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GREEN COAST RESOURCES January 2015 Hey Point Bauxite Project Management Plan Sea Turtle

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GREEN COAST RESOURCES

January 2015Hey Point Bauxite Project

Management Plan

Sea Turtle

Sea Turtle Management Plan Hey Point Bauxite Project

Radix Doc ID: 00223245

This report has been prepared solely for the benefit of Green Coast Resources. MET Serve Pty Ltd accepts no liability for the use or interpretation of any information contained in this report for any other purpose other than intended, or for its use by any party other than the above named Client.

Document History and Status

Issue Revision Issued to Date Reviewed by

1 Draft MET Serve 2/1/2015 Dave Moss

2 Draft MET Serve 5/1/2015 Megan McKinney

3 Draft MET Serve 9/1/2015 Chris Wiley

4 Draft Green Coast Resources 13/1/2015 Hugh Simmons

5 Final Draft Department of the Environment 14/1/2015 Dave Moss

6 Final Green Coast Resources 22/1/2015 Michael Correll

MET Serve Project Delivery System

Printed: 22 January 2015

Last saved: 22 January 2015

File ID: 00223245

Project Manager: Michael Correll

Name of Organisation: MET Serve Pty Ltd

Name of Project: Hey Point Bauxite Project

Name of Document: Sea Turtle Management Plan

Document Version: 009

Project Number: CL003

PO Box 306 Fortitude Valley Post Office Fortitude Valley QLD 4006 ABN 94 143 463 316

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Declaration of Accuracy by Green Coast Resources

In making this declaration, Green Coast Resources is aware that section 491 of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) makes it an offence in certain circumstances to knowingly provide false or misleading information or documents to specified persons who are known to be performing a duty or carrying out a function under the EPBC Act or the Environment Protection and Biodiversity Conservation Regulations 2000. The offence is punishable on conviction by imprisonment or a fine, or both.

I am authorised to bind Green Coast Resources to this declaration and I have no knowledge of that authorisation being revoked at the time of making this declaration.

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ..................................................................................................... 1

1 INTRODUCTION ................................................................................................... 2

2 PROJECT DESCRIPTION ....................................................................................... 3

2.1 LOCATION ................................................................................................................................3

2.2 ACTIVITIES...............................................................................................................................6

2.2.1 Construction, operation and rehabilitation phases ..................................................................6

2.2.2 Panel Mining Methodology .....................................................................................................6

2.2.3 Mine Sequencing ...................................................................................................................7

2.2.4 Schedule of Activities ........................................................................................................... 12

2.2.5 Contingency Schedules ........................................................................................................ 12

3 OBJECTIVES ....................................................................................................... 13

4 ENVIRONMENTAL MANAGEMENT ROLES AND RESPONSIBILITIES ..................... 14

4.1 SITE MANAGER ....................................................................................................................... 14

4.2 PERSONNEL ............................................................................................................................ 14

5 REPORTING ........................................................................................................ 15

5.1 REQUIRED REPORTS ................................................................................................................. 15

5.1.1 Daily reports ........................................................................................................................ 15

5.1.2 Monthly reports ................................................................................................................... 15

5.1.3 Incident reports ................................................................................................................... 15

5.1.4 Non-conformance reports .................................................................................................... 15

5.1.5 EMP audit report .................................................................................................................. 15

5.2 SCHEDULE FOR REPORTING........................................................................................................ 15

5.3 DOCUMENT CONTROL ............................................................................................................... 15

6 ENVIRONMENTAL TRAINING .............................................................................. 16

7 EMERGENCY CONTACTS AND PROCEDURES ....................................................... 17

8 PROTECTED MATTER .......................................................................................... 18

8.1 ECOLOGY OF THE SPECIES ......................................................................................................... 18

8.1.1 Green Turtle (Chelonia mydas) ............................................................................................ 18

8.1.2 Loggerhead Turtle (Caretta caretta) ..................................................................................... 18

8.1.3 Hawksbill Turtle (Eretmochelys imbricate) ............................................................................ 19

8.1.4 Olive Ridley Turtle (Lepidochelys olivacea) ........................................................................... 20

8.1.5 Flatback Turtle (Natator depressus) ..................................................................................... 20

8.2 THREATS ............................................................................................................................... 21

8.3 CONSERVATION STATUS ............................................................................................................ 21

9 POTENTIAL ENVIRONMENTAL IMPACTS AND MANAGEMENT MEASURES ............ 23

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9.1 POTENTIAL IMPACTS ................................................................................................................ 23

9.1.1 Construction Phase .............................................................................................................. 23

9.1.2 Operation Phase .................................................................................................................. 24

9.1.3 Rehabilitation Phase............................................................................................................. 24

9.2 ENVIRONMENTAL MANAGEMENT MEASURES ................................................................................... 25

9.2.1 Direct mortality from boat strike .......................................................................................... 25

9.2.2 Land use affecting the water quality of sea turtle habitat ..................................................... 27

9.2.3 Light pollution ...................................................................................................................... 27

9.2.4 Waste .................................................................................................................................. 28

10 RESIDUAL RISK ASSESSMENT ............................................................................ 29

10.1 METHODOLOGY ....................................................................................................................... 29

10.2 RISK OF MORTALITY FROM BOAT STRIKE ....................................................................................... 29

10.3 LAND USE AFFECTING THE WATER QUALITY OF SEA TURTLE HABITAT ................................................... 30

10.4 LIGHT POLLUTION .................................................................................................................... 30

10.5 WASTE .................................................................................................................................. 30

11 AUDIT AND REVIEW ........................................................................................... 31

11.1 ENVIRONMENTAL AUDITING ....................................................................................................... 31

11.2 MANAGEMENT PLAN REVIEW ...................................................................................................... 31

12 GLOSSARY .......................................................................................................... 32

13 REFERENCES ...................................................................................................... 33

FIGURES

Figure 1 Regional location ...........................................................................................................4

Figure 2 Mining lease and disturbance footprint ..........................................................................5

Figure 3 Panel mining methodology ............................................................................................7

Figure 4 2015 disturbance footprint area .....................................................................................9

Figure 5 2016 disturbance footprint area ................................................................................... 10

Figure 6 2017 disturbance footprint area ................................................................................... 11

Figure 7 Map of potential habitat area ....................................................................................... 26

TABLES

Table 1 Schedule of activities ................................................................................................... 12

Table 2 Anthropogenic threats to sea turtles ............................................................................ 21

Table 3 Conservation status of sea turtles - legislation ............................................................. 21

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Table 4 Control measures for direct mortality from boat strikes ................................................ 25

Table 5 Control measures for land use affecting water quality of sea turtle habitat .................. 27

Table 6 Control measures for risk to sea turtles from light pollution ......................................... 28

Table 7 Control measures for risk to sea turtles from wastes.................................................... 28

Table 8 Qualitative risk assessment definitions ......................................................................... 29

Table 9 Risk rating methodology .............................................................................................. 29

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EXECUTIVE SUMMARY

This Sea Turtle Management Plan has been prepared to manage potential risks to sea turtles including the Green Turtle (Chelonia Mydas), Loggerhead Turtle (Caretta caretta), Hawksbill Turtle (Eretmochelys imbricate), Olive Ridley Turtle (Lepidochelys olivacea) and the Flatback Turtle (Natator depressus) during activities associated with the Hey Point Bauxite Project (HPBP). The HPBP is a proposed small-scale open cut bauxite mining operation located 10 kilometres (km) south of Weipa.

