 of the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
22
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.16 7.11
Cumulative Impacts MNES - Please provide a discussion on
how cumulative impacts on matters of national
environmental significance can be avoided, mitigated and
managed, in cooperation with other project proponents.
The Department expects this discussion to include, but not
limited to, the following:
o a cooperative management strategy to prevent
fragmentation of critical habitats;
o consultation and cooperation with Gulf Alumina on
water management and water monitoring;
o the publication and sharing of data and other
information;
o sharing infrastructure where commercially viable; and
o adaptive management approaches, including:
maintaining biodiversity corridors, offsets (if required)
and other habitat areas;
management of port infrastructure and vessel traffic;
and
rehabilitation of disturbed areas post-mining.
Please update the Commitments Table (Table 7-50) to
demonstrate how cumulative impacts on matters of
national environmental significance will be avoided,
mitigated and managed, in cooperation with other project
proponents.
The Department notes that many of the identified
cumulative impacts on the Skardon River and adjacent
proposed Skardon River project (SRBP) can be managed
through the implementation of project specific mitigation
and management programs. The conclusion of the MNES
chapter states that no project impacts are considered
significant with the proposed mitigation measures and in
partnership with SRBP. However, no details of this
partnership are discussed in the MNES chapter.
With the acquisition of Gulf Alumina and as the owner of the SRPB,
Metro Mining will effectively be the responsible party for both the
Bauxite Hills Project EA and the SRBP EA. This means that areas
identified for cooperative management and/or consultation and
cooperation with Gulf Alumina will now occur seamlessly as part of
an amalgamated Project.
Given the acquisition potential impacts have been minimised where
possible by using existing and approved infrastructure as per SRBP’s
EA, including the MIA, BLF and accommodation camp.
Metro Mining will be responsible for establishing and implementing
operational arrangements aimed at minimising potential impacts
both cumulatively and individually as a result of the two projects.
Refer to Section 1.1 of the Supplementary Report regarding
discussion on the acquisition.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
23
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.17 7.16
Please update the Commitments Table (Table 7-50) to
ensure that all proposed plans and management strategies,
noted in Chapter 7 and proposed to be implemented, have
been included.
A review has been carried out and the commitments table has been
updated. Refer to Appendix J of the Supplementary Report. Note
that the commitments in Appendix J are specific to the Bauxite Hills
Project. Metro Mining will look to consolidating the commitments
for both projects into a single consistent approach that will be
applied across the Bauxite Hills and SRBP projects.
13 13.18 7
Please review the section numbering of the MNES chapter
to ensure it is in numerical order as there are some
inconsistencies. For example, Section 7.10 MNES Impact
Assessment – Marine Species.
This will be updated in the online version of the EIS.
13 13.19 7
Listed Threatened and Migratory Species - Please update
Chapter 7 to take account of all relevant approved
Conservation Advices for listed threatened and migratory
species. When considering whether or not to approve a
proposed action, the Minister must have regard to relevant
approved conservation advices. The Department notes
where there is no recovery plan for a species, the
conservation advice for the species provides sufficient
direction to implement priority actions and mitigate against
key threats.
Refer to Section 8.4.3 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
24
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.20 7
Listed Threatened and Migratory Species - Please update
Chapter 7 to include an assessment of how the proposed
action is not inconsistent with the actions contained in all
relevant Threat Abatement Plans for the following species:
o Black-footed Tree-rat
o Listed marine turtle species
o Dugong
When considering whether or not to approve a proposed
action, the Minister must consider the proposed action, its
impacts and mitigation measures and whether the
proposed project would be inconsistent with any applicable
threat abatement plans.
Approved threat abatement plans can be found on the
Department’s website at:
www.environment.gov.au/biodiversity/threatened/threat-
abatement-plans/approved.
There is no threat abatement plan for Black-footed Tree-rat. Refer
to Section 8.4.3 of the Supplementary Report which discusses
relevant threat abatement plans.
13 13.21 6,7
Impact Assessments - Listed Threatened Species - The
Department notes that significant impact assessments have
not been undertaken for several listed threatened species
which are dependent on hollow-bearing trees of Darwin
Stringybark woodland that dominates the project site. The
Department considers there is insufficient evidence to
conclude that there is an acceptable impact to this habitat
without further detailed investigation (see comment 5).
Comment 13.5 refers to the potential occurrence of Red Goshawk,
Northern Quoll, Masked Owl and the Bare-rumped Sheathtail Bat.
The occurrence assessment confirms that these species are not
known or likely to occur in the Project area, which is consistent with
Gulf Alumina's assessment in their EIS.
Metro Mining has provided a response to the occurrence of these
species in Section 8.2 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
25
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
13 13.22 7
Residual significant impacts to MNES - The Department
notes the conclusion in the EIS that significant impacts on
matters of national environmental significance will not
occur. No offsets are therefore proposed under the EPBC
Act. Please note that following completion of the
assessment of impacts under the bilateral agreement with
Queensland, a decision will be made as to the acceptability
of impacts on MNES and whether residual significant
impacts are likely and offsets are therefore required to
compensate for these impacts.
Section 5.12 of the EIS summarises the Project's approach to
offsetting. The Project Offsets Strategy is located in Appendix C of
the EIS.
The area required for offsets has been updated since the EIS to
reflect the use of the SRBP infrastructure and the relocation of the
east – west BH1 haul road and is detailed in Table 6-11 of the
Supplementary Report. The outcome is a significant reduction in the
originally identified offsetting requirements. The final offsetting
strategy for both Projects will be discussed and agreed with the
relevant departments, including EHP and DAF.
14 14.1
Infrastructure Duplication - For the Skardon River Bauxite
Project, Gulf Alumina proposes to utilise existing
infrastructure and develop additional infrastructure in
areas predominantly disturbed by previous mining activities
on Gulf Alumina’s mining leases. This includes the Port
infrastructure area, wharf for loading barges, haul roads,
camp and airstrip. Gulf Alumina’s existing and proposed
infrastructure areas are located in areas that make optimal
use of topography to minimise impacts on wetland and
aquatic environments.
Metro Mining proposes duplication of much of this
infrastructure in areas previously undisturbed by mining or
other activities, including the proposed barge loading
facility (BLF), roll on roll off (RORO), haul roads and camp.
Much of the duplicated infrastructure is bordering, or in
sensitive environments such as wetlands and mangroves.
Gulf Alumina is supportive of sharing Gulf Alumina’s
existing and proposed infrastructure as this will reduce or
remove the environmental impacts of duplicated
infrastructure of the Bauxite Hills project. Gulf Alumina has
and will continue to seek cooperation on infrastructure
sharing subject to mutually agreed commercial
arrangements.
As detailed throughout the Supplementary Report, with Metro
Mining’s takeover of Gulf Alumina, the Bauxite Hills Project will
utilise the approved SRBP MIA and BLF rather than constructing
standalone MIA, BLF and RoRo infrastructure. The originally
proposed duplication of major infrastructure for the Project has
been completely avoided.
Further, Metro Mining will use the existing SRBP main haul road,
airstrip and accommodation facilities.
The use of the existing and proposed infrastructure as described
variously throughout the SEIS significantly reduces the project
specific and cumulative impacts.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
26
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
14 14.2 1.7.2.5
Port of Skardon River - Far North Queensland Ports
Corporation Limited, trading as Ports North, is a company
Queensland Government Owned Corporation responsible
for the development and management of the declared Port
of Skardon River, as well as other ports in north
Queensland. The port limits for the Port of Skardon River
are shown in Figure 6-2. From this figure and similar spatial
data presented in the Skardon River Bauxite Project EIS it
appears that the proposed barge loading facility may not
be within Port limits and that the RORO is not within the
Port limits. As noted in Section 1.7.2.5 “The Port of Skardon
River is operated by Ports North and the subsequent Port
rules and the Project will apply to activities within the Port
limits”. It is therefore unclear how activities outside of the
Port limits will be regulated and controlled, especially those
activities directly upstream of Gulf Alumina’s proposed
wharf area.
Metro Mining will utilise the approved SRBP MIA and BLF to service
the Bauxite Hills Project. As such there is now no requirement to
extend the Port boundaries. Refer to Section 3.1.5 and Section 17.2
of the Supplementary Report.
14 14.3 2.6.1
Air Strip - There is one existing airstrip in the Skardon River
area, located on Gulf Alumina’s mining leases. Gulf Alumina
is supportive of shared infrastructure but notes that, as per
Section 2.6.1, Metro Mining is seeking approval for a
standalone project. Gulf Alumina therefore queries how
Metro Mining proposes to gain access to the Skardon River
area without an airstrip. It appears that Metro Mining
assumes it will use the existing airstrip. Therefore, the EIS is
not consistent in proposing duplication of some
infrastructure that could be shared, but not providing
duplication for the airstrip. If the Bauxite Hills project is a
standalone project, then the impacts associated with a
separate airstrip should be assessed as part of the EIS.
Metro Mining will utilise the approved SRBP airstrip and
accommodation facilities to service the Bauxite Hills Project. As such
there is now no requirement to build separate facilities.
Refer to Section 1.1 and 4.4 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
27
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
14 14.4 2
Haul Roads on Gulf Alumina's Mining Leases - Gulf Alumina
notes that the Metro Mining have applied for infrastructure
mining leases for various haul roads, mine infrastructure
area, BLF and RORO.
On various maps (e.g. Fig 2-5), Metro Mining’s EIS shows
haul roads crossing Gulf Alumina’s mining leases. These
haul road crossings are not subject to any mining lease
applications. Whilst Gulf Alumina is supportive of
infrastructure sharing, haul road crossings of Gulf Alumina’s
mining leases are not required for Gulf Alumina’s project
(i.e. they are not shared infrastructure) and are located in
areas proposed for mining by Gulf Alumina.
The bauxite resources within Metro Mining’s mining lease
application 20689 (BH6 West) cannot be transported to
Metro Mining’s proposed barge loading facility without
crossing Gulf Alumina’s mining leases (ML 6025, ML 40069
and ML 40082) at some point. Therefore, if the Bauxite Hills
project is a standalone project, Gulf Alumina queries how
Metro Mining proposes to transfer bauxite from MLA
20689 (BH6 West) to the barge loading facility. If there is
some alternate route or means to transport bauxite from
MLA 20689 (BH6 West), the impacts of this should be
assessed in the EIS.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP. This negates the issue of requiring s316
Mining Leases across the SRBP.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
28
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
14 14.5 2.8.5
Vessel Operations - Gulf Alumina notes that cooperation
with Metro Mining will be required, in conjunction with
Ports North and Maritime Safety Queensland, to ensure
safe and efficient operation of multiple barges and tugs
within the Skardon River and defined Port of Skardon River
limits. Whilst Gulf Alumina proposes 2 barges each
operating on 12 hour cycles, Metro Mining propose 6
barges, 5 tugs and floating cranes for transshipment of
bauxite (Section 2.8.5).
Gulf Alumina notes that the proposed tug and barge route
shown on Figure 19-29 intersects the proposed wharf
location for Gulf Alumina’s Skardon River Bauxite Project.
In the absence of an alternative tug and barge route for
Metro Mining’s Project, congestion is likely to inhibit both
Gulf and Metro operations.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP.
14 14.6 2.8.6, 17.6.3
Skardon River Depth at Barge Loading Facility - Section
2.8.6 states that the barge draft will be 3.5m. Section
17.6.3 recommends an under keel clearance of 0.5m.
Therefore, the proposed barge draft plus under keel
clearance is 4m. In addition, the draft of tug boats for the
barges is not stated so these may be more or less than 4m
with under keel clearance. With 6 barges taking 4 hours
each, over a 24 hour cycle, to load 6000t on average, there
will be at least 3 barges berthed at the barge loading facility
during periods of low tide.
Figure 2-16 shows the bathymetry at the barge loading
facility. The upstream corner of the BLF is shown in water
ranging from 3m to 4m below LAT. As the barges require
depths of up to 4m, Gulf Alumina queries whether this
corner of the BLF will require bed levelling or dredging. If
required, then Metro Mining should provide an assessment
of environmental impacts from any required bed levelling
or dredging.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
29
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
14 14.7 2
Downstream Moorings - Metro Mining have proposed tug
and boat moorings and floating crane moorings
downstream of the existing Port infrastructure and Gulf
Alumina’s proposed wharf (refer to Figure 2-3). Information
is not provided as to whether these moorings, barges
alongside moorings or barges manoeuvring to access these
moorings will interfere with Gulf Alumina’s proposed
barging operations in the Skardon River.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP.
14 14.8 17.6.6.7
Maritime Safety Queensland - The final terms of reference
for the Bauxite Hills project require details of the adopted
assessment methodology for impacts on maritime
operations in accordance with the Maritime Safety
Queensland (MSQ) Guidelines for major development
proposals.
Section 17.6.6.7 provides a commitment to prepare the
management plans required by MSQ but does not present
any draft or finalised plans. As cooperation is required on
vessel traffic management, aids to navigation and ship
sourced pollution prevention, Gulf Alumina considers that
the plans required by the MSQ Guideline should be
prepared as part of the EIS process.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP.
Metro Mining is in the process of finalising the marine management
plans in consultation with the RHM and Ports North, and in
accordance with the MSQ guidelines for major development
proposals. With the acquisition of Gulf Alumina and as the owner of
the SRPB, Metro Mining will effectively be the sole responsible party
for relevant management plans within the Skardon River. Additional
discussion regarding the preparation of management plans is
included in Section 17.5 and Section 21 of the Supplementary
Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
30
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
14 14.9
6.7.1.1, 6.6.1,
Appendix B3
(Fig 2-60 and
2-61)
Mangrove and Seagrass Impacts - Section 6.7.1.1 states
that “Based on Metro Mining’s base case, the addition of
the SRBP presents a 30% increase in mangrove distribution
(0.2ha) due to mangrove clearing to facilitate the
construction of marine facilities”. These numbers appear to
be incorrect. The Skardon River Bauxite Project will clear
approximately 300 m2 (0.03 ha) of mangroves. The Bauxite
Hills Project will clear approximately 20 ha of mangroves.
Therefore, the addition of the Skardon River Bauxite
Project presents an increase in mangrove clearing of 0.15%.
Section 6.6.1, describing potential impacts on marine
habitats, does not present information on potential
propeller wash impact to seagrass beds shown in Fig 6-4, as
identified in Fig 2-60 and Fig 2-61 of Appendix B3.
The removal of the requirement for duplicated Project infrastructure
(i.e. BLF, RoRo and east-west haul roads) and use of the existing
north-south haul road has eliminated the original requirement to
clear areas of mangroves, saltmarsh and wetland habitats.
Therefore, it is not anticipated that there will be any significant
impacts to MNES fauna potentially associated with this habitat.
The potential impact of propeller wash on seagrass beds is based on
recent wave wake modelling carried out for the Project (see
Appendix E of the Supplementary Report) and is summarised in
Section 7.3.2 and Section 19.4 of the Supplementary Report.
Appendix E of the Supplementary Report is only relevant to the
small patch of seagrass associated with the cyclone moorings as the
originally proposed BLF and RoRo are now incorporated into the
approved SRBP port area.
In terms of cumulative impacts, the concurrent operation of the
SRBP and this Project was assessed as doubling the incidence of
propeller wash in the Skardon River. With the future amalgamation
of the two projects, with individual production targets of 5 Mtpa, it
is considered the combined annual shipping tonnage of 10 Mtpa is
unlikely to be sough or achieved, thereby decreasing the extent of
vessel traffic and potential shipping impacts. Cumulative impacts to
seagrass are discussed in Sections 7.8.1 and 7.8.2 of the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
31
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
14 14.10 2.8.4
Product Stockpile - Section 2.8.4 describes that the area of
the two product stockpile areas is 120 m x 150 m = 18000
m2, with a maximum height of 18m and maximum storage
of 250,000 t (approximately 300,000 m3).
Based on Figure 2-4, the area of ‘product area 1’ is about
4000 m2 and the area of ‘product area 2’ is about 5000 m2,
providing a combined area of 9000 m2. With a stockpile
volume of 300,000 m3, that would require a minimum
stockpile height of approximately 35 m, and potentially
much higher as bauxite is not stockpiled in a cubic shape.
Gulf Alumina queries whether sufficient area has been
allocated for the bauxite stockpiles. If additional area is
required, then the impact of this additional area should be
assessed in the EIS. Gulf Alumina notes the MIA is located
between Gulf Alumina’s mining lease boundary and the
mangrove vegetation communities of the Skardon River
and therefore additional available area for the product
stockpile may be limited.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP and Section 4.4 regarding the use of
approved SRBP infrastructure.
14 14.11 9.8.1
Buffer Zones - Section 9.8.1 states that buffer zones of
either 50m, 100m or 200m will be maintained around
watercourses for vegetation clearing. This does not appear
to be possible, given that the proposed mine infrastructure
area and haul roads are all within these buffer zones, as
indicated by the scale in Figure 2.4.
No mining will be carried out within the nominated buffers.
Metro Mining has been able to significantly expand the proposed
buffer zones through the utilisation of the approved SRBP
infrastructure and also through the relocation of the east-west BH1
haul road away from the sensitive wetland areas.
Where impact to buffer areas is unavoidable, these areas will be
subject to environmental offsets as per the Qld Environmental
Offsets Policy. Refer to Sections 7.7 and 8.5 of the Supplementary
Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
32
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
15 15.1 10.7.3
Reference is made to the water being drawn from "the GAB
(Great Artesian Basin) aquifer" without providing a
description as to which aquifer of the GAB water is
proposed to be sourced to provide the main water supply
for mining purposes, which would enable accurate
consideration of extraction impacts on any potential town
water supplies in the area.
Refer to Section 10.2 of the Supplementary Report.
15 15.2 10.8.3
Reference is made to the Bulimba aquifer being present;
however it appears as though the Bulimba aquifer (a GAB
aquifer) is not present in this area as described by the
Great Artesian Basin Water Resource Plan. Department of
Natural Resources and Mines (NRM) is the administering
agency for the GAB Water Resource Plan and may have
requirements in this area, however a clear assessment of
the potential impacts for any town water supplies in the
area is desired by DEWS.
The Bulimba aquifer is present but does not form part of the GAB as
detailed in Section 10.2 and Section 4.3.4 of the Supplementary
Report.
16 16.1 10, Appendix
E1
There is inconsistency between the volumes of water
required for the project detailed in the EIS and the volumes
of water in the applications made to DNRM under the
Water Act 2000.
