WSGP Biodiversity Offset Strategy

Transcription

1 Document Number: SENEX-WSGP-EN-PLN-010 Revision: 0 Position Name (tick one column only) Signature Date Approve Review Environment Manager T. Jensen 20 / 12/ Page 1 of

2 Table of Contents REVISION HISTORY... 5 executive summary... 6 Key Terms... 7 Abbreviations Introduction Project Background Offset Strategy Background Objectives Approach to Developing the Offset Strategy Policy and Legislative context Applicability Duplicity Type and Scale of Offset Co-location Biodiversity Values Requiring Offset Introduction Matters of National Environmental Significance Threatened Ecological Communities Threatened Species Habitat Migratory Species Habitat Matters of State Environmental Significance Prescribed Regional Ecosystems (Endangered and Of Concern) Prescribed Regional Ecosystems (Intersecting a wetland and Within a defined distance of a watercourse) Connectivity Prescribed Regional Ecosystems (habitat for Endangered, Vulnerable or Special Least Concern wildlife) Summary of MNES and MSES Offset Requirements Offset Strategy Staged Offset Delivery Plan Land-based Offsets Desk-based Offset Site Identification Site Verification Prepare Offset Delivery Plan Prepare Offset Site Management Plan Property Acquisition Process and Legally Securing Mechanism Page 2 of

3 4.2.6 Calculate Actual Impact Financial Offset Options Conclusion References... Page 3 of

4 Figures Figure 1-1: WSGP Location and Production Area Figure 4-1: WSGP Offset Approval and Management Flowchart Stage Figure 4-2: WSGP Offset Delivery and Management Flowchart subsequent stages Tables Table 3-1 Estimated Matters of National Significance Offset Requirement Table 3-2 Estimated Matters of State Environmental Significance Offset Requirement Table 3-3 Summary Significant residual impacts to MNES and MSES Table 4-1 Offset Area Estimates for MNES and MSES Table 4-2 Indicative management requirements for the offset site Page 4 of

5 REVISION HISTORY Revision Revision Date Document Status Revision Comments Author Approved By A April Issued for Review Document creation ERM B May Issued for Review Revised following review ERM J.Earley C July Final Revised following review ERM J.Earley 0 Final Management actions, Delivery plan ERM, H.Wood J.Earley Page 5 of

6 EXECUTIVE SUMMARY Senex Energy Limited (ACN ) on behalf of its wholly-owned subsidiary Stuart Petroleum Cooper Basin Gas Pty Ltd (ACN ) has prepared a Biodiversity Offsets Strategy to address obligations for the proposed Western Surat Gas Project (WSGP) in accordance with the relevant State and Commonwealth offset policies. This Biodiversity Offsets Strategy identifies the likely offset obligations for the WSGP production activities, and defines a pathway to deliver an offsets package to fulfil Commonwealth and State offset requirements. The Offset Strategy aims to combine both Commonwealth and State offset obligations, to allow for efficient co-location of the Commonwealth and State environmental values where appropriate. Impact assessment undertaken in accordance with the relevant guidelines and documented in the Western Surat Gas Project Environmental Authority EPPG amendment application supporting information [SENEX-WSGP-EN-REP-025] (Senex, a) and Western Surat Gas Project Public Environment Report [SENEX-WSGP-REP-033] (Senex, b) assessed the potential for significant residual impact to Matters of National Environmental Significance (MNES) and Matters of State Environmental Significance (MSES). Senex proposes to offset significant residual impacts to MNES (threatened species and ecological communities); and MSES (prescribed regional ecosystems, connectivity and protected wildlife habitat) through staged offsets. The staged offsets will primarily be a landbased offset; financial settlement offsets or other compensatory measures may be considered if desired outcomes cannot be achieved directly. The Offset Strategy estimates the potential impact to MNES and MSES and defines the approach to select potential offset sites, secure the offset sites, and verify the actual residual impact following development. Page 6 of

7 Key Terms Term ERM Production Area Senex Meaning Environmental Resources Management Australia Pty Ltd A portion of the Western Surat Gas Project, consisting of 9 sub-blocks where the gas producing field will be developed Senex Energy Limited Abbreviation ATP BVG DBMP DEHP DEE EA EPBC Act FEED ha MLES MNES MSES PL Abbreviations Prescribed Environmental Matter Meaning Authority to Prospect Broad Vegetation Group Direct Benefit Management Plan Department of Environment and Heritage Protection (Qld Government) Department of the Environment and Energy (Australian Government) Environmental Authority Environmental Protection and Biodiversity Conservation Act 1999 (Commonwealth) Front End Engineering Design Studies Hectare Matters of Local Environmental Significance Matters of National Environmental Significance listed under the EPBC Act Matters of State Environmental Significance Petroleum Lease Matters of State environmental significance listed in schedule 2 of the Environmental Offsets Regulation 2014 QEOP Queensland Environmental Offset Policy (Revision 1.0) RE RoW WSGP Regional Ecosystem Right of Way Senex s proposed gas project, known as the Western Surat Gas Project in Queensland s Surat Basin Page 7 of

