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The Black Throated Recovery Team. PO Box 1168. Aitkenvale. QLD 4814. email: [email protected]

Hon Josh Frydenberg MP

Minister for the Environment and Energy

Parliament House

Canberra ACT 2600

[email protected]

Hon Dr Steven Miles

Minister for Environment and Heritage Protection

GPO Box 2454

Brisbane QLD 4001

[email protected]

14 July 2017

The Black-throated Finch Recovery Team response to the Carmichael Mine

Biodiversity Offset Strategy and Black-throated Finch Management Plan

The Black-throated Finch Recovery Team (BTFRT) recently obtained copies of the

Biodiversity Offset Strategy (BOS, CO2 Australia 2016) and the Black-throated Finch (BTF)

Management Plan (Species Management Plan, SMP; Eco Logical Australia 2017) prepared

for Adani Mining Pty Ltd. We understand that while the BOS has already been approved, the

relevant administering authority has the power to amend or revoke environmental approval

including the conditions of approval. Having reviewed both documents, we have multiple

concerns about the significant impacts of the proposed mining operations on the persistence

of the important population of BTF in the Desert Uplands and Brigalow Belt North

bioregions, how effectively the SMP addresses those potential impacts, and how effectively

the proposed offset strategy will counteract the planned large-scale removal of BTF habitat.

In context, the major threat to BTF is habitat loss, and habitat loss associated with this mine

will lead to ongoing decline of BTF. We provide a synthesis of our concerns (below) and

detailed comments on specific points mentioned in both documents (Appendices A & B). We

challenge the assumptions underpinning the BTF offset calculations in the BOS and

demonstrate that they are fundamentally flawed. We provide corrected offset calculations in

Appendix C.

The BTFRT recommend that conditions be varied to state that development not

proceed until offset areas are established and proven to be supporting BTF, as

evidenced by increased BTF occurrence and abundance in the offset areas. Any other

course of action will have a detrimental and irreversible impact on BTF. We also

recommend that the offset approvals be revoked until such time that an amended BOS

is developed and action can be taken to increase the percent of impact that is offset.

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The conditions set out in the Environment Authority are inadequate to avoid

detrimental and irreversible impacts on BTF

A variation on Condition I1 of the Environmental Authority EPML01470513 needs to occur

so that the land-based offsets are established and proven to be successful before BTF habitat

is impacted. Condition I9 should be varied so that management actions to maintain the

current BTF population of Ten Mile Bore and surrounds are established before BTF habitat is

impacted.

The BOS does not meet all of the Coordinator-General’s conditions

The BOS does not meet the Coordinator-General’s condition 7 (a)(v): “Evidence values to be

impacted can be offset,”. There is no evidence that the critical BTF habitat can be offset. This

evidence should be established before loss of BTF habitat occurs. Adani intend to implement

a research program to test the effectiveness of management actions for the BTF. We

recommend that BTF habitat is not cleared until the results of that research program are

available and until there is clear evidence that the management actions benefit the BTF.

The BOS has failed to address the risks of the impact on BTF: offsets will result in net

loss of habitat

Based on the figures presented in the BOS, 6,093.38 ha of BTF habitat will be impacted, and

20,284.24 ha will be offset during stage 1. While Adani are proposing to implement

management actions to improve habitat quality, there is no new habitat being created.

Therefore, this 6,093.38 ha represents a net loss of BTF habitat. As noted in the BTF

Recovery Plan, loss of habitat is the major threatening process for BTF. Thus, this proposed

net loss of habitat runs counter to the conditions of approval which state that the BOS and the

BTF Management Plan must not be inconsistent with the BTF Recovery Plan. Further losses

of habitat, especially in a BTF stronghold, will lead to further decline of BTF.

Furthermore, the habitat on Moray Downs is the best known habitat for BTF, with the largest

populations ever recorded. It is likely that this population is a source population, feeding

other, less robust populations. Therefore, the loss of this habitat is likely to have severe

ramifications for the entire region (Pulliam 1988).

The habitat value of Moray Downs and surrounds is high in part because of its extent.

Fragmenting this will reduce the habitat value of all remaining habitat in the region (Saunders

et al. 1991, Fahrig 2001, Bartlett et al. 2016) (which was not considered in the offsets

calculator).

The only way to actually “offset” loss of BTF habitat is to create more or better habitat in its

place, and achieve this before any BTF habitat is lost. The proposed offset will not create

more habitat. In fact, BTF habitat has never been successfully created and there is no

evidence that this is possible. It is also highly doubtful that the proposed offset can be

Page 2




improved to the extent that it compensates for loss of habitat due to the mine. The only

guarantee is that there will be a large net loss of habitat, and a commensurate decline in BTF.

Therefore, the BOS has failed to address the risks of impact on BTF.

Offsets are situated in less than ideal habitat

Records from Moray Downs, including Moray Downs West, indicate a much greater

frequency of BTF in areas that will be subject to open cut or underground mining compared

with the proposed offset areas. Apart from the effect of any bias in the spatial distribution of

sampling effort, this indicates that habitat in the proposed offset areas is of an intrinsically

lower quality for BTF compared with that in the areas to be mined.

Offset areas are inadequate due to incorrect use of the offset calculator and over-stated

justifications

There are manifest errors in the use of the offset calculator in terms of the risk of loss both

with and without offsets. The offset calculator has been used in direct contradiction from the

way it was designed to be used, and this has resulted in a drastic under-reporting of the offset

area needed to offset the project impacts.

In critical offset habitat where BTF occur, the risk of loss with and without the offset is

neutralised because any future loss would trigger another offset requirement (Maseyk et al.

2017). Additionally, classifying core and marginal offset areas as nature refuges will not

reduce the risk of loss of proposed offset areas. Adani state that offset areas are most at risk

of loss from future mining projects; however, nature refuges do not necessarily provide

protection from mining activities. The risk of loss estimates used within the offset

calculator need immediate rectification.

We have used a transparent, evidence-based and expert-advised recalculation, which

resulted in 48,363 hectares needed for the offset, more than double what Adani

proposes.

There is no evidence that the removal or reduction of cattle, removal of feral pest animals or

any alteration of fire management will benefit BTF. Virtually all known remaining

populations of BTF are on land grazed by cattle. We agree that further work is needed to

determine the fire and grazing regimes that favour BTF in different situations. However,

there is no basis for the 90% confidence that the proposed management actions will improve

habitat for BTF within the specified timeframe. This over-inflated confidence has a direct

impact on the amount of land dedicated to BTF offsets.

While exotic weeds are known to be a threat to BTF, there is no evidence that their removal

would successfully result in habitat improvement for the BTF, such as through the

reestablishment of native grasses. Additionally, there is limited capacity to control buffel

grass (Cenchrus ciliaris) at any scale and no examples of effective control on large scales.

Page 3




While weed removal is recommended for improving habitat for BTF, we emphasise that there

is a very high uncertainty in how beneficial this will be and the timeframe until the species

benefits.

A 90% confidence in a developer’s ability to improve habitat would only be suitable in cases

where management actions have previously been demonstrated to have a positive impact on

the species and the management actions were very straight forward to implement. This is

clearly not the case for this project. While Adani have provided reasoning to justify their

estimates, the way they calculated the estimated confidence is not clear and their

justifications are not supported by peer-reviewed literature or expert consultation. Thus, the

current proposed offsets do not currently conform to the Environment Offsets Policy as

being “transparent, scientifically robust and reasonable” (Commonwealth of Australia

2012). Thus, we recommend that the offset approvals be revoked until such time that an

amended BOS is developed and action can be taken to increase the percent of impact

that is offset.

Rehabilitation of mined areas will not lessen the impact on the BTF

Rehabilitation of mined areas is fraught with difficulties for recreating BTF habitat. It is

likely to be a slow and labour-intensive process, with a low chance of success to create a

plant community that is suitable for BTF on a scale that could support a viable population.

Timing will further exacerbate losses of BTF

Commencement of management of offset areas for offset delivery stage 1 is scheduled for

October 2017; mining operations north of the Carmichael River commence late 2017.

Therefore, habitat loss, degradation and fragmentation will occur before any improvement of

habitat value can be accrued. This is highly likely to result in death of the BTF relying on the

impact sites, well before any increased carrying capacity could be achieved in the offset sites.

The IUCN recommends that offsets not be used “where the time lag between the residual loss

of biodiversity caused by the project and the gains from the offset causes damage that cannot

be remediated and/or puts biodiversity components at unacceptable risk” (IUCN 2016). As is,

the project clearly breaches these internationally-recognised recommendations.

