Yilgarn Operations. Claw Deposit. Environmental Protection Act 1986 (WA) Clearing Permit (Area Permit) Supporting Information

Transcription

1 Claw Deposit Environmental Protection Act 1986 (WA) Clearing Permit (Area Permit) Supporting Information August 2017

2 Document Status Revision Author Distribution Date Status 0 S Hawkins DMIRS Public Release Citation This report should be cited as: (2017) Yilgarn Operations Claw Deposit - Environmental Protection Act 1986 (WA) Clearing Permit (Area Permit) Supporting Information. Report prepared by Hawkins S of Globe Environments Australia Pty Ltd for. Revision 0. August Acknowledgement This report includes recent contributions provided by Cliffs supporting consultants including (in alphabetical order) Biota Environmental Sciences, CAD Resources, Rockwater Pty Ltd, Soil Water Consultants and Western Botanical. The assistance and contributions of these supporting consultants is acknowledged and appreciated. Limitations This report has been prepared by Globe Environments Australia Pty Ltd for the exclusive use of the Client, for the sole purpose stated in the report title. Globe Environments Australia Pty Ltd has prepared this report in a manner consistent with the normal level of care and expertise exercised by members of the environmental services profession. In preparing this report, Globe Environments Australia Pty Ltd has relied on information provided by the Client, as well as other publicly available contextual information, all of which is presumed accurate and complete on receipt. Globe Environments Australia Pty Ltd makes no warranty and accepts no liability for the use of this report by persons other than the Client or for use of this report in excess of its stated purpose. Globe Environments Australia Pty Ltd Contact: Stuart Hawkins Director / Consulting Scientist B.Sc. Hons (Env. Mgt), ECA. Phone: Stuart.Hawkins@GlobeEnvironments.com.au Website:

3 Executive Summary (Cliffs) operates the Yilgarn Operations, which includes the mining of iron ore deposits at the Koolyanobbing Range, Mt Jackson Range, Windarling Range and the Deception Deposit (to be developed), processing of ore at Koolyanobbing, and road and rail transport between these operations and the Port of Esperance where the processed ore is exported to international customers. Resource drilling undertaken during 2015/2016 has identified an economic ore resource at the Claw Deposit located within Mining Lease M77/1259-I, positioned immediately adjacent to the approved Deception Deposit. Accordingly, Cliffs now proposes to extend its approved mine operations to include the Claw Deposit ( the Project ). The Project is expected to yield an estimated 3.9 million tonnes of iron ore having a gross economic value of approximately A$190million. The Project has been scheduled to commence from Q and will have an expected mining-life of approximately 2 years. The Project will be undertaken within a spatial area of approximately 110 hectares (ha), comprising the following mine infrastructure components, as identified by Figure E-1: (a) Mine Pit (46ha); and (b) Waste Rock Landform (64ha). The Project area of 110ha comprises approximately 106ha of native vegetation and 4ha of cleared land. The native vegetation will require clearing to enable the implementation of the Project. A Clearing Permit under s51e of the Environmental Protection Act 1986 (WA) will be required to enable the clearing of the native vegetation. Cliffs has submitted an application to the Department of Mines, Industry Regulation and Safety (DMIRS) for a Clearing Permit (Area Permit) for the Project in accordance with s51e of the Environmental Protection Act 1986 (WA) (Cliffs 2017a). The purpose of the Clearing Permit is to allow for the clearing of native vegetation within the area of the Project (the Application Area ). This Supporting Information document has been prepared to provide DMIRS with supporting information to assess the Clearing Permit application, as required by the DMIRS (2016) guidance document Information Required to Assess Your Clearing Permit Application. As outlined by this Supporting Information document, the potential environmental effects of the clearing of native vegetation within the Application Area are not environmentally significant; representing an incremental increase to the environmental effects of Cliffs approved Yilgarn Operations. To ensure the potential environmental effects are minimised and controlled to an acceptable level, Cliffs proposes to undertake the clearing of native vegetation within the Application Area in accordance with Cliffs Environmental Policy (Cliffs Natural Resources 2017, Attachment 1) and international standard ISO 14001:2004-certified Environmental Management System (EMS) (SGS 2015, Attachment 2). Cliffs EMS contains a series of Environmental Management Plans (EMPs) that address specific environmental aspects of the mine operations. Cliffs considers the potential environmental effects of the clearing of native vegetation can be appropriately managed to an acceptable standard in accordance with the following EMP: (a) Flora and Vegetation Management Plan (Cliffs 2016, Attachment 3). 3

4 Cliffs will implement the Flora and Vegetation Management Plan to ensure the potential environmental effects of the clearing of native vegetation within the Application Area are appropriately managed. 4

5 Figure E-1 Clearing Permit Application Area. The Application Area (110ha) is identified in yellow. Areas of Cliffs approved mine operations are identified in orange. Tenement boundaries are also identified. 5

6 1 Supporting Information The Department of Mines, Industry Regulation and safety (DMIRS) (2016) guidance document Information Required to Assess Your Clearing Permit Application identifies various information requirements to support the assessment of a Clearing Permit application. The format used in this supporting information document conforms to the DMIRS (2016) guidance, with the DMIRS s information requirements identified in the boxes, and the supporting information provided by Cliffs to address the requirements located beneath the boxes. DMIRS (2016) Guidance: The clearing permit application must consist of: o A completed application form, available from Department of Environmental Regulation A completed Clearing Permit application (Cliffs 2017a) has been submitted to DMIRS with this Supporting Information document. The Application Area for the Clearing Permit is approximately 110 hectares (ha), which comprises 106ha of native vegetation and 4ha of cleared land. DMIRS (2016) Guidance: The clearing permit application must consist of: o The prescribed fee A completed form Credit Card Payment for Clearing Permit Applications (Cliffs 2017b) has been submitted to DMIRS with the Clearing Permit application (Cliffs 2017a) and this Supporting Information document. DMIRS (2016) Guidance: The clearing permit application must consist of: o A letter of authority, if a person is signing the application on behalf of a company or incorporated body (Section 51E of Environmental Protection Act 1986) The Clearing Permit application (Cliffs 2017a) has been signed by Cliffs Senior Director Asia Pacific Iron Ore, being the most senior management position for Cliffs Australian operations. A separate letter of authority from the Senior Director providing himself with an authorisation to sign is therefore not necessary. DMIRS (2016) Guidance: The clearing permit application must consist of: o A letter from the tenement holder authorising you to apply for a clearing permit on their tenement, (if the clearing is to be done on a tenement other than your own) The Application Area is positioned within Mining Lease M77/1259-I granted to Cliffs under the Mining Act 1978 (WA). 6

7 As Cliffs is the tenement holder of Mining Lease M77/1259-I, a separate letter from the tenement holder is not necessary. DMIRS (2016) Guidance: The clearing permit application must consist of: o A scaled map of the area proposed to clear (see Mapping Information Required) Mapping Information Required Preferred formats with digital spatial data and the following properties: o format - ESRI Shapefile o geometry type - Polygon o coordinate system - GCS GDA1994 (geographic) o datum - Geocentric Datum of Australia 1994 Whilst an ESRI Shapefile format is preferred, other formats such as Autocad (dxf), Microstation (dgn) and Mapinfo (TAB, MIF) can be provided. Please be aware that formats other than ESRI shapefile will need to be converted, which may cause a delay in the processing of your application. Note: CD s, DVD s or thumb drives should be clearly labelled with proponent name and a description of the contents. Scaled mapping identifying the Application Area is provided at Figures 1 to 6. The mapping identifies the location of the Application Area, land tenure and the recorded environmental values. Shapefiles (GDA94 datum) of the Application Area are provided on the compact disc within Section 3 References. Figure 1 identifies the location of the Application Area at a regional scale, including the extent of Cliffs approved Yilgarn Operations. Figure 2 identifies the Application Area for the Clearing Permit application. Figure 2 is overlayed on aerial photography with tenement boundaries identified. Areas of Cliffs approved mine operations are also identified. Figure 3 identifies the location and general mine layout within the Application Area. Figure 4 is overlayed on aerial photography with tenement boundaries identified. Areas of Cliffs approved mine operations are also identified. The infrastructure components within the Application Area (following the clearing of native vegetation) will include a Mine Pit and a Waste Rock Landform, with these components connecting to Cliffs approved mine operations. Figure 4 identifies the locations of flora taxa of conservation significance recorded within the Application Area and surrounds. The Application Area does not coincide with any record of Rare Flora taxa protected under the Wildlife Conservation Act 1950 (WA) (WA Minister for Environment 2017a). The Application Area coincides with recorded individuals of the Department of Biodiversity, Conservation and Attractions (DBCA) classified priority flora taxon Banksia arborea (P4) (DBCA 2017a). Banksia arborea (P4) has been recorded at multiple locations across the broader Yilgarn region, with the nearest recorded group of this taxon occurring approximately 4km north of the Application Area (Cliffs unpublished data). Figure 5 identifies the locations of vegetation units mapped within the Application Area and surrounds. The Application Area coincides with the mapped area of 10 vegetation units; each which have broader distributions beyond the Application Area. The Application Area does not coincide with any mapped record of a DBCA-classified priority ecological community (DBCA 2013, 2017b). 7

8 Figure 6 identifies the locations of fauna taxa of conservation significance recorded within the Application Area and surrounds. The Application Area does not coincide with any record of Specially Protected Fauna taxa protected under the Wildlife Conservation Act 1950 (WA) (WA Minister for Environment 2017b). The Application Area coincides with recorded individuals of the DBCA-classified priority fauna taxon Aganippe castellum (P4) (DBCA 2017c). Aganippe castellum (P4) has been recorded at multiple locations across the broader Yilgarn region. The Application Area also coincides with recorded/sampled locations of potential short-range endemic invertebrate fauna taxa; none of which are of listed conservation significance. 8