8 1. INTRODUCTION Senex Energy Limited ACN (Senex) on behalf of its wholly-owned subsidiary Stuart Petroleum Cooper Basin Gas Pty Ltd (Stuart Petroleum; ACN ) has prepared a Biodiversity Offsets Strategy to address obligations for the proposed Western Surat Gas Project (WSGP) in accordance with the relevant State and Commonwealth offset policies. The WSGP will involve the development of production wells and supporting infrastructure to produce coal seam gas for domestic and export markets over more than 30 years. The WSGP production area is located approximately 30 kilometres north of the Warrego highway, between the townships of Roma and Wallumbilla in central Queensland, immediately to the north of GLNG s Roma fields. Land use of the WSGP production area and nearby surrounds is predominantly rural agricultural. The township of Roma is located approximately 23 kilometres south from the southern boundary of the WSGP. Senex s Biodiversity Offsets Strategy for the WSGP identifies the relevant Queensland and Commonwealth obligations pertaining to biodiversity offsets and outlines how the necessary offsets can be delivered Project Background Senex is authorised to conduct petroleum exploration and production activities in accordance with its Environmental Authority, EPPG (EA), within authority to prospect tenures (ATP) 767, 795 and 889; and petroleum leases under application (1022, 1023, 1024). A Production Area comprising 9 of the 12 blocks making up the WSGP is proposed within the petroleum leases. Schedule F of the EA authorises impacts to specified prescribed environmental matters and environmental offsets are required for significant residual impacts to prescribed matters. Applications for the Petroleum Leases (PL) have been made and a condition of grant is that there is a relevant Environmental Authority. As part of the application for the major amendment to the EA authorising production activities, consideration of offset obligations for significant residual impacts was undertaken. Similarly, a variation to Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) Referral submission (EPBC ) for the WSGP has also considered a need for biodiversity offsets. The WSGP Production Area will comprise up to 425 production wells and associated gas and water gathering lines, up to three gas field compression facilities, three medium pressure infield pipelines, a central processing plant, and multiple water storage dams. Figure 1-1 shows the areas relevant to the WSGP. Wells will optimally be set out on 1250m grid spacing (but may range from 700m to 1500m). There is flexibility to locate wells and gathering infrastructure to ensure land access, cultural heritage and environmental constraints can be addressed and impacts minimised wherever possible. Peak drilling is estimated in the order of wells per annum. A conceptual layout was considered to estimate potential significant residual impacts using an indicative pad size of 1 ha and right of way (RoW) of 18m. The Production Area, and subject of this offset strategy, is currently proposed to generally be developed by commencing in the southern part of the production tenure and progressing Page 8 of

9 from east to west. The exact location of the facilities will be finalised as the development progresses, in a phased approach. Significant residual impacts to prescribed environmental matters are not expected as a result of ongoing exploration activities in the WSGP. Page 9 of

10 Figure 1-1: WSGP Location and Production Area Page 10 of

11 1.2. Offset Strategy Background This Biodiversity Offset Strategy has been developed to document the likely offset obligations for the WSGP production activities based on: a conceptual development plan; the prescribed environmental matters (State and Commonwealth environmental values that may be impacted by development); State and Commonwealth offset policies. The approach to combine both State and Commonwealth offset obligations in one strategy allows the total offset obligations for matters to be quantified, enabling efficient co-location of the State and Commonwealth environmental values requiring offsetting to be identified Objectives The objective of the Strategy is to outline Senex s staged approach to delivering biodiversity offsets, by: 1. Identifying the State and Commonwealth environmental values that may require offsetting provisions on the basis that those values are either known or likely to occur in the WSGP Production Area and a significant residual impact may occur during construction; 2. Presenting a pathway to be followed to deliver necessary offsets to fulfil the offset obligations for the WSGP Approach to Developing the Offset Strategy This Offsets Strategy has been prepared by considering the following: Reviewing relevant Commonwealth and Queensland legislative offset frameworks and policies; Reviewing the Western Surat Gas Project Biodiversity Environmental Values Report (ERM, ), to identify the State and Commonwealth environmental values occurring within the Production Area; Reviewing Western Surat Gas Project Environmental Authority EPP amendment application supporting information [SENEX-WSGP-EN-REP-025] (Senex, a), that identifies the Matters of State Environmental Significance (MSES) where a significant residual impact is considered likely; Reviewing the Western Surat Gas Project Public Environment Report (Senex, b), that identifies the Matters of National Environmental Significance (MNES) where a significant impact is considered likely; Reviewing approaches to identify and secure land-based offsets. The location of the development s infrastructure will be finalised in a staged approach over the life of the gas field development, which limits the ability to define the exact extent and quality of values likely to be disturbed. In general, CSG gas fields are developed progressively in accordance with a development schedule. The planning phase to locate infrastructure is subject to a detailed constraints protocol that considers environmentally Page 11 of

