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Perth WA 6000
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(08) 9227 2699
Aurora Environmental
CIS2015-001-EPBC-005_pz
22 March 2017
22 March 2017
Mallory Owen
Department of Environment
GPO Box 787
CANBERRA ACT 2601
Dear Mallory,
RE:
EPBC 2015/7621 – RESPONSE TO REQUEST FOR INFORMATION
The purpose of this letter is to provide the Department of Environment and Energy (DoEE) with
Aurigen Group Pty Ltd’s (the Proponent) response to a request for information in relation to the
assessment of the Gingin Regional Landfill Project (EPBC Ref 2015/7621). Details of the requested
information was contained in Attachment A of the letter sent from the DoEE dated 23 March 2016
and via email sent 22 September 2016.
HABITAT SURVEY
At the request of the Department, a Black Cockatoo habitat survey was commissioned for the
Proponent. It was conducted by Greg Harewood, an experienced and competent zoologist who
visited the site in May 2016 to assess the habitat present and determine its value to Black
Cockatoos. The survey (Attachment 1) included all areas within the project footprint, as well as the
area designated as a proposed offset. It used a scoring system ranging from 0 to 6 to assign values
to areas on the site (Attachment 2). A lower score reflects habitat that has no value or very limited
value to Black Cockatoos. A higher score reflects habitat that has a greater value to Black Cockatoos.
The following were the important findings from the assessment:
•
Of the 156 flora species identified at the site, 15 taxa are documented as known food sources for
Black Cockatoos. Eleven of these were recorded in the proposed offset area and 10 in the
balance of the site (this include 2 introduced taxa). Another nine species of plant recorded in
the proposed offset area may possibly be foraged upon, but this is based on other species in the
same genus being documented as known food sources. Eight potential foraging species were
recorded in the balance of the subject site.
•
The 66.6ha project footprint contains habitat of varying quality, with scores ranging from 0
(cleared areas) to 4, reflecting the previous disturbances that have occurred on the site
(Attachment 2). Areas containing Banksia species were rated higher than those areas with
fewer or no Banksia species.
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•
Approximately 44.7% (29.8ha) of the project footprint had an assigned rating of 0 to 1, with 9.5%
(6.3ha) mapped as 1 to 2, 19.4% (12.9ha) mapped as 3 and 26.5% (17.6ha) mapped as 4. The
survey confirmed that majority of the vegetation in the project footprint has no, or negligible to
low value to Black Cockatoos.
•
The majority (63.5%) of the proposed offset area was scored as a 4, 36.48% was scored as a 3
and the balance (0.02%) of the proposed offset area being scored as 0 to 1.
•
Eight potential Black Cockatoo habitat trees were recorded in the proposed offset area. Five of
these trees appeared to have hollows with entrances large enough to allow entry of a Black
Cockatoo.
•
No evidence of Black Cockatoo roosting was identified in the survey area.
AVOIDANCE AND MITIGATION STRATEGIES
Avoidance
The Fernview Farms site was selected through a comprehensive site selection process that
discounted potential alternative sites due to potential groundwater and/or vegetation constraints.
The project site was selected as the preferred location as the site characteristics are suitable for the
landfill operation. These characteristics included topography, distance from sensitive receptors and
waterways, geological suitability, depth to groundwater, proximity to the Perth metropolitan region
and access to key transport routes. The vegetation present on the site was seen as being degraded
due to past clearing activities for agricultural purposes.
The project layout has been revised and re-modelled to reduce the impact to remnant vegetation on
the site, and in doing so reduce the potential impacts to Carnaby’s Cockatoo. By revising the landfill
layout, impacts to higher quality vegetation have been avoided. The revised layout as presented in
the referral requires the clearance of approximately 42.5ha of regrowth native vegetation. Not all of
this provides habitat for black cockatoos. In comparison, the previous footprint required the
removal of up to 61ha of regrowth native vegetation of which 26ha was considered to be of good
quality (or better). The redesign has significantly reduced the impact to black cockatoo habitat
through avoidance.
