2. Project Justification and Sustainability

Transcription

1 2. Project Justification and Sustainability 2.1. Project Justification The Project will allow the parent company, NHCL to expand its production capacity at the Mine to meet current and future market demands for its thermal coal products, which is particularly important as NHCL s West Moreton Operations, near Ipswich, exhaust their coal reserves in approximately five years. The following Sections outline the justification for proceeding with the Project Project Need Australia is the world s largest exporter of coal products. About two thirds of Australia s coal exports are derived from Queensland coal reserves. Therefore, coal is the state s most important export commodity. In , the total export value was $16.3 billion. In the financial year ending 30 June 2008, coal mining activities contributed $1.04 billion in royalties to the State Government. In line with changes to royalty payments announced in the Queensland State Budget , royalties are projected to rise to over $3.21 billion in 2008 to 2009 (DME 2007). In addition, the coal industry is a significant contributor to the State s rail and port services. Queensland Bulk Handling Pty Ltd (QBH, a NHCL subsidiary company) operates a 10 Mtpa capacity export coal loading facility at the Port of Brisbane in south east Queensland. This terminal has been loading coal for NAC and other producers as a common user facility since The coal industry in Queensland employs about 20,000 people directly. A further 70,000 indirect jobs are created through the industry s activities. At full production, the Project will directly employ more than 420 people in the later years of operation. Currently, the Mine employs approximately 275 people, with an additional 169 people required before the maximum production rate of 10 Mtpa can be achieved in The Project will boost economic activity within the TRC region of the Darling Downs through direct and indirect employment, investment and business opportunities for the life of the Project and beyond. The Project offers an opportunity for NHCL to expand its business base, improve profitability and increase its return to shareholders. The Project s thermal coal products are a valued energy resource that possess lower sulphur, produces less greenhouse emissions and provides a higher energy output than many alternative thermal coal sources. Despite the recent global economic downturn, there is sufficient sustainable demand to support the Project. Demand for power generation capacity is expected to remain relatively strong, particularly in the developing economies of China and India, which are expected to support thermal coal use in the medium to long term. NAC will invest approximately $15 billion over the life of the Project on development, operational, transport and other associated activities. The Project is expected to contribute approximately $105 million per annum to the Gross State Product. The Project will also contribute significantly to the State in rail freight and royalties. This contribution coupled with the direct and indirect employment opportunities and associated spending, highlights the value of the Project to Queensland. PAGE 2-1

2 In the event that the Project was not to proceed: a total of 225 construction and over 420 operational job opportunities (including contractors), along with the flow on (indirect) employment opportunities, would not be created; significant export income would not be realised; injection of revenue into the regional economy would not occur; significant State and Federal government taxes and royalties would not be generated; and the economic opportunity of developing a coal resource that is viable and in demand, would not be realised Technical Feasibility and Commercial Viability The Project is an expansion of the Mine currently operated by NAC. The mining methods and techniques to be utilised for the Project will be very similar in nature to those already in use at the Mine. The technologies associated with the Project are proven and do not represent a significant risk. For example, the in-pit tailing disposal currently in use at the Mine will be replicated by the Project based on the successful operation of the existing in-pit tailing disposal facility over the last eleven months. In addition, the Project will involve the construction of a new CHPP, which is commonly used in coal mining operations around the world. NAC operates within a comprehensive decision-making framework involving the assessment of commercial, social and environmental risk. The Project has been assessed as commercially viable and attractive through this process and has been identified as a priority business opportunity by NAC. The recent approval of the WWRF pipeline project is an integral component of the Project moving forward Compatibility with Policy and Regulatory Frameworks Chapter 1 Introduction summarises the key policy and regulatory documentation that applies to the Project. The Project is compatible and compliant with all relevant legislation and is consistent with the planning framework in place for the region Economic, Social and Environmental Costs and Benefits The EIS presents the impacts that potentially arise from the Project. The EIS also presents mitigation measures to minimise these impacts. In some cases the mitigation measures are able to reduce the potential for impact to insignificant levels. For example, numerical modelling of noise impacts up to year 2014 indicates that there will be no detrimental impacts off-site with the mitigation measures proposed. However in 2025, for example, noise levels from mining activities are predicted to exceed the night time noise criteria at two sensitive receivers. Mitigation measures to reduce the impacts are detailed in Chapter 11 Noise and Vibration. In other cases the mitigation measures are not sufficient to eliminate the impact, but rather reduce the impact. For example, a number of measures are proposed to reduce the quantity of greenhouse gas emissions; however there will still be emissions from the Project. The residual positive and negative impacts associated with the Project, which remain after mitigation measures are in place, represent the Project s costs and benefits. These costs and benefits range across the economic, social and environmental aspects of the Project. The costs and benefits also range in their significance. Whilst it is recognised that there may be additional costs and benefits, a general overview on the different impacts is presented in Table 2-1 below. PAGE 2-2