9 Figure 1 Regional Location. The regional location of the Application Area is identified by the yellow icon. Cliffs approved mine operations at the Koolyanobbing Range, Mt Jackson Range, Windarling Range and the Deception Deposit are also identified. 9

10 Figure 2 Clearing Permit Application Area. The Application Area (110ha) is identified in yellow. Areas of Cliffs approved mine operations are identified in orange. Tenement boundaries are also identified. 10

11 Figure 3 General Mine Layout. The Application Area (110ha) is identified in yellow. The general mine layout and conceptual design for the infrastructure components within the Application Area (following the clearing of native vegetation) are identified in white. Areas of Cliffs currently approved mine operations are identified in orange, with their general mine layout identified in grey. 11

12 Figure 4 Flora Taxa. The Application Area is identified in yellow. The Application Area coincides with individuals of the DBCA-classified priority flora taxon Banksia arborea (P4) (DBCA 2017a). Data source: Biota (2011a); Western Botanical (2009a, 2012a, 2012b). 12

13 Figure 5a Vegetation Units. The Application Area is identified in yellow. The Application Area coincides with 10 vegetation units, each which have broader distribution beyond the Application Area. Data source: Biota (2011a); Western Botanical (2012a, 2012b). 13

14 Figure 5b Vegetation Units. A description of each mapped vegetation unit is provided. Data source: Biota (2011a). 14

15 Figure 6 Fauna Taxa. The Application Area is identified in yellow. The Application Area coincides with records of the DBCA-classified priority fauna taxon Aganippe castellum (P4) (DBCA 2017c) and recorded/sampled locations of potential short-range endemic invertebrate fauna taxa (none of which are of listed conservation significance). Data source: Biota (2011b, 2011c). 15

16 DMIRS (2016) Guidance: The clearing permit application must consist of: o A description of the proposed activities Following the clearing of the native vegetation within the Application Area, mine operations are proposed to be undertaken. Resource drilling undertaken during 2015/2016 has identified an economic ore resource at the Claw Deposit located within Mining Lease M77/1259-I, positioned immediately adjacent to Cliffs approved Deception Deposit mine operations. Accordingly, Cliffs now proposes to extend its approved mine operations to include the Claw Deposit ( the Project ). The Project is expected to yield an estimated 3.9 million tonnes of iron ore having a gross economic value of approximately A$190million. The Project has been scheduled to commence from Q and will have an expected mining-life of approximately 2 years. The Project will be undertaken within a spatial area of approximately 110ha comprising the following mine infrastructure components: o o Mine Pit (46ha); and Waste Rock Landform (64ha). The land area subject to the Clearing Permit application (the Application Area ) comprises approximately 106ha of native vegetation and 4ha of cleared land (refer to aerial imagery in Figure 2). Clearing of the native vegetation within the Application Area will be necessary to enable Project development. The Project will be integrated into Cliffs approved Yilgarn Operations, with the existing infrastructure and facilities used to the extent necessary to support the Project. The Project will be subject to assessment by DMIRS of a Clearing Permit application (Cliffs 2017a) under the Environmental Protection Act 1986 (WA) to seek to authorise the clearing of native vegetation. The Project will also be subject to assessment by DMIRS of a Mining Proposal (Cliffs 2017c) under the Mining Act 1978 (WA) to seek to authorise mining development for the Project. Cliffs understands the DMIRS will assess the Clearing Permit application in parallel with the assessment of the Mining Proposal. A brief description of each infrastructure component for the Project is provided below. MINE PIT The Mine Pit is expected to yield an estimated 3.9Mt of iron ore having a gross economic value of approximately A$190million. The Mine Pit will require an area of approximately 46ha, as identified by Figure 3. Approximately 2ha (4%) of the 46ha area for the Mine Pit has previously been cleared through approved mineral exploration under the Mining Act 1978 (WA), with the remaining 44ha (96%) comprising native vegetation. Consistent with the current mining practices used across Cliffs Yilgarn Operations, development of the Mine Pit will be undertaken by standard open-pit mining methods (blasting, excavation) and using standard plant and equipment (excavators, loaders, trucks). Development of the Mine Pit will be undertaken to an elevation of approximately 365mAHD. 16

17 At mine closure, the Mine Pit will remain as an open mine void. The Mine Pit cannot be rehabilitated as the consolidated rock substrate and the steep sides will not be conducive to plant growth, with the steep sides also be prohibitive to safe rehabilitation practices. WASTE ROCK LANDFORM An estimated 16.5Mt of waste rock to be excavated from the Mine Pit will be disposed of to the Waste Rock Landform, positioned adjacent to the Mine Pit. The Waste Rock Landform will require an area of approximately 64ha, as identified by Figure 3. Approximately 2ha (3%) of the 64ha area for the Waste Rock Landform has previously been cleared through approved mineral exploration under the Mining Act 1978 (WA), with the remaining 62ha (97%) comprising native vegetation. The Waste Rock Landform will be developed to a design elevation of approximately 495mAHD. Progressively during mining and post-mining, the Waste Rock Landform will be rehabilitated by on-contour ripping of compacted areas and the respreading of the cleared rehabilitation materials (vegetation and topsoil/subsoil). The Waste Rock Landform will incorporate an outer capping of topsoil/subsoil to provide a growth media for the rehabilitation. The rehabilitation works will be undertaken to meet the rehabilitation completion criteria consistent with Cliffs Mine Closure Plan (Cliffs 2015), to be regulated by DMIRS under the Mining Act 1978 (WA). The environmental effects of the clearing of native vegetation within the Application Area can be appropriately managed in accordance with Cliffs Flora and Vegetation Management Plan (Cliffs 2016, Attachment 3). The Flora and Vegetation Management Plan is implemented across Cliffs Yilgarn Operations and outlines a range of environmental management actions to actively control and manage the potential environmental effects to flora values, for aspects including land clearing, surface water drainage, introduced flora, dust emissions, fire risk, saline water, introduced fauna, education and training, and reporting. Cliffs proposes to implement the Flora and Vegetation Management Plan to ensure the potential environmental effects of the clearing of native vegetation within the Application Area are minimised and controlled to an acceptable level. All land disturbance is expected to be contained to within the Application Area through the implementation of Cliffs standard mining controls (such as for land clearing, blasting). Whilst noting this, there is an inherent low potential during mining (in particular during blasting or when working on steep slopes) for limited material to move downslope into native vegetation adjacent to the Application Area, the effect of which would unlikely be environmentally significant. 17

18 DMIRS (2016) Guidance: The clearing permit application must consist of: o Additional information, as appropriate (see Assessment Information Required, below) To assist with the assessment of your clearing permit application in an expeditious manner, it is highly recommended that detailed information is submitted with the clearing permit application. DMP is required to assess applications for clearing permits against the 10 'clearing principles', as defined in Schedule 5 of the Environmental Protection Act The 'clearing principles' broadly relate to the potential impacts of clearing on biodiversity, land degradation, and ground and surface water quality. The level of information required will be determined by the complexity of the application to be assessed, in conjunction with the risk to the receiving environment associated with the proposed activity. Factors include: o the size of the area to be assessed o the techniques used to clear o whether the area is of high biodiversity o the purpose for which the application is intended such as exploration, mining, development and infrastructure. The Application Area covers a spatial area of approximately 110ha. The 110ha Application Area comprises approximately 106ha of native vegetation and 4ha of cleared land. Consistent with the current mining practices used at Cliffs Yilgarn Operations, clearing of the native vegetation will be undertaken by standard plant and equipment (excavators, loaders, trucks). Rehabilitation materials (vegetation, topsoil/subsoil) cleared during mine development (where safe to do so) will be temporarily stockpiled ( paddock-dumped ) with the stockpile heights up to nominally 3 metres. The rehabilitation materials will be used for progressive and post-mining rehabilitation within areas of the mine operations. The flora and fauna (biodiversity) values of the Application Area and surrounds are outlined within the following environmental survey reports (in alphabetical order): (1) Biota Environmental Sciences Pty Ltd (2011a) Deception Deposit Vegetation and Flora Survey. Report prepared by Maier M, Chukowry P and Anderson P of Biota Environmental Sciences Pty Ltd for. Revision 11. June (2) Biota Environmental Sciences Pty Ltd (2011b) Deception Deposit Vertebrate Fauna Survey. Report prepared by Cartledge V (Dr), Cairnes J and Sachse T of Biota Environmental Sciences Pty Ltd for. Revision 13. March (3) Biota Environmental Sciences Pty Ltd (2011c) Deception Deposit Short Range Endemic Invertebrate Fauna Survey. Report prepared by Watson N (Dr) and Teale R of Biota Environmental Sciences Pty Ltd for. Revision 7. March (4) (2013) Yilgarn Operations Deception Deposit Flora and Vegetation Survey for the Realignment of the Deception Deposit Haul Road. Report prepared by Wilkinson K (nee Greenacre) of Cliffs Asia Pacific Iron Ore Pty Ltd. Revision B. January (5) Western Botanical (2009a) Flora and Vegetation Survey of a Polygon at Deception Prospect for Future Drilling Programs, May Report prepared by Burgess S of Western Botanical for. September (6) Western Botanical (2012a) Deception Deposit Options Assessment Flora and Vegetation Survey. Report prepared by Eckermann B of Western Botanical for Cliffs Asia Pacific Iron Ore Pty Ltd. March