The Loggerhead and Olive Ridley Turtles are listed as Endangered under both the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act, 1999) and the Nature Conservation Act 1992 (NC Act, 1992), whilst the Green Turtle, Hawksbill Turtle and Flatback Turtle are listed as Vulnerable. Most of the turtle species are highly migratory and use a wide range of broadly separated localities and habitats during their lifetime. Loggerhead Turtles are generally found near the surface of the ocean whereas the Olive Ridley, Flatback and Green Turtles spend most of their time around soft-bottomed habitats where seagrass beds are found. Hawksbill Turtles mostly use sub-tidal coral and rocky reef habitats throughout Australia. Although there is limited habitat within the Embley River for most of these turtle species, there remains a possibility that the Embley River may be used for foraging.

Three potential impacts on sea turtles of the HPBP have been identified:

• boat strike • light pollution • water quality indirectly affecting seagrass productivity.

A set of management measures is proposed to specifically address each of these impacts, and by applying these, the HPBP aims to meet the following performance targets:

• No boat strike of sea turtles • 100 % compliance with the Erosion and Sediment Control Plan • 100% compliance with Mine Rehabilitation Plan • No lighting to be visible from sea turtle nesting sites • 100% compliance with the Waste Management Plan.

The likelihood and potential consequences of each impact, once mitigation measures are accounted for, were assessed using a qualitative risk assessment methodology as per The Australian Government’s Environmental Management Plan Guidelines 2014. The risk assessment identified a low residual risk to the turtle species for each of the potential impacts identified.

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1 INTRODUCTION

A number of sea turtles including the Green Turtle (Chelonia Mydas), Loggerhead Turtle (Caretta caretta), Hawksbill Turtle (Eretmochelys imbricate), Olive Ridley Turtle (Lepidochelys olivacea) and the Flatback Turtle (Natator depressus) have been identified by the Minister for the Environment as species that are likely to be impacted upon by the activities associated with the Hey Point Bauxite Project (HPBP). This Sea Turtle Management Plan provides information about the ecology of sea turtles, identifies the potential impacts that may occur in the context of the HPBP and proposes management strategies to mitigate the potential impacts identified.

This Sea Turtle Management Plan has been prepared to provide HPBP personnel with appropriate management strategies in the event that a sea turtle is observed in close proximity to HPBP operations. Based on the Department of the Environment’s (DoTE) Environmental Management Plan Guidelines (2014e), it is one of several species management plans documented for the HPBP and forms part of the HPBP Environmental Management Plan (EMP).

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2 PROJECT DESCRIPTION

The HPBP will produce approximately 4 million tonnes (Mt) of product bauxite over the course of its life and export up to 1.6 Mt of bauxite per year. Minimal processing (dry screening) is required and in most areas the run-of-mine bauxite tonnes are equivalent to the product bauxite tonnes. The HPBP has an optimal mine life of 3 years based on a dry season operation only. An additional year may be required subject to weather conditions limiting the length of the operating dry season.

The key elements of the HPBP are outlined below:

• Open cut mining will involve conventional panel bauxite mining methods, including truck and shovel operations with a mobile screening unit being utilised to separate bauxite from dry screening material when necessary.

• Mining will only be undertaken during the dry season. Appropriate erosion and sediment control measures will be utilised to stabilise areas of disturbance prior to the HPBP being shut down over the wet season.

• The shallow mine pit (maximum depth of 4.5 m) is not predicted to interact with the regional groundwater table during dry season operations.

• Due to site climate conditions, landform characteristics and geological properties, no overland flow is anticipated during the dry season; however, in keeping with standard erosion and sediment control principles, clean water drainage will be diverted away from mining areas and mine-affected water will be captured and contained within the mine workings for reuse.

• A mobile conveyor (approximately 320 m long) will be used to move product bauxite from the product stockpile to a barge moored in the Embley River. The 2,000 t barge will be loaded by a radial stacker positioned at the end of a floating pontoon.

• Product bauxite will be transported via barge to a bulk vessel moored approximately 3.5 km downstream in the Embley River (within the Port of Weipa waters) ready for export. The barge will require three movements per day, over a ten day period to fill the bulk vessel.

• Power will be supplied from a combination of diesel-fuelled generators and renewable energy (solar panels). A 30,000 litre diesel tanker (self-bunded) will be positioned on-site to refuel plant and equipment.

• Staff will access the Project daily via road from Aurukun or via a small boat from Weipa. All plant and equipment will be brought in via the road network from Weipa as required.

• Mining activities will be conducted seven days a week, with one 12 hour shift per day. Loading of product bauxite into the bulk vessel for export will be conducted for a total of six hours over a 24 hour period in three two hour intervals.

2.1 LOCATION

The HPBP is located on freehold land, approximately 10 km south of the township of Weipa. Weipa is located approximately 700 km north-west of Cairns and 1,200 km east of Darwin as presented in Figure 1. Figure 2 presents the proposed area of disturbance within the mining lease application boundary (MLA 20611).

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2.2 ACTIVITIES

2.2.1 Construction, operation and rehabilitation phases

This management plan is structured on three project phases which include construction, operation and rehabilitation. These phases are consistent with the panel mining methodology described below and upon commencement of bauxite extraction activities, will occur concurrently as the mine progresses. The activities within each phase are listed below:

• Construction phase: mobilisation to site, site preparation and infrastructure establishment, construction of roads and tracks, progressive clearing of vegetation throughout life of mine.

• Operation phase: extraction of bauxite, potential screening, transportation and loading product.

• Rehabilitation phase: progressive through life of mine, placing of fill, moving of topsoil, final profiling, revegetation, removal of site infrastructure, final rehabilitation of mine.

2.2.2 Panel Mining Methodology

The mining activities have been designed to minimise movement and handling of topsoil, subsoil (overburden) and screening waste, maximising the efficiency of the whole of life mining process by directly placing waste materials and topsoil with excavated areas. The aim of the mining process is to facilitate rehabilitation that closely follows the progression of the active mining pit, with only two hectares actively disturbed by mining (excluding rehabilitation activities) at any one point in time.

