Heritage Minerals has a unique approach to solving the economic barriers to treating low-grade tailings. A combination of the worlds best technology and many years of operational experience can turn around projects that are otherwise not feasible. Heritage Minerals designs and implements innovative solutions for technically tricky projects. They are also a environmentally and socially responsible problem solver.
Notice
Environmental Protection Act 1994
Information request
This information request is issued by the administering authority under section 140 of the Environmental Protection Act 1994 to request further information needed to assess an Choose an item for Choose an item.
To:
Heritage Minerals Pty Ltd Level 2 267 St Georges Tce Perth WA 6000
ATTN: Peter Mellor
Email: peter.mellor@greengoldtechnology.com
Our reference: EPML00433013; A-EA-AMD-100968556
Further information is required to assess an amendment application for environmental
authority
1
Application details
The amendment application for a site-specific environmental authority was received by the administering
authority on 29 October 2025 .
The application reference number is: A-EA-AMD-100968556 .
Land description: Mining Lease (ML) ML5615, ML5623, ML5635, ML5589, ML5616, ML5624, ML5648, ML5602, ML5617, ML5625, ML5649, ML5608, ML5618, ML5626, ML5658, ML5609, ML5619, ML5627, ML5659, ML5612, ML5620, ML5628, ML5660, ML5613, ML5621, ML5633, ML6692, ML5614, ML5622 and ML5634 .
2
Information request
The administering authority has considered the abovementioned application and is writing to inform you that further information is required to assess the application (an information request).
The information requested is specified in attachment 1 to this notice.
3
Actions
The abovementioned application will lapse unless you respond by giving the administering authority –
(a) all of the information requested; or
(b) part of the information requested together with a written notice asking the authority to proceed with the
assessment of the application; or
(c) a written notice –
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i. stating that you do not intend to supply any of the information requested; and
ii. asking the administering authority to proceed with the assessment of the application.
A response to the information requested must be provided by 18 June 2027 (the information response period). If you wish to extend the information response period, a request to extend the period must be made at least 10 business days before the last day of the information response period. The response to this information request or a request to extend the information response period can be submitted to the administering authority by email to ESCairns@detsi.qld.gov.au. If the information provided in response to this information request is still not adequate for the administering authority to make a decision, your application may be refused as a result of section 176 of the Environmental Protection Act 1994, where the administering authority must have regard to any response given for an information request.
4
Human rights
A human rights assessment was carried out in relation to this decision and it was determined that the decision is compatible with human rights. Should you have any questions about the notice, please contact the administering authority using the details provided below.
23 January 2026
Signature
Date
Robert Pettit
Enquiries:
Department of the Environment, Tourism, Science and Innovation Delegate of the administering authority Environmental Protection Act 1994
Minerals Business Centre PO Box 7230, Cairns QLD 4870 Phone: (07) 4222 5253 Email: ESCairns@detsi.qld.gov.au
Attachments
Attachment 1. Information Request.
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Attachment 1. Information Request
Item Description
Information Requested
1
Off lease disturbance
Provide advice on this off-lease discrepancy identified and detail how this will be rectified via this amendment.
The proposed revision of figure 1 (Mine Area Location) of environmental authority (EA) EPML00433013 is depicted in figure 9 of the application material (Wulguru, 2025) 1 . It appears disturbance footprints extend outside of tenure boundaries. Specifically, the Red Oxide Tails, Q Dump and a section of haul road northeast of the mining/contractor yard. Mining related disturbance subject of the EA is not authorised outside of tenure boundaries.
Clarify if there is an intention to include a mine equipment park up and workshop area to the EA. If so, provide all necessary information for its inclusion. For example, description of the infrastructure, location, footprint size, identification of environmental values and the associated risks, impacts and management measures, and rehabilitation information for this feature.
2
Regional interest development approval
It is identified that regional interest development approval RPI17/001 is approved for the project. Upon review of the documents publicly available related to RPI17/001, it is acknowledged that a ‘mine equipment park up and workshop’ is proposed downstream of the proposed Upper Mundic Gully Tailings Storage Facility (UGM TSF), however, this is not reflected in this application.
