8.3.3
Malleefowl
Measures to mitigate impacts to Malleefowl during construction and operation include:
OPR commits to not disturbing any active Malleefowl mound. Should a nest be discovered
that cannot be avoided, the nest will be disturbed only once all Malleefowl adults and
chicks have left the nest. If this is not possible OPR will apply for permission to disturb;
all personnel involved in ground disturbing works are required to attend a site specific
induction which will include guidelines in avoiding impacts to the species;
OPR have developed fact sheets for all conservation significant flora and fauna species
recorded along the rail including Malleefowl with photographs of typical habitat and form;
and
provision of fauna passages below the rail lines to allow movement across the Rail Corridor.
8.4
PREDICTED OUTCOMES
After mitigation and management measures have been applied, the Proposal is expected to result in
the following outcomes in relation to matters of NES:
no impacts to the Kalbarri Spider‐orchid or Fitzgerald’s Mulla Mulla as they have not been
recorded within or in proximity to the Proposal Area;
no direct or indirect impacts on the known locations of Hoffman’s Spider‐orchid, Moresby
Range Drummondita or Howatharra Mallee as the predicted rail alignment allows for
complete avoidance;
low likelihood of significant impact on Carnaby’s Black‐Cockatoo, with only 1.3% of the
potential feeding habitat within the Study Area expected to be impacted by the Proposal.
Suitable habitat types are also extensively represented beyond the Study Area;
low likelihood of significant impact on Slender‐billed Thornbill, with only 2.9% of the
potential habitat within the Study Area expected to be impacted by the Proposal. Suitable
habitat types are also extensively represented beyond the Study Area;
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the Rail Corridor alignment has been designed to avoid all but two of the more than 50
populations of the Western Spiny‐tailed Skink recorded in surveys undertaken within the
Study Area. The Rail Corridor has been deviated to provide at least a 200 m buffer between
most populations and the Rail Corridor. Only two populations will potentially be bisected
by the proposed rail centreline. A buffer of 50 ‐ 60 m will be maintained between
disturbance and outcrop locations so that no known habitat will be directly impacted. As
such there are not expected to be any significant impacts to the Western Spiny‐tailed Skink;
and
there may be some localised movement of fauna away from the rail construction and
operational corridor due to increased presence of people and machinery and the resulting
increase in ambient noise and vibration.
With the implementation of the identified management measures, potential impacts on matters or
NES are expected to be minor.
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9
PROPOSAL ENVIRONMENTAL MANAGEMENT FRAMEWORK
9.1
PRINCIPLES OF ENVIRONMENTAL PROTECTION
Oakajee Port and Rail (OPR) recognises that environmental responsibilities go beyond those required
for compliance and aims to encompass strong commitments to environmental management,
leadership in sustainable development and social obligations.
The Environmental Protection Act 1986 (EP Act) was amended in 2003 to include a core set of
Principles that are applied by the Environmental Protection Authority (EPA) in formal assessments. As
listed in Section 4A of the EP Act, these are:
the precautionary principle;
intergenerational equity;
conservation of biological diversity and ecological integrity;
principles related to improved valuation, pricing and incentive mechanisms; and
waste management.
OPR has embraced the EPA’s principles of environment protection as part of its Proposal engineering
and design. The environmental objective of the Proposals design, in order of priority, is to:
1.
Completely avoid the impact if possible
2.
Substitute with a lesser impact
3.
Include rehabilitation / engineering solutions to reduce the degree / risk of impact
4.
Design operational controls and emergency response around reduction of impact
Demonstration of this approach is detailed within this Public Environmental Review (PER). OPR has
applied these principles through consideration of alternative designs for the Proposal,
comprehensive environmental investigations, stakeholder and community engagement and the
commitment to local employment for construction and operation phases of the Proposal. Table 9‐1
summarises OPRs consideration of the principles of environmental protection.
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Table 9‐1 Application of Principles of Environmental Protection
Principle
Consideration given to the Principle
Addressed in
Section of
PER
The Precautionary Principle
Where there are threats of serious or irreversible damage,
lack of full scientific certainty should not be used as a
reason for postponing measures to prevent environmental
degradation. In the application of the of the precautionary
principle decisions should be guided by:
a)
Careful evaluation to avoid, where practicable,
serious or irreversible damage to the environment.
b)
An assessment of the risk-weighted consequences
of various options.