19 (7) Western Botanical (2012b) Deception Deposit Mine Area Flora and Vegetation Survey. Report prepared by Warden J of Western Botanical for Cliffs Asia Pacific Iron Ore Pty Ltd. Revision 1. December 2012 Copies of the above environmental survey reports are provided on the compact disc within Section 3 References. Mapping identifying the recorded locations of flora and fauna values within the Application Area and surrounds are provided in Figures 4 to 6. An assessment of the clearing of native vegetation within the Application Area using the Principles for Clearing Native Vegetation from Schedule 5 of the Environmental Protection Act 1986 (WA) is outlined below: (1) Native vegetation should not be cleared if it comprises a high level of biological diversity. The flora values of the Application Area and surrounds are outlined within the environmental survey reports of Biota (2011a), Cliffs (2013) and Western Botanical (2009a, 2012a, 2012b). The flora surveys in the vicinity of the Application Area and surrounds mapped 33 vegetation units comprising more than 300 native flora taxa (Biota 2011a). The flora surveys included records for 4 DBCA-classified priority flora taxa (DBCA 2017a). The flora surveys did not identify any flora taxa protected as Rare Flora under the Wildlife Conservation Act 1950 (WA) (WA Minister for Environment 2017a) or Threatened Species of flora or listed under the Environment Protection and Biodiversity Conservation Act 1999 (C th) (DEE 2017a). None of the mapped vegetation units are of listed conservation significance as a Threatened Ecological Communities under the Environment Protection and Biodiversity Conservation Act 1999 (C th) (DEE 2017b) or listed as a DBCA-classified priority ecological community (DBCA 2013, 2017b). Of the recorded flora values, the Application Area coincides with records of: (1) DBCA-classified priority flora taxon Banksia arborea (P4); and (2) Vegetation units. The Application Area coincides with records of the DBCA-classified priority flora taxon Banksia arborea (P4), as identified by Figure 4, with this taxon contributing toward the biological diversity of the vegetation units (as described below). The DBCA (2017d) identifies Banksia arborea as having a linear distribution of approximately 180km, extending from the Koolyanobbing Range in the south to the Perrinvale Range in the north, with regional records including the Helena and Aurora Range, Die Hardy Range, Mt Elvire, Mt Finnerty Range, Mt Jackson Range, Mt Manning Range, Windarling Range and the Yorkadine Range (DBCA 2017d; Western Botanical 2012c). Noting this broader distribution, the effect to this taxon is not environmentally significant. The Application Area coincides with the mapped area of 10 vegetation units, as identified by Figure 5. Each vegetation unit has a recorded spatial distribution beyond the Application Area and Cliffs approved mine operations. More than half of the mapped vegetation units were considered by Biota (2011a) to be equivalent to vegetation units previously recorded at the nearby Windarling Range, positioned approximately 20km south of the Application Area. Noting 19

20 their broader distributions, the effect to vegetation units is not environmentally significant. Within each vegetation unit occurs a variety of other native flora taxa which are not of listed conservation significance due to their population sizes and broad regional distributions, with these taxa contributing toward the biological diversity of the vegetation units. In this context, the effect to other such flora taxa is not environmentally significant. In consideration of the above, the Application Area is not considered to comprise a high level of biological diversity, but rather, have a level of biodiversity consistent with the surrounding regional area. The clearing of native vegetation within the Application Area is therefore not considered at variance to this principle. (2) Native vegetation should not be cleared if it comprises the whole or a part of, or is necessary for the maintenance of, a significant habitat for fauna indigenous to Western Australia. The terrestrial fauna values of the Application Area and surrounds are outlined within the environmental survey reports of Biota (2012b, 2012c). As identified by Figure 5, the fauna surveys in the vicinity of the Application Area and surrounds recorded 1 fauna taxa declared as Specially Protected Fauna under the Wildlife Conservation Act 1950 (WA) (WA Minister for Environment 2017b) (which is also classified as a Threatened Species under Environment Protection and Biodiversity Conservation Act 1999 (C th) as per DEE 2017c) and 1 DBCA-classified priority fauna taxon (DBCA 2017c). The fauna surveys also identified recorded/sampled locations of terrestrial potential short-range endemic invertebrate fauna taxa; none of which are of listed conservation significance. Of the recorded flora values, the Application Area coincides with records of: (1) DBCA-classified priority fauna taxon Aganippe castellum (P4); and (2) Potential short-range endemic invertebrate fauna taxa; and (3) Fauna habitat. The Application Area does not coincide with any recorded individuals of Specially Protected Fauna taxa. Whilst a number of Specially Protected Fauna have been recorded broadly across the region, and such taxa may potentially utilise the Application Area as part of their broader nesting and/or foraging habitat, the Application Area is not considered necessary or significant habitat for the maintenance of such taxa. The DBCA-classified priority fauna taxon Aganippe castellum (P4) was recorded by 2 opportunistic records within the Application Area. Whilst noting this, due to the inconspicuous nature of its burrows, Aganippe castellum is undoubtedly more abundant than the current opportunistic records would indicate, with a greater number of individuals expected to occur both within and outside of the Application Area. Aganippe castellum has a recorded linear distribution of approximately 450km, extending from near Morawa (east of Geraldton) to the south of Southern Cross (DBCA 2017e). Locally, Aganippe castellum has also been recorded at the Die Hardy Range, Windarling Range, Mt Jackson Range, 20

21 Helena and Aurora Range and the Koolyanobbing Range (Cliffs 2010a; DBCA 2017e). As outlined by Biota (2011c), Aganippe castellum is not considered to be a short-range endemic invertebrate fauna taxon due to its broad regional distribution. The removal of Aganippe castellum individuals and habitat is likely to represent only a small proportion of the individuals and habitat available to Aganippe castellum in the immediate vicinity of the Application Area and surrounds, and across the broader region. As a result of its broad distribution, the Application Area is not considered necessary or significant habitat for the maintenance of this fauna taxon. Fauna surveys for terrestrial potential short-range endemic invertebrate fauna taxa undertaken of the Application Area and surrounds recorded 26 putative taxa, comprising mygalomorph spiders, millipedes and land snails (Biota 2011c). None of the potential short-range endemic invertebrate fauna taxa recorded are of listed conservation significance. As noted by Biota (2011c), a number of the taxa have recorded distributions extending up to 110km from the Application Area and surrounds. These recorded regional distributions indicate good connectivity and distribution of suitable habitat for such taxa. Of the 26 taxa recorded, the Application Area coincides with 7 taxa comprising mygalomorph spiders and millipedes. All taxa recorded within the Application Area were also recorded at locations beyond both the Application Area and Cliffs approved mine operations. As a result of their broader distributions, the Application Area is not considered necessary or significant habitat for the maintenance of this fauna group. Whilst the clearing of native vegetation within the Application Area will increase in the spatial area of the Cliffs mine operations, this will represent only a small proportion of the fauna habitat available at a local scale (as shown by the aerial imagery in Figure 2) and across the broader region (as shown in Figure 1). Each of the mapped vegetation units (as a surrogate for fauna habitat types) coinciding with the Application Area has a recorded spatial distribution beyond both the Application Area and Cliffs approved mine operations. In this context, the Application Area is not considered to be significant habitat for fauna. In consideration of the above, the clearing of native vegetation within the Application Area is not considered at variance to this principle. (3) Native vegetation should not be cleared if it includes, or is necessary for the continued existence of, rare flora. The Application Area does not coincide with any records of Rare Flora taxa declared under the Wildlife Conservation Act 1950 (WA) (Biota 2011a; WA Minister for Environment 2017a). Accordingly, the Application Area is not considered necessary for the continued existence of Rare Flora. In consideration of the above, the clearing of native vegetation within the Application Area is not considered at variance to this principle. (4) Native vegetation should not be cleared if it comprises the whole or a part of, or is necessary for the maintenance of, a threatened ecological community. The Application Area does not coincide with any Threatened Ecological Community listed under the Environment Protection and Biodiversity 21

22 Conservation Act 1999 (C th) (Biota 2011a; DEE 2017b). Accordingly, the Application Area is not considered necessary for the maintenance of a Threatened Ecological Community. In consideration of the above, the clearing of native vegetation within the Application Area is not considered at variance to this principle. (5) Native vegetation should not be cleared if it is significant as a remnant of native vegetation in an area that has been extensively cleared. The Application Area, and its surrounds, has not been extensively cleared of native vegetation. Accordingly, the Application Area is not a significant remnant of native vegetation. The nearest area of extensive vegetation clearing is located approximately 100km to the west and south of the Application Area, where land has been cleared for agriculture (refer to the aerial imagery in Figure 1 for agricultural clearing to the south). In consideration of the above, the clearing of native vegetation within the Application Area is not considered at variance to this principle. (6) Native vegetation should not be cleared if it is growing in, or in association with, an environment associated with a watercourse or wetland. The Application Area does not contain native vegetation that is within or associated with a watercourse or wetland. The nearest surface water feature (watercourse/wetland) is Lake Barlee located approximately 35km north of the Application Area. In consideration of the above, the clearing of native vegetation within the Application Area is not considered at variance to this principle. (7) Native vegetation should not be cleared if the clearing of the vegetation is likely to cause appreciable land degradation. The clearing of native vegetation within the Application Area will be confined, and undertaken using standard mine equipment and practices. Based on the confined area and using this equipment, combined with Cliffs experience in mine operations, appreciable land degradation is unlikely. In consideration of the above, the clearing of native vegetation within the Application Area is not considered at variance to this principle. (8) Native vegetation should not be cleared if the clearing of the vegetation is likely to have an impact on the environmental values of any adjacent or nearby conservation area. The Application Area is not located within a conservation area. The Application Area is located within Mining Lease M77/1259-I granted to Cliffs under the Mining Act 1978 (WA), overlying Unallocated Crown Land vested with the Department of Planning, Lands and Heritage (DPLH) under the Land Administration Act 1997 (WA). 22