3 Table 2-1 Project Costs and Benefits Aspect Cost Benefit Economic/Social Incremental increase in the demand for suitable housing. Increasing traffic along the Warrego Highway and local roads. Loss of social fabric / structure in rural community. Displacement of existing landholders. Environmental Noise and blasting impacts. Removal of existing site vegetation and disturbance of remnant Endangered Regional Ecosystems (EREs). Water quality impacts on Lagoon Creek during the diversion stages. Low risk of Acid Mine Drainage associated with rejects and tailings. Dust Impacts from mining operations. Groundwater drawdown impacts. Fauna impacts due to loss of habitat. Direct employment of more than 220 people (at the peak) during construction and over 420 people during operations. Value-add for industries in the Region up to $70 million. Direct contribution of approximately $5 million to the TRC in the form of rates, subsidies and allocations. Community Partnership Program expands with community initiatives. Annual expenditure by employees in the local region is estimated at $9 million. Operation will generate an additional 180 jobs in the Region and an additional 540 jobs in Australia annually. Expenditure during construction is expected to support the equivalent of more than 420 fulltime jobs in the Region and an additional 1350 full-time equivalent jobs in Australia on an annual basis. Over the Project life, NAC will invest approximately $15 billion on development, operational, transport and other associated activities. Project is expected to contribute approximately $105 million per annum to the Gross State Product Utilising the WWRF as the main water supply for the Project. Rehabilitation programs to enhance existing natural landscape and/or riparian zone. Rehabilitated stable landforms at the end of mining for grazing or natural bush land. Discontinue use of the GAB aquifer as a water supply of the Mine. Development and implementation of energy efficiency opportunities, which also reduce greenhouse emissions. Development and implementation of vegetation offsets to balance the loss of remnant EREs Regional Socio-economic Issues Social and economic impacts are detailed in Chapters 16 Social Environment and Chapter 17 Economic Environment, respectively. The Project is unlikely to have a negative social impact on local or regional communities. It is envisaged that the Project will add to the prosperity of the local and regional communities. The main concern for community members is the changes that could occur to the local area as a result of continued mining development in the region. PAGE 2-3

4 2.2. Standard Criteria Assessment The EP Act requires ERAs to be authorised by an administering authority. The administering authority for the Project is the DERM. Schedule 1 of the EPR lists all ERAs that are required to be licensed under the EP Act. When deciding whether to grant, refuse an application or deciding on the conditions of the EA, the DERM must consider certain matters set out in the EP Act. One of those matters is the Standard Criteria. In order to determine the viability of the Project in Queensland, it is important to address the Standard Criteria. The purpose of this Section is to address each of these criteria and to demonstrate how these criteria will be met by the Project. Schedule 3 of the EP Act defines the Standard Criteria as: a) the principles of ecologically sustainable development as set out in the National Strategy for Ecologically Sustainable Development ; and b) any applicable environmental protection policy; and c) any applicable Commonwealth, State or Local government plans, standards, agreements or requirements; and d) any applicable environmental impact study, assessment or report; and e) the character, resilience and values of the receiving environment; and f) all submissions made by the applicant and submitters; and g) the best practice environmental management for the activities under, any relevant instrument, or proposed instrument, as follows: i. an environmental authority; ii. iii. a transitional environmental program; an environmental protection order; iv. a disposal permit; v. a development approval; and h) the financial implications of the requirements under an instrument, or proposed instrument, mentioned in paragraph (g) as they relate to the type of activity or industry carried out, or proposed to be carried out, under the instrument; and i) the public interest; j) Any applicable site management plan; and any relevant integrated environmental management system or proposed environmental management system; and k) any other matter prescribed under a regulation. PAGE 2-4