BTF monitoring is to be undertaken during the dry season according to the BOS. The

management plan stipulates that biannual surveys (October and March-April) will be

undertaken to monitor BTF. However, biannual surveys are insufficient to record information

on BTF. Black-throated finches have different habitat requirements throughout the year

(Rechetelo 2015), so it is crucial that BTF are monitored throughout the different seasons

within and between years. Black-throated finch movements and activity are highly related to

rainfall, and rainfall is highly variable inter-annually. For example, October could be

extremely dry, or be a period of high water availability, resulting in substantial fluctuations in

detectability and activity of BTF, as seen from annual water hole counts in the Brigalow Belt

Bioregion. With very high variability, biannual surveys would have no statistical power to

Page 4




detect any change in BTF populations. The survey methodology needs to be designed so that

it has a high likelihood of detecting change, if change occurs. Therefore surveys should be

conducted at least every two months for 10 years.

The BTFRT have repeatedly called for more involvement in the development of the

BOS and SMP, and for greater engagement with Adani and the regulators

The BTFRT is dedicated to ensuring the continued persistence and recovery of the

Endangered BTF. The largest known concentration of remaining BTF individuals inhabits the

area within the mine footprint (BTFRT Database 2017). Thus, it is critical that the strongest

possible mitigation strategies are put into effect to ensure the species can continue to thrive in

the region and avoid further decline. The BTFRT have a combined expertise spanning

ecology, conservation, species-specific knowledge, plant ecology, policy knowledge and

local knowledge. We would welcome the opportunity to have a stronger involvement in the

consultation process for the plans and strategies relevant to the BTF and be included in the

ongoing management of the species within the region.

We understand that Adani must submit an Offset Area Management Plan (OAMP) within

three months of the BOS being approved. While Adani committed to the Coordinator-

General that they would consult with the BTFRT when reviewing the BTF habitat

management plans, we have not been consulted in the development of the OAMP and would

appreciate the opportunity to review and provide feedback on the OAMP before a decision is

made.

Tony Grice

Chairperson

Black-throated Finch Recovery Team

Page 5




References

Bartlett LJ, Newbold T, Purves DW, Tittensor DP, Harfoot MBJ (2016) Synergistic impacts

of habitat loss and fragmentation on model ecosystems. Proceedings of the Royal

Society B: Biological Sciences 283, 20161027.

CO2 Australia (2016) Biodiversity offset strategy: Carmichael coal mine and rail project.

Prepared for Adani Mining Pty Ltd.

Eco Logical Australia (2017) Black-throated Finch management plan: Carmichael coal mine

and offsite infrastructure. Prepared for Adani Mining Pty Ltd, 11 May 2017.

Fahrig L (2001) Relative effects of habitat loss and fragmentation on population extinction.

Journal of Wildlife Management 61, 603-610.

IUCN (2016) IUCN policy on biodiversity offsets. International Union for Conservation of

Nature, Gland, Switzerland. Available at https://www.iucn.org/theme/business-and-

biodiversity/our-work/business-approaches-and-tools/biodiversity-offsets.

Pulliam HR (1988) Sources, sinks, and population regulation. American Naturalist 132, 652-

661.

Rechetelo J (2015) Movement, habitat requirements, nesting and foraging site selection: a

case study of an endangered granivorous bird, the Black-throated finch Poephila

cincta cincta in north-eastern Australia. PhD Thesis, James Cook University.

Saunders DA, Hobbs RJ, Margules CR (1991) Biological consequences of ecosystem

fragmentation: a review. Conservation Biology 5, 18-32.

Page 6



The Black-Throated Finch Recovery Team. PO Box 1168. Aitkenvale. QLD 4814. email: [email protected]

Appendix A

Below are detailed comments and recommendations pertaining to specific sections of text within the SMP.

Page/section

number

Issue Comment Recommendation

Pages 16-17,

Table 3

As part of the annual reporting

program, all revisions to the

survey and monitoring program

must be carried out in consultation

with the BTFRT. This table says

this issue is discussed in Section 8

of the BTF Management Plan.

However, there is no discussion of

this in Section 8 or elsewhere in

the management plan.

Environmental Authority EPML01470513 for the

Carmichael Coal Mine issued by the Department of

Environment and Heritage Protection states that all

revisions to the BTF survey and monitoring

program must be carried out in consultation with

the BTFRT. To date, there has been only extremely

limited consultation with the BTFRT on the

Carmichael project (Adani have met briefly with

the BTFRT once in 2013 and once in 2015) and the

BTFRT have not been given an opportunity to

provide feedback on the survey and monitoring

program. The first (and only) time the BTFRT have

been privy to the details of the survey and

monitoring programs is through this SMP which we

obtained from the Public Register under s 540 of

the Environmental Protection Act 1994 (Qld), not

through Adani or its representatives. It is important

to note that the methods outlined on page 20-21 in

Section 1.7 make no mention of consultations with

the BTFRT. Similarly, there is no mention of

The SMP should explicitly outline

when the BTFRT will be consulted

and in what capacity. All requests

for consultation should be directed

to the BTFRT Secretary at

[email protected].

To help the BTFRT make informed

assessments and provide the most

effective advice on surveying and

monitoring, relevant reports and

data prepared by or for Adani

should be provided to the BTFRT

as they are prepared. Examples of

appropriate reports and data

include, but are not limited to:

Reports summarising survey

results, together with GPS

coordinates and BTF

abundances.

High resolution spatial data of




Page/section

number


consulting the BTFRT if monitoring and

management needs to be reviewed in response to

triggers (Page 70, Table 16). Given that the BTFRT

have had no input to date into the survey methods

or monitoring program and have received little

cooperation from Adani, we are concerned that the

SMP contains no discussion about the involvement

of the BTFRT in a consultative capacity when it

comes to reviewing and amending the survey and

monitoring program.

the project site, proposed

mining area, proposed offset

area, accompanying habitat

data, BTF sightings and nest

sightings.

Reports detailing knowledge

gained about the BTF based on

observations and research

within the project and offset

area, such as (but not limited

to) foraging ecology,

behaviour, habitat preferences,

movements, breeding, use of

water sources, responses to

grazing and fire regimes and

responses to habitat restoration

efforts.

Reports about the research

program.

Reports detailing trigger

events relevant to the BTF.

Revisions to the SMP.

Page 18, Table

4; Page 42,

The onsite and offset habitat

management and monitoring

Adani made a commitment to the Coordinator-

General (P6.56) that “the onsite and offsite (offset

The SMP should explicitly outline

when the BTFRT will be consulted




Page/section

number


Section 5 program will be developed and

implemented in consultation with

relevant stakeholders, including

the BTFRT. This table says this

issue is discussed in Section 5 of

the BTF Management Plan.

However, there is no discussion of

this in Section 5 or elsewhere in

the management plan.

areas) habitat management and complementary

monitoring program, as described above, will be

developed and implemented in consultation with

relevant stakeholders (i.e. Black-throated Finch

Recovery Team, Commonwealth and State

governments).” (State of Queensland 2014). To

date, there has been only extremely limited

consultation with the BTFRT on the Carmichael

project (Adani have met briefly with the BTFRT

once in 2013 and once in 2015) and we have not

been given an opportunity to provide feedback on

proposed BTF habitat management and an

accompanying monitoring program. Thus, Adani

have not honoured the spirit of their commitment to

the Coordinator-General.

The first (and only) time the BTFRT has been

provided with the details of the habitat management

and monitoring programs is through this SMP

which was obtained from the Public Register under

s 540 of the Environmental Protection Act 1994

(Qld), not through Adani or its representatives. It is

important to note that while Section 5 discusses the

benefits of an adaptive management framework, it

and to what capacity. All requests

for consultation should be directed

to the BTFRT Secretary at

[email protected].

To help the BTFRT make informed

assessments and provide the most

effective advice on habitat

management and monitoring,

relevant reports and data prepared

by or for Adani should be provided

to the BTFRT as they are prepared.

Examples of appropriate reports

and data include, but are not limited

to:

Reports summarising survey

results, together with GPS

coordinates and BTF

abundances.

High resolution spatial data of

the project site, proposed

mining area, proposed offset

area, accompanying habitat

data, BTF sightings and nest

sightings.




Page/section

number


does not specify that the BTFRT will be consulted

when devising and revising plans under this

framework. Given that the BTFRT have had no

input to date into the habitat management plan or

accompanying monitoring program and have

received little cooperation from Adani, we are

concerned that the SMP contains no discussion

about the involvement of the BTFRT in a

consultative capacity when it comes to reviewing

and amending these aspects of the project.

Reports detailing knowledge

gained about the BTF based on

observations and research

within the project and offset

area, such as (but not limited

to) foraging ecology,

behaviour, habitat preferences,

movements, breeding, use of

water sources, responses to

grazing and fire regimes and

responses to habitat restoration

efforts.