23 The nearest conservation area is located approximately 10km east of the Application Area, being the Mount Manning - Helena and Aurora Ranges Conservation Park. As a result of the separation distance from this conservation area, an effect to this conservation area from the clearing of native vegetation within the Application Area is unlikely. In consideration of the above, the clearing of native vegetation within the Application Area is not considered at variance to this principle. (9) Native vegetation should not be cleared if the clearing of the vegetation is likely to cause deterioration in the quality of surface or underground water. The Application Area does not contain any surface water, with the nearest surface water feature being Lake Barlee located approximately 35km north of the Application Area. Groundwater is positioned at significant depth (>30m) below the Application Area (Rockwater 2011), such that the clearing of native vegetation within the Application Area will not have the potential to affect the groundwater resource. Having regard to the separation distance to both to the surface water and the groundwater, an effect to surface water quality or groundwater quality from the clearing of native vegetation within the Application Area is unlikely. In consideration of the above, the clearing of native vegetation within the Application Area is not considered at variance to this principle. (10) Native vegetation should not be cleared if the clearing of the vegetation is likely to cause, or exacerbate, the incidence or intensity of flooding. The Application Area is located within a low rainfall area (approximately 300mm/year) (BoM 2017), such that flooding within the Application Area is unlikely. Having regard to the confined extent of the Application Area and the low rainfall, the potential for the clearing of native vegetation within the Application Area to cause or exacerbate the incidence or intensity of flooding is considered unlikely. In consideration of the above, the clearing of native vegetation within the Application Area is not considered at variance to this principle. DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o Aerial photographs and site photographs of the area proposed to be cleared. Maps identifying the Application Area are provided in Figures 1 to 6. The mapping is overlain on aerial photography and identifies the recorded environmental values of the Application Area and surrounds. 23

24 DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o A Flora and vegetation survey. Detail should include: Mapping of vegetation types/associations/communities, their condition, and their representation in a regional context. Photographs of each vegetation type to be cleared are also recommended; Declared Rare and Priority Flora species present or likely to be present. Details should include the location/s and size of the population/s; the impact of the proposed clearing on the population/s; and the likely impact of the proposed clearing on the continued existence of the species. The flora values of the Application Area and surrounds are outlined within the following environmental survey reports: (1) Biota Environmental Sciences Pty Ltd (2011a) Deception Deposit Vegetation and Flora Survey. Report prepared by Maier M, Chukowry P and Anderson P of Biota Environmental Sciences Pty Ltd for. Revision 11. June (2) (2013) Yilgarn Operations Deception Deposit Flora and Vegetation Survey for the Realignment of the Deception Deposit Haul Road. Report prepared by Wilkinson K (nee Greenacre) of Cliffs Asia Pacific Iron Ore Pty Ltd. Revision B. January (3) Western Botanical (2009a) Flora and Vegetation Survey of a Polygon at Deception Prospect for Future Drilling Programs, May Report prepared by Burgess S of Western Botanical for. September (4) Western Botanical (2012a) Deception Deposit Options Assessment Flora and Vegetation Survey. Report prepared by Eckermann B of Western Botanical for Cliffs Asia Pacific Iron Ore Pty Ltd. March (5) Western Botanical (2012b) Deception Deposit Mine Area Flora and Vegetation Survey. Report prepared by Warden J of Western Botanical for Cliffs Asia Pacific Iron Ore Pty Ltd. Revision 1. December 2012 Copies of the above environmental survey reports are provided on the compact disc within Section 3 References. Figure 4 identifies the recorded locations of flora taxa of conservation significance within the Application Area and surrounds. Figure 5 identifies the locations of mapped vegetation units within the Application Area and surrounds. Flora surveys of the Application Area and surrounds mapped 33 vegetation units comprising more than 300 native flora taxa (Biota 2011a). The flora surveys identified 4 DBCA-classified priority flora taxa (DBCA 2017a). The flora surveys did not identify any flora taxa protected as Rare Flora under the Wildlife Conservation Act 1950 (WA) (WA Minister for Environment 2017a) or Threatened Species of flora or listed under the Environment Protection and Biodiversity Conservation Act 1999 (C th) (DEE 2017a). None of the mapped vegetation units are of listed conservation significance as a Threatened Ecological Communities under the Environment Protection and Biodiversity Conservation Act 1999 (C th) (DEE 2017b) or listed as a DBCA-classified priority ecological community (DBCA 2013, 2017b). Of the recorded flora values, the Application Area coincides with records of: o o DBCA-classified priority flora taxon Banksia arborea (P4); and Vegetation units. 24

25 An assessment of the potential environmental effect to flora values is provided below. To note with regards to the interpretation of the results for flora taxa and vegetation units, as the flora surveys have focused on the Application Area and surrounds (with conversely, a lesser focus on areas beyond the Application Area and surrounds), the distribution mapping and population counts for flora taxa and vegetation units bias towards a greater concentration and proportion occurring within the Application Area and surrounds (with conversely, a lesser concentration and proportion identified beyond of the Application Area and surrounds). This bias also arises for the regional flora surveys that assist to provide contextual information as to their regional distributions. Banksia arborea (P4) - Banksia arborea, commonly known as Yilgarn Dryandra, is a tree or large shrub to 8m high with yellow flowers occurring on ironstone hills on stony loam soils (DBCA 2014b cited in Woodman 2014; Western Botanical 2012c). DBCA (2017d) identifies Banksia arborea as having a linear distribution of approximately 180km, extending from the Koolyanobbing Range in the south to the Perrinvale Range in the north. Banksia arborea has also been recorded at the Helena and Aurora Range, Die Hardy Range, Mt Elvire, Mt Finnerty Range, Mt Jackson Range, Mt Manning Range, Windarling Range and the Yorkadine Range (Western Botanical 2012c; DBCA 2017d). Records held by Cliffs (unpublished data) identify approximately 29,000 records of Banksia arborea within the broader region, of which approximately 1,800 individuals have been approved for removal by Cliffs mine operations. As identified by Figure 4, a group of Banksia arborea were recorded within the Application Area, comprising 7 individuals. All individuals of this group coincide with the Application Area. Table 1 identifies the number of Banksia arborea individuals coinciding with the Application Area, as well as contextual information regarding its local and regional distribution (as referred to above). Whilst the whole group of 7 individuals of Banksia arborea will be removed, this group is not expected to present any unique characteristics or values that are not otherwise represented by the other nearby groups of Banksia arborea, including the nearest recorded group (14 individuals) positioned approximately 4km north of Application Area (Cliffs unpublished data). Clearing of the native vegetation within the Application Area is therefore not expected to affect the representation, diversity, viability or ecological function of the Banksia arborea taxon. In consideration of the number of individuals of Banksia arborea coinciding with the Application Area (7 individuals), and having regard to its distribution across the local area and the broader region (29,000 individuals across multiple ranges), the effect to the DBCA-classified priority flora taxon Banksia arborea is not environmentally significant. 25

26 Banksia arborea (P4) Application Area 7 Approved Mine Operations 1,800 Regional Distribution ~29,000 Banksia arborea has a regional distribution of approximately 180km, with regional records including the Helena & Aurora Range, Die Hardy Range, Mt Elvire, Perrinvale Range, Mt Finnerty Range, Windarling Range, Mt Jackson Range, Koolyanobbing Range, Yorkadine Range and north of the Mt Manning Range. The nearest recorded local group of Banksia arborea is positioned approximately 4km north of the Application Area, comprising 14 individuals. Table 1. Flora Taxa. The number of individuals of Banksia arborea (P4) recorded within the Application Area, within Cliffs approved mine operations and across the broader region is identified. The inset image identifies the regional distribution of Banksia arborea. Data source: Biota (2011a), Cliffs unpublished data; Western Botanical (2009a). Image: adapted from DBCA (2017d). Vegetation Units - The Application Area covers a spatial area of approximately 110ha, comprising 106ha of native vegetation and 4ha of cleared land. Flora surveys of the Application Area and surrounds mapped 33 vegetation units comprising more than 300 native flora taxa (Biota 2011a). More than half of the mapped vegetation units were considered by Biota (2011a) to be equivalent to vegetation units previously recorded at the nearby Windarling Range, positioned approximately 20km south of the Application Area. None of the vegetation units have been listed as a Threatened Ecological Community under the Environment Protection and Biodiversity Conservation Act 1999 (C th) (DEE 2017b) or listed as a DBCA-classified priority ecological community (DBCA 2013, 2017b). The Application Area coincides with 10 vegetation units, as identified by Figure 5 and Table 2. Each vegetation unit has a recorded spatial distribution beyond the Application Area and Cliffs approved mine operations. Noting this broader distribution, the effect to vegetation units is not environmentally significant. To note, as identified by Figure 5 and Table 2, the whole of the areas of Vegetation Unit 1.06 (Banksia arborea tall shrubland) and Vegetation Unit 4.01 (Ptilotus obovatus var. obovatus low shrubland) in the immediate vicinity of the Application Area and surrounds will be removed. The recorded area of each vegetation unit to be cleared is small (<1ha each) with their composition dominated by a single taxon (Banksia arborea as assessed above, and Ptilotus obovatus var. obovatus which is not of listed conservation significance). Whilst removal of these vegetation units will affect their local distribution, as outlined by Biota (2011a) and Western Botanical (2009b), Banksia arborea tall shrubland has also been recorded across the Windarling Range and the Mt Jackson Range, and Ptilotus obovatus low shrubland has also been recorded across the Windarling Range, Mt Jackson Range, Die Hardy Range, Koolyanobbing Range, Helena and Aurora Ranges and 26

27 the Mt Manning Range. In context with their broader regional distributions, the effect of clearing these vegetation units is not environmentally significant. In relation to the clearing of native vegetation more generally, the clearing of native vegetation within the Application Area will increase in the spatial area of Cliffs approved mine operations by 110ha; equating to approximately 4% of the 3,200ha area currently authorised for Cliffs Yilgarn Operations under the Mining Act 1978 (WA) (Cliffs 2017d, 2017e). Having regard to the area of the approved mine operations, and in context with the broad extent of native vegetation both at a local scale (as shown in Figure 2) and across the broader region (as shown in Figure 1), the effect to native vegetation is not environmentally significant. Within each vegetation unit occurs a variety of other native flora taxa which are not of listed conservation significance due to their population sizes and broad regional distributions. In this context, the effect to other such flora taxa within the vegetation units is also not environmentally significant. In consideration of the effect to flora taxa and vegetation units as outlined above, the clearing of native vegetation within the Application Area is not expected to result in a significant effect to flora values. 27