3
Ancillary infrastructure
Provide revised application material which describes all ancillary infrastructure required for the construction and operation of the UGM TSF. If ancillary infrastructure is proposed provide: a) A description of each feature proposed including an assessment against the environmental values, impacts and risks to environmental values and the management and monitoring measures, and rehabilitation information. b) A description of the location, including maps, GPS co-ordinates and total disturbance area in hectares (ha) for each feature. Information
Limited information is presented regarding if ancillary infrastructure is required to support the construction and operation of the UGM TSF. For example, this may include laydown areas potentially for pump systems, haul roads, access tracks, tailings pipeline and topsoil stockpiles. Further, as indicated in information request item 2 , this may also involve a mine equipment park up and workshop area.
1 Wulguru Technical Services, Mount Morgan Mine – Upper Mundic Gully TSF Environmental Authority Amendment, 23 October 2025
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should be provided in the same format as Schedule A1 (Authorised mining activities and locations) of the EA.
4
Western dump
Provide revised application material which:
The UGM TSF is proposed to be built over a portion of the existing western dump. It is acknowledged in the application that the western dump is likely contributing to acid rock drainage (ARD), however, this has not been confirmed via submission of site data or investigations. It is stated the exposed face of the western dump will be sealed, further reducing potential ARD seepage. However, no information is presented regarding the material or methods to be utilised to support the assertion this will reduce potential ARD. The application material suggests construction of the UGM TSF will involve reshaping of the western dump, however, there is no understanding regarding the extent of the proposed reshaping or its implications for areas of the dump that fall outside of the proposed UGM TSF. No information is presented confirming the suitability of constructing the foundation and embankment over the existing dump and the potential risks of exacerbation of the suggested ARD.
a) Details the proposed reshaping requirements necessary for the western dump, the potential implications for the entire western dump and the proposed management measures to avoid environmental harm caused by this action, where necessary. b) Details the risks and management measures required to ensure ARD isn’t exacerbated via the construction of the UGM TSF embankment over the existing western dump. Detail how it will be demonstrated that ARD isn’t exacerbated and how it will be determined and demonstrated potential impacts from the UGM TSF will be differentiated from the western dump. c) Confirms the suitability of the building the foundation and embankment of the UGM TSF over the existing western dump. This should involve a discussion of the findings of the relevant geotechnical investigations as recommended in the UGM TSF Design Report (WSP, 2025) 2 .
5
Dam 8
Provide revised application material which:
Dam 8 is not authorised under the EA however it is stated Heritage Minerals Pty Ltd use water from Dam 8 for construction and processing activities. This is further supported by the water balance technical memorandum (WBM Memo) (GHD, 2025) 3 which includes provisions for Dam 8 water transfers to the plant at 0.4 megalitres per day (ML/d) in Stages 2 and 4 of the project’s operation. By way of sealing the tunnel to Dam 8 via the
a) Detail how water contributions to Dam 8 may be impacted via the construction of the UGM TSF and how this will be managed in order to ensure activities undertaken by Heritage Minerals Pty Ltd and the DNRMMRRD are not affected. b) Describe the environmental values of Dam 8 and the potential implications in the event seepage flow pathways from the UGM
2 WSP, Upper Mundic Gully TSF Concept Design to RL 390 m, October 2025
3 GHD, Heritage Minerals EA Amendment Application – Updates to Water Balance Model July 2025 (Final), 1 October 2025
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construction of the UGM TSF it cannot be determined if this impacts the State acting through Department of Natural Resources and Mines, Manufacturing and Regional and Rural Development (DNRMMRRD) or Heritage Minerals Pty Ltd activities. An understanding on the environmental values of Dam 8 and the potential implications the proposed activity has on any sensitive values is not described. This may include reduction in water contributions and potential flow pathways impacting the water quality of Dam 8. The application material states a concrete plug, and mine spoil will be utilised to seal the tunnel. The mine spoil and its characteristics have not been described to confirm if this is suitable or has the potential to leach through to Dam 8 in the event the concrete plug has not sealed the entrance.