OPR has undertaken detailed site
investigations of the biological and physical
environs. Where these investigations identify
significant conservation issues, management
measures have been and will continue to be
incorporated into the Proposal design to
avoid where practicable, or minimise any
potential impacts.
See detailed
assessment of
factors in
Sections 7 & 8
Intergenerational Equity
The present generation should ensure that the health,
diversity and productivity of the environment is maintained
or enhanced for the benefit of future generations.
OPR recognises the responsibility it has to
ensure that all land within its sphere of
influence is preserved for future generations.
This includes prompt and effective
rehabilitation of disturbed land. OPR is
committed to the principles of minimum
resource use and emissions minimisation
and will incorporate sustainability into
Proposal design wherever practicable.
Section 7 & 8
Conservation of Biological Diversity and Ecological
Integrity
Conservation of biological diversity and ecological integrity
should be a fundamental consideration.
OPR will seek to minimise its footprint to
avoid disturbance as far as practicable. OPR
has sought alternative routes to avoid
impacting recognised areas of conservation
significance and is continuing biological
investigations to identify other aspects of
potential environmental significance of high
preservation value.
See detailed
assessment of
factors in
Sections 7
Rehabilitation
and closure
strategies in
Section 9.2.3
Improved Valuation, Pricing and Incentive
Mechanisms
a) Environmental factors should be included in the
valuation of assets and service.
b) The polluter pays principle – those who generate
pollution and waste should bear the costs of containment,
avoidance or abatement.
c) The users of goods and services should pay prices
based on the full life cycle of costs of providing goods and
services, including the use of natural resources and assets
and the ultimate disposal of any wastes.
d) Environmental goals, having been established should be
pursued in the most cost – effective way, by establishing
incentive structures, including market mechanisms, which
enable those best placed to develop their own solutions
and responses to environmental problems.
OPR acknowledges the need for improved
valuation, pricing and incentive mechanisms
and endeavours to pursue these principles
though out the feasibility phases. To date
environmental factors have played a major
role determining the Proposal design
including decisions on route length and
equipment selection to reduce pollution type
impacts, and decision on route location to
avoid environmental impact.
Section 7
Waste Minimisation
All reasonable and practicable measures should be taken
to minimise the generation of waste and its discharge into
the environment.
OPRs approach to waste management
across all phases and components of the
Proposal is in order of priority: avoid and
reduce at source, reuse and recycle, and
treat and/or dispose. The strategies for
waste minimisation will be outlined within the
Proposal Environmental Management
System (EMS).
Section 7.10
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9.2
ENVIRONMENTAL MANAGEMENT SYSTEM
OPR has developed an EMS to provide an over‐arching structure by which the environmental management
strategies and associated control measures have been developed. The OPR EMS has been developed in
accordance with AS/NZS 14001 standard, with a focus on continuous improvement process, as outlined in
Figure 9‐1. To consolidate the strategies and control measures, a series of environmental objectives and
targets have been developed within the EMS in accordance with the OPR Environmental Policy. To
effectively address all potential environmental aspects and impacts, the OPR EMS has implemented the
fundamental tools of risk identification and control to assist in developing the management strategies and
control measures.
To ensure the implementation of all environmental objectives, targets and commitments during the
delivery of the project, the OPR EMS will be finalised following final approval to implement procedures that
integrate commitments within the procurement and construction programs. Routine audits of the system
and a management review process will ensure the adherence to procedures and commitments during the
delivery of the project. A detailed framework of the OPR EMS is presented in Figure 9‐1.
A Safety Management System based on AS/NZS 4801 will be developed separately and aligned to the EMS
framework. The OPR Incident Management System will be developed within the Safety Management
System with procedures within the EMS instructing environmental teams and construction managers on
managing environmental incidents via the Incident Management System. In addition, Emergency Response
Procedures and Training, Competency and Awareness will be managed via the Safety Management System
with procedures outlined within the EMS.