12 sensitive areas, and concurrently considers other important factors such as sub-surface geology, engineering limitations, and landholder requirements. The precise location of infrastructure will not be known until the front end engineering and design (FEED) phase preceding construction and when detailed ecological assessments are undertaken, to minimise site specific impacts to prescribed matters. Consequently, the impact, and incorporating avoidance and mitigation measures, can only be properly rationalised directly preceding the construction stage for a project phase. To progress with identifying WSGP offset obligations, an indicative disturbance area was used to estimate significant residual impacts to MSES and MNES. The detailed significant impact assessments are documented in the WSGP approvals documentation (Senex, a and b). The disturbance areas used in this Offsets Strategy are consistent with those used to identify significant residual impact. The actual disturbance impacts may vary from those identified from the indicative disturbance area and this has been taken into consideration. This strategy presents an overarching framework to identify and deliver a suitable offset package, accounting for this uncertainty, whilst accurately accounting for impacts to prescribed matters from the project. Page 12 of

13 2. POLICY AND LEGISLATIVE CONTEXT The use of environmental offsets is guided by the following instruments: The Commonwealth EPBC Act Environmental Offsets Policy 2012, which provides guidance for offsetting significant residual impacts to Matters of National Environmental Significance (MNES); The Queensland Environmental Offsets Act 2014 (and Regulation) and Queensland Environmental Offsets Policy 2016 Version 1.2 (QEOP), which provide the framework for offsetting significant residual impacts to Matters of State Environmental Significance (MSES). The Queensland environmental offset framework also outlines offsets for Matters of Local Environmental Significance (MLES). However, neither the Maranoa Regional Council nor Western Downs Regional Council define MLES, so they are not relevant for this project. The key requirements of these policies and legislation that apply to developing this Offsets Strategy are described below Applicability Under the Commonwealth and State policies, environmental offsets are to be used only after impacts to the MNES and MSES have been avoided and minimized. Environmental offsets may then be required for significant residual impacts to MNES and MSES. The criteria for determining whether a project might have a significant residual impact is defined for: MNES, in the Significant Impact Guidelines 1.1 (DoE, 2013); and MSES, in the Significant Residual Impact Guideline (DEHP, 2014). Assessment against these guidelines has identified potential for the WSGP to have a significant residual impact to MSES and MNES. Senex will provide an offset for significant residual impacts if: for MNES, the provision of biodiversity offsets is a condition of approval under the EPBC Act; and for MSES, the provision of environmental offsets is a condition of approval of the EA Duplicity The QEOP aims to avoid duplication of offset conditions between jurisdictions. Under the QEOP, State governments cannot impose an offset condition if the same impact or matter has been assessed under the EPBC Act. State governments can impose an offset condition if an action is referred to the Commonwealth government but not assessed under the EPBC Act (i.e. not a controlled action). If the Commonwealth government imposes an offset condition for a prescribed environmental matter after the State government has already imposed an offset condition, a proponent can apply to the State government to have duplicating offset requirements for the same prescribed impact and matter removed. The strategy presented in this document provides information to allow for duplicate matters to be removed, and co-location opportunities to be identified as part of the process. Page 13 of

14 2.3. Type and Scale of Offset Commonwealth and State offset policies allow offsets to be delivered through a range of mechanisms. This Offset Strategy considered predominantly land-based offsets as well as alternative mechanisms available recognising that both the Commonwealth and State offset policies require the offset to be of a size and scale proportional to the residual impact on the matter. The Commonwealth offset policy requires offsets to manly be achieved through direct offsets (i.e. land-based offsets) (minimum of 90% of the total offset requirement). The QEOP defines a maximum multiplier of four (i.e. a maximum of four times the area of the residual impact), with the exception of connectivity impacts - which is set at a multiplier of one. For land-based offsets, the size and scale of the offset is based on a habitat quality assessment of both the impact site and offset site. The Commonwealth offset policy does not define a multiplier to calculate the size of an offset for a given impact. The Commonwealth offset policy is accompanied by a calculator that considers factors such as quality of impact and offset sites, the duration of residual impacts, the risk of loss for a proposed offset site, and time until an offset yields a conservation gain Co-location For land-based offsets, the QEOP identifies that (with some exceptions), multiple prescribed environmental matters may be co-located on an offset site, provided the site meets the offset requirements for each matter. An exception relevant to the WSGP is that offsets for habitat for species in different functional groups may not be co-located. This exception will be considered in the delivery of the offset for the WSGP, given the potential habitat of relevant species are collocated on the impact site. The Commonwealth offset policy does not specifically comment on co-location however the How to use the Offsets Assessment Guide states: offset requirements for multiple species/ecological communities could overlap if one offset could compensate for impacts to more than one species/ecological community. Page 14 of