TSF are identified towards Dam 8. Describe the mitigation and management measures proposed to avoid impacts to Dam 8.
c) Detail the properties and characteristics of the mine spoil proposed to fill the tunnel and confirm its suitability to ensure potential leachate from tailings material will be avoided.
6
Sandstone Gully Tailings Storage Facility (SSG TSF)
Provide a suitable CCA for the SSG TSF demonstrating the hydraulic performance criteria as proposed. Alternatively, revise and submit a CCA for the approved SSG TSF confirming the appropriate hydraulic performance criteria for the structure.
The hydraulic performance criteria for the SSG TSF is proposed to be amended. The application material, which includes the SSG TSF Report (Golder, 2020) 4 , does not include information supporting the assertion that the consequence category assessment (CCA) for SSG TSF determined the consequence category as ‘high’ for dam break and ‘low’ for overtopping and seepage. As such, it cannot be determined if the proposed amendments are appropriate.
7
Water balance model (SSG TSF)
Provide revised application material which:
The water balance technical memorandum confirms that SSG TSF is not considered a TSF in the assessment and instead ‘an additional area within the mine site’ (GHD, 2025). This change necessitates urgent clarification regarding the structures purpose, alignment with the sites approved activities and proposed water
a) Provide a detailed explanation and clarify what is ‘an additional mine area’ and what its intended purpose is as it relates to the SSG TSF footprint.
4 Golder, Sandstone Gully TSF, Mt Morgan Gold Mine, 12 Feburary 2020
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management strategies. Without incorporating the SSG TSF as a tailing’s dams into the water balance model or formally excluding it from the approved activities, the representation of water inputs, outputs, and storage cannot be considered accurate or reflective of the site's authorised operations. Consequently, the risks and findings presented in the report cannot be reliably validated.
b) Confirm whether there is an intention to construct the SSG TSF. If so, provide a timeframe for the proposed construction which must consider the extreme failure events identified and the required revision of the dam break and consequence category assessments if both facilities are built (WSP, 2025a) 5 . c) Confirm and provide detail whether the reclassification of the SSG TSF as ‘an additional mine area’ aligns with the authorisation currently stated in the EA. d) If the SSG TSF is no longer intended to function as a tailing’s storage facility, confirm whether it will be decommissioned or repurposed. Provide an assessment against the environmental values, impacts and risks to environmental values and the management and monitoring measures, and rehabilitation information as a result of this change. If Heritage Minerals Pty Ltd plans to maintain the SSG TSF as ‘an additional mine area’, the SSG TSF should be removed as an authorised tailings storage facility from the EA as its purpose will no longer align with the current approved activities. e) If SSG TSF remains classified as ‘an additional mine area” in the model, provide an assessment that includes a risk evaluation of the potential interactions and implications of removing the SSG TSF as a tailing’s storage facility from the water balance model. Provide an evaluation of how this change impacts the water management risks associated with the site's approved activities. f) If SSG TSF is intended to be maintained as a tailing’s storage facility, update and include this approved activity into the water balance model and present the findings.
5 WSP, Upper Mundic Gully TSF Stage 1 and 2 DBA and CCA, July 2025
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g) Demonstrate how the updated water balance model accounts for water inputs, outputs and storages across the site, and detail how this aligns with the approved and proposed activities.
8
Water balance model report
Provide revised application material which:
The WBM Memo is a technical memorandum and not a comprehensive water balance model report. The referenced report Water Balance Modelling Report – Heritage Minerals EA Amendment Application, Revision 3 (GHD, 2022) was not provided in support of this application. It is understood the UGM TSF is intended to provide a more resilient tailings and water management strategy which can better accommodate more extreme climatic conditions and further reduce water balance risks (Wulguru, 2025). Despite this, the transfer of water under extreme climatic conditions nor climate change impacts have been modelled. It is assumed based on the WBM Memo, the UGM TSF construction and status prior to it receiving reprocessed tailings will potentially be fifty-two (52) months. During that time, it is acknowledged the UGM TSF area will naturally retain water from the contributing catchment runoff, however, this has not been simulated in the model. An understanding of why this was not included in the model, and the destination of this water is required. Consideration must also be applied detailing if this water is likely to be contaminated given the western dump surface area. Further, it is acknowledged a sump and pump system will be required for the UGM TSF, however, no further information is provided.