Reports about the research

program.

Revisions to the SMP.

Reports about the BTF habitat

management plans applicable

to both the project area and

offset areas.

Page 24,

Section 2.3;

Pages 55-56,

Section 6.5

The Moray Downs West offset

area will be managed and

monitored for a minimum of 20

years.

The mine will be constructed in stages over a 30

year period (Section 2). BTF habitat may be

impacted by subsidence, weed invasion, water

contamination, and degradation during the

construction phases (Section 4.7, Table 11). Thus, a

We recommend that monitoring of

habitat on the mine site and all the

offset areas be conducted for the

duration of mining activities. At an

absolute minimum, monitoring




Page/section

number


20 year monitoring period is inadequate as it will

not capture these impacts for the final phases of

construction. Extending the monitoring period

throughout the entire construction phase is

especially important since the northern third of the

project site (containing the largest known

populations of BTF) is planned to be constructed

last (Section 6.3.1).

Additionally, mining operations will continue for

60 years (Section 2.1) and it is possible that the

neighbouring offset area could be impacted by

mining activities in stages throughout this period,

for instance, through noise and vibration

disturbance, dust emissions and the introduction or

spread of weeds (Section 4.7.2). Given the staged

implementation of mining activities, it is possible

that impacts on the latter stages (or their

neighbouring offset areas) would not be detected in

a 20 year monitoring program.

The IUCN recommends that any offset gain should

last at least as long as the impact being addressed

(IUCN 2016). In most cases, this means in

must continue for at least 30 years,

or until the end of the construction

phase should construction take

longer than 30 years. Additional

monitoring should be considered at

the end of this management period

should any impacts on habitat

quality be recorded within the

underground mine site or the offset

areas.

The SMP should specify that the

offset area must be managed in

perpetuity (or for > 100 years) and

discuss how all offset areas will be

managed after the 20 year period

has expired, for example, who

assumes responsibility. Appropriate

management of the area will be

crucial to ensure it remains suitable

for the BTF following the loss of

their former habitat.




Page/section

number


perpetuity. In the case of this project, this would

mean that offset areas need to be managed at least

until mining activities had ceased and mining sites

had been revegetated and rehabilitated to a

condition suitable to support BTF populations. If

mining activities run for 60 years, then we would

suggest the offset areas must be managed for >100

years.

Page 46,

Section 6.2

In the northern section of the

project area, stockpiling and

chemical storage will be within

and/or adjoining locations where

BTF have been recorded.

The northern section of the project area contains the

largest known populations of BTF. Retention of

quality habitat in this section of the project area is

critically important for the species. For example,

Adani has committed to underground mining in this

section to help minimise the impact on this area of

habitat. Stockpiling and storing chemicals at known

hotspots for BTF poses an unnecessary risk to

populations within the project area that are likely to

already be stressed from other project impacts.

We recommend that stockpiling

and chemical storage do not occur

at all within BTF habitat, especially

in the northern section of the

project area. Buffer zones should be

established so stockpiling and

chemical storage do not occur

within 5 km of BTF habitat.

Page 47,

Section 6.3.1

Clearing will be minimised as far

as practical during the wet season

which is the known breeding

season.

We agree that clearing should not be undertaken

during the breeding season (October to April) as the

parent birds may be reluctant to move in spite of the

disturbance. However, BTF are known to breed all

throughout the year (North 1901-14; Lavery 1968;

Morris et al. 1981; Mitchell 1996; NRA 2005;

We recommend that clearing be

avoided from September to April.




Page/section

number


Forshaw et al. 2012). Clearing should also be

avoided during the time when there is little seed

available (September to November). Forcing the

birds to move on when they are food limited (and

potentially already stressed from that food

limitation) carries a substantial risk to the

population.

Page 47,

Section 6.3.1;

Page 50, Table

12

Structuring clearing so that,

whenever possible, habitat

connectivity can be maintained by

providing stepping stones of

habitat the BTF can travel through

when escaping the clearing front.

In cases where habitat connectivity cannot be

maintained and the birds are forced to escape

through unsuitable habitat, daily clearing extents

should be reduced to give the birds more time to

escape.

More conservative daily clearing

extents (i.e. <500m per day) or

pauses in clearing are to be

implemented when clearing areas

with low habitat connectivity

through the anticipated escape

route.

Page 50, Table

12

A trigger is activated when

temporary disturbance areas that

are no longer required are not

rehabilitated.

This trigger needs to be more specific. Page 76,

Table 17 specifies that rehabilitation must

commence within 6 months of the completion of

operations in an area.

We recommend that the trigger

include a timeframe within which

rehabilitation must be conducted,

preferably as soon as the area is no

longer required.

Page 50, Table

12

Disturbed habitat and offset areas

are restored or enhanced as soon

as possible. This will include

short-term, fast acting activities

(such as shrub layer reductions

Enhancement of offset areas should not occur

concurrently with adjoining clearing activities. It

will take an unknown timeframe (presumably years)

for management actions to potentially result in

habitat improvement. For example, the BOS

Disturbed habitat should be

restored as soon as it is no longer

being used. The trigger should

specify a time frame within which

habitat must be restored.




Page/section

number


and grass layer improvements)

and longer-term activities (such as

weed management replanting

programs).

estimates it will take 5-10 years before management

actions will result in an ecological benefit. Thus, the

enhancements should be implemented at least 5-10

years prior to clearing adjacent land.

There is currently no timeframe specified as to

when disturbed habitat must be restored.

An additional trigger should be

added flagging when habitat is

cleared before the adjoining

enhanced offset areas have had

sufficient time (5-10 years) to

become suitable for BTF.

Page 50, Table

12

Clearance of vegetation will

follow vegetation clearance

protocols.

These protocols are not outlined in the SMP,

making it impossible for the BTFRT to assess how

they could impact the BTF.

Include the vegetation clearance

protocols in the SMP.

Page 53,

Section 6.4.1

Cattle will not be restricted from

accessing existing troughs and

water points because BTF have

been shown to drink at troughs

visited by cattle.

GHD (2014) states that the water sources most

commonly used by BTF are small dams and troughs

that are clean and not pugged or degraded due to

cattle access. The report specifically recommends

that troughs should be raised to prevent access by

cattle and feral animals and small dams be

contained within cattle- and feral animal-proof

fences.

Cattle and feral animals should be

excluded from water points to be

used by BTF.

Page 60, Table

13

Emissions (dust, coal and heavy

metals) will not degrade water

source quality in BTF habitat.

Visual evidence of dust impacts

on water sources will be the

trigger for this goal.

Visually estimating dust is not sufficient to identify

contamination (such as from heavy metals). Visual

estimation should be carried out in conjunction with

a chemical analysis.

The trigger for corrective action

should be visual evidence of dust

impacts to water sources and

chemical evidence of

contamination.




Page/section

number


Page 60, Table

13

There is to be no net loss of

suitable permanent water sources.

Permanent water sources within

BTF habitat will not be lost unless

suitable alternative water supplies

are available within suitable

habitat within 5km.

The majority of BTF records within the project area

are within 3km of known water sources (Appendix

C, Section 3.3.3). The SMP assumes that having

water too far away can preclude the BTF from

occupying an area (Appendix C, Section 3.3.3).

Thus, water should be within 3km of BTF habitat.

However, if a water source is lost, it will be

unknown how far the BTF had to travel to reach

that water point. For instance, if they travelled 3km

to reach the (now lost) water point, they may need

to travel 8km to reach the alternative water point.

Thus, distances between lost and alternative water

points must be more conservative to ensure that

alternative water points will be within reach of the

birds.

As this section is currently worded, there would

indeed be a net loss of suitable permanent water

sources, i.e. if a water source was lost, it would not

be replaced if there was another source available

within 5km. For no net loss, all lost water sources

must be replaced.

There should be no net loss of

permanent water sources, so lost

water sources will be replaced

regardless of the placement of other

water sources.

If this recommendation is not be

adopted, then we suggest that

permanent water sources within

BTF habitat should not be lost

unless suitable alternative water

supplies are available within

suitable habitat within 1km of the

lost water source.

Note that this goal and mitigation

measure should apply to water

sources both within the project area

and on offset areas (not only on the

project area as currently worded).

