Spring Gully North-West and North-East Project Preliminary Documentation. Appendix 2: Cross Reference with Request for Information

Transcription

1 Spring Gully North-West and North-East Project Appendix 2: Cross Reference with Request for Information

2 Spring Gully North-West and North-East Project Table 1 provides a cross reference of the request for information issued by the Department to sections of this and associated appendices. Table 1: Cross Reference to the Request for Information General The preliminary documentation must include a list of persons and agencies consulted and the names of, and work done by, the persons involved in preparing the documentation. Appendix 5 1 Impact Assessment Listed threatened species and communities The Department considers that the project is likely to impact on: White-throated Snapping Turtle (Elseya albagula) critically endangered Koala (Phascolarctos cinereus) (combined populations of Queensland, NSW and the ACT) vulnerable Greater Glider (Petauroides volans) vulnerable Squatter Pigeon (Geophaps scripta scripta) vulnerable Brigalow (Acacia harpophylla dominant and co-dominant) endangered Northern Quoll (Dasyurus hallucatus) endangered Bertya opponens (a shrub) vulnerable Large-eared Pied Bat (Chalinolobus dwyeri) vulnerable Yakka Skink (Egernia rugosa) vulnerable Dunmall s Snake (Furina dunmalli) vulnerable South-eastern Long-eared Bat (Nyctophilus corbeni) vulnerable Collared Delma (Delma torquata) vulnerable White-throated Snapping Turtle survey of the White-throated Snapping Turtle in Eurombah Creek within and adjacent to the project site, to be undertaken by a suitably qualified expert and with reference to current best practice survey approaches; detailed mapping of the known and potential suitable habitat for the White-throated Snapping Turtle within and adjacent to the project site; a habitat assessment, including but not limited to the area (in hectares), quality, location and use specifications, of known and potential suitable habitat for the species in Eurombah Creek in relation to the project disturbance area, both within and downstream of the project site; assessment of the likely direct and indirect impacts on the Whitethroated Snapping Turtle, and its habitat, as a result of changes to surface water hydrology, surface and groundwater interactions and water quality from the release of treated coal seam gas (CSG) water into Eurombah Creek; and an analysis of the likely impacts on the White-throated Snapping Turtle, and its habitat, in a regional context Section 5.1 in the and Appendix 1

3 Spring Gully North-West and North-East Project All other listed threatened species and ecological community a discussion of the survey effort undertaken to determine the presence/absence of the above species and ecological community, including reference to relevant Departmental survey guidelines and current best practice approaches ; the methodology used to identify habitat for the above species and ecological community, when planning and determining the likely placement of all infrastructure associated with the project; the methodology used to determine the area (in hectares) likely to be impacted by vegetation clearance for the above species and ecological community; detailed mapping of known and potential habitat within the project site; a habitat assessment of the quality and likely use of known and potential suitable habitat for the above species and ecological community in relation to the project s disturbance area; and an analysis of the likely impacts on the above listed species and ecological community, and their habitat, in a regional context. The impacts, including direct, indirect and consequential, to the all of the above listed threatened species and communities and their habitat must be assessed in accordance with relevant Departmental policies and guidelines. Section 5.2 and Section 5.3 in the and Appendix 1 2 Impact Assessment Water Resources Groundwater and groundwater dependent ecosystems (GDEs) In order to undertake a robust assessment of the project s impacts on groundwater and GDEs, please provide: an assessment of the likely impacts of the proposed action on groundwater resources, including from groundwater drawdown and reinjection of treated CSG water; an assessment of the likely impacts of the proposed action on GDEs within the project site, including from groundwater drawdown and inundation from proposed aquifer reinjection of treated CSG water into the Precipice Formation; details of the mitigation and monitoring measures that will be implemented to ensure that the impacts of the proposed action on GDEs are appropriately managed; details of thresholds or triggers for the implementation of management responses; and an assessment of the expected or predicted effectiveness of the mitigation measures. The impacts, including direct, indirect and consequential, to GDEs must be assessed in accordance with relevant Departmental policies and guidelines. Section 6 in the