a) Provide the comprehensive water balance model report prepared by GHD (2022) referenced in the adjacent column. b) Update the water balance model report to incorporate scenarios of the extreme climatic conditions which control the transfer of water to the UGM TSF, and climate change impacts. Present the findings clearly and ensure the updated comprehensive water balance model report is provided. c) Clarify why the clean water entering the system from the contributing catchment was not simulated and demonstrate this is suitable to not include in the model. Provide further information on the proposed sump and pump system, including the expected quantity and quality, the destination of the water pumped through this infrastructure and if this is suitable and aligns with the sites approved activities. d) Clarify who operates the DNRMMRRD water treatment plant and confirm the assumption applied is appropriate. e) Clarify who operates and maintains the evaporators and detail the reliability and efficiency of the evaporators. Provide the site data which supports the evaporators throughput capacity applied in the model. Apply a sensitivity scenario which removes the evaporators from the model and present the findings. f) Clarify the transfer of water from UGM TSF to plant (7.8 ML/d), what this is attributed to how this has been calculated. g) Clarify the transfer of water from OCP to UGM TSF (0.5 ML/d), why this is required and how this has been calculated. Confirm this
Notwithstanding information request item 7 , the following assumptions within the WBM Memo require clarification:
a) The DNRMMRRD water treatment plant is assumed to be actively pumping throughout the entire simulation period (4.8 ML/d). It is unclear who operates and maintains the
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DNRMMRRD water treatment plant, with the value applied requiring confirmation. b) The evaporators nominate a throughput capacity of 3.35 ML/d. No data is presented supporting this assumption. c) Table 3.1 of the WBM Memo suggests the UGM TSF return water to plant is 7.8 ML/d in Stages 3 and 4. However, clarity is required regarding the purpose of this water transfer and its source (i.e., decant water and/or runoff). d) Table 3.1 also suggests in Stages 3 and 4, the Open Cut Pit (OCP) to UGM TSF transfers is 0.5 ML/d. However, clarity is required regarding the purpose of this water transfer and the simulated rate. Further, this does not appear to align with the operational design aspects of the UGM TSF which states ‘no operational pond level’.
aligns with the proposed operational design aspects of the UGM TSF and the overall best practice management of tailings dams.
9
Water management (UGM TSF)
Provide revised application material which:
It is stated the UGM TSF will provide additional capacity in a potential worst-case scenario should the OCP be at risk of overtopping (GHD, 2025). There is no understanding on the trigger for water transfers to the UGM TSF should the OCP be at risk, nor the potential implications and risks, and the management proposed under the worst-case scenario. The storage of water on tailings dams is not considered best practice and presents a considerable risk, coupled with the reprocessed tailings material containing a 60% liquid content. The UGM TSF Design Report (WSP, 2025) requires clarification as it is stated the water storage requirements assumes ‘no operational pond level’. Given the intentions outlined above, clarification is required regarding this operational objective. Further, there is no discussion on potential drainage requirements with advice stating
a) Detail the trigger to transfer water from the OCP to the UGM TSF and demonstrate all risks to environmental values via a risk assessment can be managed. This must include a description of the water quality from the OCP, the anticipated water volume to be stored on the UGM TSF, the timeframe for its storage and the water content of the reprocessed tailings within the UGM TSF. Provide a robust water management strategy and plan under such event which must demonstrate potential environmental impacts are avoided, mitigated or managed. b) Provide clarification on the ‘no operational pond level’ proposed for the UGM TSF with consideration to the intention to store water on the facility under specific circumstances, the water content of the tailings and the transfer of water from the OCP at 0.5 ML/d. This must include a robust water management strategy including the
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an operational decant pond will be incorporated in the next stage of the design (WSP, 2025). It is acknowledged that a spillway with the capacity to pass the Probable Maximum Flood (PMF) event will be required for Stage 2 and closure of the UGM TSF (WSP, 2025). Despite this, a spillway for Stage 2 has not been nominated nor detailed, with advice suggesting further studies are required to assess suitable locations to discharge outflows.
operational practices required to maintain no operational pond level to ensure this operational objective can be met. c) Provide the designs, configuration and discharge outflows of the Stage 2 spillway for the UGM TSF and revise all necessary reports to include the spillway and present the findings.