Refer to Section 4.3.6 of the Supplementary Report. Note that there
may be further changes in the required volume of water
commensurate with the utilisation of the SRBP infrastructure to
service the Bauxite Hills Project and the final design of the project
infrastructure.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
33
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
16 16.2 10, Appendix
E1
The EIS has not provided sufficient information to
demonstrate how the proposal’s required take and use of
water meets the requirements of the Water Resource
(Great Artesian Basin) Plan 2006 and Resource Operations
Plan including:
a) How the project will ensure: protection of spring flows
and baseflow; the continued use of existing entitlements;
intergenerational equity; ensuring a reliable water supply
from the plan area; water availability for new users;
artesian water pressure and sub-artesian water levels;
addressing the availability of alternative water supply; and
addressing the efficiency of water use.
b) The location or alternative location of the proposed
bores.
c) A bore monitoring program.
d) The volume proposed to be taken (either 378 or 600
megalitres) is not in accordance with the spring factor rules
(Chapter 3 of the Resource Operations Plan). Grant of this
water would result in the cumulative spring factors
exceeding 400 mm for the Cockatoo Creek and Dulhunty
River watercourse springs. A volume of approximately 188
megalitres from the current proposed bore location would
be in accordance with the spring factors.
e) The volume proposed to be taken (either 378 or 600
megalitres) is not in accordance with the criteria for
protection of existing entitlements (Chapter 4 of the
Resource Operations Plan).
a) Refer to Section 10.2 of the Supplementary Report. Metro Mining
has not been able to ascertain how the referenced spring factors
have been calculated but based on the existing model for the GAB
no significant impacts were identified based on a much higher
extraction rate than what is being proposed.
b) and c) Refer to Appendix I of the Supplementary Report for the
proposed groundwater monitoring bore locations.
d) Refer to Sections 10.2 and 10.4 of the Supplementary Report.
Metro Mining has not been able to ascertain how the referenced
spring factors have been calculated but based on the existing model
for the GAB no significant impacts were identified based on a much
higher extraction rate than what is being proposed.
e) Refer to Section 10.2 of the Supplementary Report in regard to
the permit application to extract 400 ML annually from either the
shallow or GAB aquifers. Refer to Section 6.1.4.6 of the
Supplementary Report in regard to groundwater monitoring and
management.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
34
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
16 16.3 10, Appendix
E1
Insufficient information is provided to assess the
requirements for underground water from the shallow
aquifer (Greater Western Declared Subartesian Area –
currently under moratorium for Cape York Water Plan
development).
Metro Mining has submitted a temporary water permit application
pursuant to s237 of the Water Act 2000 to DNRM for while the
moratorium is in place. Information required to assess this
application has been submitted through a separate approval process
to DNRM. Refer to Section 4.3.4 of the Supplementary Report in
regard to the application process.
Refer to Sections 10.6.5 and 10.7.2 of the EIS in regard to the
modelling and identification of potential impacts to the shallow
aquifer.
16 16.4 1
Two proposed east west linkage hauls roads are not
included within the mining lease application area. The
roads overlap the adjacent mining tenement however
consent from the adjacent mining tenement lessee for the
haul roads has not been demonstrated. Under the
Queensland Vegetation Management Framework, the
Sustainable Planning Regulation 2009, Schedule 24, Part 1,
Item 6 resource activity exemption is not satisfied. These
haul roads include assessable vegetation.
Given the acquisition of Gulf Alumina by Metro Mining, consent can
now be assured across the tenements as they will be operated by
the same operator as an amalgamated operation.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP.
16 16.5 1
In the event that works proposed to be undertaken in tidal
waters of the Skardon River are assessable under the
Sustainable Planning Act 2009, owners consent will be
required for a properly made application.
Metro Mining is applying for State Owned Land consent for the
cyclone moorings and tidal gauge. Note that this is only required for
land outside of the Mining Lease. Refer to Section 3.1.1 and Section
3.1.6 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
35
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
16 16.6 5, Appendix E1
The Guideline for the Environmental Assessment of
Subterranean Aquatic Fauna recommends a desktop review
for projects, and where the presence of subterranean
aquatic fauna (stygofauna) is likely, a pilot survey must be
carried out to determine the local presence or absence of
stygofauna.
The proponent has assumed that the groundwater
environment between the Skardon River Project and the
Bauxite Hills Project is similar. However the underground
environment in coastal areas can be highly variable over
short distances and it is possible that the distribution of
stygofauna species is quite different between the two
project areas.
Refer to Section 6.1.4 of the Supplementary Report describing the
results of stygofauna surveys for the SRBP EIS, part of which
included sites within the Bauxite Hills Project area.
16 16.7 Appendix E1
The proponent has identified Great Artesian Basin (GAB)
springs more than 30km east of the project area, but has
not described the potential for a cumulative impact at the
GAB springs from the proponents’ GAB take (400ML, p3-3),
and the cumulative take for other projects, of water from
the GAB.
Impacts to the GAB springs are discussed in Sections 10.2 and 10.5
of the Supplementary Report and Section 3.4.2 of Appendix E1 of
the EIS with specific reference to the modelling study undertaken by
(DSITIA 2014).
16 16.8 Appendix E1
The proponent has not identified all Groundwater
Dependent Ecosystems (GDEs) in the project area (see
comments below).
Refer to Section 10.3 of the Supplementary Report and Section
10.6.3.5 of the EIS.
16 16.9 Appendix E1
Table 3-4 (p38) contains statements that effects are
negligible therefore impacts are unlikely.
Disturbing existing ecological equilibria even by small
amounts may impact an ecosystem. Without knowledge of
system processes and thresholds, assumptions that impacts
are unlikely cannot be made.
Refer to Section 10.3 of the Supplementary Report and Section
10.6.3.5 of the EIS.
16 16.10 Appendix E1
Figure 2-22, Groundwater Dependent Ecosystems, only
displays GDEs reliant on surface expression of groundwater
(Type 2 GDE). The GDE mapping should also identify Type 3
GDEs, as this mapping is also available from the GDE Atlas.
Type 1 GDE mapping has not been carried out for the Atlas,
so is not available except from other sources (see below).
Refer to Section 10.3 of the Supplementary Report and Section
10.6.3.5 of the EIS in regard to GDEs. Refer to Section 6.1.4 of the
Supplementary Report in regard to stygofauna.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
36
16 16.11 5, Appendix E1
The following sentence in the groundwater technical report
is ambiguous:
‘These is not unexpected as the Type 1 aquifer and cave
ecosystems where groundwater-inhabiting ecosystems
reside were not identified within the project area.’
The GDE Atlas has indicated there is no data on Type 1
GDEs available in the project area; however other sources
of data are available.
Please note, Type 1 GDEs (p6 GDE toolbox part 1,
Australian Government, 2011) are typically found in karst
and fractured rock ecosystems as well as saturated
(consolidated and unconsolidated) sedimentary
environments, including the hyporheic zones of rivers,
floodplains and coastal environments, i.e. alluvium:
Figure 2-4 (Surface Geology) identifies Quaternary
alluvium as porous. Additionally the report identifies
other porous formations (kaolinite, bauxite, ironstone,
siltstone, valley fill sands). These formations should all
be identified and discussed as potentially providing an
environment for Type 1 GDEs.
Please also note, Regional Ecosystem mapping has
identified ecosystems developed on Landzone 3 (see
table below). This landzone is broadly described as
‘recent Quaternary alluvial systems’.
Regional Ecosystem Mapping of Landzone 3 (from section
5.5.4 of the Terrestrial Freshwater ecology report, p5-27):
3.3.9 Lophostemon suaveolens open forest on streamlines,
swamps and alluvial terraces
3.3.12 Melaleuca quinquenervia open forest associated
with scattered coastal swamps
3.3.14a Melaleuca saligna +/- M. viridiflora, Lophostemon
suaveolens woodland on drainage swamps
3.3.22a Corymbia clarksoniana or C. novoguinensis
woodland on alluvial plains
3.3.49b Melaleuca viridiflora low open woodland on low
plains
Refer to Section 10.3 of the Supplementary Report and Section
10.6.3.5 of the EIS in regard to GDEs.
Refer to Section 6.1.4 of the Supplementary Report in regard to
stygofauna.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
37
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
3.3.60a Themeda arguens, Dichanthium sericeum closed
tussock grassland on marine plains
3.3.64 Baloskion tetraphyllum subsp. meiostachyum open
sedgeland in drainage swamps in dune fields
17 17.1
As stated in our review of the Terms of Reference for the
project in January/February 2016, the project is not located
near any NPSR interests, and therefore NPSR has nil
comment to make.
No response to this comment is required.
18 18.1 15.2.2
For the purpose of supporting future Cultural Heritage
assessments and management within the Bauxite Hills
Project area, in particular the areas adjacent to Mining
Lease 7024, we wish to provide the below information on
the generalised cultural heritage landscape encountered
through previous cultural heritage work undertaken on the
ML 7024 area.
Metro Mining appreciates the additional information that has been
provided to better understand the cultural heritage values in the
region. No further response to this comment is required.
18 18.2 15.2.2
Previous cultural heritage work has identified the following
cultural heritage sites in areas adjacent to the Bauxite Hills
Project area:
The areas surrounding the branches of the Skardon
River contain numerous stone artefact and culturally
modified tree sites
The areas surrounding the branches of Namaletta Creek
contain a number of shell midden sites, historic landing
areas, stone artefacts, and culturally
modified tree sites.
Refer to Section 15.2 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
38
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
18 18.3 15.2.2
Previous cultural heritage surveys have facilitated the
development of the below predictive statements in regards
to the cultural heritage landscape:
A moderate density of culturally modified trees from
the collection of native honey (sugar bag) are likely to
occur - predominately located within 1 km of existent
or remnant waterways.
A moderate to high density of stone artefacts (n=50-
500) are likely adjacent to rivers, creek lines,
waterholes, and swamps. These will typically occur on
raised gravel ridges.
A very low density of isolate artefacts or low density
scatters {n= <5) may occur on the bauxite plateau.
Historic remains from early mining exploration and the
cattle industry are likely to occur on prominent access
ways.
A low to moderate density of shell midden sites may
occur within coastal zones.
Metro Mining appreciates this information being provided and
highlighting potential areas of cultural significance.
The utilisation of the approved SRBP infrastructure to service the
service the Bauxite Hills Project significantly reduces the risk of
disturbance to cultural heritage in the vicinity of the Skardon River.
Given Metro Mining has an executed CHMA in place with the
relevant Aboriginal parties that include protocols for undertaking
surveys and managing Indigenous Cultural Heritage no update to the
information included in the EIS is proposed.
19 19.1
A summary of some key concerns raised in Part A:
The EIS provides general information on the location
and construction of various infrastructure but does not
confirm its final preferred design and location
Duplication of infrastructure
Impacts on High Ecological Significance (HES) wetlands
The EIS proposes local water quality guidelines and
limits in the draft EA that have not been derived in
accordance with national and state water quality
guidelines (DEHP 2013; ANZECC 2000)
The offsets strategy requires further discussion to give
EHP confidence that a conservation outcome can be
achieved for the impacted matters
Metro Mining notes the key concerns that have been raised. These
concerns are addressed in our responses below.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
39
19 19.2 1.6.1, Table 1-
11, Table 1-14
A granted EA for the proposed project would allow the
proponent to mine bauxite under schedule 2A (ERA 11,
particular resource activities) of the Environmental
Protection Regulation 2008 (EP Regulation). The EA would
also cover the following activities that are directly
associated with, or facilitate or support the mining
activities, and which would otherwise require approval
under the EP Act as ‘prescribed environmental relevant
activities (ERAs)’ listed under schedule 2 of the EP
Regulation.
Whilst the EP Regulation notes some ERAs exclude
resource projects, the activity must still be considered by
EHP and listed as an authorised ERA on the EA if the activity
is to occur on the lease. If these are not listed on the EA,
the proponent would not be able to conduct the activity
lawfully. For example, as the mining activity is a commercial
activity, any ancillary activities to this are also classed as
commercial. As such, any maintenance and repair of boats
(barges) on site would be classed as commercial boat
maintenance and repair.
Based on the information provided in Table 1-11 and Table
1-14 of the EIS, some of the prescribed ERAs and some of
the notifiable activities have not been included. For
completeness, the following ERAs would need to be
considered in the EA for the proposed project:
ERA 8(3) – Chemical storage - storing 500 m3 or more of
chemicals of class C1 or C2 combustible liquids under
AS 1940 or dangerous goods class 3
ERA 33 – Crushing, milling, grinding or screening more
than 5000t of material in a year
ERA 49 - Boat maintenance and repair – Operating, on a
commercial basis, a boat maintenance or repair facility
for maintaining or repairing hulls, superstructure or
mechanical components of boats or seaplanes.
ERA 50(1)(a) – Loading or unloading 100t or more of
minerals in a day or stockpiling 50,000t or more of
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP.
The removal of the BLF, RoRo and MIA for the Project, and
utilisation of the SRBP infrastructure, has significantly changed the
activities that will be undertaken as part of the Project, and
therefore changed the ERA approvals being sought.
Section 3.1.2 of the Supplementary Report discusses the ERA’s
associated with the Bauxite Hills Project and the SRBP. Notifiable
Activities are discussed at Section 3.1.3.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
40
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
minerals within 5km of the highest astronomical tide or
1km of a watercourse
ERA 50(2) – Loading or unloading 100t or more of bulk
materials in a day or stockpiling bulk materials
ERA 63(1)(b) – Sewage treatment or operating a sewage
pumping station with a total design capacity of more
than 40 kL in an hour (100 to 1,500 equivalent persons
with treated effluent discharged through an irrigation
scheme)
For completeness the following notifiable activities,
prescribed under schedule 3 of the EP Act, would also need
to be authorised under the EA as part of the proposed
project:
notifiable activity 1 – abrasive blasting
notifiable activity 7 – chemical storage
notifiable activity 20 – landfill
notifiable activity 23 – metal treatment or coating
notifiable activity 27 – pest control
notifiable activity 29 – petroleum product or oil storage
notifiable activity 37 –waste storage.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
41
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.3 1.6.1, 1.7.3.2,
Table 1-11
Section 1.6.1, 1.7.3.2 and Table 1-11, do not identify the
need for the applicant to acquire an operation works (tidal
works) approval for the installation of cyclone moorings
under the Sustainable Planning Act 2009 (SPA). If any
moorings or other proposed tidal works are proposed in
Queensland State waters outside the mining lease area, the
EIS should outline the development approval requirements
in accordance with the SPA.
The relevant assessment trigger is:
Operational work made assessable under schedule 3, part
1, table 4, item 5, other than—
(a) prescribed tidal work in a canal; or
(b) work that is for the installation, maintenance or repair
of overhead cables or lines that extend over tidal water; or
(c) work that is for the construction, installation,
maintenance or repair of pipelines, cables or lines under
tidal water.
Note: Schedule 3 Part 1 Table 4 Item 5 – For tidal works or
works within a coastal management district
Operational work (other than excluded work, work that is
self-assessable development, PDA-related development or
work carried out on a premises to which structure plan
arrangements apply) that is-
(a) tidal works
(b) any of the following carried out completely or partly
within a CMD
a. interfering with quarry material on State coastal land
above the high water mark
b. disposing of dredge spoil or other solid waste material in
tidal water
c. constructing an artificial waterway
d. removing or interfering with coastal dunes on land other
than State coastal land that is in an erosion prone area
Refer to Section 3.1 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
42
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.4 2.1
The EIS indicated that operations would be undertaken by a
contractor and not necessarily by Metro Mining itself.
Contractors are not included as part of the EIS process
when important commitments are made. It is important
that the proponent ensures that contractors would
implement the commitments.
The draft EMP at Appendix K of the EIS, specifically Table 3-1,
outlines the roles and responsibilities of site personnel. Metro
Mining will ensure contractors will implement commitments
outlined in the EA for the Project.
19 19.5
The EIS provides general comments on location and
construction of various infrastructure, however does not
provide final details on the preferred design and location of
the infrastructure at the project site (e.g. accommodation
camp, sewage treatment plant (STP), irrigation area,
composting area, bioremediation pad/land farm, borrow
pits, sediment basins, power transmission lines, water
wells). This information is important to inform EHP of the
location of proposed infrastructure and proximity to and
potential impact on EVs. Sufficient information needs to be
provided in the EIS for EHP to finalise EA conditions for the
proposed project.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP.
The updated project description is discussed at Section 4 of the
Supplementary Report.
19 19.6 2.2.4
Section 2.2.4 refers to Figure 2-5 (Mining lease tenements
and cadastre) for general arrangement of mine area,
including location of port area. However it does not
reference Figures 2-3 (Project infrastructure) and Figure 2-4
(Mine infrastructure area layout) that show the proposed
disturbance areas for mine pits and infrastructure (e.g.
accommodation camp, STP and associated irrigation area).
The updated project description is discussed at Section 4 of the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
43
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.7 2.3.1, 2.3.2,
2.6.1
The EIS states that the proponent is seeking approval for a
standalone project, however some primary options for the
project (haul road construction/operation and airstrip
utilisation for access) depend on agreements with Gulf
Alumina Limited (Gulf Alumina). The EIS does not provide
details of alternative options that may form part of the
projects approval footprint, if agreements with Gulf
Alumina are not reached. Where there is uncertainty
around key project details, alternative options should be
proposed and presented as a backup to the primary option.
The EIS states that the agreement with Gulf Alumina to
construct two haul roads to connect BH6 West mining
areas to the projects main haul road on MLA100047 are not
essential to the project, however no alternative options
have been proposed. The haul roads planned and
illustrated in Figure 2-5 would intersect Gulf Alumina
mining areas and/or rehabilitation areas depending on the
timing of haul road construction.
The EIS states that the primary site access option for
contractors and staff is to use the Gulf Alumina airstrip,
however this is based on achieving an agreement with Gulf
Alumina. A secondary option of transport via sea is briefly
mentioned; however there are no details about how this
would affect the project if this option is were used.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP.
Given the acquisition of Gulf Alumina by Metro Mining, consent can
now be assured across the tenements and for all operational
requirements as they will be operated by the same company as an
amalgamated operation.
The updated project description is discussed at Section 4 of the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
44
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.8 2.6.1.1
The infrastructure identified in Section 2.6.1.1 does not
align with the information provided in Figure 2-4 (Mine
infrastructure area layout) which notes that the MIA would
also include:
fuel farm
sediment traps grill/grate
RoRo facility
recycling storage
sediment trap
laydown
waste storage
material laydown area
product area 1 and 2
hopper
conveyor.
In addition, section 2.6.1.1 indicates that there would be
multiple workshops however Figure 2-4 only indicates
there would be one. It is possible that some of the
infrastructure noted in section 2.6.1.1 and Figure 2-4 are
the same, but with different names. However, this is not
clear. It is assumed that the following infrastructure not
described in 2.6.1.1 or Figure 2.4 may also be required for
the project:
truck/vehicle wash down facilities
hazardous material/chemical storage area.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP. As detailed throughout the Supplementary
Report, with Metro Mining’s takeover of Gulf Alumina, the Bauxite
Hills Project will utilise the approved SRBP MIA and BLF rather than
constructing standalone MIA, BLF and RoRo infrastructure. The
originally proposed duplication of major infrastructure for the
Project has been completely avoided.
The updated project description is discussed at Section 4 of the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
45
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.9 2.6.1.2
The Skardon River is a high environmental values (HEV)
environment, with the fuel farm proposed to be located in
very close proximity to the river. Due to the isolation of the
site and the potential to impact on HEVs identified in
Skardon River, the EIS should include a commitment that
the proponent would act as first responder to an incident.
The EIS should make a specific commitment that would
ensure that the fuel farm and storage facility is specifically
noted as a risk in emergency response plans, oil spill
contingency plans and first-strike oil spill response plans.