Page 63,

Section 7.1

A monitoring program will be

implemented in the project area to

Baseline monitoring commenced in 2012

(Appendix C, Table 6), so half of the 10 year

We recommend that monitoring the

impacts of mining activities on




Page/section

number


assess the effectiveness of

mitigation measures and evaluate

the success of rehabilitation

activities. The monitoring

program will continue for 10

years and has already commenced

as part of the baseline research

program.

commitment has already passed. The remaining 5

year commitment will not even cover the first phase

of construction. This is an inadequate timeframe for

detecting all possible impacts. Additionally, this

timeframe does not allow sufficient time for

rehabilitation activities to be undertaken, habitat to

recover, and the effectiveness of the rehabilitation

measures to be assessed on even those impacts that

will be immediately detected at the commencement

of construction.

The mine will be constructed in stages over a 30

year period (Section 2). BTF habitat may be

impacted by subsidence, weed invasion, water

contamination, and degradation during the

construction phases (Section 4.7, Table 11). Thus, a

10 year monitoring period is inadequate as it will

only capture these impacts for part of the first phase

of construction. Extending the monitoring period

throughout the entire construction phase is

especially important since the northern third of the

project site (containing the largest known

populations of BTF) is planned to be constructed

last (Section 6.3.1).

habitat and BTF in the project area

and adjacent offset areas continue

until two years after mining

operations are completed as per the

commitment to the Coordinator-

General. At an absolute minimum,

we recommend that monitoring of

habitat and BTF in the project area

and offset areas be conducted for a

minimum of 35 years (i.e. baseline

monitoring plus construction

phases) or until the end of the

construction phase should

construction take longer than 30

years. Additional monitoring

should be considered at the end of

this management period should any

impacts on habitat quality be

recorded within the project area.




Page/section

number


Additionally, mining operations will continue for

60 years (Section 2.1) and it is possible that the

project area could be impacted by mining activities

in stages throughout this period, for instance,

through subsidence, noise and vibration

disturbance, dust emissions and the introduction or

spread of weeds (Section 4.7.2). Given the staged

implementation of mining activities, impacts from

the bulk of the mining project would not be

detected in a 10 year monitoring program.

Adani made a commitment to the Coordinator-

General (P6.30) that “Monitoring events will

commence at least one year before mining

operations…, and continue for at least two years

after mining operations are completed” (State of

Queensland 2014). This commitment will be

breached under the proposed monitoring plan.

Page 63,

Section 7.1

Monitoring program Adani will collaborate with research institutions for

aspects of the monitoring program, where such an

approach would add value

Collaboration with research

institutions should be established

without further delay to ensure that

an adequate scientific methodology

is adopted and to ensure a before-




Page/section

number


after-control-impact study design

can be established before impacts

occur. All results should be

published in the peer-reviewed

literature and shared with the

BTFRT.

Page 63, Table

14

Pre-clearance surveys Record the areas of occupancy for all BTF. This should include repeated

abundance counts throughout the

year, as simple presence-absence is

not useful for a highly mobile

species. Abundance is an important

response variable to understand

habitat quality and population

trends.

Page 64, Table

14

The quality of known BTF water

sources will be monitored.

This is too vague. It is not clear how “quality” is

defined or being assessed. Page 60 says that water

sources will be visually assessed for dust impacts.

However, given how heavily the BTF rely on these

water points, more stringent measures of quality

should be used.

Water sources should be visually

assessed for dust accumulation and

general cleanliness (i.e. no

contamination from cattle or feral

animals). Chemical analysis should

also be undertaken to detect

contamination from mining

activities. Water flow and water

levels should be monitored to

ensure water supply is not disrupted




Page/section

number


as a result of mining activities.

Page 64, Table

14

Measure the effectiveness of

offset management by monitoring

the quality of offset areas.

The management of offset areas should be

measured in two ways: through the quality of

habitat and the occurrence and abundance of BTF

occupying the offset area. It is not enough that

offset areas be set aside and managed – they must

also be effective at supporting displaced BTF

populations.

Assessing the effectiveness of offset areas cannot

be completed within the remaining monitoring

period (approximately 5 years remaining). The

research program starts at the commencement of

stage 1 construction (Appendix C, Page 38, Table

11) and runs for four years. Results from the

research program will be consolidated in the fifth

year. Construction starts in the middle section of the

project area that contains the poorest habitat for

BTF (Pages 46-47, Section 6.3.1) where there are

expected to be fewer BTF displacements. While this

research may give some indication of how best to

manage or rehabilitate BTF habitat, there is no time

to refine the management methods and further

assess the effectiveness of any changes. The SMP

We recommend that the

effectiveness of offset area

management be measured by both

habitat quality indicators and an

increased occurrence or abundance

of BTF (given that it is assumed the

offset area will support displaced

BTF) in the managed areas.

We recommend that monitoring of

offset area management and

effectiveness be undertaken for the

duration of the construction phase,

i.e. for a minimum of 30 years.




Page/section

number


emphasises the role of adaptive management

(Section 5), yet the plan fails to extend this

approach to the management of the offset areas.

Page 65,

Section 7.1.1

Seasonal surveys will be

undertaken biannually.

Biannual surveys are insufficient to record

information on BTF. Black-throated finch

movements and activity are highly related to

rainfall, and rainfall is highly variable inter-

annually. For example, October could be extremely

dry, or be a period of high water availability,

resulting in substantial fluctuations in detectability

and activity of BTF, as seen from annual water hole

counts in the Brigalow Belt Bioregion (BTFRT

Database 2017). With very high variability,

biannual surveys would have no statistical power to

detect any change in BTF population, which is the

objective of this exercise.

Surveys should be conducted at

least every two months for 10

years.

Page 65,

Section 7.1.2;

Appendix B

Location of proposed monitoring

sites

More monitoring sites are needed in the offset

areas to statistically assess the effectiveness of

management actions and to assess how well the

offset areas are benefiting displaced BTF. This is

especially important in areas targeting BTF that are

thought to not currently support BTF.

More locations within offset areas

should be added to the monitoring

regime.

Pages 65-66,

Section 7.1.2.1

During waterhole watches,

observers will record time,

A more comprehensive assessment of the health of

the population would be desirable.

We recommend a marked-recapture

study of BTF (similar to Recheleto




Page/section

number


abundance, other species present

and BTF behaviour.

2015, 2016) to more accurately

record population structure, health

(Maute 2011) and have a reliable

measure of population abundance.

This type of information would

allow a Population Viability

Analysis to be conducted.

Abundance measures at water

source counts need to be

standardised. For example, the

BTFRT use drinking events, then

record birds not observed drinking

as incidentals.

Page 66,

Section 7.1.2

Active searches will include

random meanders within 600m of

each water point monitoring site.

BTF nest and occur several kilometres from water,

and the 600m around a water point can be degraded

from historic piosphere effects.

We recommend searches be

conducted within 1km from each

water point.

Page 67,

Section 7.1.2.6

Vegetation transects will consist

of a modified BioCondition

survey.

BioCondition is not a BTF-specific vegetation

assessment. BTF-specific vegetation assessment

methodologies have been developed by NQ Dry

Tropics NRM and these should be used instead.

BTF-specific vegetation assessment

methodologies developed by NQ

Dry Tropics NRM should be used

instead of BioCondition

methodologies.

Page 65,

Section 7.1.2

Methods for BTF survey

methodology.



Call playback to be used during

BTF surveys to increase




Page/section

number


Environment and Heritage Protection stipulates that

Adani should use call playback during BTF

surveys, but this is not specified in the methods

throughout Section 7.1.2.

detectability.

Page 69, Table

16

During breeding season

environmental representatives will

monitor all verified BTF nests

within 1km of active operational

areas.

BTFs are reported to breed throughout the year

(North 1901-14; Lavery 1968; Morris et al. 1981;

Mitchell 1996; NRA 2005; Forshaw et al. 2012),

though peaks in breeding activity seem to coincide

with periods of high food availability, which on the

Townsville Coastal Plain typically occurs two

months after substantial rainfall (Mitchell, 1996).

This rainfall can occur at any time of the year.

Nest searches should be conducted

regularly all throughout the year.

Page 69, Table

16

Monitoring program will identify

changes in BTF population size

and movements over time.

The outlined monitoring program does not identify

BTF movements at all. At best, increased

abundances in offset areas after clearing on the

project area could be suggestive that displacement

might be occurring.

The monitoring requirements

should be clarified in terms of

movements. If the requirement is to

assess movements after clearing,

then monitoring methods would

need to change to reflect this. For

example, movement can only be

ascertained by resightings of

marked individuals such as colour

bands, or radio tracking. We

recommend these measures to

better understand the movements




Page/section

number


and survivorship of the impacted

BTF population.

Page 69, Table

16

A trigger for corrective action is

an abandonment of a BTF nest

due to noise and vibration

disturbance (rather than an

alternative cause).