10
Consequence category assessment (UGM TSF)
Demonstrate via field verified data and modelling the assumptions utilised for seepage and groundwater flows from the UGM TSF are appropriate. If required, revise the CCA with verified information regarding seepage and groundwater flow pathways.
Assumptions applied in the UGM TSF CCA Report (WSP, 2025a) for seepage suggest seepage is determined to be of ‘low’ consequence category rating with flows from UGM TSF directed towards the OCP with the preferential direction of groundwater flow from the OCP east towards Mundic Creek. This has not been demonstrated via field verified data or modelling.
11
Geotechnical investigations
As outlined in the UGM TSF Design Report, provide revised application material that demonstrates the implementation and finalisation of the identified recommendations, along with the associated findings. This must include an assessment on the geotechnical stability of the UGM TSF, considering the increased hydraulic pressure from the proposed storage of water under extreme climatic events and the liquid content of the tailings.
It is stated that geotechnical investigations are needed to assess potential seepage impacts (WSP, 2025). Sections 7.8 and 8 of the UGM TSF Design Report include several recommendations required, however, there is no forwards works plan provided to address the information gaps. In the absence of necessary geotechnical information to support the application, it is significantly challenging to assess the stability, safety, and suitability of the proposed tailings dam design, as well as its potential environmental, operational and closure risks.
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Provide all relevant information in accordance with the Guideline Application requirements for activities with impacts to water (DETSI, 2026) 6 . The revised application must also include: a) Investigate, nominate and implement groundwater monitoring bores within and surrounding the proposed UGM TSF at appropriate and representative locations. The bores must be located in areas to effectively capture baseline conditions and detect potential impacts from the proposed activity. b) Undertake and submit detailed groundwater monitoring information including:
12
Groundwater
It is stated the UGM TSF is determined to be of negligible risk to all environmental values (WTS, 2025). There is no understanding of groundwater environmental values within the UGM TSF footprint or close proximity. To support the assertion made, groundwater environmental values must be investigated. This information cannot be delayed via proposed conditioning and must be provided to support the application to understand the baseline conditions, the predicted and potential impacts and risks to groundwater to appropriately inform the mitigation and management measures. The application material, although related to the Mundic Creek Catchment and not the UGM TSF, identifies seepage may occur through the shallow bedrock. It is also stated groundwater flow and influence is not understood and the influence of the OCP and western dump on the UGM TSF is unknown. A comprehensive understanding on all seepage flows and pathways from the UGM TSF must be provided. Further, the high liquid content of the tailing’s slurry, coupled with the intention to store water on the facility under extreme climatic events increases the potential for seepage and groundwater contamination, necessitating a comprehensive groundwater assessment.
i.
Background quality and characteristics.
ii.
Groundwater level and depth.
iii.
Hydraulically conductivity, transmissivity and flow rate.
iv.
Seasonal variations and influences.
As per DES (2021) 7 , a minimum of 18 samples over at least 12 and preferably 24 months is required to calculate limits. Alternatively, if there is urgency in the application, the department may consider a minimum of 8 monthly datapoints, if the concentrations are relatively stable and consistent.
c) Provide further detail on the composition of tailings material including:
i.
Identification of potential contaminants of concerns.
6 Department of the Environment, Tourism, Science and Innovation, Guideline - Application requirements for activities with impacts to water (ESR/2015/1837).
7 DES (2021). Using monitoring data to assess groundwater quality and potential environmental impacts. Version 2. Department of Environment and Science (DES),
Queensland Government, Brisbane.
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ii.
