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Yilgarn Operations

Claw Deposit

Environmental Protection Act 1986 (WA)

Clearing Permit (Area Permit)

Supporting Information

August 2017

Document Status

Revision Author Distribution Date Status

0 S Hawkins DMIRS 10.08.2017 Public Release

Citation

This report should be cited as:

Cliffs Asia Pacific Iron Ore Pty Ltd (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 Cliffs Asia Pacific Iron Ore Pty Ltd. Revision 0. August 2017.

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: 0400 455 554

Email: [email protected]

Website: www.GlobeEnvironments.com.au

Yilgarn Operations Cliffs Asia Pacific Iron Ore Pty Ltd Claw Deposit Clearing Permit Supporting Information August 2017 (Revision 0)

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Executive Summary

Cliffs Asia Pacific Iron Ore Pty Ltd (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 Q1 2018 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).


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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.


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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.


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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.


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.


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.


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).


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As Cliffs is the tenement holder of Mining Lease M77/1259-I, a separate letter from the tenement

holder is not necessary.


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).


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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.


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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.


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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.


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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.


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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).


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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).


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Figure 5b Vegetation Units. A description of each mapped vegetation unit is provided. Data source:

Biota (2011a).


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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).


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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 Q1 2018 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 Mine Pit (46ha); and

o 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.


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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.


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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 1986. 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 Cliffs Asia Pacific Iron Ore Pty Ltd. Revision 11.

June 2011.

(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


March 2011.

(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 Cliffs Asia Pacific Iron Ore Pty Ltd.

Revision 7. March 2011.

(4) Cliffs Asia Pacific Iron Ore Pty Ltd (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 2013.

(5) Western Botanical (2009a) Flora and Vegetation Survey of a Polygon at Deception

Prospect for Future Drilling Programs, May 2009. Report prepared by Burgess S of

Western Botanical for Cliffs Asia Pacific Iron Ore Pty Ltd. September 2009.

(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 2012.


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(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


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


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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.


(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,


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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’.



(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


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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’.



(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).



(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.



(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.



(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).


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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.



(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.



(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.




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.


24


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


June 2011.

(2) Cliffs Asia Pacific Iron Ore Pty Ltd (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 2013.

(3) Western Botanical (2009a) Flora and Vegetation Survey of a Polygon at Deception

Prospect for Future Drilling Programs, May 2009. Report prepared by Burgess S of

Western Botanical for Cliffs Asia Pacific Iron Ore Pty Ltd. September 2009.

(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 2012.

(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



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).


o DBCA-classified ‘priority’ flora taxon Banksia arborea (P4); and

o Vegetation units.


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.


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


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


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.


28

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).

VEGETATION UNIT MAPPED

EXTENT

(ha)

APPLICATION

AREA

(ha)

OTHER REGIONAL

RECORDS

1.01 Acacia cockertoniana, A. ramulosa var. ramulosa tall shrubland over Philotheca brucei

subsp. brucei, Eremophila clarkei, Dodonaea rigida open shrubland

92 20 Windarling Range

1.02 Acacia "aneura", A. ramulosa var. ramulosa tall shrubland 418 21 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

<1 <1 Windarling Range

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

<1 <1 Windarling, Mt Jackson,

Koolyanobbing,

Die Hardy, Helena &

Aurora and Mt Manning

- Cleared land - 4

Total 110(1)


29


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


March 2011.

(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 Cliffs Asia Pacific Iron Ore Pty Ltd.

Revision 7. March 2011.



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 DBCA-classified ‘priority’ fauna taxon Aganippe castellum (P4); and

o Potential short-range endemic invertebrate fauna taxa; and

o 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 medium-

sized 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


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



31

Aganippe castellum (P4)

Application Area 2 (up to ~9,000 est.)

Approved Mine Operations >12,000 (est.)

Regional Distribution >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


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


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. 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.


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).


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.


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.