The implementation of panel mining methodology can be seen in Figure 3.

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Step Description Step Description

1 Topsoil moved from panel A to stockpile 9 Topsoil from panel E moved to panel C; panel D mined

2 Subsoil from panel A and topsoil from panel B moved to stockpile 10 Subsoil from panel E moved to panel D

3 Panel A mined 11 Topsoil from panel F moved to panel D; panel E mined

4 Subsoil from panel B moved to panel A 12 Subsoil from panel F moved to panel E

5 Topsoil from panel C moved to panel A; panel B mined 13 Topsoil from stockpile moved to panel E; panel F mined

6 Subsoil from panel C moved to panel B 14 Soil from stockpile moved to panel F

7 Topsoil from panel D moved to panel B; panel C mined 15 Topsoil from stockpile moved to panel F

8 Subsoil from panel D moved to panel C 16 Ready for rehabilitation prior to start of wet season

Figure 3 Panel mining methodology

2.2.3 Mine Sequencing

The main features of the proposed mining sequence are outlined below:

• Vegetation will be cleared, mulched and stockpiled. Some of the larger trees will be felled and placed in the rehabilitation area for fauna habitat.

• A two-stage stripping process will be implemented. Topsoil will be stripped, followed by the subsoil, leaving exposed bauxite to be mined. The topsoil and subsoil will be placed directly into the previously mined panel commencing the rehabilitation process.

• Cap rock will be broken by deep ripping with a bulldozer if required to expose the bauxite ore body. No explosives will be required.

1 hectare (ha) panels 1 ha panels

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• Exposed bauxite will be pushed up into windrows with a bulldozer. • The majority of windrowed bauxite will be loaded into rear dump trucks and transported to the

product stockpile area where it will be either stockpiled prior to load out or dumped straight into the receivable hopper. Windrowed bauxite containing sufficient impurities will be processed through a mobile screening unit prior to transportation to the product stockpile.

• Screening waste will be placed behind the screening unit by a loader and then later used for backfilling purposes.

The optimal three year mining sequence is presented in Figure 4, Figure 5, and Figure 6. The respective figures are based on the mine plan at a specific time in each year. For example Figure 4 presents the mine progression in September 2015.

The key feature of the mining sequence is that all mining panels will have commenced rehabilitation activities prior to the cessation of operations each year. It is expected that vegetation will be established during the subsequent wet season. Access tracks for the management of the rehabilitation along with haul routes (if required) through the rehabilitated areas will be retained.

The infrastructure, plant and equipment selected for the HPBP is reflective of the small scale and nature of the operation. Based on the optimal three-year life of mine, infrastructure has been designed to be mobile, with minimal construction and decommissioning requirements.

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2.2.4 Schedule of Activities

The schedule (Table 1) presented below provides an overview of key activities for the life of the HPBP, along with anticipated timeframes.

Table 1 Schedule of activities

Time Activity

April 2015

Mobilise to site (plant and equipment/temporary office and workshops etc)

Commence vegetation clearing and early works

Establish haul roads and access tracks

May 2015 – June 2015 Floating pontoon positioned in place

Construction of mobile conveyor

June 2015 – November 2015

Commencement of panel mining sequence,

Implementation of rehabilitation management plan (progressive rehabilitation through life of HPBP)

November 2015 – April 2016 Shut down for wet season

April 2016 – November 2016

Commencement of panel mining sequence,

Implementation of rehabilitation management plan (progressive rehabilitation through life of HPBP)

November 2016 – April 2017 Shut down for wet season

April 2017 – November 2017

Commencement of panel mining sequence,

Implementation of rehabilitation management plan (progressive rehabilitation through life of HPBP)

November 2017 Shut down for wet season

November 2017 – November 2027 Ongoing rehabilitation to meet objectives of the Rehabilitation Management Plan

November 2027 Lease relinquishment and financial close

2.2.5 Contingency Schedules

Contingency schedules will be prepared based on weather conditions for each calendar year. For example, a particularly wet year may reduce the period of time during the year when efficient mining can be conducted. The planned area of disturbance for each calendar year will be adjusted accordingly

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3 OBJECTIVES

The objective of this Sea Turtle Management Plan is to provide the HPBP with sufficient controls and management strategies to reduce the risk of any potential impacts to sea turtles to as low as reasonably practicable.

To achieve this objective, a rigorous risk assessment has been undertaken. The risk assessment proposed a number of potential impacts. To reduce the risk of the potential impacts occurring, a series of control measures appropriate to the nature, size and scale of the impact were proposed. A residual risk assessment was then conducted based on likelihood and consequence analysis.

Further to the impact assessment, this management plan provides a complete management framework which includes:

• a description of the HPBP • project timeframes • roles and responsibilities • monitoring requirements • auditing and reporting requirements.

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4 ENVIRONMENTAL MANAGEMENT ROLES AND RESPONSIBILITIES

The number of employees working at the HPBP will be limited to a maximum of 20 on a rostered basis. A single rostered ‘crew’ will be on site at any one time, supervised by a Site Manager. The Site Manager, reporting directly to the Green Coast Resources Managing Director, will be responsible for the management and performance of the staff across all management disciplines including operations, safety and environment. The two-tiered management structure requires all HPBP employees to demonstrate responsible environmental stewardship.

4.1 SITE MANAGER

The Site Manager is the most senior member of staff on site. The Site Manager will be responsible for the implementation of the HPBP EMP, including the Sea Turtle Management Plan. To maximise the effective implementation of the EMP, the Site Manager will be responsible for:

• providing resources and equipment to meet objectives • initiating reviews of EMP when required • reporting non-compliances • reporting environmental incidents • implementing monitoring programs • maintaining site records • daily / monthly reporting.

The Site Manager is responsible for identifying training needs so that all HPBP personnel receive an appropriate level of training to understand and implement the requirements of the EMP. To achieve this, the Site Manager will use a combination of training and communication tools including:

• Site induction: this will provide staff with a thorough understanding of the environmental values of the site, the EMP framework and a general overview of the objectives of the EMP. The Induction will provide staff with an understanding of the general environmental duty, incident reporting requirements and set standards of environmental performance required.

• Toolbox talks: the toolbox talks will provide specific aspects of the EMP relevant to the activities being undertaken that day. It will inform the operational methodology and provide staff with appropriate management strategies to manage potential environmental impacts.

• Copies of the EMP available in the crib hut and main office.

• Environmental alerts.

4.2 PERSONNEL

The Environmental Protection Act 1994 states that all personnel have a general environmental duty. This means that all personnel are responsible for the actions they take that affect the environment.