This trigger is ineffective. Unless there is an

obvious sign of predation on a nest (such as eggs

that have been opened and eaten), the cause of nest

abandonment will be unknown.

It is also concerning that the SMP does not outline

anywhere how nest monitoring will occur.

The trigger for corrective action

should be that nests are abandoned

without obvious signs of predation.

We recommend that the SMP

specifies how nest searches will be

conducted to ensure a thorough

search is undertaken (rather than a

cursory check). Nest monitoring

will need to occur throughout the

entire year, not only during the

breeding season.

Page 71-72,

Section 7.2.2

Fire exclusion can lead to

thickening of woody shrubs,

decreasing the quality of BTF

habitat.

Rechetelo (2016) did not look at fire, so should not

be cited here. The evidence for fire regimes leading

to increased shrub density is not established

(Eldridge & Soliveres 2015). No research has been

conducted on the suitability of different fire regimes

for BTF, therefore the importance of fire for BTF is

currently unknown.

Any burning done for the purposes

of BTF habitat improvement should

be done with extreme caution, input

by experts and with intensive

monitoring.

Page 72,

Section 7.2.3

Therefore the absence of water

may preclude BTF from areas that

otherwise provide suitable habitat.

BTF congregate on the ground during drinking

events, increasing their detectability. No research

has ascertained that water sources are essential in

Research should be conducted on

the water requirements of BTF.

This should not be limited to




Page/section

number


The addition of water may

increase the area of suitable

habitat that is available.

high density, or whether this is a detection bias. monitoring new water points (as

proposed in the research plan)

because it will not overcome

detection bias.

Appendix C,

Section 3.3.1

Grazing management The grazing that is being trialled is not specified. No grazing at all should be

included as an experimental

treatment.

Appendix C,

Section 4.2

Research on home range and

movement patterns.

Movement research will be conducted across

different seasons, but timings were not specified.



Environment and Heritage Protection stipulates that

the research program must establish whether BTF at

the project site are sedentary, locally migratory or

regionally migratory. The proposed radio tracking

and colour banding studies should identify home-

range movements and perhaps local migrations

within the project area, but will provide very

limited information about potential longer-range

regional migratory movements. A failure to sight a

banded individual during a survey could indicate

they have dispersed away from the area or

undergone regional migration, or it could simply be

At a minimum, we recommend that

movements be monitored when

food is in low supply (Sep-Nov), in

the breeding season (Oct-Apr), and

in other seasons (May-Aug).

Radio tracking should be

undertaken with a large sample size

of individuals in order to

understand the movements of the

broader population. We recommend

aiming for a minimum of 100

individual birds per site.

Banding BTF should be done

specifically with colour banding, as

this is the only way individuals can




Page/section

number


due to an inability to detect the individual on that

occasion. Thus, the research program does not

currently meet the requirements of the

Environmental Authority.

be identified in the field without

recapture. Resighting rates are

extremely low, not just for BTF,

but across all studies of banding

birds in Australia (Marchant and

Higgins 1990, Marchant and

Higgins 1993, Higgins and Davies

1996; Higgins and Peter 2002,

Higgins et al. 2001, Higgins et al.

2006). Therefore 50 birds at each

site is insufficient to maximise the

opportunity of resighting

individuals. Flock sizes have been

large in this region (>100 birds),

therefore with concerted effort

colour banding of >100 birds at

each site should be aimed for. Any

less would result in extremely low

likelihood of resighting individuals.

This is exacerbated by BTF being

forced to relocate due to habitat

destruction.

Should the observers fail to locate




Page/section

number


multiple individuals within

particular seasons, then the research

program should be revised to

consider how to identify regional

migrations.

Appendix C,

Section 4.3.3

Floristic surveys BioCondition is not a BTF-specific vegetation




BTF-specific vegetation assessment

methodologies developed by NQ

Dry Tropics NRM should be used.

Page 50, Table

12; Page 69,

Table 16;

Appendix C,

Page 38,

Section 6.1

Mitigation measures for clearing

activities are dependent on offset

areas being enhanced for BTF.

Mitigation measures for the

monitoring program are triggered

when BTF abundances are

significantly declining.

Annual reports summarising the

monitoring and research programs

will be prepared annually and the

results will be applied to the

adaptive management framework.

There is a strong assumption that the proposed

management actions will improve the quality of

offset areas so that currently unoccupied offset

areas will sustain BTF after the introduction of

management actions. However, there is currently no

scientific basis to suggest that BTF will respond to

the proposed management actions. Thus, this

assumption carries a very high risk for the regional

population. There is little mention of what will

occur should BTF not respond positively to the

management actions, besides a review under the

adaptive management framework. If BTF fail to

take up residency within the currently unoccupied

offset areas by the end of the research period,

urgent action will be needed given that clearing of

For stage 1 offset management

monitoring, the Moray Downs

West offset area should be

categorised into several discrete

areas that take into account the

current BTF occupancy and

abundance and habitat suitability.

Throughout the management

period, BTF occupancy and

abundance should be monitored. At

the end of the five year research

program, if some areas are found to

remain unsuitable for BTF (i.e.

there has not been an increase in

BTF occupancy and abundance),




Page/section

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important habitat and BTF displacement will have

been taking place for approximately 5 years by that

stage.

Offset areas are not created equal – BTF currently

occupy some parts of Moray Downs West, but not

others (Page 31, Figure 8 of the BTF Management

Plan). Thus, it would be inappropriate to consider

the effect of management actions on BTF

abundance and occupancy over Moray Downs West

(or other offset properties) as a whole.

then management actions should be

reviewed, additional research

should be considered and a need for

additional high quality BTF offsets

should be urgently sourced within a

set timeframe. Clearing activities

have been designed to drive the

birds towards alternative BTF

habitat (Page 47, Section 6.3.1).

Any clearing driving birds towards

unsuitable offset areas (i.e. those

areas where birds have not taken up

residency) should be immediately

ceased until a revised SMP has

been approved and mitigation

actions have been implemented.

Triggers should be added to the

sections related to clearing

activities and the monitoring

program to reflect the need for

management actions to result in

offset areas becoming occupied by

BTF or supporting increased




Page/section

number


abundances of BTF.

The reporting for the research

program should not only highlight

that results will be fed into to the

adaptive management framework.

This reporting should also flag if

BTF occupancy and/or abundance

has not improved in managed areas

or under certain management

treatments. In that case, there is not

simply a need for a review of

management practices. Rather,

urgent intervention will be needed

to cease activities that will drive

BTF towards these unsuitable areas

until a viable solution is identified

and implemented.




Appendix B

Below are detailed comments and recommendations pertaining to specific sections of text within the BOS.

Page/section

number


Page 2, Table

1, Condition

11 (d)

A description of the potential risks

to the successful implementation

of the BOS, and details of

contingency measures that will be

implemented to mitigate these

risks.

The BOS does not adequately detail contingency

measures that will be implemented to mitigate the

risk of rapid population decline of BTF.

There is a high likelihood that the

mine will lead to declines in BTF

populations, impacting the largest

known BTF population, and that

the offsets are ineffective at

preventing this. There needs to be

better risk management to avoid

this, and to address it in the event

that it occurs.

Page 3, Table

1, Condition 7

(a)(v)

The Coordinator-General’s Report

condition is not met: evidence that

values to be impacted can be

offset, the offset delivery

mechanism(s) comprising one or

more of land-based offsets; direct

benefit management plans; offset

transfers and/or offset payments.

There is no evidence that the impact to BTF can be

offset.

The BTFRT recommend that

evidence that the BTF habitat can

be recreated and data on BTF

population increases be gathered

before any impact to BTF habitat

occurs.

Page 26 Distinction between “critical” and

“core” BTF habitat.

The distinction between “critical” and “core” BTF

habitat is that “critical” habitat is within 3 km of

water. However, it is likely that key Regional

Ecosystems are critical habitat despite being further

All of the habitat considered as

“core” habitat should be considered

“critical” habitat.




Page/section

number


than 3km from water. Furthermore, the amount of

available water changes depending on seasons;

therefore, this is an over-reliance on permanent

water sources.

Page 67,

Section 6.1.5

Securing offset areas and

commencement of management.

The BOS does not specify how long offset areas

will be protected for, how long they will be

managed for and how they will be managed once

Adani ceases management. The IUCN recommends

that any offset gain should last at least as long as

the impact being addressed (IUCN 2016). In most

cases, this means in perpetuity. In the case of this

project, this would mean that offset areas need to be

managed at least until mining activities had ceased

and mining sites had been revegetated and

rehabilitated to a condition suitable to support BTF

populations. If mining activities run for 60 years,

then we would suggest the offset areas must be

managed for >100 years. The size of offset areas

have been calculated on the basis of habitat being

improved, so these habitat improvements must be

sustained over the duration of the mining impacts.