5 Criterion (a) Ecologically Sustainable Development Key Government Strategy The prime fundamentals of Ecologically Sustainable Development (ESD) as stated in the National Strategy for Ecologically Sustainable Development (1992) (the Strategy) directly relate to social, economic and environmental issues. The key objectives of the Strategy are: the need to develop and maintain international competitiveness in an environmentally sound manner; where there are threats of serious or irreversible environmental damage, the lack of a full scientific understanding not be used as a lever to postponing measures to prevent environmental degradation; effective integration of economic, social, environmental and equity issues in the long and short term decision making process; to recognise the need to develop a strong growing and diverse economy which can enhance the capacity for environmental protection; decisions and actions should provide for broad community involvement on issues relevant to them; and cost effective and flexible policy instruments should be adopted, such as improved valuation, pricing and incentive mechanisms. The goals of ESD are to develop and improve the quality of life, both now and in the future, in a manner that maintains the integrity of ecological processes on which life depends. ( This Section reviews the Project s compatibility against the objectives defined in the Strategy and demonstrates that the Project s planning has been undertaken with consideration to these objectives. The key ESD objectives defined in the Strategy are: to enhance individual and community well-being and welfare by following a path of economic development that safeguards the welfare of future generations; to provide for equity within and between generations (the Intergenerational Equity Principle); and to protect biological diversity and maintain essential ecological processes and life-support systems. The Strategy also identifies three specific ESD objectives for the mining sector: to ensure mine sites are rehabilitated to sound environmental and safety standards and to a level at least consistent with the condition of surrounding land; to provide appropriate community returns for using mineral resources and achieve better environmental protection and management in the mining sector; and to improve community consultation and information, improve performance in occupational health and safety and achieve social equity objectives. Each of these ESD objectives are addressed below. PAGE 2-5

6 Individual and Community Well-being and Welfare The Project will provide significant benefits to the broader community in terms of income generation, employment and increased Government revenues and reinvestment as detailed in Chapter 17 Economic Environment. NAC provides significant funding for a variety of community based programs. These programs target the local communities surrounding NAC s mining and exploration operations as defined in Table 2-2 below. Table 2-2 Locality of NAC s Community Based Programs Region Acland Central Queensland Darling Downs Ipswich West Moreton Localities Covered Acland, Brymaroo, Goombungee, Jondaryan, Kingsthorpe, Kulpi, Oakey Dysart, Glenden, Nebo Aubigny, Dalby, Jimbour, Pittsworth, Toowoomba, Yandilla Ipswich City and Suburbs Amberley, Marburg, Rosewood, Walloon On a six monthly basis, NAC targets local community groups and organisations within the above areas. This process is a proactive approach and is designed to seek beneficial outcomes for the recipients. The program is designed to ensure the donation process is working efficiently and achieving the best possible outcomes for the local community and NAC. The community categories are as described below in Table 2-3. Table 2-3 Community Categories Beneficiary Arts and Entertainment Community Services Education Health and Welfare Sporting Other Covers Any art or entertainment type activity, for example, shows, festivals, expo's. Any activities, programs or events that support the community. Any activities that support educational programs or institutions, for example, schools and kindergartens. Any activities that support health and welfare associations. Any individual or group sporting activities. Any requests that fall outside of the above categories. This program is set to continue as in integral component of the NAC corporate citizenship strategy. The Intergenerational Equity Principle Through appropriate management strategies and monitoring of the impacts, the Project will not significantly reduce, or fail to maintain the health, diversity and productivity of the Queensland environment or affect future generations. Disturbed land will be rehabilitated and left in a stable, non-polluting condition, as detailed in Chapter 4 Land Resources. The proposed post mine land use for disturbed areas within the Project site is a mosaic of self sustaining vegetation communities and grazing land, using appropriate native tree, shrub and grass species, and improved pasture species as appropriate. The Project will require clearing of vegetation; however this will mostly comprise existing grasslands. The clearing of vegetation will have some effect on individual flora and fauna species as detailed. Chapter 7 Terrestrial Ecology discusses these issues along with the associated mitigation measures. NAC will PAGE 2-6