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.


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.


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.


35

(3) Watercourses

No watercourses occur within the Application Area.



Accordingly, no effect to watercourses is expected from the clearing of native


(4) Surface Water

No surface water occurs within 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


(5) Groundwater


Area (Rockwater 2011).

Accordingly, no effect to groundwater is expected from the clearing of native



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.


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.


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


(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


(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.


37

Accordingly, no effect from salinisation is expected from the clearing of native


(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



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) Cliffs Asia Pacific Iron Ore Pty Ltd (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 2016.

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:


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 post-

mining, 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).


39


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


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 GWL154459 (DWER 2014) and Licence

CAW183476 (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 GWL154459 or Licence CAW183476 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

GWL154459 and Licence CAW183476.

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 GWL154459 and Licence CAW183476 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


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 27027 ‘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 27027 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 27027 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 27027 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.


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, email 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 email 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.


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 2017.

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.


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.


44

2 Study Team

Development of this document has involved a range of supporting consultants. The key

consultants and their contributions are acknowledged and appreciated by Cliffs.

Globe Environments Australia Pty Ltd

www.GlobeEnvironments.com.au

o Project Management

o Environmental Assessment

Biota Environmental Sciences

www.Biota.net.au

o Flora and Vegetation Survey

o Vertebrate Fauna Survey

o Invertebrate Fauna Survey

Rockwater Pty Ltd

www.Rockwater.com.au

o Groundwater Assessment

Soil Water Consultants

www.SoilWaterGroup.com.au

o Soil Characterisation

Western Botanical

www.WesternBotanical.com.au

o Flora and Vegetation Survey


45

CAD Resources

www.CADResources.com.au

o Mapping and GIS Services


46

3 References

All references cited within this document are identified below. Where an organisational name

has changed since the original date of publication, the new organisational name has been used

and the former organisational name noted.

Subject to the provisions of the Copyright Act 1968 (C’th), a copy of each reference to which

Cliffs has authority to reproduce is provided on the compact disc appended to this document.

Western Australian legislation cited can be obtained from the State Law Publisher at

http://www.slp.wa.gov.au. Commonwealth legislation and International Treaties cited can be

obtained from the Australian Legal Information Institute at http://www.austlii.edu.au.

Australian Weeds Committee (2012) Weeds of National Significance 2012. Commonwealth

Department of Agriculture, Fisheries and Forestry.

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 Cliffs Asia Pacific Iron Ore Pty Ltd. Revision 11. June 2011.

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 Cliffs Asia Pacific Iron Ore Pty Ltd. Revision 13. March 2011.

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


March 2011.

Bureau of Meteorology (2017). Climate Statistics for Australia Locations: Southern Cross Airfield.

Data for years 1996 to 2017. Accessed March 2017 from the Australian Bureau of

Meteorology website at

http://www.bom.gov.au/climate/averages/tables/cw_012320.shtml.

Cliffs Asia Pacific Iron Ore Pty Ltd (2010a) Form to nominate a Western Australian species for listing

as threatened, change of category or delisting 2010. Submission by Cliffs Asia Pacific Iron

Ore Pty Ltd to the Department of Biodiversity, Conservation and Attractions (formerly as

the Department of Environment and Conservation) for removal of Tree-stem Trapdoor

Spider Aganippe castellum from listing as Specially Protected Fauna under the Wildlife

Conservation Act 1950 (WA). January 2010.

Cliffs Asia Pacific Iron Ore Pty Ltd (2010b) Koolyanobbing Iron Ore Project – Mt Jackson J1 Deposit:

Application to Take Fauna under the Wildlife Conservation Regulations 1970 (WA).

Application by Cliffs Asia Pacific Iron Ore Pty Ltd to the Department of Biodiversity,

Conservation and Attractions (formerly as the Department of Environment and

Conservation) for approval to take individuals of Tree-stem Trapdoor Spider Aganippe

castellum at the Mt Jackson J1 Deposit. May 2010.