Describe the results of leachate testing to determine the potential for contaminants to leach into groundwater. Potential impacts on ecological systems and groundwater environmental values.
iii.
d) Identify and describe all seepage pathways and flows from the UGM TSF including the receiving receptors.
e) Provide a seepage management plan which includes:
i.
Design specifications to mitigate or manage potential flows through the facility, including evidence of the liner's ability to withstand the hydraulic pressure from the high liquid content and storage of water under extreme climatic events, and prevent seepage.
ii.
Proposed measures to minimise seepage, including monitoring and maintenance strategies.
iii.
Contingency measures in the event of seepage detection.
f) Describe in detail the potential impacts due to the proposed activity and all associated risks to the groundwater environmental values in consideration of the above requested information. Consideration must be given on whether the identified impact on receiving waters supports the management intent for those waters, to the extent practicable. g) Describe in detail the strategies to mitigate and manage the identified risks to groundwater environmental values. For example:
i.
The locations, depths and purpose of the monitoring bores.
ii.
Frequency and parameters for groundwater quality and level monitoring.
h) Submit a long-term groundwater monitoring plan for the UGM TSF, including post-closure monitoring requirements and measures to
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ensure the long-term stability of the facility and the prevention of groundwater contamination after closure from the facility.
The information requested above must demonstrate the UGM TSF will not further impact waters environmental values of the receiving environment of the Mount Morgan Mine. Consideration can be given to the approved activities as a whole, however, reduction of the contaminant load to the receiving environment as a result of the approved activities must be demonstrated via modelling or other supporting evidence. Complete numerical groundwater modelling for the UGM TSF. The groundwater model report to be submitted must include: a) A hydrogeological model of the UGM TSF and its receptors, including:
13
Groundwater modelling
In the absence of a groundwater model, it is significantly challenging to assess impacts to groundwater from the proposed UGM TSF. A numerical groundwater model must be developed to assess the risks and potential impacts with the resulting report to be provided.
i.
Geological cross sections.
ii.
Aquifer connectivity and flow dynamics.
iii.
Recharge and discharge zones.
iv.
The potential interactions between surface water groundwater.
This model must be based on field verified data and information within the UGM TSF area and proximity.
b) The basis for the numerical groundwater model parameters, assumptions and model design. It must be demonstrated the model domain extent is sufficient to the extent necessary to understand potential impacts from the UGM TSF.
c) Steady-state and transient calibration results (with sufficient monitoring points surrounding the proposed UGM TSF).
d) An operational scenario which reflects the proposed design of the UGM TSF (including expected foundation conditions and any other design elements that could influence the impact to groundwater).
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e) Particle tracking around the perimeter for the proposed UGM TSF to assess potential pathways.
f) An assessment of risk to groundwater from the UGM TSF.
g) Conduct and submit contaminant transport modelling to predict the movement of potential contaminants from the UGM TSF through the groundwater system. The report to be provided must include:
i.
Predictions of contaminant concentrations at potential receptors over time and at closure. Details of the modelling approach, assumptions, and parameters used, such as hydraulic conductivity, porosity, and seepage rates. Estimated seepage rates considering the high liquid content of the tailings slurry, the permeability of the tailings material and the underlying geology. Sensitivity analyses to evaluate how changes in liquid content (i.e., due to rainfall or evaporation, and the intention to store water on the facility under extreme climatic events) could affect contaminant transport).
ii.
iii.
iv.
h) Sensitivity and uncertainty modelling to provide an indication of the potential risk to groundwater receptors.
i) Closure modelling.
14
Groundwater dependent ecosystems (GDEs)
Provide revised application material which:
There is moderate potential terrestrial GDEs and potential GDE aquifers mapped within and around the proposed UGM TSF. Field surveys have not been undertaken to verify the mapped information and the potential risks and impacts via changes in groundwater levels and quality has not been detailed. It is stated, the affected terrestrial GDEs are upslope of the seepage flow direction,
a) Determines the spatial extent of impact from the proposed activity on mapped GDEs. b) Confirms that mapped GDEs within and surrounding the proposed activity (extent of impact zone), have been ground truthed. In the absence of ground truthed information, the application assessment in relation to consideration of the significance of impacts to the
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however, seepage pathways from the facility have not been field verified or demonstrated.
receiving environment will assume that mapped GDEs are present (based on the current mapping available).
c) Based on the information developed in relation to item (b), provide:
i.