7 prepare a comprehensive offset strategy as part of the EIS process and ensure that suitable management arrangements are established in perpetuity. Groundwater drawdown from mine pit excavation is not expected to impact on remnant vegetation in the vicinity of the Project site as discussed in Chapter 6 Groundwater Resources. Water management practices on site will ensure that the downstream water quality in Lagoon Creek is not adversely affected by the construction or operational phases of the Project. Measures to protect water quality are detailed in Chapter 5 Surface Water Resources. Project emissions will be controlled to have no significant long term adverse effect on the surrounding environment by implementing best practice environmental management. A comprehensive monitoring program will be established and implemented as part of the environmental approval process to demonstrate that the emissions and discharges meet the relevant guidelines and standards set in the Project EA. Protection of Biological Diversity and Essential Ecological Processes The terrestrial and aquatic ecology values in the vicinity of the Project site are described in Chapter 7 Terrestrial Ecology and Chapter 8 Aquatic Ecology, respectively. These Chapters also provide an assessment of the impacts along with mitigations measures throughout the life of the Project. The life of mine plan has been prepared to incorporate the progressive rehabilitation of disturbed areas behind the mine path. This rehabilitation strategy will allow NAC to proactively measure the success of the rehabilitation in line with the post mine land use strategy. Although the Project will inevitably divert Lagoon Creek, a complex engineering program involving the progressive re-instatement of Lagoon Creek will be developed and it is envisaged that Lagoon Creek will be in a better condition at the completion of mining activities than its current state. Downstream water quality, will be protected as outlined in the Chapters above. Minesite Rehabilitation Disturbed land will be rehabilitated and left in a stable, non-polluting condition, as detailed in Chapter 4 Land Resources. The proposed post mine land use for disturbed areas within the Project site is a mosaic of self sustaining vegetation communities and grazing land, using appropriate native tree, shrub and grass species, and improved pasture species as appropriate. This post mine land use will be consistent with the land use of surrounding land. The land will be managed by the Acland Pastoral Company Pty Ltd (APC). Provide Appropriate Returns for Mineral Resources and Achieve Better Environmental Protection and Management in the Mining Sector Despite the recent global economic downturn, coal products produced by the Project will be the subject of high international demand due their quality characteristics and the requirement to generate energy, particularly in China and India. For the foreseeable future, coal exports from the Project will provide significant revenues to Federal, State and Local government. The coal resource has been subject to detailed investigations to define the extent of the resource and the feasibility of its extraction and processing. The Project will not impact on other coal, gas and mineral resources in the region. There are no significant resources of coal seam methane that will be lost by the development of the Project. PAGE 2-7