These plans are to be developed in discussion with officers
from Maritime Safety Queensland to ensure that the first
response adequately addresses any potential impacts on
environmental values. The response should include vessel
operation and accidental releases of storage as a credible
spill scenario and should include 1 ML of spill in one
scenario.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP. As detailed throughout the Supplementary
Report, with Metro Mining’s takeover of Gulf Alumina, the Bauxite
Hills Project will utilise the approved SRBP MIA (including the fuel
farm) and BLF rather than constructing standalone MIA, BLF and
RoRo infrastructure. The originally proposed duplication of major
infrastructure for the Project has been completely avoided.
The updated project description is discussed at Section 4 of the
Supplementary Report.
Ports North is responsible for ensuring that an adequate first-strike
oil spill response capability is maintained within the Port of Skardon
River. MSQ is designated as both the Statutory and Combat Agency
for spills that may affect Queensland coastal waters but are outside
of the Port of Skardon River waters.
Notwithstanding the above, Metro Mining will be adequately
prepared to immediately respond to spills.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.10 2.6.1.2
All fuels and chemicals should be stored in a containment
system and managed in a way that prevents release of such
fuels and chemicals to land or waters. All containment
systems for fuels and chemicals should be constructed and
maintained so as to be sufficiently impervious to:
allow retention and recovery of any materials being
stored within the system
prevent contamination of soil or any waters.
Further information is required to clarify details about the
fuel farm/storage area proposed in the MIA.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP. As detailed throughout the Supplementary
Report, with Metro Mining’s takeover of Gulf Alumina, the Bauxite
Hills Project will utilise the approved SRBP MIA (including the fuel
farm and hazardous material storage area) and BLF rather than
constructing standalone MIA, BLF and RoRo infrastructure. The
originally proposed duplication of major infrastructure for the
Project has been completely avoided.
The updated project description is discussed at Section 4 of the
Supplementary Report.
19 19.11 2.6.1.2
Bulk hazardous fuel should be sited outside of the 100 year
average recurrence interval (ARI) flood event to limit the
risk of fuel spillage and releases during flooding. The EIS
does not indicate that this would be the case.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP. As detailed throughout the Supplementary
Report, with Metro Mining’s takeover of Gulf Alumina, the Bauxite
Hills Project will utilise the approved SRBP MIA (including the fuel
farm and hazardous material storage area) and BLF rather than
constructing standalone MIA, BLF and RoRo infrastructure. The
originally proposed duplication of major infrastructure for the
Project has been completely avoided.
The updated project description is discussed at Section 4 of the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
47
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.12 2.6.3
Section 2.6.3 of the EIS outlines construction methods for
the RoRo facility. However, it is unclear whether the ramp
would need to be constructed in the dry season and
whether the impacts of creating this dry area, including
impacts to intertidal benthos and mangroves by excavators
and dozers, are included in the calculations of impacts in
later chapters.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP. As detailed throughout the Supplementary
Report, with Metro Mining’s takeover of Gulf Alumina, the Bauxite
Hills Project will utilise the approved SRBP MIA (including the fuel
farm and hazardous material storage area) and BLF rather than
constructing standalone MIA, BLF and RoRo infrastructure. The
originally proposed duplication of major infrastructure for the
Project has been completely avoided.
The updated project description is discussed at Section 4 of the
Supplementary Report.
19 19.13 2.7.4.1
It is unclear if the EIS includes impacts likely to arise from
construction methods, such as the use of a self-elevating
platform (SEP) (for example direct impacts to the benthos
or indirect impacts from shading), taking into account the
need for the SEP to be relocated during construction to
service several locations.
Refer to Section 1.1 of the Supplementary Report regarding the
acquisition of the SRBP. As detailed throughout the Supplementary
Report, with Metro Mining’s takeover of Gulf Alumina, the Bauxite
Hills Project will utilise the approved SRBP MIA (including the fuel
farm and hazardous material storage area) and BLF rather than
constructing standalone MIA, BLF and RoRo infrastructure. The
originally proposed duplication of major infrastructure for the
Project has been completely avoided.
The updated project description is discussed at Section 4 of the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.14 2.6.1.3
The EIS proposes the construction of borrow pits to supply
material for the haul roads and have proposed the location
of the borrow pits to be adjacent to the haul roads on
MLA100047 and MLA100048. It is assumed that borrow
pits would be required on Gulf Alumina’s MLs for haul
roads to BH6 West. Figure 2-15 and Table 2-6 do not
accommodate the requirement for borrow pits. There
appears to be limited area for borrow pits adjacent to the
haul roads and the feasibility of the construction of borrow
pits adjacent to the haul roads has not been adequately
explained or justified.
Erosion and sediment controls would be required to
manage these pits and they should be located outside of
High Ecological Significant (HES) wetlands.
Metro Mining will utilise the existing borrow pits associated with the
SRBP.
Where additional borrow pits are required they will be positioned as
close as practicable to the construction activities and within
identified haul road corridors. Metro Mining does not propose to
update Table 2-6 as this relates to road design.
Metro Mining commits to implementing ESC measures consistent
with IECA Guidelines.
19 19.15 2.6.1.3
The proponent has proposed construction of haul roads
between active mining areas and the MIA. There is
potential for flooding during heavy rainfall events and it is
not clear in the EIS how flooding of the haul roads and the
potential environmental impacts of this would be managed.
The haul road between BH1 and BH6 is also noted to cross
three creek systems. Insufficient information has been
provided on how the haul road would be constructed
across these creek systems and how the road would be
constructed to minimise impacts to water flow and release
of contaminants to waters.
Metro Mining will utilise the existing SRBP main haul road to access
the SRBP MIA and thereby avoiding the need to construct the
originally proposed north – south haul road.
Metro Mining has also relocated the east – west BH1 haul roads to
avoid the HES wetlands.
Sections 11.3 to 11.7 of the Supplementary Report discuss potential
impacts to haul roads associated with flooding.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
49
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.16 2.6.3
There is an inconsistency between the commentary and the
site plan about whether the mangroves around the RoRo
facility would be trimmed or cleared. The EIS states: “There
is a requirement to clear mangroves to provide
construction clearance width of 15m to allow for a ramp
width of 7.2m”. The plan states “mangroves in this area to
be trimmed”. Clearing of the mangroves, rather than
trimming, would expose mangrove mud and could be a
source of sediment and potentially PASS material which
would need to be managed.
Metro Mining no longer proposes to construct the standalone RoRo
as it will be utilising the approved SRBP BLF and MIA to service the
Bauxite Hills Project. As detailed throughout the Supplementary
Report, with Metro Mining’s takeover of Gulf Alumina, the Bauxite
Hills Project will utilise the approved SRBP MIA (including the fuel
farm and hazardous material storage area) and BLF rather than
constructing standalone MIA, BLF and RoRo infrastructure. The
originally proposed duplication of major infrastructure for the
Project has been completely avoided.
19 19.17 2.6.6.2
The EIS proposes to pump water from shallow and/or deep
aquifer bores for water supply, and store the water in
tanks. No information has been provided in the EIS on the
location of water supply bores, amount of water expected
to be pumped from each bore and location of water
storage tanks (for both mining activities and potable water
supply).
Refer to Section 4.3.6 of the Supplementary Report.
19 19.18 2.7.1
Raw water storage at the MIA and water storage dam have
been mentioned in the list of mine infrastructure. Raw
water storages have been indicated on Figure 2.21, but
have not been described in the EIS not in section 2.6.1.1 –
Mine Infrastructure.
Refer to Section 4.3.6 of the Supplementary Report..
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.19 2.7.6.2
This section notes that construction materials available at
the site is assumed to be suitable as it is the same material
used previously on site for the construction of the existing
haul road and existing air strip.
The Bauxite Hills Project is a proposed greenfield site
project with no existing infrastructure currently on site. If
the above description is referring to the Skardon River
Bauxite Project’s existing infrastructure then this should be
made clear, as it could be interpreted that there is existing
infrastructure already located at the Bauxite Hills project
site. Also, the existing haul road and airstrip at Skardon
River are made from high grade bauxite built during kaolin
mine operations – and are proposed to be mined during
the Skardon River Bauxite Project operations.
Hence, it is not clear if the bauxite resource would be used
to build haul roads. The description does not provide a
contingency in the event that the material is not suitable
for use in the haul road construction.
The Project Description (Chapter 2) and each following chapter of
the EIS states that the Project is a greenfield project. This has now
changed as a result of the acquisition of Gulf Alumina by Metro
Mining and the utilisation of approved SRBP infrastructure to service
the Bauxite Hills Project. Refer to Section 1.1 of the Supplementary
Report regarding the acquisition of Gulf Alumina.
Metro Mining will now utilise the existing SRBP borrow pits to
support the construction of the east – west BH1 haul road. This
material has been used extensively across the SRBP area for the
construction of the haul roads and airstrip.
19 19.20 4.8
The final rehabilitated landform for each of the three
mining pit areas is shown in Figure 4-20 to 4-23.
A final land use plan/map/illustration has not been
provided to address the rehabilitation and
decommissioning requirements of the project.
Reference sites need to be identified, mapped and justified
as to why they are suitable to assist the rehabilitation
completion criteria in Table 4.17.
The proposed rehabilitation approach is to progressively restore the
site with the pre-existing vegetation communities. Hence, the final
land use will be native vegetation. A conceptual illustration of the
proposed rehabilitation is provided in Figure 4-16 of the EIS.
Final predicted landforms following mining and rehabilitation are
already presented for each mining area in Figures 4-18 to Figure 4-
23 of the EIS. Refer to Section 4.8.4 of the EIS which discusses the
proposed decommissioning approach for the Project.
19 19.21 4.8.1.4
It is possible that some on land treatment of ASS would be
required given the possible disturbance of ASS during
causeway and construction of the RoRo facility. However,
the location of ASS treatment areas for ASS disturbed on
land is not indicated on any mapping.
The utilisation of the approved SRBP MIA, BLF and existing haul road
to access the MIA, in addition to the relocation of the east – west
BH1 haul road has significantly reduced the likelihood of impacts
from ASS.
Refer to Sections 5.5 and 5.6 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.22 4.8.3.3 The proposed location of the topsoil or overburden
stockpiles is not presented in the EIS.
Apart from very first cut, topsoil and overburden stockpiles will be
retained in pit. Topsoil for other disturbance areas e.g. east – west
BH1 haul road will be retained on the perimeter of the indicated
disturbance areas. Appropriate management has been described in
Sections 4.8.3 and 4.8.4 of the EIS. Refer to Appendix A3 of the EIS
for ESC measures proposed for the Project during the construction
phase.
19 19.23 4.5.1.5,
4.6.1.3, 4.8.1.4
The EIS provides details including indicative potential acid
sulfate soils (PASS) mapping, current design plans and ASS
laboratory results. Based on that information it is possible
to estimate the potential area and/or volume of ASS that
would be disturbed in order to inform management
measures and the subsequent impact assessment. The haul
road, MIA and port infrastructure are located on the border
or within marine sediments that are highly likely to be ASS.
Disturbing ASS is considered a high risk activity and
therefore the impact assessment should be more definitive
in terms of clarifying the likely areas of ASS, potential
impacts and management measures. The land chapter
states that small areas of the project may disturb ASS;
however the EIS has not provided any estimation of the
potential areas of ASS that would be disturbed based on
indicative PASS mapping, current design plans and ASS
laboratory results.
Given the size and configuration of mining leases
(ML100051 & ML100048), there appears little opportunity
for the haul road, MIA, BLF and RoRo facility to avoid or
minimise disturbance of ASS. The mitigation measures
proposed are brief, overarching and not focused on the
likely impacts the project poses on the environment.
The utilisation of the approved SRBP MIA, BLF and existing haul road
to access the MIA, in addition to the relocation of the east – west
BH1 haul road has significantly reduced the likelihood of impacts
from ASS.
Refer to Sections 5.5 and 5.6 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.24 4.6.1.2
Soil surveys and testing have confirmed that significant
differences in the erosion potential exist between various
soil units. An accurate erosion hazard assessment therefore
should include different soil erodibility factors that reflect
the soil unit’s actual risk of erosion. It appears that the soil
erosion assessment that has informed the conceptual
Erosion and Sediment Control Plan (ESCP) has used the
same soil erodibility factors across all sub catchments,
despite the soil testing and survey work identifying
significant differences between the various soil units.
The number 0.036 used in the RUSLE calculation is the worst case
scenario and includes a 20% safety factor. Emerson Class testing
identified the majority of the soils had a moderate (Emerson Class 4)
dispersive capacity with two samples showing slight (Emerson Class
5) and negligible (Emerson Class 6) dispersive capacities. Given the
worst case scenario was applied to the calculation across the site no
further change to the ESCP is proposed.
19 19.25 4.8.1.3
Important parts of the ESCP appear to be absent including:
wet season erosion and sediment control planning and
implementation;
mining pits are not included as a specific area for ESC
planning and is not considered a higher risk area.
Stockpiles are proposed to be relocated to pits prior to
the wet season posing a risk for sediment mobilisation;
the ESCP is mainly based on the erosion hazard
assessment and does not factor sensitive environments
into its sediment control planning. For example there is
no discussion around the sediment control
requirements around Big Footprint Swamp as a result of
mine extraction activities within close proximity.
Refer to Section 5.3 and 5.4 of the Supplementary Report and
Appendix E of Appendix C of the EIS. Appendix E specifically refers to
the ESC processes to be assessed prior to the commencement of
each wet season.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.26 4.8.3.2
The EIS has undertaken a research review and have
referred to various case studies which indicate that a return
to pre-existing EVs is achievable. There is no explanation of
how these learnings would be applied to the project. The
outcomes specified in the research paper were a result of
specific rehabilitation methods or experiments. The
rehabilitation proposal for the Bauxite Hills project is
general and does not provide specific details about how
rehabilitation would be undertaken to achieve the results
stated in this section.
This is incorporated throughout the rehabilitation section, including
in the discussion around topsoil management (that was identified as
a major issue through Rio Tinto experience and the Gove report),
suitable species to use in rehabilitation, suitable seed mixes to be
used, also suitable fertiliser as required, the range of uses for
cleared vegetation to be used back within the rehabilitation areas -
rather than just windrowing and burning which is standard practice,
Metro Mining is planning to include non-standard, leading practice
methods (e.g. for re-standing a small number of large hollow bearing
trees, placing some cleared vegetation back over topsoiled areas for
immediate habitat and seed stores and the proposed use of
composted material to increase the naturally limited soil volumes in
the region). A commitment to monitoring the success of the
rehabilitation is also included and it is through this monitoring
regime that change based on success rates can be applied to the
rehabilitation program. Metro Mining will continue to consult with
other Cape York operators to ensure best practice rehabilitation in
undertaken at site. No amendment to the information already
included in the EIS is proposed.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
54
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.27 4.8.3.2
The EIS did not consider a number of important indicators
in Table 4-17 that would constitute measurable and
quantifiable indicators of rehabilitated/reference
ecosystem condition and functionality. These include:
tree canopy height and cover
sub-canopy height and cover
proportion of large trees
shrub canopy cover
grass cover
course woody debris
shrub and grass species richness
non-native plant cover
nutrient cycling
soil quality, stability and infiltration
The QLD government has a bio-condition assessment
framework that can be referred to when considering
indicators of ecosystem condition. Furthermore landscape
functional analysis concepts can be referred when
considering indicators of ecosystem function.
Metro Mining has proposed rehabilitation criteria in the EIS that are
appropriate to meet the EHP guidelines for rehabilitation on mines
e.g. the four general rehabilitation goals require rehabilitation of
areas disturbed by mining to result in sites that are:
Safe to humans and wildlife;
Non-polluting;
Stable; and
Able to sustain an agreed post-mining land use.
Metro Mining believes the criteria that have been proposed meet
these requirements and are focussed on successful return of a
natural ecosystem approaching existing conditions e.g. greater than
50% of woody biomass (basal area) to be existing native dominant
tree sp. / stem densities and native species richness, natural seeding
and suckering. The environmental monitoring of rehabilitation areas
will incorporate tree heights etc., however, they are largely
irrelevant if the rehab is made of local native species, is not eroding,
is self-seeding, has a suitable native sp. richness and can be
maintained after fire. Similarly, the geotechnical stability
commitments ensure the stability of the rehabilitated land. Metro
Mining are rehabilitating a mine not doing a bio-condition
assessment. The criteria Metro Mining proposes are specifically
directed to show compliance with the necessary guidelines. No
update to the information provided in the EIS is proposed.
19 19.28 4.8.3.4
Topography maps of pre and post mining landscape
elevation are provided in this section however there are no
maps showing the difference in surface elevation pre and
post mining. Such mapping is beneficial at interpreting the
change in the landscapes hydrology.
Figures 4-18 to 4-23 of the EIS show the original topography to the
modelled mined topography and original topography to the
modelled (predicted) rehabilitated topography for each mine pit,
which together show the difference in surface elevation pre and
post mining. As no changes to the mine plan have occurred since the
release of the EIS no update to the information included in the EIS is
proposed.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
55
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.29 4.8.3.4
The EIS predicts a 3m post mining lowering of the
landscape, on average, which means in some cases it would
be greater or lesser than 3m. As stated above, surface
elevation is a critical landform attribute that dictates the
hydrology and vegetation communities within the Skardon
River area. Surface elevation is therefore also critical at
dictating rehabilitation outcomes for the project.
Metro Mining has already addressed the issue of the lowering of the
land surface and potential for changes to vegetation in response to
this in the EIS. Metro Mining has also provided pre and post mining
landforms. The EHP comment is noted. No update to the
information provided in the EIS is proposed.
19 19.30 4.8.3.4
The EIS states that the mangrove vegetation will be allowed
to naturally recolonise the area and if necessary, the
proponent will commit to undertake appropriate mangrove
revegetation activities.
A reliance on natural re-colonisation of mangroves, rather
than committing to active rehabilitation of cleared
mangroves, is not considered best practice environmental
management and would constitute the minimum action
within the mining rehabilitation hierarchy.
Metro Mining will utilise the approved SRBP MIA, BLF and main haul
road to service the Bauxite Hills Project. In addition Metro Mining
has relocated the east – west BH1 haul road outside of HEV
wetlands and mangrove habitat. Consequently, no mangrove habitat
rehabilitation is anticipated to be required.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.31 4.8.3.4
The project description states that all waste would be
shipped out from the project site but does not mention bio-
remediation pads as a proposed activity. Bio-remediation
pads can be a source of contaminated materials and a risk
to environmental values. Consideration of potential
impacts and management measures is required in the EIS.
Metro Mining will remove waste from the Bauxite Hills site as
proposed in the original EIS but will assess the opportunity to utilise
the approved SRBP landfill for inert waste. Should any change to the
existing landfill approval for the SRBP be required, this will follow
the required EHP approval process. Regulated waste will still be
removed from site as described in the EIS.
Metro Mining is not proposing specific bio-remediation pads, rather
any hydrocarbon contaminated soils will be managed in the
approved SRBP MIA.
A biosolids management area is no longer required as Metro Mining
will utilise the approved SRBP biosolids management area to service
the Bauxite Hills Project.
The waste composting area will be appropriately sized, the pad floor
will be lined or constructed with impermeable material and
appropriately bunded to prevent further contamination.
Refer to Sections 4.4.5 and 4.6.5 of the Supplementary Report.