Vegetation to the south of the proposed landfill was excluded from the project area on the basis that
the vegetation in this area was assessed as being in excellent condition. The original landfill
footprint was shifted further north to avoid this area. Under the current proposal from Aurigen, the
area of vegetation immediately south of the proposed landfill will be protected in perpetuity for
conservation as it forms a part of the proposed offset area.
On-site Mitigation
The site will be designed and operated to the highest possible standard to minimise the impact on
surrounding vegetation. Strategies to minimise the impacts on vegetation include:
•
Clearing boundaries will be clearly marked and identified, including the use of fencing where
appropriate. Personnel will be educated on the importance of adhering to clearing limits in order
to minimise disturbance to existing vegetation.
•
Cleared soil and/or vegetation will be stockpiled for potential use as daily cover and/or capping
material.
Department of Environment
Fernview Farms EPBC Referral
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•
Site disturbance is to be minimised, with vegetation retained where possible in between
infrastructure with regard to Health, Safety and Operational requirements.
•
Roads and tracks will be developed along existing easements where possible.
•
Vegetation to the south of the project area will be fenced to minimise disturbance. The
proponent will develop and implement a weed monitoring and management programme in this
area prior to the commencement of operations.
•
Vehicle use will be restricted to designated tracks with parking in allocated areas.
•
A Fire Management Plan has been prepared and will be implemented as part of the project’s
Environmental Management Plan to minimise the risk of fire.
The following fauna management strategies will be implemented during and after the development
of the site:
•
Vehicles and machinery will be parked in designated locations only to minimise habitat damage.
•
Traffic will be restricted to established roads and parking areas, to again minimise habitat
destruction.
•
Site traffic speed limits will be lowered to minimise fauna death on roads.
•
Ensuring putrescible wastes are covered with soil at the end of each day. This will minimise the
potential for night time foraging by birds and feral and native animals.
•
Ensuring housekeeping procedures such as litter removal at the perimeter of the site are
maintained to discourage fauna from the site.
•
Applying the odour control strategies to minimise the attraction of fauna to the site.
•
Site environmental inductions will raise employee awareness in relation to conservation of fauna
(particularly rare, threatened or vulnerable fauna) and their habitats.
•
Direct contact with fauna will be avoided whenever possible.
These management measures are designed to minimise direct impacts to fauna, and to reduce the
risk of attracting feral animals which could predate on Carnaby’s Black Cockatoo.
On completion of the landfill operation, the intention is to cap and rehabilitate the site with native
vegetation.
Proposed Offsets
Aurigen commits to the following:
•
Set aside 189.14ha of habitat on Lot 98 (Attachment 2) for conservation purposes in perpetuity.
The Department of Parks and Wildlife (DPAW) have expressed their interest in acquiring the
offset area and incorporating it into the State managed conservation estate. This remains a
logical approach given that the offset area abuts land recently acquired by the Department for
inclusion in the conservation estate.
•
Manage the interface between the project area and the offset area to ensure that the habitat
condition does not deteriorate from baseline condition as mapped in May 2016. This will be
achieved through the provision of fencing as required along with periodic inspection for weeds
and windblown litter or fly-tipped wastes.
•
Conduct annual monitoring of the interface between the project area and the offset area to
ensure that the conservation values of the interface do not diminish from their current levels.
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Annual reporting by Aurigen to the DoEE and DPAW demonstrating compliance with the
proposed commitments will be undertaken.
•
Implement feral animal control procedures in the project area.
•
Ensure appropriate closure of the landfill facility.
Adequacy of the Offset
The offsets area comprises high quality black cockatoo habitat. It has eight potential Black Cockatoo
habitat trees, of which five contain hollows with entrances large enough to permit entry by black
cockatoos. The presence of these hollows elevate the conservation significance of the offset area, as
the site is located in the modelled breeding zone for Carnaby’s Cockatoo and that the species is
known to breed in the nearby Boonanarring Nature Reserve.