Personnel will be responsible for:

• carrying out environmental management activities as directed by the Site Manager

• observing and informing the Site Manager regarding general environmental performance of the HPBP

• notifying the Site Manager of any environmental incidents

• notifying the Site Manager of any non-conformances

• participating in induction processes and daily tool box talks to ensure a suitable understanding of site environmental values.

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5 REPORTING

Reporting will consist of both internal and external reports. Internal reports will make up the majority of the reporting requirements and include daily and monthly reporting.

External reports will be required as a condition of approval, at the specific request of a key stakeholder or after a notifiable environmental incident.

5.1 REQUIRED REPORTS

5.1.1 Daily reports

The daily environmental checklist will be completed by the Site Manager. The environmental checklist is integrated into a standard daily report (operational requirements) for the HPBP.

5.1.2 Monthly reports

The monthly report will provide a summary of environmental performance including but not be limited to:

• summary of weather conditions • a summary of construction activities undertaken through the month • environmental incidents • number of non-conformances • corrective actions implemented • area (ha) of clearance for the month • area (ha) of rehabilitation • environmental training • a summary of community complaints (legitimate complaints) and how they were managed • any environmental initiatives

5.1.3 Incident reports

Environmental incidents will be documented in accordance with the HPBP Environmental Incident Reporting Procedure.

5.1.4 Non-conformance reports

Non-conformance reports will be documented in accordance with the HPBP Incident Reporting Procedure.

5.1.5 EMP audit report

Audits will be undertaken annually or in accordance with the HPBP Environmental Authority conditions.

5.2 SCHEDULE FOR REPORTING

A reporting schedule will be prepared to include any conditions of approval requiring reporting prior to activities commencing at the HPBP.

5.3 DOCUMENT CONTROL

Green Coast Resources have a document control system that will be implemented for the HPBP.

All environmental documentation is to be managed by the Green Coast Resources Managing Director. No other staff are authorised to make changes to HPBP environmental documentation.

Hard copies of EMP will be kept onsite. It is the responsibility of the Site Manager to ensure that the latest plans are being implemented.

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6 ENVIRONMENTAL TRAINING

Environmental training will be facilitated through site inductions and tool box talks. The site induction will be provided to all staff and include the following:

• identification of site environmental values • an understanding the requirements of the EMP • roles and responsibilities • environmental emergency response procedures • site environmental controls • environmental incident identification and response • potential consequences of not meeting environmental responsibilities.

The management controls presented in this Sea Turtle Management Plan will be included in daily toolbox talks whilst vegetation clearance is occurring.

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7 EMERGENCY CONTACTS AND PROCEDURES

Emergency contacts and procedures are found in the following HPBP documents:

• Plan of Operations • Health and Safety Management Plan • Emergency response plan.

Where required, specialist advice will be sought by a recognised sea turtle specialist.

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8 PROTECTED MATTER

8.1 ECOLOGY OF THE SPECIES

8.1.1 Green Turtle (Chelonia mydas)

The Green Turtle (Chelonia mydas) is a migratory, marine species that occupies a variety of marine and coastal habitats during different life history stages. The species has a worldwide distribution, ranging from the North Atlantic ocean to the subantarctic waters between Australia and Antarctica, but typically spends the majority of its life in tropical and warm temperate waters (Wilson and Swan 2010; DEHP 2015a).

The carapace of a mature Green Turtle can grow to over one metre in length (Hazel et al. 2009). Green Turtles can be identified by the non-overlapping scales on their shell, and four outer scales on each side of their shell (Limpus 2009).

Green Turtles spend up to the first 10 years of their life in pelagic waters before moving to shallower waters in search of seagrass and marine algae, which are the sole constituents of their diet (Seminoff 2004). Once reaching sexual maturity, Green Turtles commence breeding migrations between foraging grounds (seagrass beds) and nesting areas (Seminoff 2004). Within the coastal region of the Gulf of Carpentaria, nesting occurs year round with a peak during mid-winter (Limpus 1995a). The adult female displays a high degree of fidelity to her chosen nesting beach, with most females returning to produce successive clutches within a single nesting season (Limpus 2008).

8.1.1.1 Habitat Requirements

Green Turtles are herbivorous and forage within tidal and sub-tidal habitats including coral and rocky reefs, seagrass meadows and algal beds on sand and mud flats (Limpus 2008).

The Green Turtle is the most likely turtle species covered by this management plan to utilise the seagrass beds of the Embley River for foraging, as Green Turtles’ preferred habitat includes inshore seagrass pastures (Hazel et al. 2007).

Green Turtles require sandy beaches for nesting which are common within the coastal regions of the mainland and islands within the Gulf of Carpentaria. However, the banks of the Embley River are characterised by rocky shorelines or mudflats, and do not present suitable nesting habitat.

8.1.1.2 Local Population

The Green Turtle is abundant throughout coastal regions of Queensland (DEHP 2011) with an estimated population of 5,000 nesting females (Limpus 2008). The Gulf of Carpentaria includes a large number of nesting sites in the Wellesley Islands, Eastern Arnhem Land, Groote Eylandt and Sir Edward Pellew Islands. Minor breeding occurs at scattered locations along mainland western Cape York Peninsula (DEHP 2012). Breeding is highly unlikely to occur within the HPBP mining lease, as no suitable nest sites (sandy beaches) are present.

No Green Turtles were observed within the Embley River during ecological surveys of the HPBP mining lease in 2013. Nevertheless, seagrass meadows are found within the mining lease (along the northern coastline), and the species of seagrass that dominates these beds (Enthalus acoroides: RTA Weipa 2011) is readily eaten by Green Turtles (André et al. 2005). Green Turtles are likely to be an occasional visitor to the waters of the HPBP mining lease.

8.1.2 Loggerhead Turtle (Caretta caretta)

The Loggerhead Turtle (Caretta caretta) is a migratory, marine species, widely distributed in coastal waters, mainly in subtropical and temperate regions (DoTE 2014a). Mature Loggerhead Turtles can reach a body length of 1.5 m and can be distinguished by their large head and elongated shell, which has five non-overlapping scales on each side (DEHP 2015b).

Loggerhead Turtles are carnivorous, eating bottom dwelling molluscs, crabs, sponges and urchins, as well as free swimming jellyfish (DoTE 2014a).

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Breeding occurs every 2 years and females nest 3 to 5 times during a breeding year. In Australia, the Loggerhead Turtle mates around November with a peak nesting period in December (Limpus 1985). Loggerhead Turtle foraging habitat is widely distributed across Australia and they are found off the coast of Queensland, Northern Territory, Western Australia and New South Wales in coral reefs, bays and estuaries (DoTE 2015). However, known nesting sites are confined to specific islands and beaches in the eastern Queensland and Western Australia (Limpus 2009).