We recommend that the BOS

specifies that the offset areas will

be protected and managed for >100

years, or until the lost habitat has

been revegetated to a condition that

will support BTF populations.

Should revegetation of mining sites

not be possible, then offsets areas

must be managed in perpetuity.

Page 74, Table

25

Triggers for additional offsets. There is a strong assumption that the proposed

management actions will improve the quality of

offset areas so that currently unoccupied offset

areas will sustain BTF after the introduction of

For stage 1 offset management

monitoring, the Moray Downs

West offset area should be

categorised into several discrete




Page/section

number


management actions. However, there is currently no

scientific basis to suggest that BTF will respond to

the proposed management actions. Thus, this

assumption carries a very high risk for the regional

population. There is little mention of what will

occur should BTF not respond positively to the

management actions, besides a review under the

adaptive management framework. However, if BTF

fail to take up residency within the currently

unoccupied offset areas by the end of the research

period, urgent action will be needed given that

clearing of important habitat will have been taking

place for approximately 5 years by that stage.

Offset areas are not created equal – BTF currently

occupy some parts of Moray Downs West, but not

others (Page 31, Figure 8 of the SMP). Thus, it

would be inappropriate to consider the effect of

management actions on BTF abundance and

occupancy over Moray Downs West (or other offset

properties) as a whole.

areas that take into account the

current BTF occupancy and

abundance and habitat suitability.

Throughout the management

period, BTF occupancy and

abundance should be monitored. At

the end of the five year research

program, if some areas are found to

remain unsuitable for BTF (i.e.

there has not been an increase in

BTF occupancy and abundance),

then management actions should be

reviewed, additional research

should be considered and a need for

additional high quality BTF offsets

should be urgently sourced within a

set timeframe. Clearing activities

have been designed to drive the

birds towards alternative BTF

habitat (Page 47, Section 6.3.1 of

BTF Management Plan). Any

clearing driving birds towards

unsuitable offset areas (i.e. those

areas where birds have not taken up

residency) should be immediately




Page/section

number


ceased until a new management

plan has been approved and

mitigation actions have been

implemented.

Appendix I,

Section 3,

Table 2, Page

4

Habitat quality of impact area is

under-estimated.

The habitat on the Carmichael mine footprint is the

highest quality BTF habitat ever recorded as judged

by the abundance of birds. Where the species

stocking rate is 10/10, by definition, the habitat

quality is 10/10. Species abundance and persistence

are the only evidence of habitat quality; any other

indication is a proxy.

The habitat quality of the impact

area needs to be 10.

Appendix I,

Section 3,

Table 2, Page

4

Time until ecological benefit is

substantially longer than when the

impact will happen.

If the impact is to begin as scheduled in 2017, yet

the ecological benefit will take 5 years, this will

lead to the death of BTF that rely on the impact

area. Therefore, the population will decline (high

certainty) before any chance of population

stabilisation or increase due to ecological benefit,

both with a very low certainty.

Ecological benefit must be accrued

and sustained, with strong

evidence, before any impact begins.

Appendix I,

Section 3,

Table 2, Page

4

Actions to improve BTF habitat

value.

There is no evidence for the following actions to

benefit BTF:

Removal or reduction of cattle

Removal of feral pest animals

Any alteration of fire management.

While exotic weeds are known to be a threat to

BTF, there is no evidence that their removal would

No BTF habitat should be lost until

ecological benefit has been

achieved.




Page/section

number


successfully result in habitat improvement.

Appendix I,

Section 3,

Table 2, Page

5

Future quality without offset. There is no evidence that Moray Downs West

would decline in habitat value under current

management practices. BTF have persisted with the

management, therefore, there is no evidence that the

management had any detriment to BTF.

Estimates of future habitat quality

without the offset should be revised

or have a more scientifically-robust

justification provided.

Appendix I,

Section 3,

Table 2, Page

5

Future quality with offset. There is no evidence that the habitat could be

improved. There is no evidence that weed removal

will result in improvement of BTF habitat quality. It

is highly unlikely that pest control will have any

benefit to BTF.

Improvement of habitat should be

established before any BTF habitat

is lost.

Appendix I,

Section 3,

Table 4, Page

9

Habitat quality of impact area

(core habitat).

Habitat quality should be defined by species

stocking rate, as this is the only reliable definition

of habitat quality.

A species stocking rate of 8.25/10

should result in a habitat quality

score of 8.25.

Appendix I,

Section 3,

Tables 2-5,

Pages 4-14

Scores for site condition and

context are based on the results of

BioCondition assessments.

BioCondition is not a BTF-specific vegetation




If habitat quality is not to be solely

defined by species stocking rate (as

discussed above), then scores for

site condition and context should be

based on the methodologies

developed by NQ Dry Tropics

NRM.




Appendix C

Offsets will not reduce the risk of loss as claimed

In the stage 1 offset calculations for the BTF in critical, core and marginal habitat,

Adani has assumed that the risk of loss without the offset is 40% and the risk of loss

with the offset is 20%. They state that the primary risk to loss of habitat is future

resource development, such as coal, petroleum and minerals. However, these risk of

loss figures are fundamentally flawed.

Adani have recorded BTF occurrences in several parts of the proposed offset areas

(Page 31, Figure 8). These occurrences appear to be primarily within critical habitat,

although some sightings appear to be on the borders of offset areas consisting of core

habitat. Any attempt to clear habitat that contains a threatened species, such as the

BTF, would be subject to a separate assessment and approval process that would likely

trigger an offset requirement. This requirement neutralises the influence of that

development pressure on the offset area (Maseyk et al. 2017). Under this scenario, the

risk of loss both with and without the offset is 0% (Maseyk et al. 2017). Thus, for

critical BTF habitat in the BOS, the risk of loss both with and without the offset is

currently incorrect and should be 0%. We can have 90% confidence in this averted risk

of loss (or lack thereof) as there may be slight uncertainty over whether a further offset

requirement would be triggered in every case.

Without high resolution mapping, we cannot clearly see whether Adani have recorded

BTF in core habitat (Page 31, Figure 8). If BTF have been found in core habitat within

the proposed offset sites, then the above argument applies. However, for the purposes

here, we will give Adani the benefit of the doubt and assume that BTF have not been

recorded in core or marginal habitat. In that case, the above argument does not apply.

Instead, consideration should be given to the background rate of loss in the district and

any credible, site-specific evidence to indicate that development will occur in the

foreseeable future (Maseyk et al. 2017). Moray Downs West is located in the Isaac

Local Government Area which has a background risk of loss of 8.42% over 20 years

(Maseyk et al. 2017). However, Adani have claimed there is a 40% risk of loss in

Moray Downs West due to the viability of the underground resources and the status of

pending applications for mineral developments and mining leases. Thus, for core and

marginal offset habitat, we will accept Adani’s estimate at face value and assume that

the risk of loss without the offset is 40%.

If the risk of loss in core and marginal habitat had been based on the background rate

of loss, then protecting the offset area as a nature refuge would have averted that loss.

However, nature refuges do not necessarily provide protection from resource

development. The Nature Conservation Act 1992 states:




27 Prohibition on mining, geothermal activities and GHG storage activities

(1) A mining interest, geothermal tenure or GHG authority can not be

granted

in relation to—

(a) a national park (scientific); or

(b) a national park; or

(c) a national park (Aboriginal land); or

(d) a national park (Torres Strait Islander land); or

(e) a national park (Cape York Peninsula Aboriginal land); or

(f) a conservation park.

Nature refuges are not included in this list. Similarly, nature refuges are not classed as

a protected area in the Mineral Resources Act 1989. The Conservation Agreement for a

declared refuge can prohibit the use of the land for mining and protect the habitat from

inconsistent land uses. However, this prohibition is not compulsory and Adani have not

indicated in the BOS that they will implement this condition. Thus, conserving the

offset land as a nature refuge does not reduce the risk of loss due to mining. However,

conserving the offset land as a nature refuge does reduce the risk of loss due to the

background rate of clearing. While Adani have not specified how their 40% risk of loss

was calculated, we will again give them the benefit of the doubt and assume that it

includes the background rate of clearing of 8.42% over 20 years. Thus, the risk of loss

with the offset is 31.58%. Our confidence in this averted loss is 90%. Adani have given

no indication that the offset area is under a specific threat from planned agricultural

clearing, so we have high confidence, but not absolute certainty.

These corrections have a substantial impact on the area to be offset, so the error

should be rectified immediately. Note that the risk of loss of core and marginal

habitat with the offset could be reduced by protecting the offset area as either a

national park or conservation park.