The proposed offset area is owned freehold and therefore has no secure tenure that provides
protection to this habitat. Its values could be compromised in the long term through potential
mismanagement. Transferring the proposed offset area to the conservation estate will avert future
loss of existing habitat, by transferring the bushland to state ownership, ensuring that the bush is
managed appropriately to protect its values. The transfer will provide immediate protection of the
bushland.
When comparing habitat quality in the project area against the offset area, it can be seen in Table 1
that the offset area adequately compensates the loss of habitat expected from the implementation
of this project.
TABLE 1:
HABITAT QUALITY COMPARISON: OFFSET AREA VS PROJECT AREA
Rating Score
Offset Area
(Hectares)
Project Footprint
(Hectares)
Ratio
0 to 1
0.04
29.8
0.001:1
1 to 2
0
6.3
0
3
69
12.9
5.35:1
4
120.1
17.6
6.82:1
The predominant focus of the offset program is to preserve existing habitat and avert future loss,
which brings a high degree of certainty in terms of the outcome. As indicated, the offset area is
owned freehold. The proposal is to transfer this land to the Conservation Estate to be managed by
DPAW which will provide protection in perpetuity and avert future habitat loss. The transfer can be
initiated upon commencement of the project and will provide an immediate benefit. DPAW has
recently acquired land adjacent to the offset area.
Draft Offsets Guide
The draft Offsets Guide has been used to calculate the adequacy of the offset in meeting the DoEE
requirements. The offset area totals 189.14ha, which exceeds the minimum requirements for an
offset as outlined in the Offsets Guide and Offsets Policy.
Department of Environment
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The key parameters for the offsets guide were:
Area of habitat – project area
42.5ha
Quality Score – project area
4
(out of 10)
Total Quantum of Impact
17
(automatically calculated by Offsets Guide)
Time over which loss is averted
20 years
(maximum permissible)
Start area – offset area
189.14
Time until ecological benefit
10
Start quality – offset area
7
Risk of loss without offset
20%
Risk of loss with offset
5%
Future area without offset (adjusted)
151.3ha
Future area with offset (adjusted)
179.7ha
Future Quality without Offset
6
Future Quality with Offset
7
Calculated % of Impact Offset
145.37%
Carnaby’s Black Cockatoo Recovery Plan
The proposed offset addresses critical aspects of the Carnaby’s Black Cockatoo Recovery Plan in the
following ways:
•
The transfer of bushland to the State conservation estate prevents further loss or degradation of
existing foraging and potential breeding resources. The Recovery Plan states that “…breeding
and nearby feeding habitat…is considered habitat critical for the recovery of the species.” In the
short-term, the loss or degradation of feeding habitat adjacent (i.e.<12km) to breeding sites is
considered to pose the greatest risk to Carnaby’s Cockatoo (Saunders and Ingram, 1998). The
preservation of 189.14ha is consistent with Action 1 of the Recovery Plan – Protect and Manage
Important Habitat. The Recovery Plan states that “While planting of species that support
Carnaby’s Cockatoo is effective over the long-term and encouraged, protection and regeneration
of existing habitat is significantly more efficient and effective.”
Integration of Conditions under Western Australian Legislation
No further state environmental approvals are required in order for the Fernview Farms proposal to
proceed. Therefore, it is unlikely that the proposed avoidance, mitigation and offset measures could
be incorporated into reports or plans required under Western Australian legislation. Annual
reporting obligations under Western Australian approvals will be focussed upon those conditions
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attached to the State approvals. However, compliance with avoidance, mitigation and offset
measures can be addressed through Federal compliance reporting requirements.
Outcomes Based Conditions
Aurigen commits to the following outcomes:
•
The project footprint is limited to 66.6ha.
•
No more than 42.5ha of native vegetation will be cleared in the project footprint.
•
Within 24 months of commencing the project, Aurigen will transfer to the State of Western
Australia, 189.14ha of land containing black cockatoo habitat for addition to the conservation
estate as depicted in Attachment 2. The subdivision will be managed by DPAW and the nominal
costs associated with the subdivision will be met by Aurigen.