19 19.32 2.5.6.2
Section 2.5.6.2 of the EIS proposes to make arrangements
to share infrastructure as it would be advantageous for the
project. There are significant impacts proposed on the
Eucalyptus tetradonta woodland, HES wetlands, mangroves
and possibly seagrass beds associated with the project.
EHP is of the view that the impacts could be avoided or
significantly reduced if infrastructure is combined with the
adjoining project. EHP has had discussions with Gulf
Alumina and Metro Mining expressing such concerns. Given
these impacts are potentially avoidable; EHP considers that
they would not be acceptable impacts unless it can be
demonstrated that there is no other alternative available to
having the infrastructure in the proposed location.
As detailed throughout the Supplementary Report, with Metro
Mining’s takeover of Gulf Alumina, the Bauxite Hills Project will
utilise the approved SRBP accommodation camp, MIA (including the
fuel farm and hazardous material storage area) and BLF rather than
constructing standalone MIA, BLF and RoRo infrastructure. The
originally proposed duplication of major infrastructure for the
Project has been completely avoided.
Refer to Sections 1.1 and 4 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.33 5.4.5, of 5-19
The sampling of freshwater aquatic flora and fauna was
inadequate. Limited data creates uncertainty and is unable
to account for natural variation. Additional sampling is
required to adequately assess the seasonal variation in
aquatic communities.
Additional aquatic ecology sampling has been undertaken during
June 2016. An updated description of aquatic ecology values of the
area has been presented in Sections 6.2 and 6.3 of the
Supplementary Report. The Early Dry Season Aquatic Ecology
Technical Report is located in Appendix B of the Supplementary
Report.
19 19.34 5.7.1.15, 5.9
Haul Road crossing impacts on aquatic ecosystems have
not been adequately addressed in general. In particularly
there is no mention of the potential direct and indirect
impacts from the haul road linking BH6 and BH1.
Metro Mining will utilise the existing SRBP mail haul road to the MIA
and as such the originally proposed haul road between BH6 east and
the MIA is no longer required.
Additional aquatic ecology sampling has been undertaken during
June 2016. An updated description of aquatic ecology values of the
area has been presented in Section 6.2.2 and 6.2.3 of the
Supplementary Report. The Early Dry Season Aquatic Ecology
Technical Report is located in Appendix B of the Supplementary
Report. Potential impacts to aquatic ecology values are presented in
Section 5.8.1.16 of the EIS and updated where considered necessary
in Section 6.2 to Section 6.10 of the Supplementary Report. It is
important to note that Metro Mining has relocated the east – west
BH1 haul road outside of HEV wetland areas to further avoid
impacts to these sensitive wetland systems.
Further discussion around the design of creek crossings and flooding
is included in Section 11.4 to 11.7 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
58
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.35 5.9.3 Road crossings of creeks potentially create barriers to the
movement of fish and should be considered in the EIS.
Metro Mining will utilise the existing SRBP mail haul road to the MIA
and as such the originally proposed haul road between BH6 east and
the MIA is no longer required.
The relocation of the east-west BH1 haul road crosses two un-
named creeks. These crossings will incorporate culverts that will
allow fish passage upstream and downstream of the crossings as
outlined in Section 6.3 of the Supplementary Report.
Updated information of the potential impact of the proposed
waterway crossings is provided in Section 6.3 of the Supplementary
Report. Haul road culvert design and drainage are discussed in
Section 11 of the EIS.
19 19.36 5
The current EIS discusses the need for buffers and proposes
a minimum 100m buffer around HES wetlands, however
the adequacy of the buffers to protect the HES wetlands is
not adequately addressed in the EIS, particularly given that
the current proposal requires the clearing of HES wetlands
to accommodate port infrastructure (BLF, causeway and
RoRo facility) and the siting of port infrastructure and haul
roads immediately adjacent or within HES wetlands (see
Chapter 2, Figure 2-4 and 2-14).
However, buffers alone are not sufficient to prevent
environmental harm to HES wetlands. The EIS has not
demonstrated sufficient information on EHP’s preferred
hierarchy for managing likely impacts: to avoid; to minimise
or mitigate; and if necessary, and if possible, to offset (refer
to section 2.5 of the terms of reference for the Bauxite Hills
Project). Instead the EIS proposed offsets without
demonstrating measures to avoid and minimise impacts on
the HES environment.
No mining will be carried out within the nominated buffers.
Metro Mining has been able to significantly expand the proposed
buffer zones through the utilisation of the approved SRBP
infrastructure and also through the relocation of the east-west BH1
haul road away from the sensitive wetland areas.
Where impact to buffer areas is unavoidable, these areas will be
subject to environmental offsets as per the Qld Environmental
Offsets Policy. Refer to Sections 7.7 and 8.5 of the Supplementary
Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
59
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.37 5.9.2.2,
Appendix B2
The section in the chapter does not include sufficient detail
about the proposed REMP and particular proposals for
wetland monitoring. Monitoring should be undertaken for
all HES wetlands potentially impacted by the project, using
reference sites and measuring appropriate indicators.
Refer to Sections 6.9, 6.10, 9.7.3 and 9.7.4 of the Supplementary
Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
60
19 19.38
5.8.1.2,
5.9.2.2,
Appendix E1
The proposed mining areas for the Bauxite Hills Project and
the Skardon River Bauxite Project have the potential to
impact HES wetlands (including the creek south of BH1), Big
Footprint Swamp, Lunette Swamp, Namaleta Creek and the
Skardon River. The individual and combined impact on
groundwater and surface water hydrology from both
projects should be more clearly defined in Section 5.8.1.2.
More information is required in section 5.9.2.2 to clearly
propose how the impacts on wetlands from the proposed
project would be monitored and managed and also how
any cumulative impacts would be managed between the
two operations should they be approved.
Mining on the project’s tenements and mining on Gulf
Alumina’s tenements will each have an impact on Big
Footprint Swamp separately and cumulatively. As both
projects could impact this wetland system, there is a need
to recognise the shared responsibility and not make
assumptions about management approaches.
Metro Mining will utilise the approved SRBP MIA, BLF and main haul
road to service the Bauxite Hills Project. In addition, Metro Mining
has relocated the east-west BH1 haul road outside of the HES
wetlands. The potential for impacts to HEs wetlands has now been
significantly reduced – refer Section 6.5 of the Supplementary
Report.
Surface water and groundwater are discussed in detail in
Appendices E1 and E2 and variously through other EIS chapters such
as Chapter 10 and Chapter 11. The text from the EIS has been
updated to reflect this comment - refer Sections 6.5 to Section 6.10
of the Supplementary Report.
Pre-impact surveys including aquatic ecology, ground water and
surface water sampling have already been carried out for the Project
as is described in Section 5.6.3.2 and Appendix B2 of the EIS. Further
surveys for aquatic ecology have been carried out since the
publishing in the EIS and updated information is provided in Sections
6.2.2 and 6.2.3 of the Supplementary Report. Further sampling for
water quality and proposed water quality monitoring are presented
in Sections 9.6 and 9.7 of the Supplementary Report.
Impacts to catchment hydrology from mining is discussed in Section
3.3 and cumulative impacts to catchment hydrology from mining is
discussed in Section 6.2.2 of Appendix E2 of the EIS.
It is noted that Lunette Swamp lies approximately 1.5 km southwest
of any proposed works for the Project which is well outside of the
predicted groundwater impact zone for Project operations
(Appendix E1 of the EIS) and lies directly adjacent to proposed
mining activity for the SRBP. Monitoring and management activity
for this Project will focus on Big Footprint Swamp which lies adjacent
to Project mining activity.
The REMP will include monitoring of wetlands and watercourses
reasonably assumed to potentially be impacted by the Project. Refer
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
61
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
to Sections 9.7 and 6.10 of the Supplementary Report for further
discussion regarding the REMP.
Refer to Section 1.1 of the Supplementary Report regarding
acquisition of Gulf Alumina.
19 19.39 5.6.3.1
The stygofauna information presented in Chapter 5 is
based on a survey carried out for the Skardon River Bauxite
Project. This survey does not cover the area that is
proposed to be affected within the BH1 mining lease
including the surface springs in close proximity to the BH1
Haul Road.
Refer to Section 6.4 of the Supplementary Report.
19 19.40 7.3, Appendix
B2
The Appendix to the EIS states that there were five regional
ecosystems (REs) not previously mapped but lists a total of
seven REs.
The reference provided by EHP is incorrect and Metro Mining
assumes EHP are referring to Appendix B1 Section 7.3 of the EIS.
Following the results of early dry season surveys (refer Appendix C)
Metro Mining confirmed a total of six new REs within the revised
mapping - RE 3.1.2, RE 3.3.32, RE 3.3.42, RE 3.3.51, RE 3.3.63 and RE
3.3.65 and two new REs for the entire Project area (3.1.2 and
3.3.63). Refer to Section 6.11.1 of the Supplementary Report.
19 19.41 7.4.4,
Appendix B2
Section 7.4.4 refers to special least concern flora however,
this status does not exist for flora under the Nature
Conservation Act 1992.
Special least concern plants are listed in schedule 3A of the Nature
Conservation (Wildlife Management) Regulation 2006 which is
administered under the NC Act. Table 5-9 of the EIS refers to fauna
and is correct in attributing the correct NC Act status level. The
wording in Section 7.4.4 of the EIS describes these species as
'regulated under the NC Act' which is correct. No updates to the EIS
are proposed.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
62
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.42 Table 5-9,
Appendix B1
With the exception of bats, the EIS used the following four
categories to classify the likelihood of occurrence of
species: known (confirmed during field studies), likely
(suitable habitat & known distribution), potential
(possibility of suitable habitat but limited records within or
around the project site), Unlikely (no suitable habitat & not
known in the area).
Some of the species that meet the definition of likely have
been classified as potentially occurring, even though there
is suitable habitat and nearby records placing the project
site within the reasonable range of the species. The EIS only
considered species categorised as known or likely in the
impact assessment and the Offset Strategy in Appendix C.
Therefore some species have been not adequately
considered in the EIS and further information is required
for the red goshawk, northern quoll, masked owl and the
bare-rumped sheath tailed bat.
Where the project proposes to impact on nesting and
roosting habitat, it is likely there will be an impact on these
species.
The consideration of species that are only likely or known to occur is
a standard approach in EIS impact assessments. DotEE itself have
also stated 'The Department considers species assessed against the
significant impact criteria should be categorised as no less than
‘Likely’ to occur' (refer comment 13.7). The updated species
occurrence information is revised in Section 6.13 of the
Supplementary Report.
Under State and Commonwealth legislation offsets are only required
where a 'significant residual impact' is predicted for those species
likely or known to occur. Significant impact assessments have
already been carried out in the EIS and have been updated in
Section 6.13 of the Supplementary Report.
19 19.43
Table 5-9,
Table 8-2,
Appendix B2
Appendix B2 states that there are no known records of the
red goshawk in close proximity to the project and that the
nearest record is approximately 100km SE of the project
site. EHP has information that there is an active nest
approximately 40km south of the project site which is
within foraging range for the red goshawk. This would may
the assessment possible or likely to occur. Also the red
goshawk has been recorded on the Steve Irwin Reserve
which is approximately 50km from the project site5.
Due to the potential presence of foraging and possibly
nesting habitat, and that the project will involve clearing
this habitat, EHP considers that there is the potential that
the project will impacts on this species.
Refer to Section 16.13.1 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
63
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.44 Table 5-9,
Appendix B2
Appendix B2 states that if there are known records in
proximity to the project site and there is suitable habitat
then the species should be classed as likely to occur. The
northern quoll has been classed as possible to occur in
Table 8-2 in Chapter 5. EHP has recently become aware of
an additional record of the northern quoll in the Steve Irwin
Nature Reserve and other records are noted in the EIS in
nearby Mapoon and Scherger air base. Also, Appendix B2
notes that there is fallen timber with hollows in the
tetradonta woodlands which could provide denning
habitat.
Given these factors, there is a real chance or possibility for
the northern quoll to occur on the project site; especially
on BH6. Due to the potential presence of foraging and
possibly nesting habitat, and that the project will involve
clearing this habitat, EHP considers that there is the
potential that the project will impacts on this species.
Refer to Section 6.13.3 of the Supplementary Report.
19 19.45 6.6.1.2
Impacts of vessel movements on water quality are
discussed under the heading- “Surface Water Runoff”,
rather than vessel movements.
The online version of the EIS will be updated to address this
comment.
19 19.46 6.8
Sections 6.6.1.1 and 6.7.1.1 indicate that the project could
have indirect and cumulative impacts on seagrass. More
detail about the potential impacts is required and
management and mitigation measures need to be
proposed in section 6.8.
Metro Mining will utilise the approved SRBP MIA and BLF to service
the Bauxite Hills Project. The utilisation of the approved SRBP
infrastructure reduced the potential indirect and cumulative impacts
on seagrass with likely impacts to be restricted to a small patch of
seagrass (<0.1 ha) associated with the cyclone moorings.
Given the lack of seagrass in the disturbance footprint and broader
area the Supplementary Report has been updated to reflect a lesser
impact than initially considered. Refer to Section 7.3 and Table 6-11
of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.47 6.6.1.2
It is noted that Figure 2-21 in Chapter 2 shows a sediment
pond to capture runoff from the port stockpiles/conveyor.
It is also noted that this pond is expected to overflow in the
wet season. Insufficient detail on this source of water
discharge is included in the EIS. The impacts of this
overflow on marine water quality and the potential impacts
on marine ecology have not been adequately assessed.
Since the release of the EIS, Metro Mining has completed a
successful takeover of Gulf Alumina’s assets, including the existing
infrastructure and proposed operations. The acquisition enables the
use of the approved infrastructure at the port area. The sediment
ponds approved for the SRBP will be used for the MIA.
19 19.48 6.6.2.3, 6.8.1.3
Wildlife can be significantly disrupted by changes in light.
Turtles, roosting birds and marine fauna are particularly
vulnerable. This effect is poorly assessed in the EIS. The
‘turtle friendly lighting’ referred to on page 6-45 had little
explanation however some mitigation measures have been
presented for turtles in 6.8.1.3. Commitments in Section
6.22 does not outline how risk areas/populations will be
identified, how monitoring for light impacts on wildlife will
be undertaken, and does not detail what the ‘turtle friendly
lighting’ solutions would be.
Metro Mining will utilise the approved SRBP MIA and BLF to service
the Bauxite Hills Project. Refer to Section 4.4 of the Supplementary
Report. The use of turtle friendly lighting will be as per the approvals
for the SRBP project.
19 19.49 6.6.2.4
This section states that there would be no impact in the
marine environment from shading. However, it is unclear
which components of the project have been assessed and
whether this statement includes possible impacts of
shading from barges left moored for several months on the
cyclone moorings.
Metro Mining will utilise the approved SRBP MIA and BLF to service
the Bauxite Hills Project. Impacts associated with shading from the
SRBP has been addressed through that project’s EIS.
Potential impacts associated with the cyclone moorings are
discussed in Section 7.3.2 and Appendix D of the Supplementary
Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.50 6.6.5
Marine vegetation communities act as nurseries for
numerous species including those of recreational and
commercial value and help stabilise sediments against
scouring and erosion generally, thus contributing to water
quality and productivity. The section (and related parts of
the EIS) does not acknowledge the full range of impacts
that clearing 20.5ha of mangrove, 0.25 ha of saltmarsh and
0.4 ha of seagrass may result in.
Metro Mining will utilise the approved SRBP MIA, BLF and main haul
road to service the Bauxite Hills Project. In addition Metro Mining
has relocated the east – west BH1 haul road outside of HEV
wetlands and mangrove habitat. Consequently, no mangrove habitat
rehabilitation is anticipated to be required.
The relocation of the east-west BH1 haul road avoid all areas
identified as saltmarsh.
As the originally proposed BLF and RoRo are not required, the
potential to impact marine vegetation, including mangroves and
seagrass, has been significantly reduced. It is now assessed that <0.1
ha of seagrass may be disturbed from activities associated with the
cyclone moorings.
19 19.51 6.7.1.3
Section 6.7.1.3 does not adequately assess the potential
cumulative impacts of sediment pond overflow on marine
water quality. The Skardon River Bauxite Project and this
project both propose the use of sediment ponds that may
overflow in the wet season, however, an assessment of the
cumulative impacts of the two sediment ponds overflowing
in the wet season on water quality and MNES is not
included.
Refer to Section 4.4.1. Since the release of the EIS, Metro Mining has
completed a successful takeover of Gulf Alumina’s assets, including
the existing infrastructure and proposed operations. The acquisition
enables the use of the approved infrastructure at the port area. The
sediment ponds approved for the SRBP will be used for the MIA.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.52 6.6.1.1
The EIS does not provide a clear statement of predicted
impacts to marine communities and species. It is unclear in
the EIS what species are considered to be sensitive
receptors in the marine environment and which of them
are likely to be directly or indirectly impacted by project
activities. Detailed information outlining the zone within
which sensitive receptors would be impacted by project
activities is not clearly or adequately described.
Page 6-38 states that there would be potential indirect
impacts of project activities on seagrass. However, where
these impacts would occur and the area of seagrass likely
to be impacted is not clearly outlined in the EIS. Mapping is
planned to occur as a result of a pre-construction survey.
Describing exactly where seagrass beds are in the EIS would
better inform avoidance and mitigation measures to
minimize impacts on marine fauna likely to use the impact
zone.
As the originally proposed BLF and RoRo are not requiredthe
potential to impact marine vegetation, including mangroves and
seagrass, has been significantly reduced. It is now assessed that <0.1
ha of seagrass may be disturbed from activities associated with the
cyclone moorings.
Refer to Sections 7.3.1, 7.3.2, 7.5 and 7.6 of the Supplementary
Report in addition to Sections 6.5.4.1 and 6.5.4.2 of the EIS.
19 19.53 6.7.1
At present the impact assessment does not contain
sufficient information on the cumulative impacts on water
quality and shore erosion. The EIS should include a more
quantitative assessment of the potential impacts of the
Skardon River Bauxite Project and this project, particularly
impacts on water quality, shore erosion and MNES.
Sections 2.5, 7 and 8 of Appendix B3 of the EIS provides further
detail on the matters of concern.
Since the publication of the EIS, a detailed wave wake modelling
assessment for the Project has been carried out (refer to Appendix E
of the Supplementary Report). The assessment has been
summarised in Section 19.3 of the Supplementary Report and
includes impacts and mitigation measures. Note that the assessment
included the location of the originally proposed BLF and RoRo.
Whilst these are no longer relevant due to the utilisation of the
approved SRBP port area the assessment in relation to barge
movements from the river mouth to the BLF is still relevant.
Section 7.3.2 within the Supplementary Report describes the
predicted impacts to seagrass. MNES are discussed in Section 8 of
the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.54 6.8
Potential impacts to marine habitats identified in Section
6.6.1, includes decreased water quality and disturbance of
PASS. However, the management and mitigation measures
in Section 6.8 do not address decreased water quality or
disturbance of PASS.
The utilisation of the approved SRBP MIA, BLF and existing haul road
to access the MIA, in addition to the relocation of the east – west
BH1 haul road has significantly reduced the likelihood of impacts
from ASS.
Refer to Sections 5.5 and 5.6 of the Supplementary Report.
