Permission to proceed does not constitute acceptance of design details, calculations, test methods or materials developed or selected by Supplier and does not relieve Supplier from full compliance with full contractual and other obligations nor detract from any of the purchaser's rights.
SU PPLIER D OC U M EN T R EV IEW
1. Reviewed and no comment. Submit f inal version of document as required.
2. Revise and resubmit . Work may proceed subject to incorporat ion of changes indicated.
Learmonth Bundle Site
Section 38 referral:
Supporting
Document Prepared for:
Subsea 7
October 2017
360 Environmental Pty Ltd
Disclaimer
This report is issued in accordance with, and is subject to, the terms of the contract between the Client and 360 Environmental Pty Ltd, including, without limitation, the agreed scope of the report. To the extent permitted by law, 360 Environmental Pty Ltd shall not be liable in contract, tort (including, without limitation, negligence) or otherwise for any use of, or reliance on, parts of this report without taking into account the report in its entirety and all previous and subsequent reports. 360 Environmental Pty Ltd considers the contents of this report to be current as at the date it was produced. This report, including each opinion, conclusion and recommendation it contains, should be considered in the context of the report as a whole. The opinions, conclusions and recommendations in this report are limited by its agreed scope. More extensive, or different, investigation, sampling and testing may have produced different results and therefore different opinions, conclusions and recommendations. Subject to the terms of the contract between the Client and 360 Environmental Pty Ltd, copying, reproducing, disclosing or disseminating parts of this report is prohibited (except to the extent required by law) unless the report is produced in its entirety including this cover page, without the prior written consent of 360 Environmental Pty Ltd.
Figure 8: Potential direct impacts to BCH ...................................................................... 49
Figure 9: Subterranean fauna habitat mapping and surface hydrology in relation to the Project envelope.................................................................................................. 64
2061AE Section 38 referral – Supporting Document Learmonth Bundle Site
Plate 2: Bundle launch in February 2017 (Wester, Scotland) ......................................... 11
Plate 3: Bundle tow procedure ........................................................................................ 11
Plate 4: Deployed Silt Curtains (Left: During construction of Port Coogee Marina, Right: During construction of Perth Seawater Desalination Plant) ............................... 50
Plate 5: Conceptual imagery of Bundle fabrication site. Left: elevated view from north-west (Bundle pipe storage racks [black rectangles] will be a maximum of 2 m above ground level]). Right: elevated view of from the north-east) .................... 78
List of Appendices
Appendix A Learmonth Habitat Surveys
Appendix B Shoreline Movement Assessment
Appendix C Baseline Water and Sediment Quality Assessment
Appendix D Detailed Flora and Vegetation Assessment
Appendix E Subterranean Fauna Detailed Desktop Risk and Impact Assessment
Appendix F Desktop Assessment of Subterranean Fauna for the Learmonth Bundle Project
Appendix G Learmonth Level 1 Fauna Survey
Appendix H Learmonth SRE Desktop review
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1 Proponent and Key Proposal Characteristics
1.1 The Proponent
Subsea 7 is a world-leading seabed-to-surface engineering, construction and services contractor to the offshore energy industry. Subsea 7 operates throughout the world, delivering high-quality services built on the core strengths of engineering, project management, supply chain and vessel management, supported by their commitment to invest in people, technology and assets worldwide.
In all their major operating locations, they aim to build local businesses founded on local leadership. Subsea 7 develops high-quality personnel to deliver responsive support to their clients, contribute to local economies and communities and support regional supply chains.
Subsea 7 has operated in Australia and New Zealand for the past 40 years working with all major oil and gas operators and has an office based in Perth with about 70 permanent employees. Subsea 7 has been involved in the majority of major oil and gas developments in Australia, including the Chevron operated Gorgon Project and Woodside Pluto.
1.2 Key Proposal Characteristics
Table 1 : Key Proposal Characteristics
SUMMARY OF THE PROPOSAL
Proposal Title Learmonth Bundle Site Proponent Name Subsea 7 Australia Contracting (Subsea 7) Short Description Construction and operation of an onshore pipeline fabrication
facility.
PHYSICAL ELEMENTS
Element Location Proposed extent Bundle tracks (2) Heron Point (onshore) 10.5 km long Bundle launchway Heron Point
(intertidal/subtidal) 380 m long by 15m wide (length measured from the dune line)
Fabrication Site Heron Point (onshore) Approximately 8 ha area for site offices, changing rooms, messing facilities, storage area and car park etc.
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SUMMARY OF THE PROPOSAL
Access Roads Heron Point (onshore) Approximately 3.5 km access road to launchway facility and 250 m access road to fabrication site
OPERATIONAL ELEMENTS
Element Location Proposed extent Services: Generator power
Heron Point (onshore) 4 x 850 kVA diesel generators
Groundwater abstraction
Learmonth (onshore) Up to 26 kL/day (9.5 ML/annum) potable water for site amenities One-off hydro-test water volume of approximately 3,000 kL (note that actual volume is dependent on the pipeline diameter and length, and is specific to each project) required for initial Bundle testing (majority will be retained in ‘Hydro-testing’ pond for re-use during subsequent Bundle tests)
Bundle launch Heron Point & Exmouth Gulf (offshore)
Nominally 2 days of offshore activity per launch, annual average of 1-2 (maximum three) launches per annum (subject to market and customer uptake, etc).