8.1.2.1 Habitat Requirements

Loggerhead Turtles forage in a wide range of habitats including coral and rocky reefs, seagrass meadows, and soft-bottomed sand or mud areas. Their diet includes hard-bodied, slow moving invertebrate prey (Limpus, 2008). They have specialised nesting beaches, which in Queensland are located in southern area of the Great Barrier Reef. During the nesting season, Loggerhead Turtles remain the vicinity of nesting beaches. Following the nesting period, Loggerhead Turtles migrate to preferred foraging areas (Limpus et al. 1992). These may be near the nesting locations or over 2,000 km away (Limpus et al. 1992).

8.1.2.2 Local Population

Loggerhead Turtles are not known to breed anywhere on western Cape York Peninsula (Gyuris and Limpus 1988).

The total number of breeding females in Queensland has declined from an estimated 3,500 in 1977 to less than 500 in the 1999-2000 breeding season. There are no data on the possible number of Loggerhead Turtles that utilise the Gulf of Carpentaria coastal waters for foraging; however this is likely to be relatively small. Loggerhead Turtles are known to forage in the Gulf of Carpentaria (Limpus et al. 1992). However, most Loggerhead Turtles remain at latitudes above 28° (Limpus et al. 1992; Polovina et al. 2003), which is well south of Cape York Peninsula.

It is unlikely that the Embley River estuary constitutes important feeding habitat for the Loggerhead Turtle, but small numbers may utilise the area.

8.1.3 Hawksbill Turtle (Eretmochelys imbricate)

Hawskbill Turtles spend their first 4 to 10 years of their life drifting on ocean currents (DoTE 2014c) before settling on tropical tidal and sub-tidal coral and rocky reef habitat (DoTE 2014c). They can be identified by their pointed beak, and four overlapping scales on each side of the shell (Dobbs et al. 1999).

Their diet consists of largely of sponges, but also includes algae, animals and plants.

Nesting occurs between January and April (Dobbs et al. 1999; Loop et al. 1995) on islands across northern Queensland, Northern Territory and Western Australia (Limpus 2009). Females reproduce every two to four years, laying an average of 122 eggs each year (DoTE 2014c).

8.1.3.1 Habitat Requirements

Hawskbill Turtle habitat includes tidal and sub-tidal coral and rocky reef habitats throughout tropical Australia and warm temperate areas as far south as Northern New South Wales (Limpus, 2009). They prefer reefs rich in sponges.

Hawkbill Turtles breed on islands.

8.1.3.2 Local Population

There are no known nesting sites for Hawksbill Turtles in the Weipa region (Limpus 2009). A large nesting population (>5,000 nesting females) occurs across islands of the northern Great Barrier Reef and Torres Strait (Limpus 2009). Turtles from these populations migrate over broad areas, and forage across the Gulf of Carpentaria (Limpus 2009).

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Hawksbill Turtles likely forage in oceanic waters around Weipa, but are unlikely to regularly enter rivers due to a lack of suitable reef habitat. The HPBP mining lease is therefore unlikely to support populations of Hawksbill Turtle.

8.1.4 Olive Ridley Turtle (Lepidochelys olivacea)

The Olive Ridley Turtle is the smallest of the Australian sea turtles with a mean curved carapace length of approximately 70 cm (Limpus et al. 1983a; Whiting 1997). The turtle is characterised by more than five pairs of non-overlapping scales along the edges of the shell.

Most of the immature and adult population forage over shallow benthic habitats from northern Western Australia to south-east Queensland (DoTE 2014d). The age to maturity has been estimated at 13 years (with a range of 10-18 years) (DoTE 2014d). Breeding in northern Australia generally occurs from March to October (Hamann et al. 2002; DoTE 2014d).

The Olive Ridley Turtle eats mostly gastropod and bivalve molluscs, and may include crabs, shrimp, jellyfish, salps and algae as part of their diet (DoTE 2014d).

8.1.4.1 Habitat Requirements

The Olive Ridley Turtle prefers tropical waters between 6-35 m deep, where if feeds over soft-bottom habitats. It has not been recorded at reefs or in shallow inshore seagrass flats (Limpus 2008b).

The Olive Ridley Turtle breeds in low densities on sandy beaches across northern Australia, including coastlines in the vicinity of Weipa (Limpus 2008b).

8.1.4.2 Local Population

Low numbers of nesting females have been observed on the western coast of Cape York Peninsula in the vicinity of Weipa (Limpus 2008b). No sandy beaches suitable for nesting are present in the vicinity of Hey Point. It is unlikely that Olive Ridley Turtles regularly use the waters off Hey Point for foraging, given their preference for deeper sea habitats.

8.1.5 Flatback Turtle (Natator depressus)

Flatback Turtles (Natator depressus) are found only in the tropical waters of northern Australia, Papua New Guinea and Irian Jaya (DoTE 2014b). The Flatback Turtle is characterised by a low-domed, fleshy shell with upturned edges (Bustard 1972; Cogger 2000; Limpus 1971).

Mature Flatback Turtles forage widely through the waters over the Australian continental shelf to as far north as the Gulf of Papua New Guinea (DoTE 2014b). They are carnivorous, feeding mostly on soft-bodied prey such as sea cucumbers, corals and jellyfish.

In southern Queensland, the Flatback Turtle mating season occurs in mid-October with nesting occurring between October and January (Limpus 2007). Low-density nesting occurs along the northwest coast of Cape York Peninsula between Weipa and Bamaga (Limpus 2007).

8.1.5.1 Habitat Requirements

Flatback Turtles utilise a range of foraging habitats including turbid inshore waters, bays, coastal coral reef and seagrass shallows.

They utilise sandy coastlines for nesting. They rarely nest on beaches fronted by intertidal coral reefs, and therefore prefer mainland beaches and continental islands (Limpus 2007).

8.1.5.2 Local Population

The north-eastern Gulf of Carpentaria and western Torres Strait support the largest breeding population of the species, with the number of breeding females estimated to be in the thousands (Limpus 2007). The largest rookeries occur on Crab Island, Deliverance Island and Kerr Island; however, minor rookeries occur along sandy beaches as far south as Weipa (Limpus 2007). No suitable nesting habitat (sandy beaches) occurs in the vicinity of Hey Point.

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It is not known to what extent Flatback Turtles enter rivers to feed, but it is possible that small numbers may feed in the waters in the vicinity of the HPBP.

8.2 THREATS

The Recovery Plan for Marine Turtles in Australia (Environment Australia 2003), identifies a number of threats to sea turtles from anthropogenic activities (Table 2).