8 NAC has undertaken a comprehensive EIS process to identify the opportunities to improve environmental protection and management for the Project. This EIS documents the detailed assessments that have been undertaken. In addition, the draft EM Plan (located in Appendix N) outlines the proposed environmental management strategies and EA conditions to be employed by the Project. The Project has the technical and financial support to establish and maintain these environmental management controls. Improve Community Consultation, Improve Occupational Health and Safety, and achieve Social Equity Objectives NAC has undertaken extensive community consultation prior to and during the preparation of the EIS. The details of which, are presented in Chapter 19 Community Consultation and have been incorporated into the assessment of social impacts as defined in Chapter 16 Social Environment. NAC has undertaken a review of the risks to occupational health and safety posed by the Project and proposed appropriate management measures are detailed in Chapter 18 Health, Safety and Risk. ESD Guiding Principles The guiding ESD principles defined in the Strategy are: decision-making processes should effectively integrate both long and short term economic, environmental, social and equity considerations; where there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation (the Precautionary Principle); the global dimension of environmental impacts of actions and policies should be recognised and considered; the need to develop a strong, growing and diversified economy which can enhance the capacity for environmental protection should be recognised; the need to maintain and enhance international competitiveness in an environmentally sound manner should be recognised; cost-effective and flexible policy instruments should be adopted, such as improved valuation, pricing and incentives mechanisms; and decisions and actions should provide for broad community involvement on issues which affect them; Each of these ESD guiding principles are addressed in turn below. Decision-Making Based on Long and Short Term Considerations The Project will provide immediate and long-term benefits to the economic and social fabric of Queensland and in particular the TRC region. The Project will contribute to the national, state and local economies. NAC will invest approximately $15 billion over the life of the Project on development and operation activities. The Precautionary Principle NAC has undertaken an assessment of the risk of unacceptable environmental harm consistent with the Precautionary Principle and used the findings to determine appropriate environmental control strategies, PAGE 2-8

9 which have been detailed in the EIS and EM Plan. The Project has the technical and financial support and resources to establish and maintain these environmental protection controls. Global Environmental Impact NHCL (including NAC as a subsidiary company) is acutely aware of its corporate responsibilities in relation to the Project and greenhouse gas emissions. NHCL is a current member of the Greenhouse Challenge Plus and Energy Efficiency Opportunities programs. NHCL is clearly focused on minimising its carbon footprint. NHCL is a financial contributor to the Coal 21 Fund for the development of clean coal technologies. NHCL will be subject to the National Greenhouse and Energy Reporting System and in future the Carbon Pollution Reduction Scheme. NHCL is investigating the best approach to minimising its carbon footprint in terms of abatement and offset options and acquiring tradable permits, particularly with expanding and new coal mining operations proposed in the near future. The Project is estimated to result in approximately 15.4 Mt CO 2 -e of greenhouse gases for the life of Project, or 0.51 Mt CO 2 -e on an annual basis (based on a 30 year project life). The annual greenhouse gas emissions for the Project represent 0.09% of Australia s 2006 greenhouse gas emissions. As outlined in Chapter 10 Greenhouse Gases and Climate Change, NAC proposes a range of mitigation measures for the Project and is taking action at a corporate level to address the wider implications of greenhouse gas emissions and climate change. As detailed in Chapter 7 Terrestrial Ecology and Chapter 8 Aquatic Ecology, the Project will not result in significant impacts to threatened species, migratory species or RAMSAR wetlands. Development of a Strong, Growing and Diversified Economy which can enhance the Capacity for Environmental Protection The Project will add value to the International, Australian and Queensland economies. There will be indirect flow on effects to other areas of the Queensland economy as a result of the Project. The Minerals Council of Australia estimates that for every job created in the mining industry, at least three additional jobs are created elsewhere in Australia. The Proponent will encourage the use of local suppliers and contractors during construction and operation. Enhancing International Competitiveness in an Environmentally Sound Manner The Project will enhance Australia s international competitiveness by adopting proven mining technologies and methods. By producing a coal product which has low sulphur, low ash and high energy contents, NAC are enhancing its market position internationally. The Project will be subject to an EA which will ensure that all environmental impacts are managed appropriately. Cost-Effective and Flexible Policy Instruments The Project is consistent with the Local, State and Federal government policy. Community Involvement in Decisions and Actions NAC has undertaken community consultation prior to and during the preparation of the EIS, which is detailed in Chapter 19 Community Consultation. NAC will continue the process through the Project s life. NAC will continue to utilise the existing formal complaint procedure currently in place at the Mine, continue to have meetings with local councils and continue briefings by Project representatives to community groups. PAGE 2-9