Bundle tow Exmouth Gulf Bundle ‘Laydown Area’ (2,407 ha) within which temporary (<24 hours) tow re-configuration may occur.
Tow of floating Bundles out of Exmouth Gulf into Commonwealth Waters.
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2 General Description of Proposal
2.1 Location of the Proposal
The Learmonth Bundle Site (the Proposal) is located adjacent to the western shoreline of Exmouth Gulf, at Learmonth, to the east of the Minilya-Exmouth Road, approximately 35 km south of the Exmouth townsite and 2.5 km south east of the RAAF Learmonth (Figure 1).
2.2 Overview of the Proposal
The Proposal is to construct and operate a new pipeline fabrication facility, in order to build Bundles for the offshore oil and gas industry. A pipeline Bundle, used in the development of offshore gas fields, co-locates a number of services within a single pipeline, which is constructed onshore before being launched and towed offshore to the field under development.
The proposal includes the construction of a fabrication shed, where the Bundles will be constructed, a storage area where the Bundle materials will be stored prior to use, and two approximately 10 km long Bundle tracks along which each Bundle will be constructed and then launched. A Bundle launchway, crossing the beach and extending into the shallow subtidal area, will facilitate the launch of each Bundle.
Following launch each Bundle will be towed offshore along a pre-determined route (Figure 2).
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COPYRIGHT: THIS DOCUM ENT IS AND SHALL REMAIN THE PROPERTY OF 360 ENVIRONMENTAL. THIS DOCUMENT MAY ONLY BE USED FOR THE PURPOSE FOR WHICH IT WAS COMM ISSIONED AND IN ACCORDANCE WITH THE TERMS OF ENGAGEMENT FOR THE COMMISSION. 360 ENVIRONMENTAL DOES NOT HOLD ANY RESPONSIBILITY FOR THE MISUSE OF THIS DOCUMENT.
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Figure 2Tow Route and Bundle Laydown Area
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2.3 Proposed Disturbance
The Project envelope (or ‘the Site’), defining the potential maximum extent of physical disturbance, and including access roads, fabrication shed, laydown areas, a spray field and water storage pond, Bundle track and Bundle launchway covers approximately 502 ha. An additional Bundle ‘Laydown Area’, within which temporary seabed disturbance may occur immediately following a Bundle launch, covers approximately 2,407 ha (Figure 2). The key elements are presented in Table 2 (refer also Figure 3).
Table 2 : Proposed Disturbance
PROPOSAL ASPECT DISTURBANCE AREA (HA)
Onshore
Bundles Tracks 35
Launchway Facilities Area 1
Access Road to Launchway Facilities Area 2
Fabrication workshop, Site offices, Storage area 8
Access Roads to Bundle Fabrication site 1.5
Spray field 1.5
Drainage Sump 0.5
Hydro testing water pond 0.5
Drains, access tracks, earthworks areas Up to 120
Sub-total 170
Offshore
Bundle launchway & tow route Up to 7.5*
Bundle ‘Laydown Area’ 2,407**
Sub-total 2,414.5 *Allows for disturbance within a 1,500 m long and 50 m wide corridor (refer Figure 8 and Section 7.1).
**Actual disturbance will be limited to < 1 ha where the Bundle chains rest on the seabed (refer Section 2.6.5).
2.4 Tenure
The Proposal is located partially on Lot 233 (P219618) on the Minilya-Exmouth Road, approximately 35 km south of the Exmouth townsite and Lot 1586 (P72986). The land is zoned as Pastoral under the Shire of Exmouth Town Planning Scheme No. 3. Subsea 7 has submitted a Planning Scheme Modification request to the Shire of Exmouth in
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September 2017. A motion to proceed with this proposal was approved by the Shire on the 10th October 2017 and this application is now moving through the review process.
2.5 Native Title
One registered Native Title claim exists across the Site: Gnulli WC1997/028 (DAA 2017). This Native Title claim covers the wider Pilbara region. The Gnulli Working Group are currently being engaged to establish the most appropriate form of agreement to recognise the rights of the Traditional Owners.
COPYRIGHT: THIS DOCUM ENT IS AND SHALL REMAIN THE PROPERTY OF 360 ENVIRONMENTAL. THIS DOCUMENT MAY ONLY BE USED FOR THE PURPOSE FOR WHICH IT WAS COMM ISSIONED AND IN ACCORDANCE WITH THE TERMS OF ENGAGEMENT FOR THE COMMISSION. 360 ENVIRONMENTAL DOES NOT HOLD ANY RESPONSIBILITY FOR THE MISUSE OF THIS DOCUMENT.