Table 2 Anthropogenic threats to sea turtles

Threats increasing risk of mortality Threats to nesting Threats to habitats that are critical to survival

• bycatch of sea turtles by fishing trawlers

• customary harvest by Aboriginal and Torres Strait Islander people

• marine debris • shark control activities • boat strike • pearl farming and other aquaculture

activities • defence activities

• light pollution • tourism and recreational activities • vehicle damage • faunal predation of marine turtle

eggs

• land use and water quality • loss of sea grass or benthic habitat • oil spills and operational discharges • noise

With respect to Table 2, the activities of the HPBP that could potentially pose threats to the sea turtles utilising the Embley River include:

• boat strike (mortality) • land use and water quality (habitat) • loss of seagrass (habitat) • waste (marine debris) (mortality/habitat) • light pollution (threats to nesting).

Loss of seagrass as a result of the HPBP is only likely to occur indirectly through deterioration of water quality, and therefore these threats are considered together in this management plan.

8.3 CONSERVATION STATUS

The conservation status of sea turtles in Australia is provided in Table 3. All species in this plan are protected under the Bonn Convention on the Conservation of Migratory Species of Wild Animals. As such, they are protected as migratory species under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). All five species are protected as marine species under the EPBC Act.

Table 3 Conservation status of sea turtles - legislation

Scientific name Common Name EPBC Act Status NC Act Status

Chelonia mydas Green Turtle Vulnerable Vulnerable

Caretta caretta Loggerhead Turtle Endangered Endangered

Eretmochelys imbricata Hawksbill Turtle Vulnerable Vulnerable

Lepidochelys olivacea Olive Ridley Turtle Endangered Endangered

Natator depressus Flatback Turtle Vulnerable Vulnerable

EPBC Act: Australian Environment Protection and Biodiversity Conservation Act 1999 NC Act: Queensland Nature Conservation Act 1992

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The conservation status of each species under the IUCN Redlist and the priority listings for the Cape York region Back on Track program are listed in Table 4.

Table 4 Conservation status of sea turtles - guidelines

Scientific name Common Name IUCN Redlist Back on Track Priority

EHP Cape York Region

Chelonia mydas Green Turtle Endangered Critical Critical

Caretta caretta Loggerhead Turtle Endangered Critical Critical

Eretmochelys imbricata Hawksbill Turtle Critically Endangered Critical Critical

Lepidochelys olivacea Olive Ridley Turtle Vulnerable Critical High

Natator depressus Flatback Turtle Data Deficient Critical High

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9 POTENTIAL ENVIRONMENTAL IMPACTS AND MANAGEMENT MEASURES

9.1 POTENTIAL IMPACTS

9.1.1 Construction Phase

9.1.1.1 Risk of mortality from boat strike

Boat strike is a major source of sea turtle injury and mortality in Queensland waters with large numbers of boats (Hazel et al. 2007; Environment Australia, 2003). Sea turtles are vulnerable to boat strikes when they come to the surface to breathe, rest between dives at the surface and forage in shallow water. Sea turtles most susceptible to boat strike include those inhabiting shallow waters, such as Green Turtles, Hawksbill Turtles, Loggerhead Turtles and Flatback Turtles. A study of Green Turtles, the most likely species to utilise the seagrass beds of the Embley River estuary, suggests they are slow to respond to fast-moving boats; no turtles flee in time if a boat is travelling at 10 knots (19 km h-1) (Hazel et al. 2007). Half of turtles foraging or resting on the estuary floor respond in time to boats travelling at 6 knots (11 km h-1) (Hazel et al. 2007). Risk of collision is therefore high in shallow water (<2 m), where benthic turtles may contact the propeller. Risk of collision is much lower in deeper water where turtles are less likely to contact boat propellers (Hazel et al. 2007).

Any activities associated with the construction phase that involve watercraft (e.g., towing the floating pontoon into position) has a potential risk of boat strike to sea turtles.

9.1.1.2 Land use affecting the water quality of sea turtle habitat and seagrass beds

Land clearing in coastal regions has the potential to affect turtles through various stages of their life cycle (Environment Australia, 2003). The clearing of 111.5 ha of vegetation within the HPBP mine disturbance area to allow for the extraction of bauxite and the provision of infrastructure will occur during the construction phase. Disturbed areas have the potential to release sediment through overland surface water flow during rain events. The release of sediment has the potential to elevate in turbidity and sedimentation in the Embley River. This may contribute to the temporary degradation of seagrass bed through smothering and lack of light (Marsh et al. 2002).

Activities associated with construction that could contribute to changes in water quality within the Embley River include:

• the clearing of vegetation in preparation for bauxite extraction activities (potential for increased sediment and nutrient loads in surface water runoff)

• establishment of cleared areas for workshop, crib hut and the conveyor • the potential for hydrocarbon spills from machinery failure and vehicle workshop spills to

interact with surface water runoff returning to the Embley River. Note all major repairs and servicing will be completed off site.

Any impacts are expected to be short-term, assuming that rehabilitation of mined areas restores vegetation cover and natural levels of erosion, and seagrasses are able to rapidly recolonise following any losses (Plus et al. 2003). Both assumptions are likely to be valid.

9.1.1.3 Waste

During all stages of the HPBP, there is potential for debris and waste to cause injury or mortality to sea turtles. Plastic bags are often ingested by some species due to the similarity between plastic bags and prey items such as jellyfish (Schuyler et al 2014). During both the construction and operation phase of the HPBP there is a potential for waste to be incorrectly disposed of in proximity to water, leading to potential turtle ingestion.

This potential impact exists in the short-term, lasting the 3-year duration of the project.

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9.1.2 Operation Phase

9.1.2.1 Light pollution causing disorientation to nesting females and hatchlings

Light pollution has the potential to discourage females from nesting in coastal areas near light sources, disorientate female turtles returning to sea after nesting, and disorientate hatchlings which move towards the artificial light instead of the sea (Witherington 1992).

There is negligible risk that light pollution caused by the HPBP is a threat to sea turtles, due to the following reasons:

• The HPBP will operate for approximately two hours each night to support loading of bauxite activities onto the barge. During this time, lights from the barge will provide adequate light to ensure safe for working conditions for HPBP personnel.

• No other lighting will be present in the vicinity of the Embley River. • No habitat suitable for nesting sea turtles exists within or in proximity to the HPBP mining

lease.

9.1.2.1 Risk of mortality from boat strike

Any activities associated with the construction phase that involve watercraft pose a potential threat to sea turtles (see Section 9.1.1.1). The following activities will occur during the operations phase:

• barge movements: three return barge movements every 24 hrs • small water craft: a small water craft (fishing boat) may be used to transport staff from Weipa

to the HPBP (floating pontoon) on a daily basis.