15 3. BIODIVERSITY VALUES REQUIRING OFFSET 3.1. Introduction As described, the Western Surat Gas Project Environmental Authority EPP amendment application supporting information [SENEX-WSGP-EN-REP-025] (Senex, a), and Western Surat Gas Project Public Environment Report [SENEX-WSGP-EN- REP-033] (Senex, b); the biodiversity values (including MNES and MSES) associated with the Production Area are documented. The reports identify impacts and management approaches, and define the significant residual impact assessments for each relevant matter in accordance with the assessment guidelines. Criteria outlined in the Significant Residual Impact Guideline and Significant Impact Guideline 1.1 were considered against the MNES and MSES identified within the Production Area. The outcomes of those assessments are presented in this strategy. Potential for a significant impact/significant residual impact was identified for MNES and MSES. An offset is only required for significant residual impacts to MNES and MSES (in accordance with the legislation and policies). As a result only those matters determined likely to incur significant residual impact are identified for offsetting. While there are a number of MNES and MSES mapped within the Production Area, not all are associated with a significant residual impact and as such are not discussed in this strategy. With the implementation of the WSGP environmental management practices (documented within a variety of management plans and protocols) there will be opportunity to further avoid areas of MNES and MSES where appropriate. This will be an iterative process as the development progresses across the Production Area. As a result, the residual impact to MNES and MSES, ie the area that will be cleared, will be finalised prior to each phase of development within the WSGP. To consider the extent of clearing impact for the project, an indicative disturbance area has been estimated, based on a conceptual layout 1. The area of actual disturbance would be expected to be reduced when the avoidance measures are applied. As the WSGP progresses and the gas field layout is defined, disturbance estimates for project phases will be refined; and actual disturbance areas will be measured and reconciled against offset obligations. 1 Conceptual layout uses a 1250m grid spacing of well pads (1 ha size) and RoW width of 18m. Page 15 of

16 3.2. Matters of National Environmental Significance This section details the significant impact for MNES for which there will be an offset obligation Threatened Ecological Communities The assessment against the criteria within the Significant Impact Guidelines identified no likely significant residual impact to any threatened ecological communities Threatened Species Habitat The assessment (documented in Senex, b) against the criteria within the Significant Impact Guidelines identified a potential significant residual impact for the: Koala (Phascolarctos cinereus); Yakka skink (Egernia rugosa); Collared delma (Delma torquata); and Dunmall s snake (Furina dunmalli) Migratory Species Habitat The assessment against the criteria within the Significant Impact Guidelines did not determine any migratory species likely to be significantly impacted by the proposed activities. Table 3-1 Estimated Matters of National Significance Offset Requirement Species Total Habitat Disturbance Estimate (ha) Stage 1 Disturbance Estimate (ha) Koala (Phascolarctos cinereus) Collared delma (Delma torquata) Yakka skink (Egernia rugosa) Dunmall s snake (Furina dunmalli) Page 16 of

17 3.3. Matters of State Environmental Significance This section details the significant residual impact for MSES for which there will be an offset obligation Prescribed Regional Ecosystems (Endangered and Of Concern) The WSGP intends to avoid disturbing regional ecosystems with a listed biodiversity status of endangered or of concern status. As a result, prescribed regional ecosystems with endangered and of concern VM status are also avoided. Through avoidance, it is unlikely there will be a significant residual impact for these prescribed regional ecosystems (Endangered or Of Concern VM Status) Prescribed Regional Ecosystems (Intersecting a wetland and Within a defined distance of a watercourse) There is likely to be a significant impact resulting from clearing for linear infrastructure for infrastructure greater than 10 metres wide in a dense to mid dense (structural category) regional ecosystem within a defined distance of a watercourse Connectivity The Landscape Fragmentation and Connectivity Tool estimated a likely significant residual impact for connectivity Prescribed Regional Ecosystems (habitat for Endangered, Vulnerable or Special Least Concern wildlife) The assessment identified a potential significant residual impact for three fauna species confirmed or possible to occur within the Production Area: glossy-black cockatoo (Calyptorhynchus lathami), south-eastern long-eared bat (Nyctophilus corbeni) and yakka skink (Egernia rugosa). Belson s panic (Homopholis belsonii) will be managed separately through the Nature Conservation Act 1992 protected plant permit process, and associated offset requirements, if required. Page 17 of