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Subsea 7Bundle Site, LearmonthEPA Referral
Figure 3Disturbance Area and Project Envelope
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PREPARED FOR
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2.6 Bundle Technology
A Bundle pipeline is comprised of a number of pipes contained within a larger pipe casing (Plate 1). It consists of an outer pipe with an inner insulated sleeve pipe. Within these insulated sleeve pipes are flow lines, gas lines, communication lines and other control cables necessary to operate a gas field in one single product (Plate 1). A pipeline Bundle solution is a well-established alternative to installing subsea pipeline systems as it neatly incorporates all systems required to operate a field into one single product. This reduces pipeline corridor and system testing widths to a minimum, thereby avoiding unnecessary congestion and reducing construction times in the gas field (Subsea 7 2015).
Each Bundle pipe terminates with towhead structures (manifolds) at either end. Once launched from the onshore site, the Bundle is transported to its offshore location suspended between two tugs at a controlled depth below the surface. On entry into the gas field the Bundle is lowered to the seabed, manoeuvred into location and the carrier pipe flooded in its final position.
Plate 1: Pipeline Bundle Cross-section
The advantages of using a pipeline Bundle solution include increased flow assurance for challenging flow conditions, reduced installation fleet costs and the removal of the need to trench or bury pipes, it is also able to be pre-commissioned and tested while onshore (Subsea 7 2015).
2.6.1 Bundle Construction
The inner pipes may be fitted for particular purposes such as telecommunications, water, electricity, gas, oil. Pressure testing is carried out on-site using water (to be sourced from groundwater) before a Bundle pipeline is launched. Whilst the manufacturing of Bundles is based on customer demand, it is estimated that two launches could occur per annum.
A Bundle pipeline would be progressively manufactured as one, up to 10 km long, segment and moved out from the manufacturing facility along the track. Once manufactured to its desired length and pressure tests are carried out, the bundle pipeline
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is then towed out by boat and submerged. Once at its designated location the Bundle is installed on the sea floor to connect with other pipe segments or infrastructure. Each pipe segment would contribute to an integrated pipeline network laid on the sea floor for various uses and functions for the oil and gas industry.
2.6.2 Bundle Site Workforce
Based on two upcoming third party projects that could be executed with Subsea 7’s bundle technology, the following workforce would be required on-site:
Up to 120 people required on site for the build phase of a bundle (duration of 6 to 12 months for the build, test and then launch of a bundle); and
Over the total duration of the build, test and launch, the average number of personnel on site may be in the vicinity of 70-80 personnel.
The proposed bundle site represents a sustainable and long term employment opportunity for a locally based workforce. Subsea 7 note that as each bundle is uniquely designed to meet the specific client’s requirements, each build phase requires some differences in the number of personnel that are required, and the duration for which they are required. Being project based work, the employment opportunities on the site ultimately depend on the uptake of the concept by operators and clients.
When there are no live projects at the bundle base, the site would be run in a maintenance mode, with a small workforce on site maintaining the readiness of the site to be able to ramp up should a new project be awarded.
2.6.3 Bundle Launch
To launch a Bundle, the Towhead on the offshore end of the Bundle is connected to a tug (the ‘Leading Tug’) via a long tow wire. The tug then slowly (≤ 2 knots) heads offshore, pulling the Bundle along the track and into the ocean (Plate 2). The onshore end of the Bundle is connected to another wire which is slowly paid out from an onshore winch, until the Bundle reaches sufficient water depth for connection to another tug (the ‘Trailing Tug’).
The Bundle rolls down the track, which extends across the beach and into the shallow subtidal area. As the Bundle moves beyond the end of the launchway, the towheads on either end of the Bundle will skid along the seabed. As the towheads move in to deeper water, the buoyancy of the Bundle and towheads increase. Full buoyancy required to float the towheads (so they are no longer in contact with the seabed) occurs at a depth of 6 m. This depth mark (at mean sea level) occurs within 1,500 m of the shoreline, and 1,220 m from the offshore end of the Bundle launchway. Bundles will always be launched on a rising (flood) tide.
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will gently move ahead and the Bundle will lift within the water column before the offshore tow commences.
Upon arrival at a field, the Bundle is manoeuvred into final location before the carrier pipe and towheads are flooded to stabilise the Bundle in its final location.
2.7 Operational Activities
2.7.1 Water
As part of the construction of the Bundle and daily operations of the Bundle site the Proposal would require a potable water source for hydrostatic testing purposes as well as for use by site staff.
Site amenities (based on a day shift workforce and offsite accommodation) will have a potable water requirement of approximately 26 kL/day (9.5 ML/annum).
The project hydrostatic testing requires approximately 3,000 kL (3 ML) of high quality water per test (testing will occur prior to each Bundle launch, maximum three times per year). It is proposed that this hydro-test water would be stored in a lined ‘Hydro Testing Water Pond’ between Bundle launches and re-used (Figure 3).
Site investigations are currently being undertaken to determine the best options for obtaining this potable water. It is currently proposed that a small number (nominally 3) of production bores will be drilled and commissioned at a location to the north west of the Project envelope (pending the appropriate construction and abstraction licences from Department of Water and Environmental Regulation [DWER]). Initial consultation with DWER has indicated that an abstraction licence for any individual bore would have an operational limit of 0.3 L/s in order to preserve groundwater regimes.
