Item
Description
Information Requested
Response
Corresponding Sections
Catchment reporting to the OCP
Provide evidence demonstrating the proposed activity will comply with existing EA condition W10.
Further clarification has been provided in the supporting information report that material from UMG TSF will not be discharged into the OCP or Dam 8. A dam break assessment (DBA) undertaken for UMG TSF with results summarised in Section 5.2 of the supporting information report and the full assessment provided as Appendix C. This assessment considers the likely failure mechanisms that were assessed by the designers. Dam break mechanisms were assessed including piping (internal erosion) and slope instability/foundation failure. The UMG TSF operational philosophy is that the TSF has been designed with sufficient storage to contain a PMF event and a spillway will not be required during operations. There will be no releases from the UMG TSF to the OCP or any other receiving water body during operations. A spillway with capacity to pass the PMF will be required for UMG TSF closure to limit water storage in the longer term. The closure spillway concept design has been provided in the updated CCA.
Section 5.16 and 5.17 and Appendix C
EA condition W10 states “The holder of this environmental authority must only undertake mining activities that result in no change to, or a reduction of the effective catchment reporting to the Mount Morgan Open Cut Pit.” The cover letter provided (WTS, 2025a)[9] states the only potential mechanism where the catchment reporting to the OCP could change is through a spill or seepage from the UGM TSF, however, as indicated in this information request seepage requires investigation. A dam break mechanism was not considered, and it is unclear why. Further, the reference to the CCA results to demonstrate compliance with this condition requires clarification as the UGM TSF CCA Report and the application materials does not consider or detail the catchment nor how Heritage Minerals Pty Ltd can comply with the existing condition. Noise The application material states the proposed UGM TSF construction works will not occur between 6:00AM to 6:00PM and no works will occur at night. Consequently, it is unclear when the facility will be constructed and comply with current noise limit authorisation.
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Provide advice on when the proposed UGM TSF is intended to be constructed in consideration of the comment in the adjacent column and how the construction and operation will adhere to the current noise limit authorisation of the EA.
This error has been rectified in the revised application
Section 6.5.3
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Environmental Offsets Act 2014 (EO Act) – Matters of State Environmental Significance (MSES)
The Queensland Herbarium provides the information required to update the mapping. Refer to DETSI (2025)[10] to update the mapped MSES value (RE 11.10.2, Regulated Vegetation – Category B ‘Of Concern’) and provide evidence regarding its completion.
Information will be submitted to the Herbarium and the process for managing offsets will occur simultaneously with the forward works plan.
Section 9
Regional ecosystem (RE) 11.10.2 is classified as a MSES (Regulated Vegetation – Category B ‘Of Concern’) and it is acknowledged an environmental offset under the EO Act is required for the permanent destruction. Ground truthing surveys have identified discrepancies between on ground values and mapped values. As such, the RE mapping requires to be updated via the Queensland Herbarium. Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act) Regarding the identified impacts to matters of national environmental significance (MNES), the application material suggests that grandfathering provisions of the EPBC Act apply to the proposal, however, no reference or citation to specific sections of the EPBC Act is provided. Further, the application relates to a new impact not existing. In accordance with section 68 of the EPBC Act, it is the proponent’s responsibility to determine whether their proposed activity is likely to have a significant impact on MNES. This obligation requires any person proposing an action that may significantly impact MNES to refer the proposal to the Federal Minister for assessment.
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Provide advice on the due diligence undertaken regarding the impact to the identified MNES species.
No references are made in the actual supporting report to the grandfathering provisions, on the basis that the assessment concluded that there will be no significant impact on MNES. The application form should be updated similarly to identify that the action 'Is not likely to have a significant impact on MNES', rather than referring to the transitional provisions. NA
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a) NA b) Appendix J c) Appendix K
Translocation plans
Provide revised application material which includes:
a) The management and translocation plans act as the offset strategies for the species subject to the plans. These plans are not intended as offsets under the EO Act as the species subject to the plans are not located in the wild and so do not trigger offset obligations under the EO Act. b) i) The onsite nursery is located near the existing lookout to the north east of the Open Cut Pit. The application has been updated to include the nursey as a new disturbance area. The nursey will be managed by an experienced person with relevant experience with Cycadales.
It is stated translocation plans are proposed to manage impacts to MNES and MSES species including Cycas megacarpa and Grevillea hockingsii, however, these plans require greater detail to demonstrate feasibility and no net loss of the species. Both plans state the loss of these species “will be compensated via a land based offset, with details provided in a separate stand alone offset area management plan.” An understanding on the intention and consequence of this objective is required.
a) Clarify and elaborate your intention regarding the statement that the species “will be compensated via a land-based, with details provided in a separate stand alone offset area management plan”, including a detailed explanation of how this will be achieved. If the intention is for an offset under the EO Act this must be clearly defined. b) For the Cycas megacarpa translocation plan: i. Clarify where the ‘onsite nursery’ is, who will manage it, and what husbandry techniques are required to demonstrate successful establishment. ii. Clarify and demonstrate the timeframe for translocation (i.e., five (5) years) is suitable. Compare your scenario to the circumstances outlined in your reference to Silcock et al.
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ISO 9001 • ISO 14001 • ISO 45001
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