18 Table 3-2 Estimated Matters of State Environmental Significance Offset Requirement Prescribed environmental matter Total Project Disturbance Estimate (ha) Stage 1 Disturbance 1 Estimate (ha) Stage 1a Disturbance 2 Estimate (ha) Stage 1b Disturbance 3 Estimate (ha) (EA) (EA) Regulated vegetation (MSES) Prescribed regional ecosystems (within defined distance of relevant watercourse) Connectivity (MSES) Connectivity area that is a regional ecosystem Protected wildlife habitat (MSES) Habitat for an animal that is vulnerable wildlife - glossy-black cockatoo (Calyptorhynchus lathami) Habitat for an animal that is vulnerable wildlife - south-eastern long-eared bat (Nyctophilus corbeni) Habitat for an animal that is vulnerable wildlife - yakka skink (Egernia rugosa) Estimate for gas field development to FY 2021 (Stage 1a + 1b), 2- Estimate for FY2018/19, 3- Estimate for FY Summary of MNES and MSES Offset Requirements Table 3-3 Summary Significant residual impacts to MNES and MSES Prescribed environmental matter Total Project Disturbance Estimate (ha) Stage 1 Disturbance Estimate (ha) Phascolarctos cinereus (koala) MNES Delma torquata (collared delma) Egernia rugosa (yakka skink) Furina dunmalli (Dunmall s snake) Prescribed regional ecosystems (within defined distance of relevant watercourse) Connectivity area that is a regional ecosystem MSES Habitat for an animal that is vulnerable wildlife - glossy-black cockatoo (Calyptorhynchus lathami) Habitat for an animal that is vulnerable wildlife - south-eastern long-eared bat (Nyctophilus corbeni) Habitat for an animal that is vulnerable wildlife - yakka skink 1 (Egernia rugosa) Species triggered for offsets under MNES and MSES Page 18 of

19 4. OFFSET STRATEGY Senex s approach to achieving the required offset obligation for the WSGP is through staged offsets. This staged offset will primarily be a proponent driven land-based offset, however financial settlement offsets, or other compensatory measures may be considered if the desired outcomes cannot be achieved directly Staged Offset Delivery Plan The staged offset approach will enable offsets to be estimated accurately and delivered in a way that meets the obligations of the WSGP without under or over estimating the offset obligations. Staged offsets enable values to be accounted for as the project proceeds and more detailed conceptual field design of areas of the gas field become available. The WSGP will be delivered progressively across the Production Area whereby the infrastructure layout (and disturbance footprint) will be finalised as each phase is planned. The layout is refined for each stage based on environmental constraints and landholder constraints at which stage a more accurate estimate of significant residual impact can be calculated. Figure 4-1 shows the approach to delivery of offsets for the WSGP during Stage 1 of production. This stage incorporates the approvals processes required for the Commonwealth and State government agencies. Figure 4-2 shows the approach to deliver offsets for the WSGP as the project moves through subsequent stages of development. This stage considers the requirement to reconcile the actual disturbance against the offset delivered in order to identify and (if necessary rectify) a credit or debit scenario moving into subsequent stages. Page 19 of

20 Figure 4-1: WSGP Offset Approval and Management Flowchart Stage 1 Page 20 of

21 Figure 4-2: WSGP Offset Delivery and Management Flowchart subsequent stages Page 21 of

22 4.2. Land-based Offsets This section describes the process to identify and secure a land-based offset. Based on the assessment described in Section 3, offsets will be required for: MSES regulated vegetation, connectivity and protected wildlife habitat MNES threatened species habitat for four species A significant residual impact was identified for one threatened species (yakka skink) under both Commonwealth and State requirements Desk-based Offset Site Identification The largest offset obligations are related to the protected wildlife habitat prescribed matter. The extent of habitat for protected wildlife species was determined through development of habitat criteria for each species. This is documented in detail within the Western Surat Gas Project Environmental Authority EPP amendment application supporting information [SENEX-WSGP-EN-REP-025] (Senex, a) and Western Surat Gas Project Public Environment Report [SENEX-WSGP-EN-REP-033] (Senex, b). Table 3-3 summarises the MNES and MSES with a significant residual impact. The habitat criteria and/or relevant regional ecosystem types are shown for each matter. The QEOP allows co-location of multiple prescribed environmental matters, with the exception of species in different functional groups. As such, there will be opportunity to colocate offsets for prescribed regional ecosystems and connectivity where regional ecosystem types align. For the MNES, there is commonality in the regional ecosystems represented in the MSES that are likely to have a significant residual impact. To avoid duplication between State and Commonwealth offset matters it is considered likely that the QEOP requirement could satisfy the Commonwealth offset requirement and a conservation outcome could be achieved for MNES if land-based offsets are delivered for MSES. Page 22 of