To enable the treatment of groundwater to provide the potable water/hydro-test water, a Reverse Osmosis (RO) plant will be installed. It is estimated that the RO plant will produce 17 kL/day of wastewater (during active operations on site) with a total dissolved solids (TDS) content of less than 1300 mg/L (for reference seawater has a TDS of approximately 35,000).
Several options for the disposal of the treated wastewater (TWW) stream from the site amenities (approximately 16 kL/day) are under consideration, including a spray field, re-injection, infiltration/irrigation or an evaporation pond. The final selection will be made following the completion of further studies on subterranean fauna within the Project envelope.
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2.7.2 Power
Power at the fabrication facility will be provided by four x 850 kVa diesel generators. These will be fully bunded generators with daily inspections to minimise the risk of spills or leaks to the environment.
2.7.3 Chemical and Hydrocarbon Storage
In order to power the generators and fuel the mobile equipment, a 110 kL above-ground diesel storage tank is proposed onsite. This diesel tank will be self bunded and inspected weekly for leaks. Spill kits will be stored at the tank.
2.7.4 Transport
Road transport of the Bundle construction and fabrication materials from nearby port facilities to the Bundle site is proposed. Subsea 7 is in consultation with the Shire of Exmouth and Main Roads WA to determine the appropriate safety and traffic mitigation measures (i.e. additional overtaking lanes along Minilya Road).
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2.8 Alternative Options Considered
Numerous alternative sites were assessed for suitability as a Bundle construction and launch site, with the environmental, planning and engineering constraints considered.
The project requires a 10 km long Bundle track, with adjacent medium gradient shore crossing. The site profile needs to be gentle enough to ensure uniform load distribution from the ground to the Bundle via Bundle support systems during assembly, testing and launch (Subsea 7 2017).
A number of sites in the North West region of Western Australia were considered. (Figure 4). Using risk assessments and environmental opportunity and constraints tools to assess the suitability of each site, it was determined that the majority of the sites were unsuitable.
This enabled Subsea 7 to short-list two possible sites – Anketell (Karratha) and Learmonth (Exmouth). Further and more detailed environmental opportunity and constraints analysis, and studies including bathymetry surveys, were undertaken. These indicated that the Anketell site was unsuitable for Bundle fabrication and launch and thus Learmonth was determined to be the only feasible site.
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3 Local Context
3.1 Exmouth Gulf Values and Reservation
The conservation values of Exmouth Gulf are recognised in several State government publications, policies and guidelines:
In 1975, the Conservation Through Reserves Committee recognised its conservation significance and recommended that a series of studies on biophysical characteristics of the tidal and supra-tidal flats of Exmouth Gulf be conducted (EPA 1975);
The fringe of arid zone mangroves along the east coast of Exmouth Gulf is recognised as being of ‘regional significance’ in EPA Guidance Statement No. 1. The EPA’s objective for areas of regionally significant mangroves is that “no development should take place that would adversely affect the mangrove habitat, the ecological function of these areas and the maintenance of ecological processes which sustain the mangrove habitats” (EPA 2001);
The salt flats, mangrove creeks and inshore waters were recommended for reservation in the report ‘A Representative Marine Reserve System for Western Australia by the Marine Parks and Reserves Selection Working Group’ referred to as the Wilson Report (CALM 1994);
The coastal waters along the east coast of Exmouth Gulf have been recommended for the ‘maximum’ level of ecological protection in the Department of Environment document Pilbara Coastal Water Quality Consultation Outcomes (DoE 2006). The objectives for ‘maximum’ water quality protection are that there be no contamination and no detectable change from natural variation in water quality; and
Humpback whales, dugong and both green and hawksbill turtles are all listed as specially protected under the Wildlife Conservation Act 1950, and occur in Exmouth Gulf or along its eastern shores. Other specially protected and migratory species regularly use the area.
To protect the ecosystem services and recreational enjoyment that are provided along the east coast and south of Exmouth Gulf, the coastal waters have been a permanent nursery closure area for trawling since 1983, and were recommended as a ‘Fish Habitat Protection Area’ in the draft Fisheries Environmental Management Plan for the Gascoyne Region (Shaw 2002).
Consolidating this body of complementary policy instruments and guidelines, the Ningaloo Coast Regional Strategy Carnarvon to Exmouth, was endorsed by the WA Government and released by the WA Planning Commission in 2004 (WAPC 2004). The strategy recommends that the southern and south-eastern mangrove areas of Exmouth
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Gulf and adjacent coastal waters become marine protected areas, consistent with the findings of the Wilson Report (CALM 1994).
The EPA emphasised its established position on the regional significance of the Exmouth Gulf mangroves and their status as a ‘critical asset’ of the environment during its assessment of the proposed Yannarie Solar Salt project.