4 Spring Gully North-West and North-East Project Groundwater contamination from drilling chemicals In order to undertake a robust assessment of the impacts of drilling chemicals on water resources and matters of national environmental significance, please provide: a chemical risk assessment of the chemicals to be used in coal seam gas extraction in accordance with best practice national or international standards and guidelines including, but not limited to: Section in the and Appendix 17 - US EPA (2014). EPA-Expo-Box (A Toolbox for Exposure Assessors), available at: - OECD (2014). The OECD Environmental Risk Assessment Toolkit: Tools for Environmental Risk Assessment and Management, available at: toolkit.htm. a complete list of chemicals to be used in coal seam gas extraction for the project, which must include: - chemical name; - CAS registry number; - likely quantities; - concentrations; and - the chemical s general purpose and function. consideration of the chemical life-cycle under specific site conditions both at both the surface and subsurface; mitigation and management measures to reduce the risk to matters of national environmental significance to a low level for each listed chemical; a monitoring and reporting framework to assess the efficacy of the proposed mitigation and management measures; a schedule for the regular review of the listed chemicals, including the inclusion of new chemicals; and a peer review by a suitably qualified chemical risk assessment expert/s, including a statement that they carried out the peer review of the findings of the chemical risk assessment and evaluated the adequacy of the proposed monitoring, mitigation and management measures

5 Spring Gully North-West and North-East Project Surface water impacts The Department notes that treated CSG water is proposed to be managed in accordance with the existing Spring Gully Water Management Plan and Queensland s CSG Water Management Strategy. However, the Department considers that the treated CSG water has the potential to impact on surface waters and therefore other users of those surface waters. Therefore, please provide: an assessment of the likely impacts of treated CSG water on surface waters as a result of proposed treated CSG water management measures; details of the mitigation and monitoring measures that will be implemented to ensure that impacts from CSG produced water on surface waters are appropriately managed; and a cumulative assessment of the expected or predicted effectiveness of the proposed mitigation and monitoring measures to manage treated CSG water in order to avoid the release of treated CSG water into Eurombah Creek. Aquifer reinjection In order to undertake a robust assessment of the impacts of the proposed reinjection of treated CSG water into the Precipice Sandstone on water resources, please provide: a detailed description of each step of the process to reinject treated CSG water into the Precipice Formation, from when the water is taken out of the Bandanna Coal Measures to when the treated water is reinjected into the Precipice Formation; an assessment of the likely impacts of the reinjection of treated CSG water; and an assessment of the expected or predicted effectiveness of the reinjection of treated water as a mitigation measure, including reference to scientific evidence to support this process as a best practice mitigation measure. Cumulative impacts The Department considers that the proposed action will likely contribute to cumulative groundwater impacts in the Bowen Basin and the Surat Basin, as the project area lies within the Surat Cumulative Management Area. The preliminary documentation should identify and address cumulative impacts, where potential project impacts are in addition to existing impacts of other activities (including known potential future expansions or developments by the proponent and other proponents in the region). This cumulative impact assessment should reference and consider the cumulative impact assessment of the Surat and southern Bowen Basin within the Queensland Government Office of Groundwater Impact Assessment s 2016 Underground Water Impact Report (2016 UWIR). Section 3 and Section 7 in the Section and Section 6 in the Section 6.10 in the