9.1.2.2 Change of Land use affecting the water quality of sea turtle habitat

Activities associated with the operation phase that could contribute to changes in water quality within the Embley River include:

• sediment runoff from mining areas, tracks and other areas lacking vegetation cover • the potential for hydrocarbon spills from machinery failure and vehicle workshop spills to

interact with surface water runoff returning to the Embley River.

Any impacts are expected to be short-term, assuming that rehabilitation of mined areas restores vegetation cover and natural levels of erosion, and seagrasses are able to rapidly recolonise following any losses (Plus et al. 2003). Both assumptions are likely to be valid.

9.1.2.3 Waste

During the operation phase of the HPBP, there is potential for debris and waste to cause injury or mortality to sea turtles. Plastic bags are often ingested by some species due to the similarity between plastic bags and prey items such as jellyfish (Schuyler et al 2014). During the operation phase of the HPBP there is a potential for waste to be incorrectly disposed of in proximity to water, leading to potential turtle ingestion.

This potential impact exists in the short-term, lasting the 3-year duration of the project.

9.1.3 Rehabilitation Phase

9.1.3.1 Changes in turbidity affecting health of seagrass meadows

Seagrass meadow decline can be caused by prolonged periods of elevated turbidity, which may occur if rehabilitated mined sites do not develop appropriate levels of vegetation cover (leading to prolonged periods of erosion).

This is considered to be a low risk during the rehabilitation phase as the rehabilitation methods to be adopted are highly successful elsewhere (refer to the Mine Rehabilitation Plan).

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9.2 ENVIRONMENTAL MANAGEMENT MEASURES

For each phase (construction, operation and rehabilitation) of the HPBP, proposed environmental management measures are presented to mitigate the potential risks identified. Figure 7 illustrates the potential habitat areas for the sea turtles (e.g. seagrass meadows) with respect to the disturbance footprint of the HPBP and is used as a reference throughout this section.

9.2.1 Direct mortality from boat strike

9.2.1.1 Environmental Management Activities, Controls and Performance Targets

Risk control measures for direct mortality from boat strikes can be found in Table 4, including:

• boat speed • volume of boat traffic • depth of water • density of sea turtles.

Table 4 Control measures for direct mortality from boat strikes

Risk Control Measures Timing Performance Target

A tug boat (or similar vessel) will be used to tow and manoeuvre the floating pontoon into position. Speed of the tug boat will be limited to 6 knots during towing operations, slowing to 4 knots when within waters less than 2 m deep

Construction phase

No boat strike of sea turtles

The speed limit of the barge will be 6 knots when empty and 4 knots when full Operation phase

The transit route (refer to Figure 7) to be utilised avoids seagrass meadows (turtle foraging habitat)

Construction, operation and rehabilitation phases

If a sea turtle is observed within 20 m of a boat, speed must slow down to 4 knots until the turtle has moved on beyond the 20 m of the operation

Construction, operation and rehabilitation phases

Small water craft (used for transporting staff) will be restricted to 6 knots within 100 m of sea grass beds and must slow down to 4 knots if a sea turtle has been sighted within a 20 m radius of the boat until the sea turtle moves on (beyond 20 m from the boat)

Construction, operation and rehabilitation phases

9.2.1.2 Environmental Monitoring

Any boat strikes or near misses to sea turtles will be recorded in an incident register. Any boat strikes will trigger corrective actions.

9.2.1.3 Corrective Actions

Any observed mortality of sea turtles through collisions with boats will be recorded and submitted to the Queensland Marine Wildlife Stranding and Mortality database. Data collected will inform the need for further controls of vessel movements in the Embley River.

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9.2.2 Land use affecting the water quality of sea turtle habitat

Control measures for land use affecting water quality of sea turtle habitat and sea grass beds are listed in Table 5.

Table 5 Control measures for land use affecting water quality of sea turtle habitat

Risk Control Measures Timing Performance Target

An Erosion and Sediment Control Plan will be prepared and implemented for the HPBP. This will incorporate sediment basins, clean water diversion channels, and a 100 m wide strip of remnant vegetation surrounding all shorelines

Construction, operation and rehabilitation phases 100 % compliance with

the Erosion and Sediment Control Plan HPBP employees and contractors will be made aware of environmental

obligations and compliance requirements through the site induction program, daily toolbox talks and other work instruction mechanisms will be employed on site

Construction, operation and rehabilitation phases

A Water Management Plan has been prepared that details surface and groundwater monitoring locations and the frequency of sampling regimes. The water monitoring at the HPBP will be undertaken in accordance with the Water Management Plan

Construction, operation and rehabilitation phases

100% compliance with the Water Management Plan

A Mine Rehabilitation Plan has been prepared that details the procedures to be adopted by the HPBP to ensure appropriate levels of vegetation reestablishment on mine sites. Staged clearing will remove vegetation in 1 ha blocks, which will then be progressively rehabilitated. This will limit the requirement to rely on erosion and sediment controls to restrict sediment laden water leaving site for long periods of time

Construction, operation and rehabilitation phases

100% compliance with Mine Rehabilitation Plan

9.2.2.1 Environmental Monitoring

Environmental monitoring will focus on sources of potential pollution during all phases of the HPBP. This will direct monitoring efforts to the erosion and sediment control structures, and will include:

• Weekly inspection of erosion and sediment controls to assess adequate implementation and effective control

• Inspection of erosion and sediment controls after rainfall events.

Ongoing implementation of the Water Management Plan (surface and groundwater monitoring) will provide additional supporting information to confirm the adequacy of the implementation of the Erosion and Sediment Control Plan.

Failure to comply with the Erosion and Sediment Control Plan, the Water Management Plan and the Mine Rehabilitation Plan will trigger corrective actions.

9.2.2.2 Corrective Actions

Corrective actions will be implemented in the event that inspections identify a failure to meet performance targets. An incident investigation will be undertaken and appropriate corrective actions documented. Corrective actions will be appropriate to the size, nature and scale of the incident identified.

9.2.3 Light pollution

9.2.3.1 Environmental Management Activities, Controls and Performance Targets

Control measures for the managing the risk of light pollution affecting nesting females and hatchlings can be found in Table 6.

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Table 6 Control measures for risk to sea turtles from light pollution

Risk Control Measures Timing Performance Target

No lights are required on the floating pontoon except for marker lights (in accordance with maritime safety regulations)

Construction, operation and rehabilitation phases

No lighting to be visible from sea turtle nesting sites

Lighting requirements for loading will be provided for from the barge. There will only be a maximum of one loading event undertaken within any one night, with a duration of approximately 2 hours. Once loading is complete, Lights will then be switched off

During loading

9.2.3.2 Environmental Monitoring

In the unlikely event that any sea turtles are observed on land during the course of the HPBP, or the presence of tracks are observed in the vicinity of the loading area, this will be recorded in a species observation book, and will trigger corrective actions.