23 Table 4-1 Offset Area Estimates for MNES and MSES Prescribed environmental matter QEOP requirement Habitat criteria/ Regional Ecosystems Functional Group or BVG (1M) QEOP Multiplier Total Disturbance (ha) Stage 1 Disturbance (ha) Offset Area Offset Area (ha) Total (ha) for Stage 1 Prescribed regional ecosystems (within defined distance of relevant watercourse) (MSES) Offset site must be of the , a, , same broad vegetation group as the impacted RE, within the same bioregion and associated with a watercourse 12a, 17a, 17b and 20a Connectivity area that is a regional ecosystem (MSES) Offset site must be a nonremnant ecosystem and in the same subregion , a, a, , , Glossy-black cockatoo (Calyptorhynchus lathami) and South-eastern longeared bat (Nyctophilus corbeni) (MSES) Offset site must contain, or be , a, , capable of containing, a selfsustaining population of the and , impact species , , a, , , , a, , a, , , Page 23 of

24 Prescribed environmental matter QEOP requirement Habitat criteria/ Regional Ecosystems Functional Group or BVG (1M) QEOP Multiplier Total Disturbance (ha) Stage 1 Disturbance (ha) Offset Area Offset Area (ha) Total (ha) for Stage 1 Yakka skink (Egernia rugosa) (MSES and MNES) Offset site must contain, or be , , , capable of containing, a selfsustaining population of the , , , a, , a, impact species a, , a, , , Phascolarctos cinereus (koala) (MNES) Delma torquata (collared delma) (MNES) Quality of site must be at least equal to that of the impact site , , , , , , a, , a, , , , , , , a, , , , a, , a, , , NA NA Delivery of a land-based offset for the yakka skink will meet Commonwealth offset requirements for MNES NA NA Furina dunmalli (Dunmall s snake) (MNES) , , , a, , a, , , , a, , a, , , NA NA Page 24 of

25 Using the QEOP maximum multiplier of four and colocation, an indicative total offset area for Stage 1 would require: 4 ha for yakka skink habitat which in turn provides offset outcomes for relevant MNES species (koala, collared delma and Dunmall s snake); 4 ha for the collocated glossy-black cockatoo and south-eastern long-eared bat habitat; 3 ha for prescribed regional ecosystems (within a defined distance of relevant watercourse); and 108 ha for connectivity area. Preliminary offset site identification and prioritisation will involve geospatial analysis of available data, including: Regional ecosystem and regrowth mapping data and consideration of species habitat mapping criteria for the MNES and MSES values; Pre-clearing mapping data; Biodiversity Planning Assessment mapping; Strategic investment corridor locations; and Protected areas mapping. The criteria for preliminary site selection will include: Patches of woodland and forest >400 ha. A patch is defined as a collection of fragmented woodland and forest where all areas are within 1km of each other; and The patch contains one of more Endangered or Of Concern regional ecosystems; Patches located entirely on freehold tenure; and The patch includes at least 200 ha of woodland or forest within one lot/plan boundary. Review of sites against these criteria will provide a preliminary number of candidate offset sites for further screening. Further screening will consider the context of other landscape features, for example proximity to reserve or national park. Specifically, the characteristics to be considered in the selection of preferred candidate offset sites are: The presence and extent of required environmental values; and Connectivity to existing vegetation, with preference for connectivity to protected vegetation (e.g. in reserves) and bioregional corridors. In the absence of regional scale habitat mapping, constituent REs of each threatened species habitat will be used to calculate the areas of species habitat in each candidate offset site. The site selection process is an iterative process that incorporates spatial analysis, legal and due diligence review followed by ground-truthing of REs. Page 25 of

26 4.2.2 Site Verification Senex recognises that the available broad-scale vegetation mapping contains some inaccuracies, meaning that mapped values may not correspond to those verified through field survey. Ground assessments will be undertaken at selected preferred candidate offset sites to verify offset site biodiversity values. Verified data will inform the assessment process and the selection of the preferred offset package. Ground-truthing will be undertaken by suitably qualified ecologists and will involve: Recording the extent of environmental values at selected candidate offset sites; and Describing the quality/condition of the environmental values within the candidate offset sites. The proposed approach will provide comparable datasets to demonstrate that the appropriate values can be offset by the preferred sites. The values being sought for the offset site are outlined in Table 4-1 for stage Prepare Offset Delivery Plan Following site verification, an Offset Delivery Plan will be prepared for Stage 1 that describes how the proposed offset will provide a conservation outcome. The Plan will describe the offset site, the appropriateness of the size and scale of the offset for the impact, including co-locating of offsets, and define management actions to achieve the conservation outcome. The Plan will also outline the proposed method to legally secure the offset site Prepare Offset Site Management Plan The offset management plan will outline the management requirements to be undertaken at the offset site to improve the biodiversity conservation outcomes and provide benchmarks for the monitoring assessments to measure. Table 4-2 outlines indicative management actions for the vegetation required at the offset site. Page 26 of