19 19.55 Table 6-21
Table 6-21 of the EIS states that “Trained marine fauna
observer to inspect area for 30 minutes prior to start”. EHP
is concerned that many species would not be visible from
the surface to make this an effective mitigation measure.
Surface monitoring will be undertaken for the presence of marine
turtles, dugongs and cetaceans.
Trained marine observers is only one of the measures proposed in
the Table 6-21 of the EIS and taken in conjunction, these
management measures are considered effective. Refer to Sections
7.2.1 and 7.2.2 of the Supplementary Report.
Note that with the utilisation of the approved SRBP BLF, the only
piling works proposed by Metro Mining for the Bauxite Hills Project
are associated with the cyclone moorings.
No additional monitoring methods are proposed during piling works.
19 19.56 Table 6-21
Table 6-21 of the EIS indicates that there would be “Soft
start-up of piling operations”, however, there is no
indication of the ramping time. Section 6.8.1.1 dot point 6
indicates some details about the intended soft start-up but
it is not clear whether it is consistent with the literature
which indicates a ramping up between 15 to 30 minutes
would be required to minimise impacts.
Refer to Section 7.2.2 of the Supplementary Report which
incorporates a 15 minute ramp up period for piling operations.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.57 6.8.1.1
This section of the EIS does not provide sufficient
explanation of how the mitigation measures would be
implemented in relation to acoustic impact on species.
Different species have differing thresholds with respect to
the impact of noise levels on their behaviour or health. In
addition, and as raised in comments on Chapter 13 - Noise,
the reflectivity or absorption of noise levels has not been
considered in their effect on noise propagation and so the
true extent of impact is not known.
On page 6-53 of the EIS a 500m safety exclusion zone is
proposed to be established around piling work however it
is unclear whether this would be sufficient for the species
and the levels of noise and vibration generated. Also, it is
not clear how this would be implemented, particularly for
species that are not visible from the surface.
Refer to Sections 7.2.1 and 7.2.2 of the Supplementary Report.
19 19.58 6.8.1.1
The underwater noise and vibration resulting from the
project may have biologically significant effects on
threatened marine species. These potential impacts were
not considered in the EIS for the following marine species:
speartooth shark (Glyphis glyphis) – listed as critically
endangered.
dwarf sawfish (Pristis clavata) – listed as vulnerable.
freshwater sawfish (Pritis pritis) – listed as vulnerable.
green sawfish (Pritis zijsron) – listed as vulnerable.
There is no scientific literature available to assess the impacts of
noise and vibrations on Speartooth Shark or Sawfish spp.
Section 4.4.3.1 of Appendix B3 of the EIS already provides a detailed
analysis of the known impacts of underwater noise on marine fauna.
Section 2.1.15 of Appendix I of the EIS provides an assessment of the
predicted underwater noise levels and impact on marine fauna
produce by large OGVs.
This assessment approach and the proposed mitigation measures
for potential impacts to marine species is consistent with Gulf
Alumina's approach in the SRBP SEIS in regard to the lack of
scientific data to these species.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.59 6.8.2.1, 6.6.2
CSIRO considers that the sawfish species are likely to be in
the Skardon River and the speartooth shark may also be
there. The species are recorded in Port Musgrave and adult
speartooth sharks were recently caught there. Bauxite
mining in the area will result in a significant increase in
vessel traffic in the Skardon River and very little is known
about the ecology and occurrence of these species and
what their response to disturbance may be.
Section 6.6.2 lists potential impacts including fauna
avoiding an area because of disturbance and section states
that a behavioural response to disturbance may occur over
an area of many kilometres. As such, the EIS should provide
reasons why the proponent considers that the long-term
disturbance of the estuary by vessel traffic may not cause
marine fauna to avoid the area. The EIS contains
information about the transhipment area but does not
consider the significant increase in vessel traffic in the
estuary.
Refer to Section 8.4 of the Supplementary Report.
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No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.60 7.9.1.4
It is possible that offsets may be required for impacts to
MNES. The EIS notes that one vulnerable species (black-
footed tree-rat) was found in the Skardon River Bauxite
Project surveys. This species relies on hollows in eucalyptus
tetradonta woodlands and pandanus for habitat which
would be cleared for the project.
The EIS states that no black-footed tree-rat was found
during surveys at the Bauxite Hills Project area. However,
there were no targeted surveys undertaken on the site to
provide evidence that this species would not be present.
Given the species was confirmed in close proximity to the
project site, and suitable habitat occurs on the project site,
the EIS reflects that the species is “confirmed” for the
purposes of the assessment.
A significant impact assessment for the black-footed tree-
rat is included in Table 7-25. It concludes that no significant
impact would result for this species against any of the
criteria. EHP considers that the removal of hollow bearing
trees would indicate that a significant impact is likely to
result from the project.
The information for the Black-Footed Tree Rat is included in Section
8.4.3.3 of the Supplementary Report. The Project requires the
clearing 1,410 ha of Darwin Stringybark woodland (RE3.5.2). This
habitat remains widespread in the surrounding region with a further
44,280 ha located within a 20 km radius of the Project area. Given
the general lack of records and the abundance of this habitat in the
wider landscape no significant residual impacts have been predicted
for this species and therefore no offsets are required. The species
will be part of the Project-specific Significant Species Management
Plan (refer Section 8.4.3.3 of the Supplementary Report).
19 19.61 7, Table 5-9,
Appendix B1
Some of the species that meet the definition of likely have
been classified as potentially occurring, even though there
is suitable habitat and nearby records placing the project
site within the reasonable range of the species. The EIS only
considered species categorised as known or likely in the
impact assessment and the Offset Strategy in Appendix C.
Therefore some species have been not adequately
considered in the EIS and further information is required
for the red goshawk, northern quoll, masked owl and the
bare-rumped sheathtail bat.
Refer to Section 6.13 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.62 7.14
The risk assessment does not include the removal of
marine plants (mangroves and saltmarsh), wetland area or
watercourse REs in the risk assessment within Table 7-49.
The removal of this habitat may potentially impact MNES
species.
Metro Mining will utilise the approved SRBP MIA, BLF and main haul
road to service the Bauxite Hills Project, in addition Metro Mining
has relocated the east-west BH1 haul to avoid HES wetlands.
Consequently that will be no clearance of mangrove or saltmarsh
habitat.
19 19.63 4.8.3.2
The level of groundwater in the groundwater dependent
ecosystems (Big Footprint Swamp and Skardon River)
would provide an important measure of rehabilitation of
the site and whether further rehabilitation work is required
to maintain the water catchment values. This was not
included as a completion criteria in Table 4-17.
Maintenance of stable groundwater levels, within natural variations,
the groundwater dependent ecosystems (Big Footprint Swamp and
Skardon River) have been included as a completion criterion in Table
10-1 of the Supplementary Report.
19 19.64 4
ASS are present on the site and pose a potential hazard to
receiving waters. Figure 4-8 shows areas within the
mangrove and riparian habitats that have a high probability
to generate ASS. Preliminary lab results indicate the
presence of actual ASS in the project area. There is
potential that ASS would be disturbed or removed during
the construction of the MIA, RoRo facility, BLA and haul
roads; and the stockpiles and laydown areas within the MIA
would also be on PASS.
The potential impacts to water quality from the
disturbance, removal or onshore management of ASS are
not discussed in this Chapter. The MIA layout is not shown
on an adequately scaled map that allows the location of
infrastructure and the risk of PASS to be evaluated.
The utilisation of the approved SRBP MIA, BLF and existing haul road
to access the MIA, in addition to the relocation of the east – west
BH1 haul road has significantly reduced the likelihood of impacts
from ASS.
Refer to Sections 5.5 and 5.6 of the Supplementary Report.
19 19.65 5.6.3.2
The water quality information presented in Chapter 5 does
not describe all aquatic habitats within the project area,
such as freshwater streams, swamps and surface springs.
The water quality is likely to vary between these habitats
and water quality data for these aquatic habitat types
should be provided in the EIS. Currently only in situ data at
3 sites sampled once is presented in Chapter 5. Additional
water quality sites are presented on Figure 5-4 and
information for these sites is presented in Chapter 9.
The aquatic ecology section has been updated with surface water
quality data collected for the Project and SRBP. Refer to Sections
6.2.2 and 6.2.3 of the Supplementary Report in reference to aquatic
ecology and Section 9 of the Supplementary Report more generally
for water quality.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.66 9.5.2
It is not appropriate to define water quality objectives
(WQOs) for physico-chemical indicators using the 80th
percentile of background for high ecological value (HEV)
waters. In section 9.5.1 it was recognised that the waters
potentially impacted by the Project area are considered to
be ‘high ecological value’ (waters in which the biological
integrity of the water is effectively unmodified or highly
valued). In ANZECC & ARMCANZ (2000) and the
Queensland Water Quality Guidelines (DEHP, 2009) the
management intent for such waters is to ensure “no
change to existing condition” (refer to appendix D, Table D1
DEHP, 2009). For HEV areas, the principal of ‘no change to
existing condition’ applies to all parameters (including
physical and chemical, biological, toxicants, and habitat and
flow attributes).
It is also not appropriate to use slightly disturbed
ecosystem or livestock drinking water trigger values as
interim WQOs, as the waters within the Project area are
considered to be ‘high ecological value’ and livestock
drinking water is not considered an EV for the Project area.
The methodology used to report and interpret data at or
below the Limit of Reporting (LoR) was not clear and did
not appear to be applied consistently for all data sets
reported.
The water quality data presented in the tables (the data for
Pisolite Hills presented in Table 9-5) contains errors which if
included could affect interpretation of the data.
Since the submission of the EIS further site-specific samples have
been collected. Refer to Section 9 of the Supplementary Report.
19 19.67 9.5.3
The concentration of metal data for the Dulhunty River is
presented in Table 9-4. It is unclear whether this data is for
dissolved or total concentrations of metals.
Since the submission of the EIS further site-specific samples have
been collected. Refer to Section 9.4 of the Supplementary Report.
This excludes the Dulhunty River data as it is no longer required for
the purpose of developing site-specific WQOs.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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19 19.68 9.5.4
There is a lack of adequate water quality data to define
background conditions and define locally relevant water
quality guidelines for the project area. Most sites have only
been sampled once. A single sample is not adequate to
define natural seasonal variations in water quality.
Between 8 and 18 samples over a 12 month period
(preferable 24 months) is required to determine reference-
based guidelines (Queensland Water Quality guidelines
(refer to Table 4.4.2 page 78 DEHP, 2013a)).
Using combined data from the Skardon River project to
define background conditions is appropriate as the Skardon
River project was collected within the same catchment and
is within similar ranges for most parameters. However,
combining data from sites with different water types and
varying characteristics is not appropriate to define
background conditions as each can have very different
water quality.
In addition to this, Table 9-9 notes that S6 and S9 were
used to collect surface water quality information. This is
not considered an appropriate surface water quality
collection site as both these locations are downstream of
an existing release point from the Skardon River Kaolin
mine water pits. As such, these are impacted sites and
would not reflect true background data for this creek
system.
S14 is also noted as an estuarine/marine surface water
quality sampling site. However, this is a designated release
point for a new sediment pond at the Skardon River bauxite
project. Therefore, it is unclear how this location is relevant
to the collection of such data.
These pages present what appears to be raw data for 5
different monitoring locations, referred to as WQ1 – WQ5.
However, these locations have not been referred to in the
water quality chapter (Chapter 9), therefore it is unknown
where these locations are and how these are relevant to
the project and the data collected. If these refer to a
With the addition of water quality data from three further sampling
events undertaken in May, June and July 2016 sufficient sampling
events (i.e. minimum of eight as outlined in the QWQG) to establish
‘interim guidelines’ for the majority of quality indicators were able
to be established based on the 20th, 50th and 80th percentiles.
Refer to Section 9 of the Supplementary Report for discussion on
water quality and Appendix I of the Supplementary Report for draft
EA conditions.
The requirement for consistency in terminology is noted.
The error in the calculations of means for physicohemical
parameters for WQ5 in January 2012 as presented in Appendix D is
noted.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
monitoring location that has been listed in the EIS (EG: W1
– W5), clarification should be provided (preferably in the
water quality chapter) on which location this refers to and
why the reference name has changed. Naming convention
should always be consistent between chapters and
appendices, for ease of reference.
The time series data for WQ5 collected in January 2012,
and the calculated mean for each physiochemical
parameter, includes data collected from WQ1 (date 2/6/12,
time 10:47). As such, the data is skewed. Likewise, as this
data has not been included in the mean for WQ1, the mean
for this will also be incorrect.
19 19.69 9.5.4
Based on Figure 9-2 SW03 and AQ01 appear to be two
different monitoring sites, yet they have been grouped
together as the same site in Table 9-9.
Table 9-9 notes, that AQ02 is a large heavily disturbed
Melaleuca swamp system to the south of S10. Based on
Figure 9-2, AQ02 is based to the north west of S10, not the
south. In addition, it is not clear what is classed as
disturbed. This location is a greenfield site, therefore no
disturbance should be present at the site.
SW03 and AQ01 are different locations but represent sampling
locations within the same water body “Big Footprint Swamp” which
explains why they have been grouped together in Table 9-9 of the
EIS. Descriptions for each site are provided in Table 9-10 of the EIS.
AQ02 is located to the north of SRBP site S10 rather than to the
south as noted in the EIS. Section 9.6.1 of the Supplementary Report
describes the number of sites and samples used to establish
reference conditions and neither AQ02 or S10 (SRBP site) are used.
As mentioned in Table 4.6 of EIS Appendix B2 Large numbers of wild
pigs were observed during aquatic ecology surveys at the Project
site, watering and the open areas around the waterhole were
heavily disturbed from foraging by feral pigs.
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No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.70 9.5.4
Table 9-9 notes, that S6 and S9 were used to collect surface
water quality information. This is not considered an
appropriate surface water quality collection site as both
these locations are downstream of an existing release point
from the Skardon River Kaolin mine water pits. As such,
these are potentially impacted sites and may not reflect
true background data for this creek system.
In addition to this, S14 is noted as an estuarine/marine
surface water quality sampling site. However, this is a
designated release point for a new sediment pond at the
Skardon River bauxite project. Therefore, it is unclear how
this location is relevant to the collection of such data.
Data from sites S6, S9 and data from potentially impacted sites have
not been used in the revised assessments.
Data from site S14 post operation of the new SRBP sediment ponds
will not be used.
Refer to Section 9 of the Supplementary Report for updated water
quality discussions.
19 19.71 Figure 9-2
The location of water quality monitoring sites sampled for
the Bauxite Hills and the Skardon River Bauxite Projects and
the Dulhunty River gauging station are provided in Figure 9-
2. The water quality monitoring sites sampled for the
Amrun and Pisolite Hills Projects are not presented in the
EIS.
Water quality from the Amrun and Pisolite Hills Projects will not be
used to characterise the receiving water for the Bauxite Hills Project
with the relevant surface water monitoring points clarified in
Section 9 and in Appendix I of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
76
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.72 Table 9-2
The surface water and groundwater in this area are
naturally high in aluminium. Background concentration of
aluminium exceeds the ANZECC & ARMCANZ (2000) trigger
value for aluminium (pH>6.5) for both dissolved and total
aluminium at sampling locations within the project area.
The groundwater in the area is also naturally high in copper
and zinc. Background concentrations of copper and zinc in
the groundwater within the project area exceed the
ANZECC & ARMCANZ (2000) aquatic ecosystem toxicant
trigger value for the protection of 95% of species.
The QWQG (refer to Table 4.4.2 page 78) stipulate that to
derive interim or local water quality guidelines, a minimum
of 8 samples per site collected over 12 months (preferably
24 months). Based on the combined Bauxite Hills Project
and Skardon River Bauxite Project’s water quality data from
23 samples the 20th, 50th and 80th percentile for dissolved
aluminium is 23.8, 64 and 130 μg/L respectively. The
variation in water quality between sites, however, needs to
be evaluated before the combine water quality data for
both projects can be used to determine interim local water
quality guidelines. For example, some differences were
found between Skardon River data and the current project.
The EIS used an estuarine/marine WQO for aluminium of
0.5μg/L. According to recent guidelines, a figure of 2.1 μg/L
(for 99% species protection) total aluminium in estuarine
marine waters should be used (as published by Golding et
al., (2015)).
With the addition of water quality data from three further sampling
events undertaken in May, June and July 2016 sufficient sampling
events (i.e. minimum of eight as outlined in the QWQG) to establish
‘interim guidelines’ for the majority of quality indicators were able
to be established based on the 20th, 50th and 80th percentiles. For
some parameters there remains insufficient data to establish interim
guidelines and for these, where possible, Metro Mining have
defaulted to the ANZECC / ARMCANZ 2000 guidelines for tropical
waters 99% species protection levels.
Refer to Section 9 of the Supplementary Report for water quality
and Appendix I of the Supplementary Report for revised EA
conditions.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
77
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.73 Table 9-2
There is limited data to derive local freshwater and marine
water quality guidelines. The guidelines should be
considered as interim and be revised when further data
becomes available. Interim local guidelines should be
determined based on Comments 11, 13 and 15 above.
With the addition of water quality data from three further sampling
events undertaken in May, June and July 2016 sufficient sampling
events (i.e. minimum of eight as outlined in the QWQG) to establish
‘interim guidelines’ for the majority of quality indicators were able
to be established based on the 20th, 50th and 80th percentiles. For
some parameters there remains insufficient data to establish interim
guidelines and for these, where possible, Metro Mining have
defaulted to the ANZECC / ARMCANZ 2000 guidelines for tropical
waters 99% species protection levels.
Refer to Section 9 of the Supplementary Report for water quality
and Appendix I of the Supplementary Report for revised EA
conditions.
19 19.74 9.3.2
The Environmental Protection Regulation 2008 (EP
Regulation) includes a performance outcome for wetlands
which is: “there will be no potential or actual adverse effect
on a wetland as part of carrying out the activity”. The
current performance outcome stated in the EIS for
wetlands is not consistent with those stated in the EP Reg.
The proposed performance criteria in the EIS reflects that there will
be impacts and these impacts will be prevented or minimised to the
extent possible. As such no amendment is proposed.
19 19.75 9.5.4
This section of the EIS refers to table 9-7 and table 9-9 for a
list of the surface water monitoring locations, and figure 9-
2 for a map of where these are located. However, not all
locations listed in this table are reflected in figure 9-2.
Specifically, the following locations are missing from figure
9-2:
S11
SW04
SW06
SP01a
S3
S8
S14
All monitoring locations should be listed for ease of
reference for the reader.
The proposed surface water and groundwater monitoring locations
have been updated as discussed in detail in Section 9 and Appendix I
of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
78
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.76 9.5.6
The surface water quality results presented in Table 9-11
depict a very limited amount of data that is representative
of the various freshwater environments.
The freshwater stream water quality results in Table 9-11
come from the following freshwater environments that
should ideally be characterized separately;
SW01/AQ03 is a freshwater stream (Irish Creek);
SP01 was a wet season spring expression at ground
surface near Irish Creek;
AQ01/SW03 is Big Footprint Swamp, a freshwater
wetland; and
AQ02 is described as a large heavily disturbed
Melaleuca Swamp system.