47

Cliffs Asia Pacific Iron Ore Pty Ltd (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 2013.

Cliffs Asia Pacific Iron Ore Pty Ltd (2015) Yilgarn Operations - Mine Closure Plan. Report prepared

by Harry N of Cliffs Asia Pacific Iron Ore Pty Ltd. Revision 0. April 2015.

Cliffs Asia Pacific Iron Ore Pty Ltd (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 2016.

Cliffs Asia Pacific Iron Ore Pty Ltd (2017a) Application for a Clearing Permit (Area Permit).

Clearing Permit Application for mine development of the Claw Deposit within Mining

Lease M77/1259-I in the Shire of Menzies. August 2017.

Cliffs Asia Pacific Iron Ore Pty Ltd (2017b) Credit Card Payment for Clearing Permit Applications.

Credit card payment form for the Clearing Permit Application for mine development of

the Claw Deposit within Mining Lease M77/1259-I in the Shire of Menzies. August 2017.

Cliffs Asia Pacific Iron Ore Pty Ltd (2017c) Yilgarn Operations - Claw Deposit - Mining Act 1978

(WA) Mining Proposal - Addendum to Notice of Intent 37155 – Mining Lease M77/1259-I.

Report prepared by Hawkins S of Globe Environments Australia Pty Ltd for Cliffs Asia Pacific

Iron Ore Pty Ltd. In prep. August 2017.

Cliffs Asia Pacific Iron Ore Pty Ltd (2017d) Annual Environmental Report. Annual Environmental

Report prepared by Harry N of Cliffs Asia Pacific Iron Ore Pty Ltd for the Department of

Mines Industry Regulation and Safety (formerly as the Department of Mines and

Petroleum) for the Deception Deposit Mine Operations. Report for period April 2016 to

March 2017. DMIRS Reference ID AER-841-16854. March 2017.

Cliffs Asia Pacific Iron Ore Pty Ltd (2017e) Annual Environmental Report. Annual Environmental

Report prepared by Harry N of Cliffs Asia Pacific Iron Ore Pty Ltd for the Department of

Mines Industry Regulation and Safety (formerly as the Department of Mines and

Petroleum) for the Yilgarn Operations. Report for period April 2016 to March 2017. DMIRS

Reference ID AER-922-16858. March 2017.

Cliffs Natural Resources Incorporated (2017) Environmental Policy. July 2017.

Department of Biodiversity, Conservation and Attractions (2013) Results of TEC/PEC Search -

Jackson (CAD) (Our Ref: 19-01113EC). Email of Priority Ecological Community Data

supplied by the Department of Biodiversity Conservation and Attractions (formerly as the

Department of Parks and Wildlife) to CAD Resources on behalf of Cliffs Asia Pacific Iron

Ore Pty Ltd. November 2013.

Department of Biodiversity, Conservation and Attractions (2017a) FloraBase. Available at

www.FloraBase.dpaw.wa.gov.au. Accessed May 2017.

Department of Biodiversity, Conservation and Attractions (2017b) NatureMap. Available at

www.NatureMap.dpaw.wa.gov.au. Accessed July 2017.


48

Department of Biodiversity, Conservation and Attractions (2017c) No title. List of Specially

Protected Fauna and Priority Fauna. Accessed March 2017 from the Department of

Biodiversity Conservation and Attractions (formerly as the Department of Parks and

Wildlife) website at https://www.dpaw.wa.gov.au/plants-and-animals/threatened-

species-and-communities/threatened-animals. Website Excel file dated February 2017.

Department of Biodiversity, Conservation and Attractions (2017d) NatureMap: Banksia arborea.

Accessed May 2017 from the Department of Biodiversity Conservation and Attractions

(formerly as the Department of Parks and Wildlife) NatureMap website at

www.NatureMap.dpaw.wa.gov.au.