27 Table 4-2 Indicative management requirements for the offset site Management action How the action will be carried out Where the action will be carried out When the action will be carried out Who will be carrying out the action Progress /measurable outcomes Comments/ corrective actions Vegetation clearing Vegetation clearing on the Offset Area is restricted to: that necessary for the removal of non-native weeds or declared pests; establishing and maintaining fencing around the boundary of the declared area; establishing and maintaining fire breaks; and ensure public safety. Where vegetation clearing is sought for any other purpose, the landowner or other person proposing to undertake the clearing must contact the relevant department administering the Vegetation Management Act 1999 and SENEX. Clearing for fire breaks will be collocated with access tracks for the internal fencing of the offset area. As required to maintain access for fire mitigation and control Pastoral Company Manager Any clearing apart from weeds, is to be noted in the Annual Landholder reports Timber harvesting and Native Forest Practices are NOT allowed in the offset area. Corrective action: If illegal clearing has occurred, access protocols and site access is to be reviewed. The relevant department administering the Vegetation Management Act 1999 and SENEX are to be notified within 3 days of the occurrence being noted. Fire Fire is to be, where possible, excluded from the Offset Area except for ecological burns by: Maintaining firebreaks relative to the Offset Area; Using a low intensity fire >20 years in mosaic patches however the same areas are not to be burnt again for another 20 years; and Firebreaks are to be co-located with existing roads and fence lines on the property where possible and be kept clear and accessible Note: Fire is not to be used as a tool for regrowth or fallen Throughout the Offset Area Clearing for fire breaks will be collocated with access tracks for the boundary fencing of the offset area. As required If any fire is used, a low intensity fire at no more than 20 year intervals in a small patch mosaic to assist regeneration process. The same area is then not to be Pastoral Company Manager or suitable qualified person appointed by the Pastoral Company Manager All fire control line maintenance, mosaic burns and any other fire occurrences are to be noted in the Annual Landholder reports. Any occurrence of fire in the Offset Area is to be noted in the Annual Landholder reports. Corrective action: Fire and grazing to be excluded until ground cover has increased to the acceptable level of xx% in R.E. 11.x.x (xxxx: benchmark is xx% native perennial grass cover + xx% organic litter cover = xx% ground cover) Page 27 of

28 Management action How the action will be carried out Where the action will be carried out When the action will be carried out Who will be carrying out the action Progress /measurable outcomes Comments/ corrective actions woody debris management on the Offset Area. burnt for minimum of another 20 years. Grazing Stock will be grazed in the Offset Area for fuel reduction purposes only. Stock is only to be grazed during the dry season to allow native grasses to seed. There is no set stocking rates or times throughout the year where stock is to be permitted to graze. Throughout the Offset Area As required during the dry season when the soil is dry Pastoral Company Manager The Landowner, at their discretion, is to graze stock during the dry season, at rates and times necessary to reduce the fuel load in the Offset Area without lowering the total ground cover at the end of the dry season to below xx% in R.E. 11.x.x (coolabah: benchmark is xx% native perennial grass cover + xx% organic litter cover = xx% ground cover) Photo point and BioCondition results of grass cover and groundcover to be incorporated into the Annual Landholder Reports and the Compliance reports to SENEX and the regulator/s. Corrective action: Grazing to be excluded until the total ground cover at the end of the dry season to ensure that is does not fall below xx% in R.E. 11.x.x (xxxxxx: benchmark is xx% native perennial grass cover + xx% organic litter cover = xx% ground cover) Other Pest Animal Management Minimise introducing pest animals and control of existing populations of pest animals (eg wild pigs) within the Offset Area in accordance with the Biosecurity Act 2014 Throughout the Offset Area. As required Pastoral Company Manager or suitable qualified person appointed by Incidents of wild pigs, cats and foxes, observations and control measures taken are to be noted in the Annual Landholders Reports. Corrective action: if an increase in pig numbers is observed, the landholder will be implementing a pest animal management program to control the feral animal population. Page 28 of