•
Aurigen will manage the interface between the landfill operations and the offset area through
the provision of fencing and periodic inspection for weeds, windblown litter and illegally
dumped wastes. The offset area condition is not to diminish below current levels as a result of
the landfill project.
•
Following decommissioning, Aurigen will transfer to DPAW the area of land where the
weighbridge, office facilities and storage area are located. Prior to decommissioning of the site,
Aurigen will discuss and agree with DPAW the transfer details.
•
Aurigen is to undertake annual reporting to the Commonwealth and DPAW to demonstrate
compliance with the above outcomes. Reporting will be published on their website by 30 June
of each year after the commencement of the action.
•
Non-compliance with the above outcomes will be reported to the Federal Minister for
Environment.
•
Any variance from the above conditions will require written authorisation from the Federal
Minister for the Environment.
The above outcomes and conditions have been discussed and agreed with DPAW.
Economic and Social Matters
The Fernview landfill project will provide employment for up to 20 people during the 12-month
construction phase and then employ five people on ongoing basis for the life of the project. The total
capital expenditure will be in the order of $25m-$30m for the 10 cells to be developed on the site.
The landfill will provide the Shire of Gingin with a viable long-term disposal option, as well as be one
of only three Class II northern suburbs landfill sites. With five of the six current local government
owned landfills expected to be full by 2022, the Fernview Landfill will form a key waste management
infrastructure solution well beyond that date.
Stakeholder Consultation
Aurigen has entered into an arrangement with Veolia to enable the commencement of construction
of the Fernview Landfill. Development of the landfill is also the subject of a Deed of Agreement
between Veolia and the Shire of Gingin. Aurigen will enter into a Deed of Assignment with the
Council to transfer the obligations and conditions of the Deed from Veolia to Aurigen.
As Aurigen has recently acquired the Project, the company has not conducted any specific
consultation, other than to establish contact with relevant government agencies. However, as there
Department of Environment
Fernview Farms EPBC Referral
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was extensive consultation previously completed for the project no additional consultation has been
planned given that the project details remain unchanged. The specific modes of communication
used previously in relation to the proposed operation included:
•
Letters inviting personal briefings were sent to State and Federal MPs who represent the
residents in the Shire of Gingin, as well neighbouring landowners and key interest groups;
•
Informal and formal meetings;
•
Telephone conversations;
•
Distribution of information packages within the community containing:
o
Question and answer sheet;
o
List of project participants with contact details;
o
Map of proposed Fernview site;
o
Photos of site and existing landfill facilities on the Swan Coastal Plain; and
o
Company brochure.
•
E-mail correspondence.
A series of briefings were held by the former proponent at the Gingin Hotel with identified
stakeholders to inform them about the proposal. Information provided at these briefings included
details on the nature of the facility, timing of the project and the approval process.
A second stage of community consultation involving continued liaison with engaged stakeholders
and distribution of information on the project through the local media was completed. A public
meeting was held when the proposal was been formally submitted to the EPA. Following the public
meeting, a newsletter was prepared for general distribution within the community and email
briefings to key stakeholders to provide additional information and updates. Table 2 lists the
relevant stakeholders that were included during the consultation process.
TABLE 2:
LIST OF RELEVANT STAKEHOLDERS
GOVERNMENT AND PARLIAMENTARY STAKEHOLDERS
NON-GOVERNMENT STAKEHOLDERS
Department of Environment and Conservation (now
DER)
Neighbouring landowners
EPA
Local community
Shire of Gingin
Wider community
Shire of Chittering
Gingin Land Conservation District Committee
Judi Moylan Federal MP
Friends of Gingin Brook
Kim Chance MLC, Minister for Agriculture and Food,
Forestry, the Midwest and Wheatbelt
Concerned Citizens Against Waste
Gary Snook MLA
Gingin Group for Property Rights
Department of Environment
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