The mangroves along the south-western end of Exmouth Gulf are described in the EPA’s Guidance Statement 1 (EPA 2001) as ‘Area 1: Bay of Rest’ and are classified as being of ‘Very High’ importance. For Guideline 1 areas, the EPA expects that ‘no development should take place that would adversely affect the mangrove habitat, the ecological function of these areas and the maintenance of ecological processes which sustain the mangrove habitats’ (EPA 2001).
One Nationally Important Wetland, listed in the ‘Directory of Important Wetlands in Australia’ as wetland ‘Cape Range Subterranean Waterways - WA006’ occurs in proximity to the Project site. The spatial dataset attached to this site includes small areas adjacent to the Bay of Rest, including within the Project envelope, which have a high likelihood of supporting subterranean fauna.
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Figure 5Exmouth Gulf Existing/Proposed Reserves
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3.2 Exmouth Gulf Prawn Fishery
Prawn trawling commenced in 1963 targeting schooling banana prawns (Penaeus merguiensis) during daylight hours (Penn et al. 1997). As the catch of banana prawns declined over the ensuing four years the trawl fleet transferred effort to night time fishing on king (Penaeus latisulcatus), tiger (Penaeus esculentus) and endeavour prawns (Metapenaeus endeavouri). Annual nominal effort in the fishery gradually increased to about 50,000 hours trawled in the late 1970’s to the early 1980’s when a maximum of 23 trawlers operated in the fishery. In 1985 the number of trawlers was reduced to 17, to 16 in 1990, another boat was removed in 1998 and in 2000 two more were removed to 13 (Department of Fisheries 2006).
The Exmouth Gulf Prawn Fishery is one of the largest trawl fisheries in WA and has had catches ranging from 771 to 1,456 tonnes per year over the past 10 years (since 2006).
Marine components of the Project envelope (tow route and Bundle ‘Laydown Area’) overlap with the area currently trawled (Figure 6).
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JA
0 4,000 8,000 12,000 16,000Meters
LegendProject EnvelopeTow RouteBundle LaydownAquaculture SitesPearling SitesTrawled Area (2015-2016)
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3.3 Cape Seafarms Project
In February 1997 Cape Seafarms Pty Ltd proposed to develop an onshore prawn farm at Heron Point. The proposal was referred to the EPA under s38 of the EP Act based on the following preliminary key environmental factors:
Mangroves;
Dunes;
Groundwater Quality;
Marine Water Quality;
Solid Waste disposal; and
Disease.
The project was assessed via a consultative environmental review (CER) and was recommended for approval by the EPA (EPA Bulletin 854) on the basis that EPA objectives for each factor could be met, subject to the commitments, conditions and procedures being enforceable. Ministerial Statement 456 was published on 27 August 1997. It is noted that Subsea 7’s proposed Project envelope overlaps the proposed prawn farm.
The proposal disturbance area (onshore only) was 30 ha under Stage 1 (within 5 years) increasing to 250 ha by Stage 4, with prawn breeding ponds of 1 ha each (with a depth of 1.7 m).
A total of 45 ML/day of seawater was required under Stage 1, expanding to 224 ML/day for Stage 4, with a 10 m wide trench through the dunes required for the seawater intake pipeline at Heron Point.
The proposal included the discharge of waste water into Wapet Creek. A total of 20 – 40 m3 of pond sludge was to be left to dry in the ponds for approximately 3 weeks before being moved to a stockpile area and dried for a further 12 to 18 months to allow for breakdown of bacteria.
The EPA concluded that the discharge of wastewater to Wapet Creek “is unlikely to increase the level of Wapet Creek above the natural tidal fluctuations within the creek”, that given “preliminary information regarding the ability of the receiving environment to accommodate additional nutrient inputs, the impact is not deemed significant.” and that “potential effects of erosion from discharge to the creek are unlikely to be significant” (EPA 1997).
Regarding the trench through the dunes it was concluded that “Given the small area of dune system that will be directly affected (10 metre wide trench); the function of the dune system as a visual screen, and to maintain a physical barrier against storm surge and wind damage will be retained; and the fact that the dune vegetation is well
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represented elsewhere in the region it is unlikely to have a significant impact” (EPA 1997).
Regarding potential impacts to stygofauna it was concluded that “There is unlikely to be stygofauna in the groundwater beneath the site as most stygofauna occupy brackish to saline water (Humphreys 1994). There are no other groundwater dependent ecosystems which would be affected by the project. The EPA notes that this proposal may potentially cause some local mounding of the saline aquifer beneath the site. The leaching of the pond water into the aquifer is unlikely to significantly alter the salinity of the ground water beneath the site which is already saline to hypersaline” (EPA 1997).
Subsea 7’s proposal involves similar elements (i.e. the construction of the Bundle track through the seaward dune line at Heron Point, the proposed storage of hydro-test water and the proposed discharge of RO plant water).
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4 Key Policy and Guidance
Subsea 7 has taken into consideration relevant EPA policies and guidance in the design of the Proposal, in undertaking the environmental impact assessment and throughout the development of this referral document.
A summary of the relevant policies and guidance, and how these have been considered by Subsea 7, is presented in Table 4.