Furthermore, the freshwater quality data provided in Table
9-11 ranges from 8 to 2 samples. Considering these
samples were taken across the various freshwater
environments described above (springs/swamps/creek),
they provide a limited reference data set capable of
characterising the various freshwater environments.
It is not clear how many samples have been taken within
the Irish Creek system that will be impacted by a haul road
and lays adjacent to the BH1 mining area. It is likely that
there is very limited data of this freshwater system. It
should be noted that the Skardon River Bauxite Project did
not monitoring this freshwater system. It would not be
appropriate to use the Skardon River Bauxite Project data
from Namaleta Creek in replacement of obtaining
reference condition data.
With the addition of water quality data from three further sampling
events undertaken in May, June and July 2016 sufficient sampling
events (i.e. minimum of eight as outlined in the QWQG) to establish
‘interim guidelines’ for the majority of quality indicators were able
to be established based on the 20th, 50th and 80th percentiles. For
some parameters there remains insufficient data to establish interim
guidelines and for these, where possible, Metro Mining have
defaulted to the ANZECC / ARMCANZ 2000 guidelines for tropical
waters 99% species protection levels.
Whilst it is acknowledged that these sites represent systems that
may be classified differently, one-way ANOVA assessment of
variance in water quality between sites indicates sufficient similarity
for their use in this instance. As additional data is collected it will be
possible to establish classifications unique to each system.
Refer to Section 9 of the Supplementary Report for water quality
and Appendix I of the Supplementary Report for revised EA
conditions.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
79
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.77 9.5.6.1
Recommended site specific pH value despite
acknowledging not enough data points collected as per
ANZECC. This is not appropriate.
With the addition of water quality data from three further sampling
events undertaken in May, June and July 2016 sufficient sampling
events (i.e. minimum of eight as outlined in the QWQG) to establish
‘interim guidelines’ for the majority of quality indicators were able
to be established based on the 20th, 50th and 80th percentiles. For
some parameters there remains insufficient data to establish interim
guidelines and for these, where possible, Metro Mining have
defaulted to the ANZECC / ARMCANZ 2000 guidelines for tropical
waters 99% species protection levels.
Refer to Section 9 of the Supplementary Report for water quality
and Appendix I of the Supplementary Report for revised EA
conditions.
19 19.78 9.5.7
A description of the groundwater quality of bores and any
similarity and differences between major ions within bores
and aquifers is not presented in the EIS.
The water quality within the shallow aquifer is sampled and
data is presented in the EIS. There is no data presented on
the water quality within the deeper GAB aquifer. There are
potentially water quality differences between these
aquifers however data describing the quality of the GAB
aquifer has not been presented in the EIS.
The shallow aquifer is proposed to be used for drinking
water and the deep GAB aquifer for other uses. The water
quality in both aquifers needs to be compared to guidelines
based on the proposed use of the water.
The piper diagram of groundwater samples (Figure 9-6,
page 9-41) suggests ionic differences between bores in the
shallow aquifer. Based on this data there may be
differences between the bores in BH1 and BH6.
Metro Mining has submitted a temporary water permit application
pursuant to s237 of the Water Act 2000. Information required to
assess this application has been submitted through a separate
approval process to DNRM. Refer to Section 4.3.4 of the
Supplementary Report in regard to the application process.
The groundwater quality of the shallow aquifer relevant to the
water permit is described in Section 9.5.7 of the EIS. This includes
discussion around the analysis of the major ions and also a piper
diagram presents the relationship of the water quality between the
bores.
Section 9.5.2 of the Supplementary Report has been updated to
include additional discussion regarding groundwater quality through
the three recent rounds of groundwater sampling and monitoring.
Should it be the case that GAB water is required further assessment
of the water quality characteristics will be undertaken and the EA
amended accordingly.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
80
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.79 9.5.7 Interim local groundwater WQO have not been proposed in
the EIS.
With the addition of water quality data from three further sampling
events undertaken in May, June and July 2016 sufficient sampling
events (i.e. minimum of eight as outlined in the QWQG) to establish
‘interim guidelines’ for the majority of quality indicators were able
to be established based on the 20th, 50th and 80th percentiles. For
some parameters there remains insufficient data to establish interim
guidelines and for these, where possible, Metro Mining have
defaulted to the ANZECC / ARMCANZ 2000 guidelines for tropical
waters 99% species protection levels.
Refer to Section 9 of the Supplementary Report for water quality
and Appendix I of the Supplementary Report for revised EA
conditions.
19 19.80 9.5.7
Table 9-16 indicates that despite being a major area of
proposed impact, there has been no wet season
groundwater quality data collected from the BH1 mining
area.
The seasonal variations in groundwater levels and quality
should be established prior to mining commencing in order
for test site/compliance data collected during and after
mining to be able to detect any impacts as a result of
mining activities.
Continuous groundwater level data is provided in Section 2.4.4 of
Appendix E1 of the EIS.
Background groundwater quality establishing the 20th, 50th and 80th
percentiles over an average of 65 data points across the parameters
is presented in detail in Section 9 of the Supplementary Report.
Once the Project is operational ongoing wet season groundwater
monitoring will be undertaken.
19 19.81 9.6.1
The EIS states that the Irish Creek tributary of the Skardon
River is at most risk of sedimentation impacts due to the
BH1 haul road and mining areas. The freshwater quality
sampling undertaken to date does not appear to have
focused on establishing baseline water quality data for this
freshwater system. Based on the risk of impacts, this data
gap should be addressed.
An additional water quality monitoring site has been nominated for
the Irish Creek system downstream of the haul road and mining
activities. The location of this site (W2(SW01)) is illustrated in
Appendix I in the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
81
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.82 9.7.1
The EIS states that the water quality of Big Footprint
Swamp may be impacted by the close proximity of mining
activities. Also it states that “Detailed erosion and sediment
control measures will be implemented to minimise
sediment mobilisation into Big Footprint Swamp”. The ESCP
provided in Appendix A3 is “conceptual” by nature and has
not been designed based on the protection of the Big
Footprint Swamp environmental values. Also, it states that
no releases of contaminated water will occur in Big
Footprint Swamp however the ESCP has proposed to
“minimise” not “prevent” sediment mobilisation into Big
Footprint Swamp.
The EIS includes a performance outcome for wetlands on
page 9-4 as “The activity will be managed in a way that
prevents or minimises adverse effects on wetlands” which
is inconsistent with that listed in the EP Regulation.
It appears that basic erosion hazard assessments have been
used to inform the design of the “conceptual” ESCP
however the significant EV’s of the Big Footprint Swamp,
should also be considered as a means of designing a
“detailed” ESCP that will adequately protect the Big
Footprint Swamp and other freshwater systems prone to
sedimentation impacts.
Refer to Sections 5.3, 5.4, 6.6 and Appendix I of the Supplementary
Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
82
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.83 20
While it is recognised that Figure 20-3 of Chapter 20
indicates the location of RP1 and coordinates are provided
in the draft EA Conditions in Chapter 20, Chapter 9 does
not contain a map at a suitable scale to indicate the likely
location of release points for the project. This would
include point of release from sediment dams but also
potential release points in the vicinity of the MIA in the
event of a spill or accident in handling hazardous
substances.
The following matters need to be amended or resolved in
the draft EA conditions:
Table 20-7 notes there is no release points, however
receiving water monitoring locations have been
proposed. If no release is proposed for this system,
then the EIS should clarify why SW01 and SW03 are
proposed as receiving water monitoring locations
for tables 20-7 and 20-8, no description of the receiving
waters has been provided (eg” Skardon River, Namaleta
Creek, Irish Creek). This information will be used to
form release limit and receiving water trigger values
release limits have not been proposed for RP1 (listed in
Table 20-8)
Metro Mining will utilise the approved SRBP MIA to service the
Bauxite Hills Project. As a consequence no release points are
proposed for the Bauxite Hills Project. Refer Section 9 of the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
83
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.84 9.6
EHP reviewed the proposed sediment basin design and
concluded that it is inappropriate for the scale of operation
and location (wet tropics with high rainfall events during
summer). The 5 day storm design following the
International Erosion Control Association Manual is
typically used as design criteria for high efficiency sediment
basins. They are generally used for smaller projects and in
practice, these design storm criteria are typically smaller
than the 1 in 10 year 24 hour storm event as they exclude
very high rainfall periods. EHP recommends that the
minimum design standard of the erosion and sediment
control ponds should be designed to capture rainfall during
a 1:10 ARI 24 hour storm event.
The location and design of the wharf drainage sump and
MIA recovery slot referred to in Figure 9-8 needs to be
included in the assessment of potential impacts on water
quality.
Since the release of the EIS, Metro Mining has completed a
successful takeover of Gulf Alumina’s assets, including the existing
infrastructure and proposed operations. The acquisition enables the
use of the approved infrastructure at the port area. The sediment
ponds approved for the SRBP will be used for the MIA.
19 19.85 9.6
Onshore management of ASS is proposed as a management
method during construction of the RoRo facility in Chapter
2, Section 2.7.5 and Chapter 4, Section 4.8.1.4. The location
of onshore management of ASS is not discussed in the EIS.
The potential impacts to water quality from the
disturbance, removal or onshore management of ASS are
not discussed in Chapter 9.
The utilisation of the approved SRBP MIA, BLF and existing haul road
to access the MIA, in addition to the relocation of the east – west
BH1 haul road has significantly reduced the likelihood of impacts
from ASS.
Refer to Sections 5.5 and 5.6 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
84
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.86 9.8.8
The design of a REMP program should be undertaken in
accordance with the Receiving Environment Monitoring
Program Guideline - For use with Environmental Relevant
Activities under the Environmental Protection Act (1994)
(EHP 2014).
The proposed surface water and groundwater monitoring
sites, parameters, monitoring frequency and trigger levels
that would be used to assess impacts for freshwater,
marine and groundwater sites are not included in Chapter
9. Monitoring of the GAB as part of the REMP was also
missing.
Metro Mining notes the need to follow EHP's guideline in preparing
the REMP. Metro Mining also note that the purpose of the REMP is
to monitor potential impacts from actual or potential releases of
contaminants to water. As the Project is only proposing to release
water from the MIA to the Skardon River, the purpose of including
standard water quality monitoring requirements in the REMP is
queried as Metro Mining believes these are adequately covered in
the water monitoring section of the draft EA conditions.
Monitoring of the GAB is not relevant for the REMP due to the
shallow nature of the bauxite mining. Water quality monitoring will
be undertaken as part of the operational requirements of the mine
and will be included in the groundwater monitoring requirements of
the draft EA. Detailed discussion around the extent to which the
Project will interact with the GAB is provided throughout Appendix
E1 – Groundwater of the EIS.
Monitoring frequencies and parameters for other water monitoring
commitments are described in Appendix I of the Supplementary
Report.
Given Metro Mining has committed to the preparation of a REMP,
and the further commitment to prepare the REMP in accordance
with the Receiving Environment Monitoring Program Guideline - For
use with Environmental Relevant Activities under the Environmental
Protection Act (1994) (EHP 2014) no update to the information
included in the EIS is proposed. It is proposed to add a condition to
monitoring water quality from the GAB production bore as part of
the groundwater monitoring requirements in the draft EA.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
85
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.87 9.10 The Chapter Summary does not include potential impacts
from sediment basins or ASS.
Metro Mining acknowledges that the Chapter 9 summary does not
include impacts from sediment ponds or ASS. Sediment ponds and
ASS are discussed in detail in Appendix A3 of the EIS (specifically
Section 3.4.2.1 and Section 5.5.3). Section 5.1.2 and 5.1.3 of the
Supplementary Report discuss ASS. Sediment ponds are discussed in
Sections 4.3.1, 11.1.1 and 11.1.6 of the Supplementary Report.
19 19.88 11.4.2.3
From Figure 11-4 and Figure 11-6 it appears that the MIA
may be impacted by the peak 1,000 year ARI, including the
RoRo facility and sediment traps. It is however, difficult to
determine due to the scale of the map provided showing
the MIA.
Metro Mining will utilise the approved SRBP MIA to service the
Bauxite Hills Project. As such this comment is no longer relevant.
19 19.89 10.4.3
The EIS identified that haul roads would be impacted by
flooding (see 11-4 and Figure 11-6). It is proposed in the EIS
to construct low flow culverts which allow a 2 year ARI to
pass under the haul road (Section 11.5). In larger flows,
flood water would pass over a floodway.
The design for a 2 year ARI event may be a sufficient culvert
sizing design to adopt if the operations are proposed only
during the dry season. However, in this case the culvert
sizing and design would also need to suit wet season
conditions.
It is not clear in the EIS how the culverts will be affected by
wet season rain events and what potential issues could
arise as a result of the designs. There could be potential
impacts to water quality during wet weather when haul
roads are inundated by flood waters.
Refer to Sections 11.3 and 11.4 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.90 Appendix D
These pages present what appears to be raw data for 5
different monitoring locations, referred to as WQ1 – WQ5.
However, these locations have not been referred to in the
water quality chapter (Chapter 9), therefore it is not known
where these locations are and how these are relevant to
the project and the data collected. If these refer to a
monitoring location that has been listed in the EIS (EG: W1
– W5), clarification should be provided (preferably in the
water quality chapter) on which location this refers to and
why the reference name has changed. The naming
convention should always be kept consistent between all
chapters and appendices, for ease of reference.
The time series data for WQ5 collected in January 2012,
and the calculated mean for each physiochemical
parameter, includes data collected from WQ1 (date 2/6/12,
time 10:47). As such, the data is skewed. Likewise, as this
data has not been included in the mean for WQ1, the mean
for this will also be skewed.
The error in the calculations of means for physiochemical
parameters for WQ5 in January 2012 as presented in Appendix D is
noted and will be corrected for any revisions of the EIS.
More recent data has been used to establish interim reference
criteria for the 20th, 50th and 80th percentiles for upper estuary
waters of Skardon River as presented in Section 9 and Appendix I of
the Supplementary Report.
19 19.91 10.6.3
There is uncertainty as to whether bauxite mining will
intercept any meandering paleo-channels that may affect
Lunette Swamp, Namaleta Creek and Big Footprint Swamp.
If this was the case, the hydrology of these wetlands may
be adversely affected.
Refer to Section 10.6 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.92 10.6.3.5
The EIS states that the spring observed during the 2015 wet
season (SP01) is not considered a GDE as it does not meet
the classification of a GDE. Sufficient justification why the
spring (SP01) does not meet the definition of a GDE has not
been provided.
The EIS assumed the spring (SP01) is an ephemeral wet
season feature, based on a desktop study of aerial imagery
in 2011 by WorleyParsons. No follow up survey details
were undertaken of the area to determine the extent and
period the spring flows and if there are any other springs
within the area. The spring (SP01) is found immediately
within the footprint of the haul road between BH6 east and
BH1 mining areas (see figure) and therefore likely to be
impacted by mining activities. The spring (SP01) is absent
from the impact assessment.
During the wet season the water table rises and intersects the
ground surface over low lying areas. The groundwater impact
assessment considered the effects of bauxite mining on
groundwater discharge and found that due to a very small increase
in peak discharge rate (up to 5%) it is unlikely that significant
potential impacts on the health of the ecosystem would arise.
The identified ephemeral spring (SP01) is located outside the area of
predicted influence (and on the adjacent side of the local
groundwater flow system/discharge zone), indicating that bauxite
mining will not result in a significant impact.
Refer to Sections 10.2 and 10.3 of the Supplementary Report.
19 19.93 10.6.5
The section named Calibration Performance Criteria states
the “dry season stress period lengths range from 276 to
305 days”. It appears unrealistic that a dry season stress
period would last 276 to 305 days of a year.
Dry season stress periods are, as described, periods over in which
there has been insufficient rainfall to cause recharge and associated
increase in groundwater level. The bore hydrographs and rainfall
presented in Section 2.4.4 of EIS Appendix E1 clearly show that the
groundwater level steadily declines from the highest to the lowest
elevation over a period that ranges from 276 to 305 days. Stress
periods have been appropriately set to match the periods of
effective recharge and peaks in the groundwater levels, producing
annual recharge rates that are entirely consistent with recharge
estimated from other modelling studies. If stress period lengths are
altered, periods of active recharge will change, producing
discrepancies between the computed and observed hydrographs.
Refer to Section 10.5 of the Supplementary Report for further
discussion.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.94 10.6.3.5,
10.6.5
The groundwater predictive modelling predicts about a
1.5m increase in groundwater elevation due to mining at
BH6MB3D and it is assumed a similar increase would be
applicable to BH6MB2D next to Big Footprint Swamp.
Figure 10-15 Big Footprint Swamp schematic cross-section
indicates that the wet season groundwater level rises to
the base of the bauxite layer. A predicted 1.5m increase in
groundwater level would bring the wet season
groundwater level to an elevation well-above the ironstone
layer. It appears that if the groundwater levels are
predicted to increase to an elevation well above the
ironstone layer, then it will be contributing significantly to
overland flow following mining.
The reference to "overland flow" is assumed to represent
overtopping of groundwater discharging into the
mined/rehabilitated pits. If so, this is highly unlikely to happen. An
increase of up to 1.5 m is predicted to occur (before bauxite is
removed) due to the rapid filling of macropores (tight vugs and
fissures) as recharge is increased over the adjacent mined areas.
Once the bauxite is stripped away and a depression is formed after
mining, the rising water table will intersect the floor of the pit and
groundwater will discharge into the pit. Because of the large volume
of the pit (open space that provides significant increase in storage
compared to the macropores) and effects of evaporation, significant
volumes of groundwater would be necessary to completely fill the
pit and overflow. Given that the maximum 1.5 m increase in the
water table is not predicted to reach the pre-mining ground surface,
it is highly unlikely that there will be sufficient volume of
groundwater discharging into the open pit (representing a much
larger storage volume) to cause overland flow. Refer to Section 10.5
of the Supplementary Report for further discussion.
19 19.95 10.6.5.3
The EIS has not provided any details around the modelling
of groundwater impacts to the shallow aquifers as a result
of groundwater extraction, only the basic outcome has
been provided. Furthermore, the predicted extraction rates
from the Gulf Alumina project have not been included in
the impact assessment.
Section 10.6.5.3 of the EIS describes modelling undertaken to assess
the potential impacts of extracting 400 ML/yr groundwater from the
shallow aquifer. Potential combined effects of pumping due to the
Bauxite Hills Project and SRBP can be assessed although this is likely
to be small due to the predicted localised drawdown and the
location of Gulf Alumina's bores within Namaleta and Lunette
aquifer, at some distance from Bauxite Hills proposed water supply
bores drawing from the Bulimba aquifer.
Refer to Section 10.5 of the Supplementary Report for further
discussion.
19 19.96 10.9.2
The section does not provide details about the proposed
groundwater monitoring network, assessment approach, or
reporting proposals. These details are relevant to the
development of a draft environmental authority.
Refer to Section 9 and Appendix I of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
89
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.97 10.9.1
The REMP will be an important management and
mitigation tool used to detect changes to groundwater
quality and therefore trigger management actions but it
has not been mentioned in this section.
Metro Mining notes the need to follow EHP's guideline in preparing
the REMP despite this not being included in Section 10.9.1 of the
EIS. The REMP is discussed in Chapter 9 of the EIS (Section 9.8.8).