Table 9‐2 outlines the proposed EMS management actions proposed.
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Table 9‐2 EMS management strategies
Management Strategies
Phase
Responsible
Persons
Prepare and implement an EMS consistent with the Principles of ISO 14001 that includes the
following elements:
incident management system;
targets and objectives;
promotion of continuous improvement;
compliance
auditing;
environmental requirements in contracts;
environmental awareness and specific training (where relevant); and
obligations
register.
Construction
& Operation
Environment
Manager
Inductions will be conducted for all employees and contractors to include information on:
the appropriate storage, handling and transport procedures for potential contaminants;
the importance of preventing contamination of all areas including marine waters;
emergency response procedures and responsibilities;
the importance of minimizing impacts on terrestrial fauna;
the procedures and protocols for fauna management;
methods of minimising power and water usage within the Proposal;
restricted access areas;
protection of significant flora and vegetation;
restriction of activities to approved areas;
the OPR clearing permit system;
waste management procedures including avoidance and minimisation, re-use and recycling,
and appropriate disposal;
significance of Aboriginal heritage;
procedures to report potential new Aboriginal Heritage sites;
obligations under the Aboriginal Heritage Act 1972 (AH Act);
requirements for the protection of known Aboriginal sites; and
other environmental management risks as identified through risk assessment procedures.
The induction information may be tailored to particular positions so as to ensure that the information
presented is relevant to the activities the position is responsible for.
Construction
& Operation
Environment
Manager
Prepare and implement an Emergency Response and Crisis Management Plans to include response
to fire, hazardous material leaks or spillages, accidents and other key risks identified through OPR
risk assessment and management processes (refer to Emergency Response Plans).
Construction
& Operation
Environment
Manager,
Safety
Manager
Prepare and implement a purchasing policy that includes:
preference for purchase of materials with low embodied energy;
energy efficiency of key energy using equipment;
appropriate
communications;
spill protection as per regulation;
licences and other precautions regarding hazardous materials and safety risks;
key contractors to minimise waste by avoidance; and
reuse and recycling and ensuring safe waste disposal opportunities.
Construction
& Operation
Construction
Manager,
Operations
Manager
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Figure 9‐1 EMS process flowchart
A Safety Management System based on AS/NZS 4801 will be developed separately but will be aligned to the
EMS framework, including emergency response procedures. Figure 9‐2 demonstrates the proposed
structure of the EMS.
Planning
Environmental Policy
Objectives & Targets
Aspects & Impacts
Risk Evaluation
Legislative & Regulatory
Management
Implementation
Structure & Responsibility
Management Control
Training & Communication
Improvement
Review
Management Plans & Procedures
Contractor Management
Incident Review
Non-Conformance Management
Compliance Auditing
Monitoring & Measurement
Management Plan Review
Contractor Management
Review
Training & Communication
Review
Continuous
Improvement
Performance Reporting
EMP & Procedure Implementation
Planning
Environmental Policy
Objectives & Targets
Aspects & Impacts
Risk Evaluation
Legislative & Regulatory
Management
Implementation
Structure & Responsibility
Management Control
Training & Communication
Improvement
Review
Management Plans & Procedures
Contractor Management
Incident Review
Non-Conformance Management
Compliance Auditing
Monitoring & Measurement
Management Plan Review
Contractor Management
Review
Training & Communication
Review
Continuous
Improvement
Performance Reporting
EMP & Procedure Implementation
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Figure 9‐2 EMS structure
9.2.1
Environmental Management Plans
There are several significant environmental and social impacts expected as a result of this Proposal. OPR
have developed Environmental Management Plans (EMPs) for these factors as a primary method of
controlling, managing and monitoring the environmental impacts associated.
The EMPs are elements of the OPR EMS that will be used to achieve the environmental and social
objectives, targets and commitments of the Proposal and the application of management and mitigation
measures described in this PER.