29 Management action How the action will be carried out Where the action will be carried out When the action will be carried out Who will be carrying out the action Progress /measurable outcomes Comments/ corrective actions the Pastoral Company Manager. Anecdotal evidence collected yearly and included in the Monitoring and Reporting to the Regulator. Weeds Keep the introduction, establishment and spread of non-native weeds including Declared Pest Plants listed under the Land Protection (Pest and Stock Route Management) Act 2002 to less than 10% weed cover over the Offset Area. Control existing infestations of non-native weeds including Invasive Pest Plants under the Biosecurity Act 2014 to ensure that the nonnative weeds cover less than 10% of the Offset Area. e.g., parthenium. Throughout the Offset Area. Any weed control required will be undertaken as early as practicable within the natural regeneration process throughout the Offset Area and then periodically as required to treat the weeds at the optimum time in their life cycles to control and minimise the spread of the existing weed species. Pastoral Company Manager or suitable qualified person appointed by the Pastoral Company Manager. Photo point and BioCondition results of grass cover and groundcover to be incorporated into the Annual Landholder Reports and the Compliance reports to SENEX and the regulator. Page 29 of

30 4.2.5 Property Acquisition Process and Legally Securing Mechanism There are a number of mechanisms by which Senex can legally secure and manage suitable offset sites for the WSGP. The most appropriate of which will be determined by the specific characteristics of the selected site/s and the management actions required so that offset obligations are achieved. There are three constituents to the legally securing process: Acquisition (land dealings) strategy; Securing mechanism; and Management strategy, as described in the offset delivery plan. Offset sites are to be legally secured by Senex or secured under a legally binding agreement from the landowner and managed in such a way to protect the relevant offset matter. The most appropriate course of action will be advised through Senex s organisational direction, legal input to determine rights of interest and suitable tenure, government interactions, landholder discussions and the outcomes of the field surveys to consider the site s environmental values as well as considering the offset site s surrounding land tenure and primary uses. Two initial options to secure the offset site are those of an outright purchase or, alternatively, entry into a legally binding agreement with the registered landholder. The preferred option is for entry into a legally binding agreement with a landholder. With this option, managing the offsets would be the responsibility of the landowner, and Senex would be responsible for ongoing monitoring Calculate Actual Impact An indicative disturbance area will be used to inform identification of the candidate offset sites and in turn understand the potential adequacy of the sites toward achieving the obligation. As the development progresses and the WSGP Environmental Protocol for Field Development and Constraints Analysis (SENEX-WSGP-EN-PRC-002) is implemented, the area of disturbance to each environmental value, and quality of disturbed area, will be determined more accurately. As described, this Offset Strategy is designed to identify, secure and manage an offset site based on an indicative disturbance area, and as a contingency measure, seek to secure values above what may be obligated by the offset environment. At the stage of finalising the development layout for a project phase, when actual significant residual impact can be quantified, Senex will re-assess project impacts to reconcile the actual impacts of the development to environmental values contained within the candidate offset site. Actual significant residual impacts will be used to re-assess the identified offset obligations. Actual impacts will be used to acquit offsets against the existing offset portfolio and Senex will propose additional offsets where the obligation cannot be achieved within the established portfolio. It is anticipated that the use of upper disturbance estimates to select the offset site provides a conservative approach and will lead to an overestimation of the obligation. Page 30 of

31 4.3. Financial Offset Options In addition to land-based offsets, the QEOP allows for financial settlement offset. Two alternative offset mechanisms exist: Direct Benefit Management Plan (DBMP); and Financial settlement offset. In accordance with the QEOP financial settlement offsets acquit the offset obligation by making a payment in accordance guideline. Once the amount has been paid, the offset obligation has been met. The Commonwealth policy requires at least 90% of the offset obligation to be delivered through direct (land-based) offsets, as described above. The policy allows up to 10% of the offset obligation to be delivered through other compensatory measures, such as education or research. If a land-based offset is not available to fully acquit the State and Commonwealth offset obligations, Senex may pursue, financial settlement and other compensatory measures in combination with land-based offsets. 5. CONCLUSION This Offsets Strategy defines a pathway to deliver a staged, land-based offset package to meet Senex s obligations under both State and Commonwealth legislation as a result of development activities associated with the WSGP. Senex will seek to implement the Strategy and select and secure the offset site for Stage 1. Page 31 of

32 6. REFERENCES Department of Environment (DoE) Matters of National Environmental Significance: Significant Impact Guideline 1.1. Accessed April from Department of Environment and Heritage Protection (DEHP) Queensland s Environmental Offsets Policy: Significant Residual Impact Guideline, Accessed April from Department of State Development, Infrastructure and Planning (DSDIP) Significant Residual Impact Guideline for Matters Of State Environmental Significance And Prescribed Activities Assessable under the Sustainable Planning Act 2009; Queensland Environmental Offsets Policy Accessed April from ERM.. Western Surat Gas Project Biodiversity Environmental Values Report. Report prepared for Senex Energy Limited. Senex. a. Western Surat Gas Project Environmental Authority EPPG amendment application supporting information. SENEX-WSGP-EN-REP-025. Senex. b. Western Surat Gas Project Public Environment Report (EPBC 2015/7469). SENEX-WSGP-EN-REP-033. Page of