The baseline conditions of all GDEs that have the potential to be impacted by the proposed amendment, or otherwise indirectly impacted. A description of any potential risks and impacts to all GDEs to be impacted or likely to be impacted by the proposed activity. This must include potential changes to groundwater level and quality, including the expected locality and extent of the groundwater level and quality changes. Proposed management and monitoring strategies and/or program to detect potential impact on GDEs and any corrective action(s) if impacts are detected. Incorporate this information into the groundwater model accordingly.
ii.
iii.
iv.
d) Revise the consequence category assessment with consideration of the information requested above. Please consider relevant guidance material to determine and assess impacts to GDEs, including the EIS Information Guideline (2024) 8 .
15
Basal Seepage
Provide revised application material which:
The application material states the underlying geology provides for limited connectivity between the proposed TSF and underlying
a) Provides evidence to confirm the hydraulic permeability of the base of UGM TSF to support the adjacent statement identified in the application material.
8 Department of Environment, Science and Innovation 2024, Groundwater dependent ecosystems—EIS information guideline, ESR/2020/5301, Queensland Government,
Brisbane.
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aquifers. No site testing has taken place within the TSF footprint to verify this.
b) Confirms the permeability of the base of UGM TSF is accurately represented in the groundwater model.
16
PMF Assessment
Provide a PMF assessment of the proposed UGM TSF including consideration of the hydraulically connected features and present the findings.
PMF modelling has not been conducted for the proposed UGM TSF facility. A detailed PMF assessment is required and must quantify the total flood volume and peak flood level, and must evaluate the spillway positioning and requirements.
17
Rehabilitation
Provide revised application material which:
The application materials states rehabilitation for the proposed UGM TSF structure will involve the transfer of potentially acid forming (PAF) waste rock exposed during construction transferred to a void. Based on the EA definition of ‘void’, there is no clear understanding on the disposal location of PAF waste rock. The only available information on the rehabilitation of the embankment is ‘runoff management systems installed on the embankment’. There is limited understanding on what this entails and more importantly how the embankment will achieve the proposed post mining land use.
a) Clarify what ‘void’ is intended to be used as the disposal location for PAF waste rock and demonstrate this aligns with Heritage Minerals Pty Ltd activities. b) Provide information on the rehabilitation of the embankment including details on the runoff systems proposed and how the feature will achieve the proposed post mining land use.
18
Laboratory waste disposal
Provide justification for the proposed amendment to EA condition E7. In providing a response, detail:
It is proposed to amend existing EA condition E7 to dispose mineral waste from the laboratory into the UGM TSF. Further justification is required on this proposed amendment including what constitutes laboratory waste and why this cannot be accounted for under the existing approval.
a) What constitutes laboratory waste.
b) The expected quantity of laboratory waste to be disposed of in the UGM TSF, including why this cannot be accounted for under the existing approval and disposal locations. c) Demonstrate the expected quantity has been accounted for in the UGM TSF capacity and does not impact the storage volume determined.
19
Catchment reporting to the OCP
Provide evidence demonstrating the proposed activity will comply with existing EA condition W10.
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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.
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.
20
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. Environmental Offsets Act 2014 (EO Act) – Matters of State Environmental Significance (MSES) 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
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.
21
9 WTS, Prelodgement Upper Mundic Gully TSF EA Amendment, 28 October 2025
10 Department of the Environment, Tourism, Science and Innovation, Information Sheet – Regional ecosystem mapping overview for environmental assessments
(ESR/2023/6632).
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identified discrepancies between on ground values and mapped values. As such, the RE mapping requires to be updated via the Queensland Herbarium. 22 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.
Provide advice on the due diligence undertaken regarding the impact to the identified MNES species.