Table 4: Consideration of EPA Policy and Guidance
EPA POLICY/GUIDANCE CONSIDERATION FOR PROPOSAL
General Guidance Statement of Environmental Principles, Factors and Objectives (EPA 2016a)
Referred to in the identification and assessment of Preliminary Key Environmental Factors
Instructions on how to prepare an Environmental Review Document (EPA 2016q)
Template completed and provided alongside this document
Instructions on how to define the key characteristics of a proposal (EPA 2016r)
This guidance was followed in the definition of the Proposal’s Key Characteristics
Guidance related to Environmental Factors Environmental Factor Guideline - Benthic Communities and Habitats (EPA 2016d)
This guidance was consulted in the consideration of potential direct and indirect impacts to Benthic Communities and Habitat (BCH) as a result of the Proposal, and in the development of options to avoid or mitigate impacts.
Technical Guidance - Protection of Benthic Communities and Habitats (EPA 2016h)
This guidance was consulted in the development of a LAU for the assessment of potential impacts to BCH, the characterisation of the BCH present within the LAU, and in the calculation of cumulative impacts.
This guidance was consulted in the consideration of potential impacts to geophysical processes and how these may impact natural coastal dynamics causing an impact to coastal ecosystems and associated values such as landforms, recreation and tourism. Consideration of this factor in the context of climate change was also completed.
This guidance was consulted in the consideration of potential direct and indirect impacts on marine fauna as a result of the Proposal, and in the consideration of critical habitats and ecological windows.
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This guidance was consulted in the consideration of potential impacts on subterranean fauna and the assessment of the significance of the subterranean fauna values within and adjacent to the Proposal area.
This guidance was consulted in the consideration of the environmental values dependent upon the current surface water and groundwater regimes and the potential impacts on hydrological processes.
Methodology was referred to in this document when mapping the position of coastal vegetation to develop a shoreline movement plan for the area.
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5 Stakeholder Consultation
Stakeholder consultation undertaken to date is outlined in Table 5, this includes town planning, native title, shire, indigenous heritage and environmental stakeholders related to the proposed Bundle site.
In addition to the consultation outlined in Table 5, a Land Use agreement with the Pastoral Lease holder has been executed and meetings have been held with the Shire of Exmouth and Exmouth Community Group.
Table 5: Stakeholder Consultation undertaken for Learmonth Bundle Site
DATE STAKEHOLDERS SUMMARY/STAKEHOLDER
COMMENTS OUTCOME/SUBSEA 7
RESPONSE
28 November 2016
Jane Lefroy and Phil Kendrick (Pastoralist)
Subsea 7
Squire Patton Boggs
This meeting was to introduce the development concept to the Pastoral Lease Holder at the proposed site.
The discussed was well received by the Pastoralist, leading to the discussion of the willingness to formalise a Land Use Agreement (which was agreed and executed over the next 6 months).
28 November 2016
Shire of Exmouth
Subsea 7
Squire Patton Boggs
This meeting was to introduce the development concept to the Shire of Exmouth, and gauge initial feedback on the development and the site selection.
NA
28 February 2017
Office of the EPA
Subsea 7
360 Environmental
This meeting was to introduce the development concept to the EPA Service Unit and the scope of the project from an environmental perspective. As part of the meeting, the results of the initial assessments and research were
NA
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DATE STAKEHOLDERS SUMMARY/STAKEHOLDER
COMMENTS OUTCOME/SUBSEA 7
RESPONSE
presented, and discussion was held on the scope of further assessments and potential key environmental considerations were discussed.
2 May 2017 Department of Planning
Taylor Burrell Barnett
Squire Patton Boggs
The meeting was held to discuss some planning process options that could be available for the proposal. The concept of lodging a modification to the draft LPS 4 was discussed.
NA
8 May 2017 Shire of Exmouth Commissioner
Subsea 7
Taylor Burrell Barnett
Squire Patton Boggs
Claypan Services
Banks-Smith & Associates
The meeting broadly introduced the project to the Exmouth Commissioner. The scope of the project was discussed from a tenure, engineering, environmental, planning, and indigenous heritage and native title perspective.
A number of future meetings will be held to maintain communication with the local government and engagement with other stakeholders.
19 May 2017
Department of Lands
Subsea 7
Squire Patton Boggs
This meeting broadly introduced the development to the Department of Lands. The meeting included discussion on the tenure of the site (given the site is under a Pastoral Lease) including options for obtaining a permit for
NA
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DATE STAKEHOLDERS SUMMARY/STAKEHOLDER
COMMENTS OUTCOME/SUBSEA 7
RESPONSE
non-pastoral use of the site as well as the potential for an excision of the site from the pastoral lease.
30 May 2017
Shire of Exmouth
Subsea 7
Taylor Burrell Barnett
Squire Patton Boggs
The meeting broadly introduced the project to the new Chief Executive Officer of the Shire of Exmouth.
An update on stakeholder engagement and the project programme were discussed. A memorandum was provided to the Shire of Exmouth outlining the requested modification to the draft Local Planning Scheme No. 4.