28 VEGETATION UNIT 1.01 Acacia cockertoniana, A. ramulosa var. ramulosa tall shrubland over Philotheca brucei subsp. brucei, Eremophila clarkei, Dodonaea rigida open shrubland MAPPED EXTENT (ha) APPLICATION AREA (ha) OTHER REGIONAL RECORDS Windarling Range 1.02 Acacia "aneura", A. ramulosa var. ramulosa tall shrubland Windarling Range 1.03 Acacia sp. narrow phyllode, A. ramulosa var. ramulosa tall shrubland over Philotheca brucei subsp. brucei open shrubland over Eremophila metallicorum low open shrubland 1.05 Acacia cockertoniana, Melaleuca leiocarpa, Calycopeplus paucifolius tall shrubland over Philotheca brucei subsp. brucei, Leucopogon sp. Clyde Hill shrubland 1.06 Banksia arborea (Acacia cockertoniana, Eremophila clarkei) tall shrubland over Philotheca brucei subsp. brucei shrubland over Olearia humilis scattered low shrubs 2.01 Eucalyptus salubris and/or E. loxophleba subsp. lissophloia low open woodland over Eremophila scoparia (Atriplex nummularia subsp. spathulata) scattered tall shrubs over A. stipitata low open shrubland over Sclerolaena diacantha, S. fusiformis very open herbland 2.02 Eucalyptus longissima, (E. corrugata) very open tree mallee over Acacia ramulosa var. ramulosa tall open shrubland over Eremophila clarkei, E. decipiens subsp. decipiens, Scaevola spinescens open shrubland over Olearia muelleri, Ptilotus obovatus var. obovatus low open shrubland 2.05 Eucalyptus longissima, (E. corrugata) very open tree mallee over Acacia cockertoniana tall shrubland over Eremophila clarkei, E. decipiens subsp. decipiens, Philotheca brucei subsp. brucei open shrubland over Olearia humilis, Ptilotus obovatus var. obovatus scattered low shrubs 2.06 Eucalyptus loxophleba subsp. lissophloia low open woodland over Acacia sp. narrow phyllode, (A. ramulosa var. ramulosa, Eremophila caperata) tall shrubland over Olearia muelleri, Ptilotus obovatus var. obovatus low open shrubland 4.01 Ptilotus obovatus var. obovatus low shrubland over Enneapogon caerulescens scattered grasses and Cheilanthes sieberi subsp. sieberi, C. brownii very open herbland - Cleared land Windarling Range 16 3 Windarling Range <1 <1 Windarling Range Windarling Range Windarling Range Windarling Range 24 1 Windarling Range <1 <1 Windarling, Mt Jackson, Koolyanobbing, Die Hardy, Helena & Aurora and Mt Manning Total 110 (1) Table 2. Vegetation Units. The Application Area coincides with 10 vegetation units. The area of each vegetation unit coinciding with the Application Area is identified. The mapped extent of each vegetation unit recorded in the vicinity of the Application Area and surrounds is also identified, with notation also of additional regional records. Note: (1) Errors may occur due to rounding. Data source: Biota (2011a), Western Botanical (2012a, 2012b). 28

29 DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o A fauna assessment. Detail should include: the fauna present or likely to be present, and their conservation significance; an assessment of the significance of the vegetation and landform to be cleared, as a habitat for fauna; including mapping of any significant fauna habitats. The fauna values of the Application Area and surrounds are outlined within the following environmental survey reports: (1) Biota Environmental Sciences Pty Ltd (2011b) Deception Deposit Vertebrate Fauna Survey. Report prepared by Cartledge V (Dr), Cairnes J and Sachse T of Biota Environmental Sciences Pty Ltd for. Revision 13. March (2) Biota Environmental Sciences Pty Ltd (2011c) Deception Deposit Short Range Endemic Invertebrate Fauna Survey. Report prepared by Watson N (Dr) and Teale R of Biota Environmental Sciences Pty Ltd for. Revision 7. March Copies of the above environmental survey reports are provided on the compact disc within Section 3 References. Figure 6 identifies the recorded locations of fauna taxa of conservation significance within the Application Area and surrounds. Recorded/sampled locations of terrestrial potential short-range endemic invertebrate fauna taxa (none of which are of listed conservation significance) are also identified. The fauna surveys recorded 1 fauna taxon declared as Specially Protected Fauna under the Wildlife Conservation Act 1950 (WA) (WA Minister for Environment 2017b) (which is also classified as a Threatened Species under Environment Protection and Biodiversity Conservation Act 1999 (C th) as per DEE 2017c) and 1 DBCA-classified priority fauna taxon (DBCA 2017c). Of the recorded fauna values, the Application Area coincides with records of: o o o DBCA-classified priority fauna taxon Aganippe castellum (P4); and Potential short-range endemic invertebrate fauna taxa; and Fauna habitat. An assessment of the potential environmental effect to fauna values is provided below. To note with regards to the interpretation of the results for fauna taxa, as the fauna surveys have focused on the Application Area and surrounds (with conversely, a lesser focus on areas beyond the Application Area and surrounds), the distribution mapping for the fauna taxa bias towards a greater concentration and proportion occurring within the Application Area and surrounds (with conversely, a lesser concentration and proportion identified beyond of the Application Area and surrounds). This bias also arises for the regional fauna surveys that assist to provide contextual information as to their regional distributions. Aganippe castellum (P4) - Aganippe castellum, commonly known as the Tree-stem Trapdoor Spider, is a mediumsized trapdoor spider which builds its nest in the ground with an aerial, webbed tube extending up against the base of a tree or shrub. Clusters of twig lines from the aerial tube 29

30 drape to the ground and surround the nest, with the twig lines directing foraging prey (mainly ants) past the opening of the nest (Main 1983 and 1986 both cited in Russell 2008). Aganippe castellum has a recorded linear distribution of approximately 450km, extending from near Morawa (east of Geraldton) to the south of Southern Cross (DBCA 2017e). Locally, Aganippe castellum has been recorded at the Die Hardy Range, Windarling Range, Mt Jackson Range, Helena and Aurora Range and the Koolyanobbing Range (Cliffs 2010a; DBCA 2017e). As outlined by Biota (2011c), Aganippe castellum is not considered to be a short-range endemic invertebrate fauna taxon due to its broad regional distribution. Based on the recorded species density and interpretation of potential habitat the regional population of Aganippe castellum has been estimated at >240,000 individuals (Cliffs 2010a). This regional population estimate is considered to be highly conservative as it includes only the surveyed areas of the Mt Jackson Range and the southern Koolyanobbing Range, with the recorded Aganippe castellum populations at all other locations (as identified above) yet to be estimated. The number of individuals of Aganippe castellum authorised to be removed from across Cliffs Yilgarn Operations has not been estimated, however, for Cliffs Mt Jackson Range mine operations it was previously estimated that approximately 12,000 individuals could be affected (Cliffs 2010b). Aganippe castellum was recorded by 2 opportunistic records within the Application Area. Whilst noting this, due to the inconspicuous nature of its burrows, Aganippe castellum is undoubtedly more abundant than the current opportunistic records would indicate, with a greater number of individuals expected to occur both within and outside of the Application Area. As such, whilst the Application Area coincides with only 2 records of Aganippe castellum, it is likely the direct effect to Aganippe castellum individuals will be greater than the current opportunistic records indicate, and similarly likely this taxon also occurs in greater numbers across habitat beyond the Application Area. As an indicative guide, to use the recorded Aganippe castellum burrow densities from the Mt Jackson Range, Koolyanobbing Range and the Helena and Aurora Ranges of between 65 to 79 burrows per hectare (as identified in Cliffs 2010a), the number of individuals within the Application Area could be in the order of up to between 7,000 to 9,000 individuals, and equally, the total population beyond the Application Area could be expected to be several times larger than that estimate based on the broad extent of the available habitat. Table 5-3 identifies the recorded number of Aganippe castellum individuals coinciding with the Application Area, as well as contextual information regarding its distribution and conservatively estimated population size. The removal of Aganippe castellum individuals and habitat within the Application Area is likely to represent only a small proportion of the individuals and the habitat available to Aganippe castellum in the vicinity of the Application Area and surrounds, and across the broader region. In consideration of the number of individuals of Aganippe castellum estimated within the Application Area (up to ~9,000 individuals), the effect of Cliffs approved mine operations (>12,000 individuals) and having regard to its regional distribution and population size (conservatively >240,000 individuals across multiple ranges), the effect to the DBCA-classified priority fauna taxon Aganippe castellum is not environmentally significant. 30