9.2.3.3 Corrective Actions

In the unlikely event that sea turtle breeding is suspected in the HPBP mining lease (evidence that sea turtles have come ashore), this Management Plan will be reviewed.

9.2.4 Waste

9.2.4.1 Environmental Management Activities, Controls and Performance Targets

Control measures for managing risk of impacts on turtles from wastes are listed in Table 7.

Table 7 Control measures for risk to sea turtles from wastes

Risk Control Measures Timing Performance Target

Regulated wastes will be collected and managed using labelled, colour-coded receptacles, and removed off-site for final disposal

Construction, operation and rehabilitation phases

100% compliance with the Waste Management Plan Wastes will be removed from site by a suitably licenced waste

contractor As required

A Waste Management Plan will be prepared. This will contain information about actions to be taken in the event of accidental spills

Prior to commencing works

9.2.4.2 Environmental Monitoring

The Waste Management Plan will detail the checks and controls to be in place at the HPBP. It will also describe the triggers for corrective actions, should the Waste Management Plan not be adhered to.

9.2.4.3 Corrective Actions

Corrective actions to be taken in the event of non-compliance with the Waste Management Plan are detailed within the Waste Management Plan.

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10 RESIDUAL RISK ASSESSMENT

10.1 METHODOLOGY

The likelihood and consequences of each potential impact, once mitigation measures are accounted for, were assessed using qualitative risk assessment methodology recommended by The Australian Government’s Environmental Management Plan Guidelines (Table 8). These were used to generate a risk rating using Table 9.

Table 8 Qualitative risk assessment definitions

Qualitative measure of likelihood after control strategies have been put in place

Highly likely Is expected to occur in most circumstances

Likely Will probably occur during the life of the project

Possible Might occur during the life of the project

Unlikely Could occur but considered unlikely or doubtful

Rare May occur in exceptional circumstances

Qualitative measure of consequences if this issue does occur

Minor Minor incident of environmental damage that can be reversed

Moderate Isolated but substantial instances of environmental damage that could be reversed with intensive efforts

High Substantial instances of environmental damage that could be reversed with intensive efforts

Major Major loss of environmental amenity and real danger of continuing

Critical Severe widespread loss of environmental amenity and irrecoverable environmental damage

Table 9 Risk rating methodology

Consequence

Likelihood Minor Moderate High Major Critical

Highly likely Medium High High Severe Severe

Likely Low Medium High High Severe

Possible Low Medium Medium High Severe

Unlikely Low Low Medium High High

Rare Low Low Low Medium High

10.2 RISK OF MORTALITY FROM BOAT STRIKE

A boat strike with a sea turtle is unlikely or doubtful to occur throughout the three-year life of the HPBP. This is because few turtles inhabit the riverine waters of the HPBP mining lease, boating transit channels will occur primarily in deep water, low speed limits will be adhered to, and the increase in boating traffic proposed is relatively minor. This gives a likelihood of Unlikely, under the definitions within Table 8.

The death of a sea turtle from boat strike fulfils the definition of a Moderate consequence; it is an isolated environmental incident that is reversible through natural recruitment. Given the long generation times of turtles, this recruitment is expected to be slow (an ‘intensive effort’).

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The overall risk rating for sea turtle mortality from boat strike is Low.

10.3 LAND USE AFFECTING THE WATER QUALITY OF SEA TURTLE HABITAT

In light of the avoidance measures and controls in place, as well as the small scale of the HPBP, the likelihood that turbidity within the Embley River is increased by the HPBP to the point that seagrass productivity is affected is Rare to Unlikely.

Any incidence of increased turbidity is likely to be short-term and localised (e.g., only following extreme rain events, and only during short phases of the mining operation when a large area of ground is cleared and not yet rehabilitated). The rapid regeneration of seagrass following such events implies that any environmental damage is reversible. This amounts to a Minor consequence under the risk assessment definitions in Table 9.

The overall risk rating for the HPBP affecting turbidity levels that impact sea turtles is Low.

10.4 LIGHT POLLUTION

The likelihood of light pollution disorientating nesting turtles and hatchlings is Rare, given the improbability of any nesting occurring near the HPBP.

The consequence of light pollution disorientating nesting turtles and hatchlings would be Minor, given the short duration of time for which any lighting will be used on site, and therefore the small number of individuals that may be affected.

The risk rating for light pollution from HPBP activities disorientating sea turtles is Low.

10.5 WASTE

Adherence to the Waste Management Plan should result in no solid wastes entering the Embley River, and therefore a Rare likelihood of any impact to sea turtles.

The death of a sea turtle from ingesting plastic wastes fulfils the definition of a Moderate consequence; it is an isolated environmental incident that is reversible through natural recruitment. Given the long generation times of turtles, this recruitment is expected to be slow (equivalent to an ‘intensive effort’).

The overall risk rating for the HPBP impacting sea turtles through wastes is Low.

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11 AUDIT AND REVIEW

11.1 ENVIRONMENTAL AUDITING

The implementation and effectiveness of this Sea Turtle Management Plan will be internally audited on an annual basis. The Site Manager will be responsible for coordinating this audit.

11.2 MANAGEMENT PLAN REVIEW

This management plan, in its current state, is to remain in place throughout the three-year duration of the HPBP, unless:

• The conservation status of Sea Turtles is downgraded to a non-threatened class (Least Concern or Near Threatened).

• An incident investigation finds reason to amend risk controls nominated within this management plan.

If a review is required, it will take into account environmental monitoring records, corrective actions and results of audits. The Site Manager will be responsible for coordinating reviews, which should be undertaken by qualified ecologists, in consultation with the Queensland Department of Environment and Heritage Protection and the Commonwealth Department of the Environment.

In the event that the Sea Turtle Management Plan is altered, the revised plan will be submitted to DoTE.

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12 GLOSSARY

Carapace: The dorsal (upper) section of the exoskeleton or shell in Turtle species.

Construction Phase: The phase of the HPBP that involves the mobilisation to site, site preparation and infrastructure establishment, construction of roads and tracks, progressive clearing of vegetation throughout life of mine.

Operation Phase: The phase of the HPBP that involves the extraction of bauxite, potential screening, transportation and loading product.

Pelagic: living in open oceanic waters

Rehabilitation Phase: The phase of the HPBP that involves the placement of fill, movement of topsoil, final profiling, revegetation, removal of site infrastructure and final rehabilitation of mine.

Significant Impact: as defined under Commonwealth Government’s Significant Impact Guidelines 1.1 – Matters of National Environmental Significance.

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13 REFERENCES

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