Department of Biodiversity, Conservation and Attractions (2017e) NatureMap: Aganippe

castellum. Accessed May 2017 from the Department of Biodiversity Conservation and

Attractions (formerly as the Department of Parks and Wildlife) NatureMap website at

www.NatureMap.dpaw.wa.gov.au.

Department of Mines, Industry Regulation and Safety (2016) Information Required to Assess Your

Clearing Permit Application. Guidance material. Accessed May 2016 from the

Department of Mines, Industry Regulation and Safety (formerly as the Department of

Mines and Petroleum) website at http://www.dmp.wa.gov.au/Environment/Information-

required-to-assess-4944.aspx.

Department of Planning, Lands and Heritage (2017a) Aboriginal Heritage Inquiry System

Aboriginal Sites Database: Registered Aboriginal Sites in Mining Tenement M77/1259.

Accessed from the Department of Planning, Lands and Heritage (formerly as the

Department of Aboriginal Affairs) website at http://maps.dia.wa.gov.au/AHIS2/.

March 2017.

Department of Planning, Lands and Heritage (2017b) Aboriginal Heritage Inquiry System

Aboriginal Sites Database: Other Heritage Places Registered Aboriginal Sites in Mining

Tenement M77/1259. Accessed from the Department of Planning, Lands and Heritage

(formerly as the Department of Aboriginal Affairs) website at

http://maps.dia.wa.gov.au/AHIS2/. March 2017.

Department of Planning, Lands and Heritage (2017c) Aboriginal Heritage Inquiry System

Aboriginal Sites Database: Other Heritage Place ID 27027. Accessed from the

Department of Planning, Lands and Heritage (formerly as the Department of Aboriginal

Affairs) website at http://maps.dia.wa.gov.au/AHIS2/. March 2017.

Department of Planning, Lands and Heritage (2017d) Aboriginal Heritage Inquiry System

Aboriginal Sites Database: Registered Aboriginal Sites in Mining Tenement M77/1259.

Accessed from the Department of Planning, Lands and Heritage website at

http://maps.dia.wa.gov.au/AHIS2/. August 2017.

Department of Planning, Lands and Heritage (2017e) Aboriginal Heritage Inquiry System

Aboriginal Sites Database: Other Heritage Places Registered Aboriginal Sites in Mining

Tenement M77/1259. Accessed from the Department of Planning, Lands and Heritage

website at http://maps.dia.wa.gov.au/AHIS2/. August 2017.

Department of Planning, Lands and Heritage (2017f) Aboriginal Heritage Inquiry System Aboriginal

Sites Database: Registered Site ID 27027. Accessed from the Department of Planning,

Lands and Heritage website at http://maps.dia.wa.gov.au/AHIS2/. August 2017.


49

Department of the Environment and Energy (2017a) EPBC Act List of Threatened Flora. Accessed

March 2017 from the Department of the Environment Department of the Environment and

Energy (formerly as the Department of the Environment) website at

http://www.environment.gov.au/cgi-

bin/sprat/public/publicthreatenedlist.pl?wanted=flora.

Department of the Environment and Energy (2017b) EPBC Act List of Threatened Ecological

Communities. Accessed March 2017 from the Department of the Environment

Department of the Environment and Energy (formerly as the Department of the

Environment) website at http://www.environment.gov.au/cgi-

bin/sprat/public/publiclookupcommunities.pl.

Department of the Environment and Energy (2017c) EPBC Act List of Threatened Fauna.

Accessed March 2017 from the Department of the Environment Department of the

Environment and Energy (formerly as the Department of the Environment) website at

www.environment.gov.au/cgi-bin/sprat/public/publicthreatenedlist.pl?wanted=fauna.

Department of the Environment and Energy (2017d) Australia’s National Heritage List. Accessed

March 2017 from the Department of the Environment Department of the Environment and

Energy (formerly as the Department of the Environment) website at:

http://www.environment.gov.au/heritage/places/national/index.html.