Metro Mining has made a commitment in Table 9-21 of the EIS to
develop and implement a REMP to monitor water levels and quality
and Big Footprint Swamp. Given Metro Mining has committed to the
preparation of a REMP, and the further commitment to prepare the
REMP in accordance with the Receiving Environment Monitoring
Program Guideline - For use with Environmental Relevant Activities
under the Environmental Protection Act (1994) (EHP 2014) no
update to the information included in the EIS is proposed.
19 19.98 10.9.2.1 to
10.9.2.3
More information is required regarding groundwater
monitoring to inform the conditions on the EA.
As stated in Section 10.9.2.3 of the EIS, Metro Mining commits to preparing and implementing a Water Management Plan and collection of additional data, which will ensure ongoing information relating to groundwater conditions for the EA. The Water Management Plan will address potential water quality impacts as assessed in Chapter 9 and be relevant to the final EA Conditions. Metro Mining proposes, in the Draft EA conditions (Appendix I of the Supplementary Report), that the Water Management Plan be submitted to the administering authority at least 30 business days prior to the commencement of construction. Metro Mining has also undertaken an additional three rounds of both surface water and groundwater monitoring since the EIS was submitted. The additional water quality data is included in Section 9 of this Supplementary Report.
19 19.99 10.10
The draft ESCP is discussed in Sections 10.9.1.2 and
10.9.1.3 as a surface water management and mitigation
measure. ESCP should be included in Table 10-25 as a
surface water management and mitigation measure.
Section 10.9.1.2 and 10.9.1.3 of the EIS demonstrates that the ESCP
will be used as a management and mitigation measure for surface
water. Water quality monitoring is discussed in Section 9 of the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
90
19 19.100
2.6.5, 11.6,
Appendix E2
(Section 4.1)
In Chapter 2 on Description of the Project, in Section 2.6.5,
it states that the MIA Sediment Basin would be sized to
capture and treat the 1 in 10 year ARI, 24 hour storm event.
This is the standard required by the DEHP Stormwater
Guideline. The EIS also states that sediment basins would
have sediment removed prior to the commencement of the
wet season to provide a maximum storage capacity.
The 1 in 10 year ARI, 24 hour storm from BOM is 235
millimetres at Skardon River. The area of the Mine
Infrastructure Area shown in Table 2-1 of the EIS is 6.05 ha.
Based on these two figures the runoff which needs to be
held in the MIA Sediment Basin in a 1 in 10 year rainfall
event is 14.2 Megalitres (ML).
In Chapter 2 in Figure 2-4 and again in Figure 2-14 the two
Sediment Dams catching sediment from the MIA are shown
on the eastern side of the product storage and works area.
To hold the 1 in 10 year rainfall event from the MIA two
Dams would need to be 7.1 ML each. Based on the scale
shown in Figure 2-4 these two Sediment Dams are only 30
m x 15 m and manifestly too small to hold the runoff
volume of 14.2 ML. If the average depth is 2 metres, these
Dams would hold only 0.9 ML each, seriously short of the
total requirement for the MIA. In addition the locations
shown on Figure 2-4 may not be suitable if the river bank
slopes and contours are unfavourable.
The proximity of the MIA Sediment Dams to the Skardon
River increases the risk of sediment discharge to the River if
the Basins are not effective. There are diversion banks
shown as lines in Figure 2-4 which are critical to
successfully collecting runoff from the MIA. There is also a
sediment trap grill/gate at the RoRo facility. How these
elements would work together effectively is not discussed.
There is no indication shown on Figure 2-20 as to how
runoff from the MIA in storm events would be directed
towards the Sediment Dams rather than flowing straight
down onto the ramp of the RoRo facility and then into the
Since the release of the EIS, Metro Mining has completed a
successful takeover of Gulf Alumina’s assets, including the SRBP and
all existing infrastructure and proposed operations. The acquisition
enables the use of the approved infrastructure at the port area. The
sediment ponds approved for the SRBP will be used for the MIA.
Refer to Sections 4.4.1 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
91
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
Skardon River.
In Chapter 11 in Section 11.6 on Regulated Structures it is
stated that the sediment dams required for the project
would be less than 2.5 ML in size. As discussed above it
appears that the two Sediment Dams shown in Figure 2-4
for the MIA may have to be much larger than 2.5 ML, or
alternatively there would have to be many more than two
Dams to retain the sediment and runoff if the sediment
retention standard is to be achieved.
The commitment to retain stormwater runoff and sediment
in the 1 in 10 year ARI, 24 hour event, as described in the
EHP Stormwater Guideline, was also made in Section 4.1 of
Appendix E2 – the Surface Water Technical Report. The
Erosion and Sediment Control Plan is referenced in
Appendix 3 for further information about sediment control;
but there is no information in Appendix 3 about the
Sediment Dams collecting runoff from the MIA.
The information supplied in Chapter 2 and Appendix E2
does not provide assurance that the site would be able to
direct, capture and manage sediment laden runoff flowing
out of the MIA towards the Skardon River.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
92
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.101 11.6
The EIS states that the project met the following exemption
requirements for the undertaking of the consequence
category assessment under EHP’s Manual for assessing
consequence categories and hydraulic performance of
structures 2016:
contain fluids for no longer than 24 months
store less than 2.5ML of fluids
However the manual also provides the following
exemptions, which have not referred to:
minimise the site-specific risks of seepage
minimise passage of the wetting front and
allow the structure to be managed in a way that first
prevents then minimises the potential of fluids
overtopping
The exemption of the consequence category assessment
should meet all the exemption requirements in the
Guideline.
Since the release of the EIS, Metro Mining has completed a
successful takeover of Gulf Alumina’s assets, including the SRBP and
all existing infrastructure and proposed operations. The acquisition
enables the use of the approved infrastructure at the port area. The
sediment ponds approved for the SRBP will be used for the MIA.
Refer to Sections 4.4.1 of the Supplementary Report.
19 19.102 11.9.1
The EIS indicates that bridge structures would be necessary
for the construction of the haul roads at river crossing
locations. There are two areas within the ML100047 and
ML100058 that would require the crossing of
approximately 400 to 500m of estuarine areas – see the
figures below. It is assumed that these bridge structures
would need to be designed and constructed in a specialised
way to be capable of crossing a considerable length of
estuarine area and provide support for haul road
operations. The EIS provides little to no details about the
design, construction, operation, potential impacts and
management measures regarding the bridge structures.
The relocation of the east-west BH1 haul road and use of existing
SRBP main haul road removes the potential need for bridge
structures. Refer to Section 11.7 of the Supplementary Report for
further discussion on bridge structures.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
93
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.103 11.9.1
The EIS has not provided sufficient detail about how the
haul roads will perform under various flooding conditions
based on their location and design. The haul roads are
located within estuary areas and the predicted flooding
zone.
There is insufficient detail provided about the size and
capacity of the spoon drains, where they will be located,
where they will be releasing to and whether they will be
releasing directly to marine vegetation and therefore
receiving waters.
Refer to Sections 11.2 to 11.6 of the Supplementary Report.
19 19.104 11.4.2.3
No information is provided in the EIS regarding the likely
duration of flooding. This information is required to
understand how long the port infrastructure may be
inundated and for how long the haul road to the port may
be unpassable. This information is important to understand
for how long sediment pond releases and any other issues
at the port may not be able to be monitored during a flood
event, given that 4WD and helicopter access to the port
may not be possible during or post-cyclone.
Refer to Sections 11.2 to 11.7 of the Supplementary Report.
19 19.105 12.5.5
The EIS outlines that two 500 kW and two 250 kW diesel
fired power generation units would be installed at the site.
NOx emissions from these units would be main issue and
stack emission limits would be specified in the EA. EIS did
not provide any information on the stack emission
parameters.
Refer to Section 12.2 of the Supplementary Report.
19 19.106 12.6.1
It is stated in the EIS that for the preparation of the site for
construction involves clearing and burning vegetation.
Burning of vegetation would create odour and dust
nuisance. It is unclear how this issue would be minimised.
Refer to Section 12.3 of the Supplementary Report.
19 19.107 12.8
This section does not provide information on the dust
mitigation of conveyer belt, barge loading system, and bulk
carrier loading system and how dust spillage would be
managed so as to avoid release to waters.
Metro Mining will utilise the approved SRBP MIA and BLF to service
the Bauxite Hills Project. Dust management within the SRBP MIA
and BLF will be undertaken in accordance with the EA for that
Project.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
94
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.108 13, Appendix
G
The closest sensitive receiver is identified as being R44
which is 18km SW of MLA yet there is the accommodation
village within the MLA of the adjacent Skardon River
Bauxite project identified in Table 2-2 page 11 of Appendix
G. Campers at the river mouth of the Skardon River are also
potential sensitive receptors but this camp has not been
considered in the EIS.
Metro Mining will utilise the approved SRBP MIA and BLF to service
the Bauxite Hills Project. Noise management within the SRBP MIA
and BLF will be undertaken in accordance with the EA for that
Project.
19 19.109 Appendix G
The background noise was measured to be below 30dB for
several nights. The minimum default value of 30dB should
therefore be used in model mining conditions equation.
The resulting model mining condition should include the
following table and criteria (refer to submission for the
criteria).
Refer to Section 13.4 of the Supplementary Report.
19 19.110 Appendix G
(Section 4.2.2)
The worse weather condition should be used to correspond
to the resulting worse favourable propagation condition.
Stability Class G is a temperature inversion strength which
corresponds to the winter temperature inversion. It is
consequently considered that Stability Class G should be
used for propagation for winter night time.
The CONCAWE methodology determines the stability classes into
categories and classes F and G are in the same category. VIPAC have
run a test comparing the two classes and there is 0.1 -0.2 dB
difference. As the results are rounded, there will be no material
change in the results between Class F which was used and the
suggested Class G. No change to the EIS is proposed.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
95
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.111 13.6.2.2, 13.8
The EIS states that the noise level predicted to affect Gulf
Alumina’s accommodation camp is up to 62dB(A) LAeq
which is an exceedance of the 35dB(A) criterion. Due to its
close proximity, 62 dB(A) can also be taken to be the
predicted noise level at the Bauxite Hills project
accommodation camp. An attenuation of 30dB(A) would
need to be achieved at both camps to make the project
acceptable.
Section 13.8 paragraphs 1 (dot point 10), 3 and 4 describe
management and mitigation measures. Dot point 10 is not
accurate as the camp location is located within a high noise
operational environment. EHP notes Metro Mining’s
intention in paragraph 3 & 4 but EHP requires that the EIS
provides greater assurance that the required level of
attenuation (30dB(A)) can be achieved through location,
building design and mitigation measures and therefore that
they can comply with the model mining condition at this
location.
The Project will now utilise the existing and to be constructed
accommodation facilities approved for the SRBP. Consequently, the
comments in regard to potential noise impacts associated with
having two separate accommodation facilities in operation are no
longer relevant.
19 19.112 Appendix G
(Table 7-1)
While the noise level LAeq was predicted to be 62 dBA in
page 27, in the table 7-1 the village is shown with level of
41 to 44dBA.
Refer to Section 13.5 of the Supplementary Report.
19 19.113 Appendix G
(Section 3.2)
Underwater noise propagation in shallow water is sensitive
to the acoustic nature of the seabed. The river bed may be
acoustically reflective or acoustically absorptive and
whichever it is would change the acoustics propagation
beyond the proximity of the pilling. It is not clear in the EIS
what values were used for the seabed
absorption/reflectivity.
Refer to Sections 7.2.1 and 7.2.2 of the Supplementary Report.
19 19.114 14.7.1.4
The EIS has not appropriately acknowledged or identified
the potential impacts to the groundwater environment, in
particular the shallow groundwater environment from
waste streams such as; hydrocarbons and chemicals in the
MIA, sewage effluent and leachate from bio-remediation
pads.
The management of waste streams within the MIA and BLF will be in
accordance with the SRBP EA. Metro Mining will utilise the approved
SRBP accommodation facilities to service the Bauxite Hills Project.
Management of the SRBP STP will be in accordance with the EA for
that Project.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
96
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.115 14.9.1.2,
14.9.1.6
The EIS proposes to undertake bio-remediation of
hydrocarbons and the soil conditioning of compostable
wastes and bio-remediated hydrocarbons. Insufficient
details have been provided about the potential
environmental impacts associated with these activities and
the management practices that will be employed to ensure
this waste management practices is not a source of
contaminants to the receiving environment. Bio-
remediation pads and composting facilities can be sources
of contaminants to the receiving environment.
Metro Mining is not proposing specific bio-remediation pads. Any
hydrocarbon contaminated soils will be managed at the bio-
remediation pad located within the approved SRBP MIA.
The biosolids area is no longer required as the approved SRBP
accommodation facilities will be utilised for the Bauxite Hills Project.
Should a composting are be required in addition to that approved
for the SRBP it will be appropriately sized, the pad floor will be lined
or constructed with impermeable material and appropriately
bunded to prevent further contamination.
Refer to Sections 1.1 and 4.4 of the Supplementary Report in regard
to the utilisation of the approved SRBP infrastructure.
19 19.116 14.6
The EIS does not identify ASS as a potential waste stream
that should be managed, however, in Chapter 4 – Land ASS
is proposed to be removed and treated in land pads.
The utilisation of the approved SRBP MIA, BLF and existing haul road
to access the MIA, in addition to the relocation of the east – west
BH1 haul road has significantly reduced the likelihood of impacts
from ASS.
Refer to Sections 5.5 and 5.6 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
97
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.117 14.9.1.3
A sewage treatment plant (STP) is proposed to be located
near the accommodation camp. Insufficient information
has been provided in the EIS to enable the EA to include a
condition to regulate the activity.
Indicative treated sewage effluent characteristics provided
in Table 14-5 includes effluent characteristics that differ
markedly (especially with respect to nutrient
concentrations) to those specified in draft EA conditions
listed in Section 20.2.10 of the EIS, Schedule G – Sewage
Treatment, Table 2-111. It is not clear which effluent
quality characteristics are to be delivered by the proposed
STP treatment system for the project.
In addition, the EIS does not describe how solid waste
(typically as “biosolids”, screenings and grit) from the STP
would be managed and where the proposed composting
facility (involving the probable beneficial use of these
“biosolids”) would be located and managed.
The Project will utilise the existing and to be constructed
accommodation facilities approved for the SRBP. Consequently, the
comments in regard to the Bauxite Hills STP are no long applicable. Refer to Section 4.4 of the Supplementary Report in regard to the
utilisation of the approved SRBP infrastructure.
19 19.118 19.5.1
The section refers to the current design of the coastal
infrastructure required for the project but does not address
the alternative option on combining the infrastructure with
the adjacent Skardon River Bauxite Project.
As detailed throughout the Supplementary Report, with Metro
Mining’s takeover of Gulf Alumina, the Bauxite Hills Project will
utilise the approved SRBP accommodation camp, haul roads, MIA
(including the fuel farm and hazardous material storage area) and
BLF rather than constructing standalone MIA, BLF and RoRo
infrastructure. The originally proposed duplication of major
infrastructure for the Project has been completely avoided.
Refer to Sections 1.1 and 4.4 of the Supplementary Report in regard
to the utilisation of the approved SRBP infrastructure.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
98
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.119 19.7, 19.7,
The EIS in Section 19.8 estimates the number of vessels
likely to be using the river to transport bauxite from the
project and the adjacent Skardon River Bauxite Project. It
has not indicated how many additional vessels will be
required for the delivery of plant and equipment and
removal of waste, the frequency of these movements, and
the potential impacts associated with them.
Logistic barge operations, including estimated number of barges and
support vessels during construction and operations, have been
provided in Section 17.6.3.5 of the EIS.
As stated in Section 17.6.3.5 of the EIS all materials associated with
the construction of the Project will be barged to site using shallow
draught barges from either the Port of Cairns or the Port of Weipa. It
is anticipated that approximately 30 barge movements, including
both to and from the site, will be required during the construction
period for equipment and infrastructure. These barges will typically
be 40 to 55 m in length with a maximum draft of between 2.4 to 2.9
m. Some smaller barge movements may be required for
consumables, anticipated to be at four movements per week during
construction.
It is anticipated that a single logistics barge will be required each
week during the operation of the mine. The barge will be used to
transport materials to site and take waste material from site on the
return transit. The logistic barges will be approximately 40 m in
length with a maximum draft of 2.4 m.
Potential impacts from these barge operations is discussed in
Section 17.6.4 and cumulative impacts are discussed in Section
17.6.5 of the EIS.
Note since the acquisition, barge operations will utilise the approved
SRBP BLF rather than the originally proposed standalone BLF.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
99
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.120 19.7.4, 19.7.9
The project proposes 6-7 barge movements within the
Skardon River each day within a HEV river. There is no
quantitative assessment of the potential impacts of these
barge movements on the shoreline and bank evolution. It is
stated that mangroves on the shoreline will attenuate wave
action, resulting in a low risk rating of barge movements to
shore line and bank evolution. However, no quantitative
assessment of barge movement impacts in the river has
been made to support this finding. Section 19.7.4 does not
provide a conclusion as to whether the project would
impact on the shoreline or not. Section 19.7.9 does not
address shoreline erosion and states that barge
movements are not considered to have potential to cause
significant changes to coastal processes.
Since the EIS was released Metro Mining has undertaken wake and
wave modelling, presented in Appendix E, to assess potential impact
of barge movement on the shoreline and bank evolution. The results
from this assessment are also presented in Section 19.3 of the
Supplementary Report.
Note since the acquisition of Gulf Alumina, barge operations will
utilise the BLF, at the approved SRBP port area, rather than the
originally proposed standalone BLF.
19 19.121 19.9
This section does not include management and mitigation
measures for potential impacts to water quality. Other
chapters of the EIS refer to the potential use of sediment
curtains as a mitigation measure for increased turbidity and
impacts on seagrass and marine fauna during construction
(e.g. during piling). The use of sediment curtains in tidal
areas can however be problematic and result in damage to
surrounding benthic habitats.
As per the ToR, water quality is discussed in Chapter 9 of the EIS.
Management and mitigation measures are discussed in Section 9.8
of the EIS.
Metro Mining will consider a range of operational and practical
management measures to minimise potential impacts to water
quality. Practical measures are outlined in Appendix A3 of the EIS.
Note piling will now be limited to the construction of the cyclone
moorings as the approved SRBP BLF will be utilised to support the
Bauxite Hills Project.
19 19.122 20
EHP acknowledges the draft EA conditions provided in
chapter 20 of the EIS. Draft EA conditions will be provided
as part of EHP’s EIS assessment report and would be based
on the following;
Model mining conditions;
Site specific conditions;
The EHP regulatory approach, which focuses on
providing outcome focused conditions; and
Prescriptive conditions, when considered necessary.
The draft EA conditions presented in Chapter 20 of the EIS has been
reviewed and updated based on received submissions. The updated
conditions are included in Appendix I of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
100
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.123 20 Condition D3 does not refer to sawfish and sharks and
needs to be amended.
Metro Mining addresses potential impacts to marine fauna from
underwater noise (particularly piling) in Section 6.8.1.1 of the EIS. In
summary, there is no scientific assessment on the impacts of noise
to these species to enable a thorough analysis of the potential
impacts from piling activities.