31 Aganippe castellum (P4) Application Area 2 (up to ~9,000 est.) Approved Mine Operations Regional Distribution >12,000 (est.) >240,000 (est.) Aganippe castellum has a regional distribution of approximately 450km, extending from near Morawa (east of Geraldton) to the south of Southern Cross with local records including the Helena & Aurora Range, Die Hardy Range, Windarling Range, Mt Jackson Range, Johnston Range and the Koolyanobbing Range. Aganippe castellum is undoubtedly more abundant than the current opportunistic records would indicate, with a greater number of individuals expected to occur both within and outside of the Application Area. Table 5-3. Fauna Taxa. The Application Area coincides with records of 2 individuals of the DBCA-classified priority fauna taxon Aganippe castellum (P4), however, this taxon is undoubtedly more abundant that than the current opportunistic records would indicate. The number of individuals of Aganippe castellum recorded/estimated within the Application Area, within Cliffs approved mine operations and across the broader region is identified. The inset image identifies the regional distribution of Aganippe castellum. Data source: Cliffs (2010a, 2010b) Image: adapted from DBCA (2017e). Potential Short-range Endemic Invertebrate Fauna Taxa - Fauna surveys for terrestrial potential short-range endemic invertebrate fauna taxa undertaken of the Application Area and surrounds recorded 26 putative taxa, comprising mygalomorph spiders, millipedes and land snails (Biota 2011c). None of the potential short-range endemic invertebrate fauna taxa recorded are of listed conservation significance. As noted by Biota (2011c), a number of the taxa have recorded distributions extending up to 110km from the Application Area and surrounds, with the regional records including Pigeon Rocks (10km south), Die Hardy Ranges (10km south-east), Windarling Range (20km south), Mt Jackson Range (40km south-south-west), and the Koolyanobbing Range (110km south-south-east). These recorded regional distributions indicate good connectivity and distribution of suitable habitat for such taxa. Of the 26 taxa recorded, the Application Area coincides with 7 taxa comprising mygalomorph spiders and millipedes. All taxa recorded within the Application Area were also recorded at locations beyond both the Application Area and Cliffs approved mine operations. To note, the survey location records for potential short-range endemic invertebrate fauna taxa reflect the field sampling locations rather than the actual spatial distribution of each taxon. Based on the vegetation units from within which each taxon was recorded (as a surrogate for habitat), each taxon undoubtedly has a broader distribution than the point location survey records indicate, both within and beyond the Application Area, and within and beyond Cliffs approved mine operations. In consideration that all taxa recorded within the Application Area were also recorded at locations beyond both the Application Area and Cliffs approved mine operations, the 31

32 effect to potential short-range endemic invertebrate fauna taxa is not environmentally significant. Fauna Habitat - The clearing of native vegetation within the Application Area will increase in the spatial area of the Cliffs mine operations by 110ha; equating to approximately 4% of the 3,200ha area currently authorised for Cliffs Yilgarn Operations under the Mining Act 1978 (WA) (Cliffs 2017d, 2017e). Having regard to the area of Cliffs approved mine operations, and in context with the broad extent of potential fauna habitat both at a local scale (as shown by the aerial imagery in Figure 2) and across the broader region (as shown in Figure 1), the effect to fauna habitat is not environmentally significant. As identified above, each of the mapped vegetation units (as a surrogate for fauna habitat types) coinciding with the Application Area has a recorded spatial distribution beyond both the Application Area and Cliffs approved mine operations. Noting this broader distribution, the effect to the types of habitats available for fauna is not environmentally significant. Within the fauna habitat occurs a variety of other native fauna taxa which are not of listed conservation significance due to their population sizes and broad regional distributions. environmentally significant. In this context, the effect to other fauna taxa is not expected to be As identified above, the Application Area does not coincide with any recorded individuals of Specially Protected Fauna taxa. Whilst a number of Specially Protected Fauna have been recorded broadly across the region, and such taxa may potentially utilise the Application Area as part of their broader nesting and/or foraging habitat, the Application Area is not considered necessary or significant habitat for the maintenance of such taxa. In consideration of the effect to fauna taxa and fauna habitat as outlined above, the clearing of native vegetation within the Application Area is not expected to result in a significant effect to fauna values. DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o A Site overview, with a brief description of topography, landforms, soils and hydrology. An assessment of the topography, landforms, soils and hydrology for the Application Area and surrounds is provided below: (1) Topography The land topography within the Application Area is gently undulating, presenting as a low rise with elevations between approximately 470mAHD and 505mAHD. Surrounding the Application Area are extensive plains of varying elevation, interspersed with a number of large elevated ironstone ridges (the nearest being the Die Hardy Ranges to 640mAHD, positioned approximately 10km south-east) and low-lying salt lakes (the nearest being Lake Barlee approximately 35km north). 32

33 In consideration of the low-elevation positioning and the confined extent of the Application Area, the clearing of native vegetation within the Application Area is not expected to result in a significant effect to land topography. (2) Landforms The Application Area is gently undulating, presenting as a low rise. To date, part of the surface of the landform within the Application Area has been modified through land clearing for approved mineral exploration works. The clearing of native vegetation within the Application Area will further modify the landform. The characteristics of the landform (e.g. soils, vegetation) are considered to be well represented beyond the Application Area. Surrounding the Application Area are extensive plains of varying elevation, interspersed with a number of large elevated ironstone ridges and low-lying salt lakes. In consideration of the low-elevation positioning, the confined extent of the Application Area, as well as its separation from the prominent landforms (large ironstone ridges and salt lakes), the clearing of native vegetation within the Application Area is not expected to result in a significant effect to landform values. (3) Soils The clearing of native vegetation within the Application Area will disturb land areas containing soils and soil profiles. Investigations of the soils at the adjacent Deception Deposit (SWC 2011) identified 3 soil units described as skeletal soils over ironstone, shallow gravely soils over laterite and shallow-deep sandy loam over laterite, with the delineation of these areas reflecting the landforms/topography. Generally, the soils were classified as being non-saline, non-sodic, having high coarse rock fragment content, of low nutrient and organic carbon content, and naturally acidic due to the abundance of iron oxides. The SWC (2011) assessment outlined that the skeletal soils over ironstone and shallow gravely soils over laterite had properties that were suitable for use in mine rehabilitation works. The shallow-deep sandy loam over laterite soils were not considered suitable for surface use in mine rehabilitation works due to their potentially dispersive nature, however could be used in the form of subsoil (with an outer capping of the other materials). Whilst the soils of the Application Area have not been subject to detailed assessment, it is expected the soils of the Application Area are similar to the general soil types identified by SWC (2011) due to their formation through the same geological process. Consistent with Cliffs current mining practices, recoverable topsoil/subsoil materials from within the Application Area will be removed and temporarily stockpiled for subsequent use in progressive and post-mining rehabilitation works. In consideration of the nature of the soils recorded, the management actions proposed and the confined extent of the Application Area, the clearing of native vegetation within the Application Area is not expected to result in a significant effect to soils. 33

34 (4) Hydrology The Application Area does not contain any surface water, with the nearest surface water feature being Lake Barlee located approximately 35km north of the Application Area. Groundwater is positioned at significant depth (>30m) below the Application Area (Rockwater 2011), such that the clearing of native vegetation within the Application Area will not have the potential to affect the groundwater resource. In consideration of the separation distance to both to the surface water and the groundwater, and the confined extent of the Application Area, the clearing of native vegetation within the Application Area is not expected to result in a significant effect to hydrology. DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o A summary and/or map of the proposed developments on the site. A map identifying the location and area of the Application Area are provided in Figure 2. Follow the clearing of the native vegetation within the Application Area, the Project will involve the development of Mine Pit and Waste Rock Landform infrastructure components, as described above and identified in Figure 3. DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o A hydrological summary, which includes discussion of the likelihood of impact from the clearing on riparian vegetation, wetlands, watercourses, surface water or groundwater. An assessment of the potential for an effect to riparian vegetation, wetlands, watercourses, surface water and groundwater from the clearing of native vegetation within the Application Area is provided below: (1) Riparian vegetation No riparian vegetation occurs within the Application Area. The nearest surface water feature (which may contain riparian vegetation) is Lake Barlee located approximately 35km north of the Application Area. Accordingly, no effect to riparian vegetation can be expected from the clearing of native vegetation within the Application Area. (2) Wetlands No wetlands occur within the Application Area. The nearest surface water feature is Lake Barlee located approximately 35km north of the Application Area. Accordingly, no effect to wetlands is expected from the clearing of native vegetation within the Application Area. 34

35 (3) Watercourses No watercourses occur within the Application Area. The nearest surface water feature is Lake Barlee located approximately 35km north of the Application Area. Accordingly, no effect to watercourses is expected from the clearing of native vegetation within the Application Area. (4) Surface Water No surface water occurs within the Application Area The nearest surface water feature is Lake Barlee located approximately 35km north of the Application Area. The Application Area is located within a low rainfall area (approximately 300mm/year) (BoM 2017), and accordingly, surface water following rainfall is limited. Accordingly, no effect to surface water is expected from the clearing of native vegetation within the Application Area. (5) Groundwater Groundwater is positioned at significant depth (>30m) below the Application Area (Rockwater 2011). Accordingly, no effect to groundwater is expected from the clearing of native vegetation within the Application Area. DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o A vegetation degradation summary, which includes discussion of the likelihood of the spread of dieback disease and/or weeds. An assessment of the potential for an effect from the spread of dieback disease (Phytophthora cinnamomi) and weeds from the clearing of native vegetation within the Application Area is provided below: (1) Dieback The Application Area is not located within an area of sufficient annual rainfall to be susceptible to Phytophthora cinnamomi. Phytophthora cinnamomi is generally restricted to areas receiving >400mm/year of rainfall (Dieback Working Group 2008). The Application Area is located beyond the >400mm/year rainfall area, receiving approximately 300mm/year (BoM 2017). Phytophthora cinnamomi has not previously been recorded within the Application Area or surrounds. Accordingly, no effect from Phytophthora cinnamomi is expected from the clearing of native vegetation within the Application Area. 35