30 May 2017
Department of Planning
Taylor Burrell Barnett distributed a memorandum to the (then) Department of Planning officers outlining the requested modification to the draft Local Planning Scheme No. 4.
NA
21 July 2017
Office of the EPA
Subsea 7
360 Environmental
Taylor Burrell Barnett
Subsea 7 provided a brief project overview including proposed schedule, construction methods, and proposed environmental approvals process. An update was provided in relation to technical studies that are being undertaken or completed.An update on stakeholder consultation
The Office of the EPA indicated that the modification should aim to align as closely as possible with the section 38 referral (being prepared).
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DATE STAKEHOLDERS SUMMARY/STAKEHOLDER
COMMENTS OUTCOME/SUBSEA 7
RESPONSE
was provided. The proposed modification to the draft LPS 4 was discussed.
23rd August 2017
Shire of Exmouth
Subsea 7
Squire Patton Boggs
Taylor Burrell Barnett
The meeting was held to discuss the options available within the planning process to obtain approvals for the site. The project proponents presented a proposed planning approvals strategy that was discussed by the attendees.
It was agreed to hold a further discussion inclusive of the Department of Planning in order to gain their insight and recommendation as to the correct process to be utilised.
23rd August 2017
Exmouth Community Reference Group
Exmouth Chamber of Commerce and Industry
Gascoyne Development Commission – Exmouth Branch
Subsea 7
Shire of Exmouth
Squire Patton Boggs
This engagement session was planned as the initial community engagement presentation by the proponent in Exmouth. The presentation included an overview of the development, the proponent, and a general opportunity for question and answer within the group. Key queries related to the maintenance of public access to/along the beach, increased traffic volumes on Minilya Rd and identification of the environmental values of the Gulf.
Subsea 7 made a commitment to investigate the issues raised and respond at the next meeting
29th August 2017
Department of This meeting was held as a follow up to the
It was agreed at the discussion that a
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DATE STAKEHOLDERS SUMMARY/STAKEHOLDER
COMMENTS OUTCOME/SUBSEA 7
RESPONSE
Lands, Planning and Heritage
Subsea 7
Squire Patton Boggs
Taylor Burrell Barnett
discussion held on the 23rd August 2017, regarding the appropriate planning process to be utilised for the development. The Department of Lands also were present at the meeting, and some general discussion as held regarding the land tenure.
modification to the existing town planning scheme 3 was the most appropriate process to utilise. It was agreed that further discussion would be held in future meetings.
30th August 2017
Gnulli Working Group (Traditional Owners)
YMAC – Native Title Representative Body
Subsea 7
Squire Patton Boggs
Banks-Smith and Associates
The development was included as an agenda item in the Gnulli Working Group meeting. Subsea 7 and their Native Title Consultants attended the meeting to present an overview of the development, and commence discussions with the Native Title holders of the site.
The meeting resolved to perform a site visit in the coming months with the plan to then conduct a heritage survey of the site. It was resolved that the development would become an agenda item for future meetings of the working group.
21st September 2017
Scheme Amendment Request
The formal request was submitted for the proposed amendment to Town Planning Scheme 3, with the Shire of Exmouth
NA
4th October 2017
Exmouth Community
Exmouth Community
This engagement session was the 2nd community engagement presentation in Exmouth. The session presented an overview of
Subsea 7 confirmed it’s commitment to provide ongoing access to/along the beach, except during
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DATE STAKEHOLDERS SUMMARY/STAKEHOLDER
COMMENTS OUTCOME/SUBSEA 7
RESPONSE
Reference Group
Exmouth Chamber of Commerce and Industry
Gascoyne Development Commission – Exmouth Branch
Subsea 7
360 Environmental
the development, provided responses on the feedback received at the previous engagement session (23rd August 2017), and an update on the progress with the development proposal. The session was also attended by 360 Environmental in order to provide the community with information on the environmental aspects of the development, any potential impacts and the mitigations that are proposed. Key community concerns related to potential water quality (turbidity) impacts during launchway construction and Bundle launch, and impacts on local tourism operators. The Proposal’s impact on the visual amenity of the area was also raised.
a Bundle launch. Subsea 7 confirmed that a traffic study was underway, with mitigation measures (e.g. overtaking lanes) to be investigated. The presentation included a summary of the environmental studies completed to fully characterise the existing environmental values (onshore and offshore). Subsea 7 indicated that any water quality impacts were expected to be minor and short-term, with no long-term impacts to surrounding BCH expected. It was noted that the fabrication shed is likely to be visible from the Minilya Rd and the launchway would be visible at the coast, while the Bundle track will not be visible except from the air.