An ISO 14001 based EMS will be finalised prior to commencement of construction, as will construction
EMPs for the following:
Aboriginal cultural heritage;
acid sulfate soils (ASS);
air quality;
emergency response;
vegetation and flora (including weed, clearing and rehabilitation);
fauna, including terrestrial vertebrate and subterranean fauna;
groundwater;
OPR Environmental Policy
Environmental Objectives
& Targets
Port Marine
Port
Landside
PER
Register of Environmental
Factors & Potential Impacts
Register of Management
Strategies (Proposed
Management)
Rail PER
Surface Water
Flora & Vegetation
Fauna
Construction
Management Plans
Flora & Vegetation
Fauna
Noise & Vibration
Operation
Management Plans
Legislative Database
Aspects & Impacts
Construction & Operation
Management Plan
Commitments Register
Construction Procedures
& Induction
OPR Environmental Management System
Monitoring Plans and
Contingency Procedures
Document Control &
Reporting
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surface water;
hazardous materials and contamination;
noise and vibration; and
sustainable resource efficiency (including waste).
Operations EMPs will be finalised prior to operation, including management strategies relevant to:
Aboriginal heritage;
air quality;
emergency response;
fauna, including vertebrate, invertebrate and subterranean fauna;
vegetation and flora;
groundwater;
surface water;
hazardous materials and contamination;
noise and vibration; and
sustainable resource efficiency (including waste).
Table 9‐3 contains a summary of significant management actions that will be included and in many cases
expanded upon in the EMPs.
9.2.1
Consolidated Key Management Actions
Table 9‐3 consolidates the key management actions proposed in this PER.
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Table 9‐3 Consolidated key management actions for the Proposal
Management Strategies
Relevant
EMP
Phase
Responsible Persons
Vegetation and Flora
Vegetation clearing will occur within clearly defined boundaries
Vegetation
and Flora
Management
Plan (VFMP)
Design &
Construction
Construction Manager
All conservation significant locations will be avoided where possible and will be visually marked with restricted access
VFMP
Design &
Construction
Project Engineer,
Construction Manager
Required clearing will be minimised, for example:
Material from cut rail sections will be used where practicable in preference to material sourced from borrow pits to minimise clearing; and
Pre-disturbed areas will be used wherever possible for temporary infrastructure.
VFMP Design
&
Construction
Project Engineer,
Construction Manager
Throughout the freehold area native vegetation will not be cleared except for the purposes of the rail alignment and access tracks where alternative routes are not
practicable
VFMP Design
&
Construction
Project Engineer,
Construction Manager
The rail alignment will be restricted to an average disturbance width of 100 m in width when it passes through areas of native vegetation in the freehold area
VFMP
Design &
Construction
Project Engineer,
Construction Manager
Priority Ecological Communities (PECs) will be avoided and a 50 m buffer will be put in place around these areas
VFMP
Design &
Construction
Project Engineer,
Construction Manager
The impact on active creek beds will be minimised through the use of bridges and culverts, to help protect riparian vegetation. For more information see surface water
section
Surface Water
Management
Plan (SWMP)
Design &
Construction
Project Engineer,
Construction Manager
All proposed disturbance areas that are to be located outside of the Study Area will be surveyed for all potential Threatened Ecological Communities, PEC, Declared
Rare Flora (DRF) and Priority Species to the same level as the remainder of the Study Area.
The results of these surveys will be used to perform the same vegetation and flora impact assessments as detailed in Section 7.2 of the PER.
VFMP Design
&
Construction
Environment Manager
All final proposed disturbance areas will be subject to detailed targeted surveys for DRF and the following Priority Flora species prior to disturbance:
Chamelaucium sp. Yalgoo (P1);
Eremophila sp. Tallering (P1);
Goodenia lyrata (P1);
Gunniopsis divisa (P1);
Petrophile vana (P1);
Ptilotus tetrandrus (P1);
Eremophila arachnoids subsp . arachnoids (P3);
Homalocalyx echinulatus (P3);
Tecticornia cymbiformis (P3);
Thryptomene sp. Moresby Range (P3); and
Thryptomene sp. Wandana (P3).
The survey information will be included in OPR databases and documentation to ensure that OPR will not disturb beyond the areas approved in the PER.
VFMP Design
&
Construction
Environment Manager
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