36 (2) Weeds Flora surveys of the Application Area and surrounds recorded 2 introduced flora taxa, being Pentameris airoides ssp. airoides (recorded by its former name of Pentaschistis airoides ssp. airoides) and Centaurea melitensis (Maltese cockspur) (Biota 2011a). The Application Area coincides with a single record of Pentameris airoides ssp. airoides. Both Pentameris airoides ssp. airoides and Centaurea melitensis are well distributed across the southern half of Western Australia (DBCA 2017a). Neither taxa are Declared Pests under the Biosecurity and Agriculture Management Act 2007 (WA) or listed as a Weed of National Significance (Australian Weeds Committee 2012). Introduced flora within the Application Area can be effectively managed through standard mine hygiene procedures, which includes the control of vehicle and personnel movements within weed-infested areas, and the spraying of weed-infested areas. In consideration of the introduced flora taxa recorded, the implementation of standard mine hygiene procedures and the confined extent of the Application Area, the clearing of native vegetation within the Application Area is not expected to result in a significant effect to introduced flora. DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o A land degradation summary, which includes discussion of the likelihood of land degradation, including waterlogging, acidification, salinisation, deep subsoil compaction and erosion. An assessment the potential for land degradation from waterlogging, acidification, salinisation, deep subsoil compaction and erosion from the clearing of native vegetation within the Application Area is provided below: (1) Waterlogging The clearing of native vegetation within the Application Area will not involve the inundation of land with water or the discharge of water which could result in waterlogging. Accordingly, no effect from waterlogging is expected from the clearing of native vegetation within the Application Area. (2) Acidification The clearing of native vegetation within the Application Area will not involve excavations which could expose rock materials that may be acid forming. Accordingly, no effect from acidification is expected from the clearing of native vegetation within the Application Area. (3) Salinisation The Application Area is located at significant elevation (>30m) above the groundwater level (Rockwater 2011), such that the clearing of the vegetation is not expected to result in a subsequent rise in the groundwater table that could lead to salinisation. 36

37 Accordingly, no effect from salinisation is expected from the clearing of native vegetation within the Application Area. (4) Deep subsoil compaction The Application Area does not contain deep subsoils. The soils of the application area comprise limited topsoil/subsoil overlying consolidated rock. Accordingly, no effect from deep subsoil compaction is expected from the clearing of native vegetation within the Application Area. (5) Erosion The Application Area is located in an area of low annual rainfall (300mm/y) (BoM 2017), with limited topsoil/subsoil which could be mobilised. Previous assessments of the soils in the area (SWC 2011) identified the surficial soils as generally being non-sodic (i.e. not dispersive) and having high coarse rock fragment; with similar soil characteristics expected for the soils across most of the Application Area. Accordingly, no effect from erosion is expected from the clearing of native vegetation within the Application Area. DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o An outline of environmental management measures and rehabilitation practices that will be undertaken during and subsequent to the completion of the project. Existing Management Plans and Mining Proposals should be submitted, if they are relevant to the clearing proposal. Cliffs mine operations are undertaken in accordance with an Environmental Policy (Cliffs Natural Resources 2017, Attachment 1), which outlines Cliffs overarching objectives for environmental protection and continual improvement in environmental performance. The Environmental Policy is implemented through Cliffs international standard AS/NZS ISO 14001:2004-certified EMS (SGS 2015, Attachment 2), which includes Environmental Management Plans for the management of key environmental aspects. Cliffs considers the potential environmental effects of the clearing of native vegetation within the Application Area can be appropriately managed in accordance with the standard environmental management actions for land clearing contained in: (1) (2016) Yilgarn Operations - Flora and Vegetation Management Plan. Report prepared by Howard R (Dr) for Cliffs Asia Pacific Iron Ore Pty Ltd. Revision G. June A copy of the Flora and Vegetation Management Plan is provided at Attachment 3. The Flora and Vegetation Management Plan is implemented across Cliffs Yilgarn Operations. The Flora and Vegetation Management Plan outlines a range of environmental management actions to actively control and manage the potential environmental effects to flora values, which in relation to land clearing and land management includes: o Implementation of management actions for avoiding and/or minimising the environmental effects to flora values of: 37

38 o Land clearing, by: o A Site Disturbance Permit process to control land clearing to within authorised areas; o Surface water drainage, by: o Mine planning of surface water drainage through containment and control measures (e.g. sumps, culverts, table drains) to control surface water flows which may affect flora values; o Daily inspection of saline water equipment (pipelines and water carts) to minimise the risk of inadvertent water flow to areas containing flora values; o Introduced flora, by; o Weed monitoring and weed control (spraying) to manage introduced flora taxa which may affect flora values; o Dust generation, by: o Dampening of cleared areas using groundwater to minimise the potential for dust generation which may affect flora values; o Fire, by: o Fire control equipment (fire extinguishers) within mine vehicles for the control of any small fires which may affect flora values; o Installation of fire breaks at selected locations between mine infrastructure and flora taxa of listed conservation significance; o Introduced fauna, by: o Control of introduced fauna (trapping and culling) which may potentially disturb flora taxa of listed conservation significance; o Education and training of mine personnel on the flora values present and flora management, including: o Site inductions which include identification of the flora values present, with a particular focus on Rare Flora ; o An incident reporting system to identify and communicate any inadvertent environmental effects to flora values; and o Reporting on the implementation of the Flora and Vegetation Management Plan. The clearing of native vegetation within the Application Area is not expected to result in a significant environmental effect. Cliffs proposes to implement the Flora and Vegetation Management Plan to ensure the potential environmental effects of the clearing of native vegetation within the Application Area are minimised and controlled to an acceptable level. Following the clearing of the native vegetation within the Application Area, mine operations for the Project are proposed to be undertaken. Progressively during the mine operations and postmining, Cliffs will seek to restore the flora values through rehabilitation works consistent with the approach outlined within Cliffs Mine Closure Plan (Cliffs 2015). As outlined by the Mine Closure Plan, Cliffs broad mine closure objectives are to decommission mine infrastructure, rehabilitate disturbed areas with native vegetation, and to ensure the land and landforms are safe, stable and non-polluting to enable a post-mining land use. The rehabilitation works will be undertaken to meet specified rehabilitation completion criteria, with the implementation of the Mine Closure Plan to be regulated by DMIRS under the Mining Act 1978 (WA). 38

39 DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o Copies of any correspondence with DPaW or other Government Agencies regarding the proposal. Stakeholder consultation is an integral component of Cliffs planning, assessment and development processes. During the planning and assessment for the Project undertaken to date, Cliffs has undertaken consultation with a range of key stakeholders from both Government and community sectors. A summary of the consultations undertaken for the Project is provided below. The consultations were undertaken in the form of meetings, telephone discussions and/or written correspondence, during which Cliffs identified the Project, studies and investigations undertaken, anticipated environmental effects, and the proposed environmental management approach. Whilst the stakeholder views have not resulted in any changes to the Project, the stakeholder views have informed the type and detail of the assessment information presented within this Supporting Information document. Consultation during implementation of the Project will be ongoing with DMIRS through the annual reporting provisions and site inspections relevant to the Clearing Permit, and the associated Mining Proposal (Cliffs 2017c) under the Mining Act 1978 (WA). Ongoing consultation with the community during implementation of the Project will be undertaken through the existing framework of Cliffs Community Consultation Group. GOVERNMENT CONSULTATION DEPARTMENT OF MINES, INDUSTRY REGULATION AND SAFETY The Project will be subject to environmental and mining assessments by DMIRS of a Clearing Permit application (Cliffs 2017a) under s51e of the Environmental Protection Act 1986 (WA) and a Mining Proposal under s82a(2) of the Mining Act 1978 (WA) (Cliffs 2017c). Accordingly, DMIRS is a stakeholder for the Project. In April 2017, a meeting was held with representatives for DMIRS (J Allen, L Stirbinskis) and Cliffs (T Benson, S Hawkins) to discuss the Project. This consultation included identification of the conceptual infrastructure components and location, potential environmental effects, mine closure, and proposed assessment by DMIRS under the Mining Act 1978 (WA). The DMIRS did not identify any significant environmental concerns in relation to the Project, and noted Cliffs proposed approach to utilise existing information for the adjacent mine operations as a surrogate where appropriate. To note, consultation with DMIRS initially indicated assessment of the Project under the Environmental Protection Act 1986 (WA) would occur through a separate Government agency and process, however, since that consultation it has been identified the appropriate assessment pathway under the Environmental Protection Act 1986 (WA) is for the submission of a Clearing Permit application to be assessed by DMIRS. Submission of the Clearing Permit application and the associated Mining Proposal, including their subsequent assessment by DMIRS, represents further consultation between Cliffs and DMIRS on the Project. As an outcome of the assessment and approvals processes under the Environmental Protection Act 1986 (WA) and the Mining Act 1978 (WA), further consultation between 39

40 Cliffs and DMIRS during Project implementation is expected to continue through annual compliance reporting and site inspections. DEPARTMENT OF WATER AND ENVIRONMENTAL REGULATION Cliffs has been granted Groundwater Licence GWL (DWER 2014) and Licence CAW (DWER 2016) by the Department of Water and Environmental Regulation (DWER) in accordance with s5c and s26d of the Rights in Water and Irrigation Act 1914 (WA). The Project will also be subject to a Works Approval and a Licence regulated by DWER under the Environmental Protection Act 1986 (WA) for groundwater dewatering. Accordingly, DWER is a stakeholder for the Project. In June 2017, a meeting was held with representatives for DWER (T Gentle) and Cliffs (N Smith) to discuss the Project, as an extension to the approved mine operations. This consultation included identification of the conceptual infrastructure components and location, and the requirement for a Works Approval and Licence. During this consultation DWER did not identify any significant environmental concerns in relation to the Project. In July 2017, a further meeting was held with representatives for the DWER (T Gentle) and Cliffs (N Smith, SHawkins) to discuss the assessment processes and assessment schedule for the Works Approval and Licence required for the Project. Submission of the Works Approval and Licence applications, including their subsequent assessment by DWER, will represent further consultation between Cliffs and DWER on the Project. To note, consultation with DWER has not been necessary in relation to Groundwater Licence GWL or Licence CAW as these approvals currently allow for groundwater well construction and groundwater abstraction within Mining Lease M77/1259-I within which the Project is situated, and further, the Project is not expected to result in a significant effect to the groundwater resource. Cliffs can implement the Project in accordance with the previously granted Groundwater Licence GWL and Licence CAW Further consultation between Cliffs and DWER during Project implementation is expected to occur through annual compliance reporting and site inspections in accordance with the Licence under the Environmental Protection Act 1986 (WA), and the Groundwater Licence GWL and Licence CAW approvals under the Rights in Water and Irrigation Act 1914 (WA). DEPARTMENT OF PLANNING, LANDS AND HERITAGE The Project is located within Mining Lease M77/1259-I granted to Cliffs under the Mining Act 1978 (WA), which overlies Unallocated Crown Land under the Land Administration Act 1997 (WA) vested with DPLH. The Project also coincides with a Registered Aboriginal heritage site under the Aboriginal Heritage Act 1972 (WA) regulated by DPLH, and Cliffs will be required to make an application for s18 Consent to enable this site to be disturbed by the Project. Accordingly, DPLH is a stakeholder for the Project. In February 2016, Cliffs consulted DPLH to seek comment on various operational extensions to its Yilgarn Operations coinciding with Unallocated Crown Land (however noting that consultation did not specifically include the Project). In April 2016, DPLH (C Ziatas) advised of no comment or objection to various operational extensions proposed by Cliffs within Unallocated Crown Land as such mine operations could be appropriately managed by DMIRS under the Mining Act 1978 (WA). As this Project is consistent with the types of operational extensions previously discussed between Cliffs and DPLH, consultation with 40