10 Criterion (b) Environmental Protection Policies The following Environmental Protection Policies have relevance to the Project: Environmental Protection (Water) Policy 1997; Environmental Protection (Air) Policy 2008; Environmental Protection (Noise) Policy 2008; and Environmental Protection (Waste Management) Policy Environmental Protection (Water) Policy 1997 NAC will prepare a comprehensive water management program for the Project which will be predominately based on the existing program in place at the Mine. Wastewater prevention options will be assessed and a hierarchy will be used to decide the preferred methods for dealing with wastewaters. This assessment will consider the minimisation of wastewater, recycling, water treatment and reuse. Chapter 5 Surface Water Resources presents the water balance for the Project and outlines the required water usages in line with the water requirements for the Project. Environmental Protection (Air) Policy 2008 The EPP (Air) establishes guidelines for ambient air quality and technology based standards for point-source emissions. Schedule 1 of the EPP (Air) states air quality indicators and goals that are the maximum for contaminants, which may be present in the air environment. Air quality modelling has been conducted to address the Projects compliance with the requirements for all gaseous emissions from the Project site. The results of the modelling are presented in Chapter 9 Air Quality. Mitigation measures to reduce air emissions from the Project are also presented in this Chapter. Environmental Protection (Noise) Policy 2008 The EPP (Noise) covers environmental values and acoustic quality objectives. Chapter 11 Noise and Vibration presents the results of noise modelling undertaken for the Project. This Chapter also details mitigation measures to be implemented by the Project to reduce the noise and vibration impacts from site operations. Environmental Protection (Waste Management) Policy 2000 The EPP (Waste) stipulates the provisions of the Waste Management Hierarchy and outlines the guiding practices and principles behind waste management in Queensland. The EPP (Waste) also provides a framework for decision making on the generation and transportation of waste. In developing the Waste Management Plan (WMP) for the Mine, the waste management hierarchy was employed to identify waste generation sources and determine suitable management options for particular waste types. The Project will review and amend the existing WMP to reflect the new activities being undertaken. PAGE 2-10

11 Criterion (c) Applicable Commonwealth, State or Local plans, Standards, Agreements or Requirements Federal, State and Local plans, agreements, standards and requirements have been considered in the preparation of this EIS. Plans The construction and operation of the Project is consistent with the TRC s Strategic Plan. Agreements The Federal government is a signatory to agreements on climate change, migratory birds, world heritage and bio-diversity. There are four main principles of these conventions: the precautionary principle; intergenerational equity; conservation of biological diversity; and improved valuation, pricing and incentive mechanisms. These principles, in relation to the Project, have been addressed above in Section Standards and Requirements The Project relevant standards are those set out under the National Environment Protection Council (Qld) Act 1994 (NEPC Act). This reflects the Federal legislation, which provides for standards that will have effect nationally. NEPMs outline national objectives for protecting and managing particular aspects of the environment. The NEPMs relevant to the Project are: Ambient Air Quality; and National Pollutant Inventory. To meet the requirements of these NEPM s, NAC will: comply with the EPP (Air); and prepare and submit an annual NPI Report which details air emissions from the Project for a variety of air quality parameters Criterion (d) Environmental Impact Study NAC has prepared the EIS subject to the EIS process under the SDPWO Act and therefore has undertaken numerous studies to determine the environmental impact of the Project. The EIS details the existing environmental values, the impacts of the Project and the mitigation measures to be implemented to reduce the impacts. PAGE 2-11