6 Spring Gully North-West and North-East Project Referral to the IESC The Department is required to submit the project to the Independent Expert Scientific Committee on Coal Seam Gas and Large Coal Mining Development (IESC). The Information Guidelines for the IESC advice on coal seam gas and large coal mining development proposals (Guidelines) outlining the requirements for submission to the IESC can be found at: committee-advice-coal-seam-gas. The proponent must complete the checklist in the Guidelines to ensure that the information requirements for the IESC review have been addressed. The IESC will provide comment on the groundwater modelling presented in the preliminary documentation. The proponent must include the IESC advice and a response to the IESC advice in the preliminary documentation prior to submitting the preliminary documentation to the Minister for approval to publish the preliminary documentation for public comment. Appendix 6 3 Avoidance, Safeguards and Mitigation Measures The preliminary documentation must include a consolidated list of mitigation measures proposed to be undertaken by the proponent to avoid, minimise and manage relevant impacts of the action for each controlling provision, including: specific and detailed descriptions of measures proposed to be undertaken to avoid and mitigate the relevant impacts of the proposed action, based on best available practices and scientific evidence to support proposed mitigation measures; assessment of the expected or predicted effectiveness of the proposed mitigation measures; any statutory or policy basis for the proposed mitigation measures, including reference to approved conservation advices relevant to the listed threatened species and communities, and discussion on how the proposed mitigation measures are not inconsistent with recovery plans and threat abatement plans relevant to the listed threatened species and communities; any mitigation measures proposed to be undertaken by State and local governments; and the name of the agency responsible for endorsing or approving each mitigation measure or monitoring program. The preliminary documentation must include a draft Environmental Management Plan (EMP) that sets out the framework for management, mitigation and monitoring of relevant impacts of the action, including any provisions for independent environmental auditing. The EMP needs to address the project phases (construction, operation and decommissioning) separately. It must state the environmental objectives, performance criteria, monitoring, reporting, corrective action, responsibility and timing for each environmental issue. The EMP must be prepared in accordance with the Department s Environmental Management Plan Guidelines (2014), available at managementplan-guidelines. The Project will be managed under existing documentation currently in use for the Spring Gully CSG Project as detailed in Section 8 in the. 4 Environmental Offsets

7 Spring Gully North-West and North-East Project The preliminary documentation must include an assessment of the likelihood of residual significant impacts occurring, after mitigation and management measures relating to the project have been applied. Please provide: details of an offset package proposed to be implemented to compensate for residual significant impacts of the project; and an analysis of how the Offset meets the requirements of the Department s EPBC Act Environmental Offsets Policy (2012) (EPBC Act Offset Policy), available at: Offsets required by the State/Territory can be applied if the offset/s meet the Department s EPBC Act Offset Policy Section 9 in the and Appendix 18 5 Environmental Outcomes The preliminary documentation should provide information on the outcomes that the proponent will achieve for matters of national environmental significance (MNES). Outcomes need to be specific, measurable and achievable, and must be based on robust baseline data. To allow application of outcomes-based conditions, the preliminary documentation should include: Consideration of the draft Outcomes-based Conditions Policy 2015 and Outcomes-based Conditions Guidance 2015, with suitable justification for considerations identified in the policy and guidance. The specific environmental outcomes to be achieved, and reasoning for these in reference to relevant Recovery Plans, Conservation Advices and Threat Abatement Plans. For each proposed outcome, please provide: Section 10 in the - the risks associated with achieving the outcome; - the measurability of the outcome, including all suitable performance measures; - appropriate baseline data upon which the outcome has been defined and justified; - the likely impacts that the proposed outcome will address; - demonstrated willingness and capability of achieving the outcome; - commitments to independent and periodic audits of performance towards achieving outcomes; and - details of proposed management to achieve the outcome including, but not limited to, performance indicators, periodic milestones, proposed monitoring and adaptive management, and record keeping, publication and reporting processes 6 Environmental Record of Person(s) Proposing to take the Action

8 Spring Gully North-West and North-East Project The preliminary documentation must include details of any proceedings under a Commonwealth, State or Territory law for the protection of the environment or the conservation and sustainable use of natural resources against: the person proposing to take the action; and for an action for which a person has applied for a permit, the person making the application. If the person proposing to take the action is a corporation, details of the corporation s environmental policy and planning framework must also be included. Section 1.2 in the 7 Social and Economic Matters The proponent must provide a discussion and analysis of the social and economic impacts of the proposed action, both positive and negative, in the preliminary documentation. Economic and social impacts should be considered at the local, regional and national levels. Matters of interest may include: details of any public consultation activities undertaken, and their outcomes; details of any consultation with Indigenous stakeholders; projected economic costs and benefits of the project, including the basis for their estimation through cost/benefit analysis or similar studies; and employment opportunities expected to be generated by the project (including construction and operational phases) Section 4 in the 8 Conclusion An overall conclusion as to the environmental acceptability of the proposed action should be provided, including discussion on compliance with principles of ESD and the objects and requirements of the EPBC Act. Reasons justifying undertaking the proposal in the manner proposed should also be outlined. Measures proposed or required by way of offset for any unavoidable impacts on MNES, and the relative degree of compensation, should be restated here Section 11 in the