41 DPLH regarding the Project coinciding with Unallocated Crown Land under the Land Administration Act 1997 (WA) is not necessary. In March 2017, a meeting was held with representatives for the DPLH (T Butler) and Cliffs (V Roberts, K Halford, R O Connor) to discuss the Project and the potential effects to Aboriginal heritage matters under the Aboriginal Heritage Act 1972 (WA). This consultation included identification of the Project location and the proposed disturbance to other heritage place record Site ID Deception 1 (DPLH 2017a, 2017b, 2017c). The DPLH identified the assessment processes of the DPLH and the Aboriginal Cultural Materials Committee under the Aboriginal Heritage Act 1972 (WA) to determine the status of the Site ID record. In March 2017, Cliffs submitted an application under s16 of the Aboriginal Heritage Act 1972 (WA) to DPLH to undertake archaeological investigations of Site ID in order to provide additional information on the Aboriginal heritage value of the record. In July 2017, a Section 16 Permit was issued to Cliffs by the Registrar of Aboriginal Heritage Sites of DPLH for the archaeological investigations. Concurrently with the granting of the s16 Permit approval, Site ID was Registered as an Aboriginal heritage site pursuant to s5 of the Aboriginal Heritage Act 1972 (WA) (DPLH 2017d, 2017e, 2017f). Following the proposed archaeological investigations, Cliffs will submit an application to the Minister for Aboriginal Affairs for a Section 18 Consent under the Aboriginal Heritage Act 1972 (WA) to authorise the disturbance of Site ID 27027, with the DPLH to review and provide advice to the Minister for Aboriginal Affairs on the application. Submission of the s18 Consent application, including its subsequent assessment by DPLH, will represent further consultation between Cliffs and DPLH on the Project. As an outcome of the assessment and approvals processes under the Aboriginal Heritage Act 1972 (WA), further consultation between Cliffs and DPLH during Project implementation is expected to continue through annual compliance reporting and site inspections. ENVIRONMENTAL PROTECTION AUTHORITY Whilst the Project does not require statutory approval from the Environmental Protection Authority (EPA), Cliffs has consulted EPA (through the EPA Services unit of DWER (formerly known as the Office of the Environmental Protection Authority)) on the Project in relation to the environmental assessment processes under the Environmental Protection Act 1986 (WA) and in relation to the effect to the recorded environmental values. In May 2017, representatives for Cliffs (S Hawkins) requested a meeting through representatives for EPA (F Browne, C Pengelly, M Jefferies) to discuss the Project. This request was accompanied by information on the Project including identification of the conceptual infrastructure components and location, potential environmental effects, mine closure, and proposed assessment processes. In July 2017, representatives for EPA (M Jefferies) advised that it had considered the potential effects of the Project, and advised its view on the assessment pathway and processes of the EPA under the Environmental Protection Act 1986 (WA). Cliffs subsequently advised EPA that assessment and approval of the Project under the Environmental Protection Act 1986 (WA) would be sought through a Clearing Permit application and assessment process under s51e through DMIRS, such that an assessment process through EPA through other provisions of the Environmental Protection Act 1986 (WA) would not be necessary. 41

42 Consultation between Cliffs and EPA during Project implementation is not expected to occur in a formal capacity (due to the absence of any statutory approval regulated by EPA for the Project), however, it is noted that consultation between Cliffs and EPA will continue to occur through the existing statutory approvals regulated by EPA under the Environmental Protection Act 1986 (WA) for other components of Cliffs Yilgarn Operations. DEPARTMENT OF BIODIVERSITY, CONSERVATION AND ATTRACTIONS Whilst the Project does not require statutory approval from DBCA, Cliffs has consulted DBCA on the Project in relation to its general interest in the conservation of flora and fauna values. In June 2017, correspondence with representatives for DBCA (S Thomas, M Baker, D Pickles) and Cliffs (V Roberts, N Smith, S Hawkins) included identification of the location of the Project and its conceptual infrastructure components, potential environmental effects, mine closure, and proposed assessments under the Mining Act 1978 (WA) and the Environmental Protection Act 1986 (WA). During this consultation DBCA did not identify any significant environmental concerns in relation to the Project. Further consultation between Cliffs and DBCA during Project implementation is expected to occur through the established communication arrangements associated with Cliffs Yilgarn Operations. SHIRE OF MENZIES Whilst the Project does not require statutory approval from the Shire of Menzies, Cliffs has consulted the Shire of Menzies on the Project in relation to its general interest in activities occurring within the Shire boundaries. In July 2017, a telephone discussion and correspondence with representatives for the Shire of Menzies (D Hadden) and Cliffs (S Hawkins) included identification of the location of the Project and its conceptual infrastructure components, and of Cliffs proposed schedule for mine development. Also discussed was the location, infrastructure components and proposed mining schedule for the adjacent Deception Deposit mine operations, which includes a wastewater treatment plant which will require the approval of the Shire of Menzies under the Health Act 1911 (WA) (note that approval applies to the Deception Deposit mine operations only). During this consultation the Shire of Menzies did not identify any significant concern in relation to the Project. Consultation between Cliffs and the Shire of Menzies during Project implementation is not expected to occur in a formal capacity (due to the absence of any statutory approval regulated by the Shire of Menzies for the Project), however, it is noted that consultation between Cliffs and the Shire of Menzies will continue to occur through the approval for the Deception Deposit wastewater treatment plant regulated by the Shire of Menzies under the Health Act 1911 (WA), and for other similar approvals applying to other components of Cliffs Yilgarn Operations. DEPARTMENT OF THE ENVIRONMENT AND ENERGY Consultation has not been undertaken with DEE as the Project will not result in a significant effect to any matter of national environmental significance protected under the Environment Protection and Biodiversity Conservation Act 1999 (C th) (DEE 2017a, 2017b, 2017c, 2017d). Accordingly, consultation with DEE on the Project is not necessary. 42

43 COMMUNITY CONSULTATION COMMUNITY CONSULTATION GROUP Cliffs maintains a Community Consultation Group (CCG) to provide review and comment on the environmental aspects of its Yilgarn Operations. The CCG was established in 2004 and includes representatives of: (a) Shire of Yilgarn; (b) Wildflower Society of Western Australia; (c) Yilgarn Land Conservation District Committee; (d) Windarling Preservation Group; (e) Toodyay Naturalists Club; (f) Pastoral representatives; and (g) Community representatives. The membership of the CCG was previously determined by the WA Minister for Environment based on submissions of interest from environmental and community stakeholders. Accordingly, the CCG represents the key community stakeholders with an interest in Cliffs mine operations and its environmental effects. The potential for mine development at the Claw Deposit was raised with the CCG at its meeting in September 2016, however at that time no details of the mine infrastructure or its environmental effects were available. Noting the CCG meets annually in September each year and the timing of the Clearing Permit application, Cliffs has not since had the opportunity to discuss the Project with the CCG. Whilst noting the above, most of the environmental surveys outlined within this Supporting Information document (i.e. Biota 2011a, 2011b, 2011c; Rockwater 2011; SWC 2011; Western Botanical 2009a, 2012a, 2012b) were previously made available to the CCG for review during 2011/2012 as part of the approval and assessment processes for the adjacent Deception Deposit mine operations, and as such, the CCG have previously been made aware of the environmental values in the vicinity of the Project and surrounds. Cliffs proposes to present the Project at the next CCG meeting scheduled for September Consultation between Cliffs and the CCG is expected to continue during Project implementation through the annual meetings of the CCG. GENERAL COMMUNITY As Cliffs key community stakeholders are represented on the CCG, and noting the confined spatial extent of the Project, extensive general community consultation on the Project (e.g. public meetings) is not necessary. DMIRS (2016) Guidance: Standard information recommended for the assessment of the application includes: o A statement against each of the 10 clearing principles. An assessment of the clearing of native vegetation within the Application Area using the Principles for Clearing Native Vegetation from Schedule 5 of the Environmental Protection Act 1986 (WA) is outlined above. 43

44 2 Study Team Development of this document has involved a range of supporting consultants. consultants and their contributions are acknowledged and appreciated by Cliffs. The key Globe Environments Australia Pty Ltd o Project Management o Environmental Assessment Biota Environmental Sciences o Flora and Vegetation Survey o Vertebrate Fauna Survey o Invertebrate Fauna Survey Rockwater Pty Ltd o Groundwater Assessment Soil Water Consultants o Soil Characterisation Western Botanical o Flora and Vegetation Survey 44

45 CAD Resources o Mapping and GIS Services 45