Department of Water and Environmental Regulation (2014) Licence to Take Water. Licence

GWL154459 under s5C of the Rights in Water and Irrigation Act 1914 (WA) granted to Cliffs

Asia Pacific Iron Ore Pty Ltd by the Department of Water and Environmental Regulation

(formerly as the Department of Water). August 2014.

Department of Water and Environmental Regulation (2016) Licence to Construct or Alter Well.

Licence CAW183476 under s26D of the Rights in Water and Irrigation Act 1914 (WA)

granted to Cliffs Asia Pacific Iron Ore Pty Ltd by the Department of Water and

Environmental Regulation (formerly as the Department of Water). November 2016.

Dieback Working Group (2008) Managing Phytophthora Dieback in Bushland: A Guide for

Landholders and Community Conservation Groups. Edition 4. 2008.

Rockwater Pty Ltd (2011) Deception Iron Ore Deposit - Assessment of Dewatering and Final Void

Water Level. Report prepared by de Broekert P (Dr) of Rockwater Pty Ltd for Cliffs Asia

Pacific Iron Ore Pty Ltd. April 2011.

Russell M G (2008) Abundance, Distribution and Habitat Requirements of the Tree-Stem Trapdoor

spider, Aganippe castellum (Arachnida: Idiopidae) in the eastern West Australian

Wheatbelt. Masters Thesis. Edith Cowan University, Western Australia.

SGS Systems and Services Certification Pty Ltd (2015) System Certification Cliffs Asia Pacific Iron

Ore Limited. ISO 14001:2004 Environmental Management System Certification granted by

SGS Systems and Services Certification Pty Ltd to Cliffs Asia Pacific Iron Ore Pty Ltd for the

Koolyanobbing Range, Windarling Range and Mt Jackson Range mine operations.

October 2015.

Soil Water Consultants (2011) Deception Deposit Pre-Mine Soil Characterisation. Report prepared

by Collins S of Soil Water Consultants (Soil Water Resources Pty Ltd) for Cliffs Asia Pacific

Iron Ore Pty Ltd. Revision C. July 2011.


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Western Australian Minister for Environment (2017a) Wildlife Conservation (Rare Flora) Notice 2016.

In: Western Australian Government Gazette. No. 4. January 2017.

Western Australian Minister for Environment (2017b) Wildlife Conservation (Specially Protected

Fauna) Notice 2016. In: Western Australian Government Gazette. No. 4. January 2017.

Western Botanical (2009a) Flora and Vegetation Survey of a Polygon at Deception Prospect for

Future Drilling Programs, May 2009. Report prepared by Burgess S of Western Botanical for

Cliffs Asia Pacific Iron Ore Pty Ltd. September 2009.

Western Botanical (2009b) Flora and Vegetation of the Western Jackson Range (Mt Jackson

Range), Western Australia. Report prepared by McNee S A and Cockerton G T B of

Western Botanical for Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore Ltd).

April 2009.

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 2012.

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.

Western Botanical (2012c) Flora and Vegetation of the Windarling Range. Report prepared by

Eckermann B of Western Botanical for Cliffs Asia Pacific Iron Ore Pty Ltd. December 2012.

Woodman Environmental Consulting Pty Ltd (2014) Southern Koolyanobbing Range Flora and

Vegetation Assessment. Report prepared by Coultas D of Woodman Environmental

Consulting Pty Ltd for Cliffs Asia Pacific Iron Ore Pty Ltd. Revision 0. February 2014.


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Attach CD of

References and Spatial Data


52

Attachments Attachment 1 Environmental Policy

(Cliffs Natural Resources 2017)

Attachment 2 AS/NZS ISO 14001:2004 Environmental Management System Certification

(SGS 2015)

Attachment 3 Flora and Vegetation Management Plan

(Cliffs 2016)

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