It is unrealistic to expect that Adani can improve upon the best known BTF

habitat

Adani have scored the quality of the critical habitat being impacted by the project as

8/10. They claim that they will improve the quality of critical and core habitat in offset

areas to 9/10. While it is commendable that Adani is striving for such improvement,

this is a blatantly unrealistic goal. The critical habitat being impacted is the best quality

BTF habitat in the world as evidenced by the size of the BTF population it is currently

supporting (BTFRT Database 2017). We have a basic scientific understanding of some

habitat features preferred by BTF, but our understanding is not fine enough or deep

enough to understand how to improve upon the best known habitat. Additionally,

Adani’s proposed research program does not delve deep enough into BTF preferences

to learn what would improve the best known habitat.




The best outcome we could realistically expect from management actions is for habitat

quality to be capped at the level currently observed in the best known BTF habitat.

Thus, critical habitat quality would be maintained at 8/10 and core habitat quality

would be improved to 8/10.

Adani’s confidence in the change in habitat quality is over-stated

Adani states that they are 90% confident that they will improve critical habitat to their

specified levels, 85% confident in improving core habitat to their specified levels and

70% confident in improving marginal habitat to their specified levels (all within

defined timeframes). However, their justifications for using these percentages are

subjective, lack transparency and fail to use published literature or expert knowledge to

back up their claims. Thus, the proposed offsets fail to meet the offset principles

outlined in the Environment Protection and Biodiversity Conservation Act 1999

Environmental Offsets Policy of being “transparent, scientifically robust and

reasonable” (Commonwealth of Australia 2012). A confidence level of 90% would

be appropriate if the proposed management regimes had previously been demonstrated

to benefit the species, or if the management regimes were very simple and straight

forward to implement. However, that is not the case here. It is more reasonable for

untested management regimes to have a confidence level below 50%.

Offsets are notorious for over-promising and under-delivering. This problem is perhaps

best articulated by Suding (2011) ‘‘although restoration is often possible and results in

net positive benefits, it often does not go as well as planned. The inability to meet set

criteria in many projects occurs at a high enough frequency to bring into question our

ability to set realistic goals and our confidence in meeting these goals’’. Thirty-nine

percent of offsets demonstrate success against targets (May et al. 2017). Most of these

successes are related to land acquisition. When considering offset targets achieved

through on-ground management strategies (like threat management or habitat

restoration), only 3% of offsets demonstrate successful outcomes and 5% demonstrate

partial success (May et al. 2017).

In general, restoring degraded habitat is only successful in about one third to one half

of all cases (Suding 2011). Success rates are lower when restoration is conducted as

compensation for habitat loss (Suding 2011). A meta-analysis has revealed that

restoring degraded land can improve biodiversity values in 44% of cases, but not to the

level observed in intact reference landscapes (Rey Benayas et al. 2009).

Adani aims to restore the condition of habitat within offset areas so it is more suitable

for BTF. This will be very difficult since many of the offset areas do not currently

support BTF at all as far as we know (Page 31, Figure 8). Adani have several

hypotheses to explain why BTF occurrence and abundance is lower in offset areas than

within the project area (grazing management, fire regimes and weed invasion). These

hypotheses are so far untested. Most research on the BTF has occurred in the

Townsville Coastal Plains and, as highlighted by Adani (SMP Page, Appendix C,




Section 2.3), the ecology of the BTF is likely to differ in the more arid Desert Uplands

Bioregion. We are unaware of any work done to date that has aimed to restore habitat

for BTF and measured how the BTF have responded to those restorations. Thus, there

is great uncertainty over how successful they will be in achieving their aims. When

assessing the suitability of offsets, government decision-making must “incorporate the

precautionary principle in the absence of scientific certainty” (Commonwealth of

Australia 2012).

It should be noted that Adani have emphasised in the SMP that buffel grass (Cenchrus

ciliaris) poses a threat to BTF in the region, but they have not outlined how this threat

will be addressed, except through a suggestion that it could be influenced through

grazing (BTF Management Plan, Page 37, Section 4.6.2). However, some evidence

suggests that grazing can actually facilitate the spread of the weed (Fensham et al.

2013). By not specifically addressing this threat, the success of their management

interventions becomes more uncertain.

We recognise that relatively good success rates are possible when restoration is

targeted towards providing specific resources for individual species (Maron et al.

2012), such as providing additional water points for BTF. We also recognise that

committing to an adaptive management process can help lower the uncertainty inherent

in restoration offset goals (Hilderbrand et al. 2005; McKenney and Kiesecker 2010;

Maron et al. 2012). Simultaneously trialling a range of management options is also

likely to reduce the risk of failure (Maron et al. 2012).

Assuming that habitat quality targets are amended as described in the previous section,

we estimate that it would be more accurate to rate the confidence in maintaining the

quality of critical habitat at 8/10 within the specified timeframe at 60%. This

estimation is based on:

the average success of restoration projects (approximately 40%),

plus 10% for specifically targeting efforts towards providing resources for a

single species,

plus 20% for implementing a research program and adopting an adaptive

management framework,

plus 5% because this habitat needs maintenance, not improvement,

minus 15% for not adequately addressing a key threat in the plan (invasion of

buffel grass).

We estimate that it would be more accurate to rate the confidence in changing the

quality of core habitat to 8/10 within the specified timeframe at 55%. This estimation

is based on:



single species,







buffel grass).

We estimate that it would be more accurate to rate the confidence in changing the

quality of marginal habitat to the specified level within the specified timeframe at

45%. This estimation is based on:



single species,




buffel grass),

minus 10% because there is considerable uncertainty whether the proposed

management actions will improve marginal offset habitat to a state that will

support BTF. While Adani have allowed an extra five years to attain the targets

on this habitat type, the research program will not run that long, so later

adjustments under the adaptive management framework will be largely

guesswork.

It is difficult to draw upon the published literature to provide specific support for our

justifications given the paucity of BTF studies. However, our suggestions are based on

the combined expertise of the BTFRT that encompasses ecology, conservation,

species-specific knowledge, plant ecology, policy knowledge and local knowledge.

Our estimated confidence levels are still generous, but are more realistic than those

proposed by Adani.

Corrected offset area calculations demonstrate that proposed offsets are

inadequate

Even assuming that all other figures in the BTF offset calculators are correct, the above

adjustments to the risk of loss and habitat quality, and the confidence in the averted

loss and change to habitat quality have a major impact on the degree to which proposed

offsets will mitigate the loss of BTF habitat. A total of 6,093.38 ha of BTF habitat will

be impacted by stage 1 activities, and Adani proposes to establish a stage 1 offset of

20,284.24 ha of BTF habitat (BOS Page 17; Table 1). Adani have calculated that this

proposed area will offset over 100% of the impacted habitat (BOS Page 17; Table 1).

We contest that this proposed offset area actually only offsets 16.08% of critical

habitat offset by critical habitat, 17.23% of critical habitat offset by core habitat,

42.19% of core habitat and 59.27% of marginal habitat (Table 1; Figures 1-4). These

levels are clearly unacceptable and do not meet the minimum requirement of 90% of

impacts being offset (Commonwealth of Australia 2012).




We calculated the area required to offset 100% of the impacted habitat. Adani did not

specify in the BOS why they plan to offset some critical habitat with core habitat,

again demonstrating a lack of transparency. We recommend that impact habitat and

offset habitat be like-for-like whenever possible. For the purposes of our calculation,

we have assumed this is not possible for some reason (for example, a lack of critical

habitat adjacent to the project area) and that there is a maximum of 10,533.70 ha

available for offsetting in critical habitat. In that case, Adani would actually need to

protect, manage and improve 48,362.70 ha to fully offset their proposed impacts – over

double what is currently proposed (Table 2; Figure 1; Figures 5-7).

We recommend that the offset approvals be revoked until such time that an

amended BOS is developed and action can be taken to increase the percent of

impact that is offset.

While we have only provided calculations for the stage 1 offset, our justifications for

the corrected figures also apply to calculations for later offsets, so these should also be

revised. Note that the confidence in the change of habitat quality for later stages of

offsets could be adjusted in future once further information is available on how

successfully managed habitat supports BTF populations.

Table 1 Proposed area of BTF habitat to be dedicated as an offset in stage 1 of the

offset strategy and the corrected percentage of impact are that will be offset.

BTF habitat

impacted

Stage 1

impact on

BTF (ha)*

BTF habitat

to be

provided

Proposed

offset area

(ha)*

Percent of

impact

offset (%)*

Corrected

percent of

impact offset

(%)#

Critical 4,628.23 Critical 10,533.70 102.86

16.08

Critical N/A Core 4,869.86 17.23

Core 725.83 Core 1,950.00 104.30 42.19

Marginal 739.32 Marginal 2,930.68 114.83 59.27

Total 6,093.38 Total 20,284.24 N/A N/A

* Data reported from BOS Page 27.