12 Criterion (e) Character, Resilience and Values of Receiving Environment The environment surrounding the Project site has been thoroughly described in this EIS and is summarised in the draft EM Plan located in Appendix N Criterion (f) Submissions made by Applicant and Submitters The EIS and any other subsequent environmental studies will constitute NAC s submission in support of the Project s Application for the EA and ML. NAC has undertaken an extensive community consultation program prior to preparing the EIS. The details of which, are presented in Chapter 19 Community Consultation Criterion (g) Best Practice Environmental Management Best practice environmental management is defined in the EP Act, section 21 as: the management of the activity to achieve an ongoing minimisation of the activity s environmental harm through cost-effective measures assessed against the measures currently used nationally and internationally for the activity. The Project will implement a comprehensive rehabilitation program and water management strategy which meets or exceeds the guidelines set out in DME Technical Guidelines for the Environmental Management of Exploration and Mining in Queensland Criterion (h) Financial Implications The Project will undoubtedly financially benefit the local community directly, not only in value adding but also in providing the local community with employment and opportunity. The Project has the technical and financial support to establish and maintain commitments associated with infrastructure requirements and environmental management controls Criterion (i) Public Interest The Project will directly employ more than 220 people during the construction phase and over 420 long-term jobs in the operating phase. The Project will significantly add to Queensland s Gross State Product. The Project will provide employment and wealth for the region. Issues of community interest and concern have been dealt with during the EIS process and are detailed in Chapter 19 Community Consultation. NAC will continue to engage with the community throughout the life of the Project as an extension of its existing community consultation program Criterion (j) Site Management Plan Comprehensive site environmental management plans will be prepared to address environmental issues. Information will be derived from the existing site environmental program. The site management plans will state management strategies to minimise the potential for environmental harm and will also set out a framework to manage environmental obligations set out in the EA. The aspects covered in the site management plan are detailed in Table 2-4 below. PAGE 2-12

13 Table 2-4 Site Management Plan Aspects Site Aspect Monitoring and Assessment Staff Training and Awareness Conduct of Environmental and Energy Audits Waste Prevention, Treatment and Disposal Program for Continuous Improvement Reporting Arrangement on the Effectiveness of the Environmental Management of the Activities Component To ensure compliance with the EA, monitoring data will be collated and assessed and the information used to improve the overall environmental performance of the Project. This process of review and improvement will continue throughout the life of the Project. An effective internal communication strategy for employees and contractors will be established to outline responsibilities for environmental protection. All employees and contractors will be required to attend environmental management training outlining targets and objectives for which they are responsible and accountable. Appropriate information will be provided as a means of raising awareness and motivating continual improvement of environmental performance. As part of the continual improvement process, environmental and energy audits will be undertaken. Participation in the Energy Efficiency Opportunities program will assist this aspect. The generation and management of waste will be assessed in line with the waste management hierarchy outlined in the EPP (Waste), including: the use of all new plant and equipment, using clean production technologies; and re-using wastes and wastewater to dampen roads for dust suppression. Through an ongoing auditing and management process, opportunities for continuous improvement will be identified and researched with a view to implement management procedures that improve environmental performance to go beyond best practice environmental management. The submission of an Annual Return to the DERM is a requirement under the EA. The purpose of which, is to report on the effectiveness of their environmental management activities. NPI Reporting and other statutory programs will also be undertaken by the Project Criterion (k) Other matters An EM Plan is a prescribed matter under section 187 of the EP Act. The draft EM Plan for the Project is located in Appendix N Sustainability Principles for the Project This Section describes the key aspects of the Project which relate to embedding sustainability in the Project s planning and design phases and outlines the Project s compatibility with the objectives and principles defined in the Strategy. Environment Establishing a Greenhouse Gas (GHG) reduction and management plan; Managing water to minimise releases and maximise reuse; Planning for closure and considering final landforms and sustainable post mining land uses at the outset; and Identifying opportunities to enhance endangered regional ecosystems through appropriate offsets. PAGE 2-13

14 Economy, Social and Community Fully engaging the community; Investing in the community to build business capacity; Engaging the indigenous community through procurement, training and employment; Injecting capital into the local region to advance economic activity; Attracting and retaining workforce for construction and operation; and Integrating Project planning at regional and local levels. Resource use efficiency Maximising synergies between the existing Mine through mine planning, design and shared resources; Influencing the supply chain towards sustainability; Reducing impacts on the road and rail transport corridors; Reducing the impact of coal storage areas; and Understanding the sustainable use of the coal resource. It is important to note that these planning challenges and opportunities do not represent commitments for the purpose of the EIS. They represent the outcomes of a process designed to identify guiding principles for design and management of the Project. These principles are reflected in the Project design and mitigation measures nominated in the EIS. PAGE 2-14