It is noted that Gulf Alumina’s draft EA has no conditions directly
relating to sawfish and sharks being impacted by underwater noise
mitigation, despite their more invasive bed-levelling activities that
are proposed. Metro Mining does not propose to include a specific
measure in the revised draft EA conditions presented in Appendix I.
19 19.124 20, Appendix
K
The EIS states that it is proposed to monitor the sediment
dam release point “initial after first release then monthly”
(Table 11-4 in Appendix K, page. 11-9). Monitoring initially
and then monthly may not allow sufficient sampling during
an event.
In this scenario, extreme summer rainfall events may
overwhelm sediment basins reducing their treatment
efficiency. During events, weekly sampling is unlikely to
provide sufficient information to characterise peak flows
which pose the highest risk for sediment runoff.
A final decision regarding the timing of initial and
subsequent sampling should be based on the modelled
characteristics of expected overflows from the water
release point.
Refer to Sections 4.4.1 of the Supplementary Report. Since the
release of the EIS, Metro Mining has completed a successful
takeover of Gulf Alumina’s assets, including the existing
infrastructure and proposed operations. The acquisition enables the
use of the approved infrastructure at the port area. The sediment
ponds approved for the SRBP will be used for the MIA.
19 19.125 20 (Schedule
F)
There is concern regarding access to the MIA during the
wet season when the haul road may be inundated by flood
water. The proponent needs to provide a commitment to
undertaking water quality monitoring during the wet
season and provide assurance that all reasonable steps are
taken to collect samples.
Metro Mining will utilise the approved SRBP MIA and existing haul
road to service the Bauxite Hills Project. The existing haul road is
located outside of the PMF and thereby providing year round access
to the SRBP MIA.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
101
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.126
20 (Schedule
E, Table 20-6,
Schedule F,
Table 20-9,
Table 20-10)
The proposed limits for all parameters do not reflect the
approaches recommended in the QWQG (DEHP, 2009). For
a HEV area there should be no change in the 20th, 50th and
80th percentiles of all monitoring data. The proposed limits
should be amended to reflect this.
Refer to Section 9 and Appendix I of the Supplementary Report.
19 19.127 Appendix C
(Section 7)
In Appendix C Offsets Strategy (section 7 Next Steps)
discussions with stakeholders are proposed to develop an
offset package consisting of a combination of direct and
compensatory measures. The EIS notes that as a condition
of approval the proponent will have to submit a Direct
Benefit Management Plan (DBMP) and Offset Delivery Plan
to the Chief Executive at least three months prior to project
commencement.
Section 255D of the Sustainable Planning Act 2009 (SPA)
would apply for tidal works and removal or interference
with marine plants proposed outside of the mining lease.
The Department of Infrastructure, Local Government and
Planning (DILGP) would seek advice on an application
authorising these activities from EHP and DAF, specifically
on how the application meets the requirements of the
State Development Assessment Provisions (SDAP),
including offsets. However, only the Chief Executive of the
DILGP has the authority to enter into any subsequent
environmental offset agreements under SPA if offsets are
required.
Metro Mining will continue to work with relevant government
departments such as EHP, DILGP and DAF to complete the final
offset package.
Metro Mining will be submitting an Operational Works application
for tidal works and impact to marine plants for infrastructure
outside the MLA. Metro Mining will be completing a pre-lodgement
meeting with the State Assessment Referral Agency (SARA), part of
DILGP, to discuss the proposed infrastructure regulatory
requirements prior to submission.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
102
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.128 Appendix C
(Section 6.4)
A DBMP may be suitable to offset some of the impacts of
the project but not all. For example, impacts to mangroves
may be achieved through a direct land based offset further
south along the Cape. Financial payments could also be
made. Any DBMP proposed would need to be able to
demonstrate a conservation outcome can be achieved for
the impacted matter. The program implemented via an
approved DBMP would need to have a strict monitoring
framework to measure changes in ecological indicators and
demonstrate conservation outcomes. See section 2.2.2 of
the Queensland Environmental Offsets Policy (V1.1).
Offsets proposed would need to meet the requirements of
the Queensland Environmental Offset Act, and should give
EHP confidence that offsets will compensate for the loss of
the matter and are achievable.
Table 6-1 of the Offset Strategy refers to an area of
Melalueca quinquinervia forest as an offset. The suitability
of this area to offset impacts is not clear. The EIS would
need to demonstrate a conservation/condition gain for the
particular matters impacted and a measurable increase in
habitat quality of at least 2 points. A habitat quality
assessment would need to be undertaken on the impact
site and the offset site to set a baseline from which to
measure improved habitat quality.
Consideration of a direct offset or an offset payment for
impacts to mangroves is encouraged.
Offsets cannot be actions that would already be required as
part of the management and mitigation measures. The
monitoring of Big Footprint Swamp and other wetlands and
springs would be required a part of carrying out the activity
on the site in any case and could not be taken to be an
offset.
The proponent could consider a financial offset if other
offset options do not comply with the policy.
Metro Mining will continue to work with relevant government
departments such as EHP, DILGP and DAF to complete the final
offset package.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
103
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.129 Appendix C
(Section 5.2)
This section states that offsets are required for residual
impacts to 19.4 ha of HES wetlands. However, the
Executive Summary (page 22) states that 25 ha of HES
wetlands would be impacted at the port.
Metro Mining will utilise the approved SRBP MIA, BLF and main haul
road to service the Bauxite Hills Project and in addition Metro
Mining has relocated the east-west BH1 haul road outside of the
mapped HES wetland area. As a result of these changes only 1.05 ha
of watercourse REs will be impacted. Refer to Section 6.12 of the
Supplementary Report.
19 19.130 Appendix C
(Table 4-1)
The likely hood of occurrence assessment indicated that
the species is confirmed for the purposes of the
assessment. The Offset Strategy has not included an offset
for impacts to this species.
The Black-footed Tree Rat has been assessed against the significant
impact guidelines and no significant residual impact is likely and
henceforth no offset is proposed for this species.
The information for the Black-footed Tree Rat is included in Section
8.4.3.3 of the Supplementary Report.
Assessment of significant residual impacts for this species is
discussed in Sections 7.8 and 7.9 of the EIS.
19 19.131 Appendix C
(Table 4-1)
There is a real chance or possibility that the red goshawk,
northern quoll, masked owl and the bare-rumped sheath-
tail bat will occur on the project site.
EHP has recommended earlier in these comments that the
likelihood of occurrence assessment should reflect that
these species are considered “likely” to occur on the site.
Consequently these species should be subject to a full
assessment and offsets may be required for impacts to
their breeding, feeding or foraging habitat.
Refer to Section 6.13 of the Supplementary Report.
19 19.132 Appendix K
(Section 7.9)
Bio-remediation/land farming pads have not been
discussed in this section of the EM Plan. Bioremediation
and land farming has been proposed as a waste
management strategy.
Metro Mining is not proposing specific bio-remediation pads. Any
hydrocarbon contaminated soils will be managed at the bio-
remediation pad located within the approved SRBP MIA.
The composting area will be appropriately sized, the pad floor will
be lined or constructed with impermeable material and
appropriately bunded to prevent further contamination.
Refer to Sections 4.3 and 4.4 of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
104
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.133
Appendix K
(Section 7.8,
Table 7.2)
Insufficient information has been provided regarding the
following disposal and management measures listed in
Table 7-2 of the EMP:
Disposal of organic waste disposed in the onsite inert
landfill area;
Effluent will be treated and used for irrigation on-site;
Sewage sludge and bio-solids used for soil conditioning
practices;
Disposal of concrete in mining pits.
Metro Mining will utilise the approved SRBP MIA, BLF and
accommodation facilities to service the Bauxite Hills Project.
Metro Mining is considering using the approved SRBP landfill for the
disposal of inert waste; however, the base case is still to have all
waste removed from site. Regulated waste will be removed from
site as described in the EIS.
As discussed in Section 14.9.1.2 of the EIS a composting system is
planned to be trialled to incorporate a number of organic waste
streams, including green waste and food wastes.
With the use of the approved SRBP accommodation facilities to
support the Bauxite Hills Project, effluent management is no longer
relevant to the Bauxite Hills Project. Effluent will be managed in
accordance with the SRBP EA.
19 19.134
Appendix K
(Section
7.9.1.6)
The location of the irrigation area for the sewage treatment
effluent has not been proposed and there are no
monitoring requirements stated to monitoring the
potential for shallow water aquifer contamination.
With the use of the approved SRBP accommodation facilities to
support the Bauxite Hills Project, effluent management is no longer
relevant to the Bauxite Hills Project. Effluent will be managed in
accordance with the SRBP EA.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
105
19 19.135
Appendix K
(Section
10.7.1)
This section states that sediment control structures will be
used to control runoff of cleared slopes near watercourses,
however the majority of the EIS chapters do not recognise
the need for sediment control structures apart from the
one proposed in the MIA.
The EIS contains details of sediment controls in a number of
sections. These sections include:
Section 2.6.5 – MIA Sediment Basin
Section 2.7.2 – Construction Program
Section 2.7.3.1 – Civil Works
Section 2.8.4 – Mining Sequence
Section 4.5.1.4 – Soils (specifically section on soil erosion
susceptibility)
Section 4.6.1.2 – Erosion and Sediment Mobilisation
Section 4.8.1.1 – Topography and Surface Water Runoff
Section 4.8.1.3 – Erosion and Sediment Controls
Section 9.8.2 – Mine Pits and Sediment Management
Section 9.8.3 – Mine Infrastructure Area Drainage
Section 9.8.4 – Haul Road Cross Drainage
Section 9.8.5 – Erosion and Sediment Control
Section 11.9.1 – Haul Road Cross-Drainage
The Erosion and Sediment Control Plan (ESCP) is included as
Appendix A3 to the EIS. The ESCP should be referenced when
identifying sediment control structures for the Project. Sediment
control management measures are discussed in Section 5 of
Appendix K of the EIS. Sediment controls are also discussed in
Section 4.8.1.3 of the EIS and Appendix A3. Given the Project
sediment control structures are identified throughout the EIS no
further updates to the EIS are proposed.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
106
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
Note that the sediment controls for the originally proposed
standalone MIA are no longer relevant as the approved SRPB MIA
and BLF will be utilised to support the Bauxite Hills Project.
19 19.136 Appendix K
(Section 11)
Based on the number of comments made about the surface
water EIS chapters, the environmental management
strategies proposed in the EM Plan will need to be updated.
While an EM Plan is no longer a specific regulatory
requirement of new EA applications, EHP may require
specific management plans in relation to surface water
management including but not limited to;
Erosion and sediment control plans;
Water management plans;
Receiving Environment Monitoring Plans;
Aquatic Ecology Monitoring Plans.
Metro Mining has already developed or has committed to
developing a number of management plans, including those listed.
The Erosion and Sediment Control Plan is included in the EIS as
Appendix A3.
Management plans that have been committed to in the EIS include:
A Water Management Plan;
If ASS is confirmed, an Acid Sulfate Soils Management Plan;
A Receiving Environment Monitoring Program (including aquatic
ecology); and
Marine water quality and ecology monitoring plan.
A Significant Species Management Plan These plans are discussed in
Append K and relevant chapters in the EIS. Given Metro Mining
commits to implementing the aforementioned plans no further
updates to the EIS are proposed.
19 19.137 Appendix K
(Section 9.8)
Section 9 of the EMP commits to water quality monitoring
in response to visual monitoring observations, activities or
incidents which may impact water quality, however no
details of such a monitoring plan is included in the EMP as
required of the TOR 8.14.8. Also, a marine monitoring plan
is committed to however not enough detail is provided
despite this being required by the EIS TOR 8.14.8.
Section 9.8.8 and Section 11.8.1 of Appendix K of the EIS provides
detail around the monitoring proposed and a commitment to
prepare monitoring plans. This commitment to prepare and
implement marine monitoring is already included in the EMP. The
nominated section of the Terms of Reference does not require that
a detailed monitoring plan is included in the EIS. Metro Mining
commit to a monitoring plan to be submitted within three months of
the grant of the EA. No change to the EIS is proposed.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
107
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.138
Appendix K
(Section
10.7.1)
The management of a number of potential sources of
impacts has not been included in this section such as:
ASS;
bio-remediation pads;
effluent irrigation areas;
haul road construction and operations.
The utilisation of the approved SRBP MIA, BLF and existing haul road
to access the MIA, in addition to the relocation of the east – west
BH1 haul road has significantly reduced the likelihood of impacts
from ASS. Refer to Sections 5.5 and 5.6 of the Supplementary
Report.
Metro Mining is not proposing specific bio-remediation pads, rather
any hydrocarbon contaminated soils will be managed in the
approved SRBP MIA.
A biosolids management area is no longer required as Metro Mining
will utilise the approved SRBP accommodation facilities to service
the Bauxite Hills Project.
Haul road construction and operations are discussed variously
throughout the EIS and the Supplementary Report. Metro Mining
propose to provide an updated EMP on receipt of draft EA
conditions and the management of haul roads during construction
and operations will form part of that document.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
108
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.139 Appendix K
(Section 12.7)
Groundwater monitoring networks need to be designed on
a site specific basis and should be tailored to detect
impacts to sensitive ecosystems. This means that a
monitoring network should be designed to achieve certain
objectives and goals. The EIS proposes a groundwater
monitoring program as the groundwater impact control
strategy but does not provide sufficient detail to inform the
proposed groundwater monitoring strategy such as:
the location of bores in respect to contaminant sources
the location of bores in respect to sensitive ecosystems
the appropriate location and design of bores for the
purpose of reference sites
the appropriate location and design of bores for the
purpose of compliance sites
the reason why some aquifers are targeted for
monitoring, such as the shallow aquifer will be
monitored as it will be used for potable water and is
also prone to surface water contamination
the reason for why contaminant parameters have been
nominated for monitoring
Refer to Appendix E1 of the EIS which describes the existing
groundwater network for the Project including the rationale for the
location of the bores. As a number of the existing bores within the
proposed mining pits will be destroyed during mining alternate
bores have been located nearby to those bores that will be
destroyed and the establishment and monitoring of these bores will
commence prior to construction.
The proposed Water Management Plan including the location of
each bore (including reference bores) and parameters to be
monitored are shown at Figure 9-5 and discussed in Section 9 and
Appendix I of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
109
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.140
Appendix K
(Section
11.8.2, 12.8)
The design of a REMP program should be undertaken in
accordance with the Receiving Environment Monitoring
Program guideline - For use with Environmental Relevant
Activities under the Environmental Protection Act (1994)
(DEHP 2014).
There are a number of considerations that need to be
included in the design of the REMP. The number and
location of monitoring sites for both surface and
groundwater needs to be reassessed. Additional upstream
freshwater monitoring sites are required, the depth at
which the groundwater bores would be sampled needs to
be included, the groundwater monitoring program should
assess both shallow and deep aquifers in the Project Area,
additional reference groundwater bores are required and
the surface springs should be included in the monitoring.
The REMP should also include riparian vegetation
monitoring in Big Footprint Swamp and hydrologic
indicators in wetlands.
A stated aim of the REMP was to “monitor and record the
effects of contaminant release on the receiving
environment and changes to groundwater and surface
water levels.” yet Section 11.8.2 did not describe
adequately describe the water quality monitoring, or
ground or surface water levels.
Refer to Section 9 and Appendix I of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
110
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.141
The EIS refers in different chapters to either “overburden
material, or subsoil'. In chapter two there are also
references to ‘sediment basins, sediment traps, and
sediment dams’. Where the EIS is addressing the same
area, the terminology should be consistent throughout for
consistency of reference.
For clarification of these terms definitions are provided below.
Sediment ponds: Sediment ponds are the permanent sediment
control storage features located in the approved SRBP MIA. These
are permanent features and will be retained throughout the life of
the Project; however Metro Mining is not proposing to construct
sediment ponds in addition to those approved in the SRBP EA.
Sediment basins: Sediment basins are temporary structures to be
used during construction, if required. Where sediment basins are
discussed in the document as permanent structures, these are
incorrectly referenced and should be labelled as sediment ponds.
Sediment traps: Sediment traps can include rock filter dams,
sediment trenches or sediment weirs. Appropriate access will be
provided to all sediment traps for maintenance and sediment
removal.
Overburden: As discussed in Section 2.6.9.2 of the EIS overburden is
waste material associated with the pit development and mining
(including sub-soils and weathered rock).
19 19.142 2.6.1
Section 2.6.1 refers to figure 2-3 (project infrastructure) for
layout of mine infrastructure. However figure 2-3 does not
show the location of the STP and associated irrigation area.
Metro Mining will utilise the approved SRBP accommodation
facilities to support the Bauxite Hills Project. Refer to Section 4.4.4
of the Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
111
Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.143 5.7 Dot point 5 on page. 5-63 refers to coal resources.
Error noted. This section should read:
“Throughout the construction, operation and decommissioning
phases, the Project has the potential to impact on these ecological
values through the following activities:
Removal of remnant vegetation for the MIA, open-cut mine pits,
road corridors and barge landing;
Topsoil stripping;
Construction of above ground buildings and facilities;
Day and night time operation of bauxite mining activities;
Stockpiling and transportation of the bauxite resource; and
General transportation movements.”
The online version will be amended to reflect this comment.
19 19.144 The PDF was protected making it very difficult to navigate
and extract information for assessment purposes. Unlocked pdf versions will be provided to EHP.
19 19.145
Appendix B1
(Section 7.1,
8.1)
Section 8.1 says that Section 7.1 would provide a detailed
floristic description but the link does not take me to a
detailed floristic description.
The floristic description of RE3.5.2 is provided in Table 7-3 of
Appendix B1 of the EIS. Attachment 3 of Appendix B 1 provides
descriptions of structure and floristics observed for RE3.5.2. See also
Attachment 6 of Appendix B1.
Metro Mining notes this incorrect link; however, as a floristic
description is provided in the sections mentioned above no updates
to Appendix B1 are proposed.
19 19.146 9.5.6.1
The last sentence of the paragraph discussing pH on page
9-33 states “Hence, site specific trigger values for EC should
be used as outlined in Table 9-2.”
The last sentence on page 9-33 should read: “Hence, site specific
trigger values for pH should be used as outlined in Table 9-2.”
The online version will be amended to reflect this comment.
19 19.147 9.5.1 The spatial location of the groundwater monitoring bores is
not presented in the EIS.
The spatial location of the groundwater monitoring bores is
presented in the EIS. Please refer to Figure 9-5 of the Supplementary
Report for the location of groundwater monitoring bores.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
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Submitter
No.
Submission
Reference No.
Relevant EIS
Section Issue Detail Metro Mining Response/Cross-reference Location
19 19.148 Figure 2-4 and
10-1
The EIS uses inconsistent names for some infrastructure
when they are referred to between text, tables and figures
throughout the EIS. In particular, sediment basins,
sediment dam, Stockpile sediment pond (Figure 10-1) and
Sediment trap (Figure 2-4) are used.
Metro Mining acknowledges there was some inconsistency with
terminology for sediment controls. References to sediment
infrastructure and management have been corrected in the
Supplementary Report.
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Bauxite Hills Project Supplementary Report to the Environmental Impact Statement
113