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Translocation plans
Provide revised application material which includes:
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. The purpose of the Grevillea hockingsii translocation plan requires clarification as it does not appear to be translocating the individuals but instead collecting seeds and propagating with a view to establish the plant at an alternative site. It has not been demonstrated via literature review the feasibility of successfully translocating Grevillea hockingsii . Further, the current recipient site
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. Clarify and demonstrate the timeframe for translocation (i.e., five (5) years) is suitable. Compare your scenario to
ii.
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appears to be unsuitable with no management currently occurring and the two individuals identified in poor health.
the circumstances outlined in your reference to Silcock et al. (2021) to demonstrate it is commensurate. Demonstrate that long term legal security or management security has been obtained for the recipient site. Provide advice on how the recipient site will be managed to support successful translocation and future recruitment.
iii.
iv.
c) For the Grevillea hockingsii translocation plan :
i.
Demonstrate and provide advice regarding the feasibility of translocating this species as proposed via propagating, including providing references to relevant literature that supports your determination (i.e., demonstrate directly relevant reestablishment projects have been successfully carried out elsewhere). Demonstrate a suitable nursery has been identified and is capable of successfully propagating and maintaining individuals. Demonstrate the recipient site is geologically and ecologically equivalent and individuals are present and successfully established to demonstrate suitability. Clarify and demonstrate the timeframe for translocation (i.e., 5 years) is suitable. Compare your scenario to the circumstances outlined in relevant literature to demonstrate it is commensurate. Demonstrate that long term legal security or management security has been obtained for the recipient site. Provide advice on how the recipient site will be managed to support successful translocation and future recruitment.
ii.
iii.
iv.
v.
vi.
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Provide revised application material which addresses the comments in the adjacent column and includes a comprehensive assessment on the below species to demonstrate a significant residual impact will not be triggered. a) Cycads - Xanthorrhoea johnsonii, Macrozamia miquelii and Cycas media.
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Species assessment
A number of flora and fauna species require further assessment to clearly demonstrate a significant residual impact will not take place. This includes: a) Three special least concern cycads are identified on the State held databases, however, have not been detailed or comprehensively assessed. b) Two special least concern Orchids, with the application material suggesting Cymbidium canaliculatum was not searched for. c) Northern Quoll which is an EPBC Act listed species was confirmed as present on the project site, however no management mechanisms for this species is provided. d) Koala is identified in the application material as likely to occur, with advice suggesting the nearest record is over 100 kilometres (km) away incorrect. e) Ghost bats cannot be readily determined using bat detectors, with techniques available in literature using acoustic attractants and camera traps to determine site use by this species already developed. f) The tunnel may be a likely breeding place for Rhinolophus, Miniopterus and Taphozous species as well as the Northern Quoll. The activity levels recorded for Rhinolophus megaphyllus, Miniopterus orianae and Miniopterus australis appear to be indicative of a roost on or near to the proposed facility. A determination if the tunnel is a likely breeding place is required. g) The photographs provided in the application material of quoll habitat appear to display features of Chalinolobus dwyeri roosting sites. Disturbance to this rocky scarp area
b) Orchids - Cymbidium canaliculatum and Cryptostylis erecta.
c) Northern Quoll ( Dasyurus hallucatus).
d) Koala ( Phascolarctos cinereus ).
e) Ghost bats (Macroderma gigas). Alternative techniques, including inspections for indicators of use, should be utilised to determine the presence of this species. f) A determination supported by field evidence confirming if the tunnel is a breeding place for Rhinolophus megaphyllus, Miniopterus orianae and Miniopterus australis is required. g) Chalinolobus dwyeri and the determination if the proposed facility will impact potential roosting sites.
h) Squatter pigeon (southern) Geophaps scripta scripta.
i) Collared Delma ( Delma torquata).
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should be avoided. If avoidance is not possible, this area should be intensively sampled acoustically for the presence of this species. h) There are multiple records of squatter pigeon within 15 km of the proposed facility. i) The collared Delma warrants further investigation / survey as habitat parameters visible in the site photographs are suited to the occurrence of this species.
When preparing a response to this information request, where applicable, existing reports must be revised and supported with additional tracked changed documents. Further, a summary document that references this information request and indicates where relevant sections of supporting reports address each of the items requested must be provided.
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