# Corrected calculations use the same data as that used by Adani (BOS Appendix I),

except that 1) the risk of loss in critical habitat both with and without the offset is 0%

with 90% confidence, 2) the risk of loss in core and marginal habitat is 40% without

the offset and 31.58% with the offset, 3) the confidence in the averted loss in core and

marginal habitat is 90%, 4) the future habitat quality with the offset in critical and core

habitat is 8/10, and 5) the confidence in the change of habitat quality has been

decreased to 60% for critical habitat, 55% for core habitat and 45% for marginal

habitat.




Table 2 Corrected area of BTF habitat needed to offset 100% of the impacted habitat.

BTF habitat

impacted

Stage 1

impact on

BTF (ha)*

BTF habitat

to be

provided

Corrected

offset area

(ha)#†

Percent of

impact

offset (%)#

Critical 4,628.23 Critical 10,533.70 100.00

Critical N/A Core 28,263.00

Core 725.83 Core 4,621.50 100.00

Marginal 739.32 Marginal 4,944.50 100.00

Total 6,093.38 Total 48,362.70 N/A

* Data reported from BOS Page 27.

# Corrected calculations use the same data as that used by Adani (BOS Appendix I),

except that 1) the risk of loss in critical habitat both with and without the offset is 0%

with 90% confidence, 2) the risk of loss in core and marginal habitat is 40% without

the offset and 31.58% with the offset, 3) the confidence in the averted loss in core and

marginal habitat is 90%, 4) the future habitat quality with the offset in critical and core

habitat is 8/10, and 5) the confidence in the change of habitat quality has been

decreased to 60% for critical habitat, 55% for core habitat and 45% for marginal

habitat.

† Assumes that a maximum of 10,533.70 ha of critical habitat is available to be offset.

BioCondition is not an accurate tool for assessing BTF habitat quality

Adani scored critical habitat quality in the impact area as 6.43/10 (effectively ranging

from 5.1 to 6.9), with a BTF stocking rate of 10/10. This land is a veritable BTF

hotspot with the largest known populations ever recorded. To the best of our

knowledge, this habitat quality is 10/10 for BTF. However, our limited understanding

of BTF requirements restricts our ability to assess habitat condition for BTF.

BioCondition may have scored the habitat quality so low because the methodology is

targeted to biodiversity as a whole and is not specific to the BTF. North Queensland

Dry Tropics NRM has created a habitat assessment tool that more closely aligns habitat

measurement and assessment to BTF requirements. We recommend the use of this tool

over BioCondition when assessing BTF habitat quality. Further information on the tool

can be sourced from NQ Dry Tropics NRM at [email protected].

Relying on the BioCondition tool to assess habitat improvements may lead to perverse

outcomes for the BTF. By aiming for higher BioCondition scores, Adani are

effectively aiming to improve vegetation characteristics to align more closely to those

associated with higher biodiversity values. We recognise the value of increasing

biodiversity; however, the primary aim of the BTF offset areas must be to support

displaced BTF. Characteristics that maximise biodiversity and BioCondition values

may actually be suboptimal for BTF. Benchmark BioCondition values are not yet

available for the Desert Upland Bioregion, so local benchmarks needed to be

established by Adani. The BTFRT are unable to comment on the local benchmarks

used to assess habitat scores because Appendix C is missing from our copy of the

BOS.




References

BTFRT Database (2017) Database of Black-throated Finch records. Black-throated

Finch Recovery Team, Townsville.

Commonwealth of Australia (2012) Environment Protection and Biodiversity

Conservation Act 1999 Environment Offsets Policy. Department of

Sustainability, Environment, Water, Population and Communities, Canberra.

Eldridge DJ, Soliveres S, (2015) Are shrubs really a sign of declining ecosystem

function? Disentangling the myths and truths of woody encroachment in

Australia. Australian Journal of Botany 62, 594-608.

Fensham RJ, Donald S, Dwyer JM (2013) Propagule pressure, not fire or cattle grazing

promotes invasion of buffel grass Cenchrus ciliaris. Journal of Applied

Ecology 50, 138-146.

Forshaw JM, Shephard M, Pridham A (2012) Grassfinches in Australia. CSIRO

Publishing, Melbourne.

GHD (2014) Carmichael Coal Mine and Rail SEIS: report for Black-throated Finch on-

site monitoring survey 2, Rev 0. Report prepared for Adani Mining Pty Ltd,

February 2014.

Higgins PJ, Davies SJJF (1996) Handbook of Australian, New Zealand and Antarctic

Birds. Vol. 3. Snipe to Pigeons Oxford University Press, Melbourne.

Higgins PJ, Peter JM (2002) Handbook of Australian, New Zealand and Antarctic

Birds. Vol. 6. Pardalotes to Shrike-thrushes. Oxford University Press,

Melbourne.

Higgins PJ, Peter JM, Cowling SJ (2006) Handbook of Australian, New Zealand and

Antarctic Birds. Vol. 7. Boatbill to Starlings. Oxford University Press,

Melbourne.

Higgins PJ, Peter JM, Steele WK (2001) Handbook of Australian, New Zealand and

Antarctic Birds. Vol. 5. Tyrant-flycatchers to Chats. Oxford University Press,

Melbourne.

IUCN (2016) IUCN policy on biodiversity offsets. International Union for

Conservation of Nature, Gland, Switzerland. Available at

https://www.iucn.org/theme/business-and-biodiversity/our-work/business-

approaches-and-tools/biodiversity-offsets.

Lavery HJ, Hopkins N (1963) Birds of the Townsville district of north Queensland.

Emu 63:242-252.

Marchant S, Higgins PJ (1990) Handbook of Australian, New Zealand and Antarctic

Birds. Vol. 1. Ratites to Ducks. Oxford University Press, Melbourne.

Marchant S, Higgins PJ (1993) Handbook of Australian, New Zealand and Antarctic

Birds. Vol. 2. Raptors to Lapwings. Oxford University Press, Melbourne.

Maseyk FJF, Evans MC, Maron M (2017) Guidance for deriving ‘Risk of Loss’

estimates when evaluating biodiversity offset proposals under the EPBC Act.

Report to the National Environment Science Programme, Department of the

Environment and Energy. April 2017. Threatened Species Recovery Hub,

Brisbane.




Maute KL (2011) Variation in the health of tropical finches in relation to conservation

status, season and land tenure, PhD Thesis, University of Wollongong.

May J, Hobbs RJ, Valentine LE (2017) Are offsets effective? An evaluation of recent

environmental offsets in Western Australia. Biological Conservation 206, 249-

257.

Mitchell DF (1996) Foraging ecology of the Black-throated Finch Poephila cincta

cincta M.Sc. Thesis, James Cook University.

Morris AK, McGill AR, Holmes G (1981) Handlist of birds in New South Wales.

NSW Field Ornithologists Club, Sydney.

Natural Resource Assessments Pty. Ltd. (2005) Enertrade North Queensland Gas

Pipeline Black-throated Finch Studies (Post-Construction). Unpublished report

prepared by NRA Environmental Consultants for Enertrade, Brisbane.

North AJ (1901-1914) Nests and eggs of birds found breeding in Australia and

Tasmania. Australian Museum, Sydney.

Rechetelo J (2015) Movement, habitat requirements, nesting and foraging site

selection: a case study of an endangered granivorous bird, the Black-throated

Finch Poephila cincta cincta in north-eastern Australia. PhD Thesis, James

Cook University.

Rechetelo J, Grice A, Reside AE, Hardesty BD, Moloney J (2016) Movement patterns,

home range size and habitat selection of an Endangered resource tracking

species, the Black-throated Finch (Poephila cincta cincta). PLoS ONE 11,

e0167254.

State of Queensland (2014) Carmichael Coal Mine and Rail project: Coordinator-

General’s evaluation report on the Environmental Impact Statement.

Department of State Development, Infrastructure and Planning, Brisbane.




Appendix D

Guidance for deriving ‘Risk of Loss’ estimates when evaluating biodiversity offset

proposals under the EPBC Act. Available from

http://www.nespthreatenedspecies.edu.au/publications-tools/guidance-for-deriving-

risk-of-loss-estimates-when-evaluating-biodiversity-offset-proposals-under-the.


http://www.nespthreatenedspecies.edu.au/publications-tools/guidance-for-deriving-risk-of-loss-estimates-when-evaluating-biodiversity-offset-proposals-under-the

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