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DATE STAKEHOLDERS SUMMARY/STAKEHOLDER
COMMENTS OUTCOME/SUBSEA 7
RESPONSE
5th October 2017
Cape Conservation Group
Subsea 7
360 Environmental
A meeting was held with the Cape Conservation Group (CCG) to discuss the development proposal. In the meeting, Subsea 7 and 360 Environmental presented the findings of the surveys and studies that have been conducted in relation to the development, including discussion on the proposed mitigations and management plans for any potential impacts. Key comments included:
The extent of seabed disturbance during Bundle launch, and the extent of water quality impacts;
The degree of flexibility around the timing of a Bundle launch;
How waste will be managed;
Whether the facility will be lit 24/7;
Whether the Proposal site will be fenced; and
How the Proposal is related to the proposal for a deepwater port.
The meeting included question and answer from the CCG. A copy of the draft Marine Fauna Management Plan (MFMP) was given to the CCG for comment in advance of submission with the EPBC Act referral. Subsea 7 confirmed:
The small extent of seabed disturbance during Bundle launch (20 m corridor);
Some flexibility around the timing of a Bundle launch (weather dependent);
Only daylight shifts will be worked except during a Bundle launch;
The Proposal site will be fenced; and
The Proposal is NOT related to the proposal for a deepwater port.
10th October 2017
Department of Biodiversity Conservation and
Phone call and e-mail to introduce the proposal and offer a briefing.
NA
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DATE STAKEHOLDERS SUMMARY/STAKEHOLDER
COMMENTS OUTCOME/SUBSEA 7
RESPONSE
Attractions (DBCA) 10th October 2017
Conservation and Parks Commission (CPC)
Phone call and e-mail to introduce the proposal and offer a briefing. CPC advised that at this stage a briefing was not required and recommended that the DBCA be contacted.
NA
10th October 2017
Department of Transport (DoT) (Marine Safety)
Phone call and e-mail to introduce the proposal and offer a briefing. DoT advised that:
All relevant approvals must be identified and obtained.
All operations and activities must be conducted in accordance with the relevant marine legislative provisions.
A Temporary Notice to Mariners (TNTM) must be issued by DoT for the works (launchway construction/Bundle launch) taking place in state coastal waters prior to the works commencing. A TNTM outlining the scheduled dates, details and scope of the works will be developed and promulgated to
NA
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DATE STAKEHOLDERS SUMMARY/STAKEHOLDER
COMMENTS OUTCOME/SUBSEA 7
RESPONSE
mariners.
The offshore tow(s) in Commonwealth Waters will require relevant notices to be issued by Datacentre / Australian Hydrographic Office.
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6 Environmental Studies and Survey Effort
To identify and assess the environmental constraints relevant to the Proposal, existing baseline environmental information was collated and reviewed. Additional environmental surveys were then commissioned to fill any knowledge gaps and support the thorough assessment of the Proposal. These additional studies included:
Mapping and characterisation of Benthic Community Habitats (BCH) within and adjacent to the Bundle launch area (360 Environmental 2017a) and Bundle ‘Laydown Area’ (360 Environmental 2017f);
Shoreline Movement desktop assessment (M P Rogers & Associates 2017);
Baseline assessment of nearshore water and sediment quality (360 Environmental 2017b);
Desktop assessment of Subterranean Fauna for the Learmonth Bundle Project (Invertebrate Solutions 2017a);
Desktop impact assessment to Subterranean Fauna (Bennelongia Environmental Consultants 2017);
Detailed Flora and Vegetation Assessment (360 Environmental 2017c);
Design Report (Drainage and Coastal Engineering) (GHD 2017c); and
Potable water supply and Treatment Options (GHD 2017d).
Further information regarding the surveys including areas surveyed, survey timing and limitations are provided in Table 6. All current survey reports have been provided in Appendices A-H.
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Table 6: Summary of Studies and Survey Effort for the Proposal
FACTOR CONSULTANT SURVEY NAME STUDY AREA, TYPE AND
TIMING STUDY STANDARD,
GUIDANCE, LIMITATIONS APPENDIX
Benthic Communities and Habitats
360 Environmental Pty Ltd (2017a)
Learmonth Habitat Surveys
Heron Point towed video survey (December 2016)
Local Assessment Unit towed video and infauna survey (May/June 2017)
Bundle laydown area towed video survey (September 2017)
Technical Guidance - Protection of Benthic Communities and Habitats
Appendix A
Coastal Processes
M P Rogers & Associates PL (2017)
Shoreline Movement Assessment
A review of the local shoreline behaviour at the proposed Bundle site, and of the Learmonth Jetty to provided indications of potential shoreline changes (October 2017)
Coastal Demarcation Lines for Administrative & Engineering
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FACTOR CONSULTANT SURVEY NAME STUDY AREA, TYPE AND
TIMING STUDY STANDARD,
GUIDANCE, LIMITATIONS APPENDIX
No. 2.6 (Western Australian Planning Commission 2006)
Marine Environmental Quality
360 Environmental Pty Ltd (2017b)
Baseline assessment of water quality
Baseline assessment of sediment quality
Sites adjacent to Bundle launch route, sediment characterisation and water quality monitoring (December 2016)
Technical Guidance - Protecting the Quality of Western Australia’s Marine Environment (EPA 2016)
Appendix C
Flora and Vegetation
360 Environmental Pty Ltd (2017c)
Detailed Flora and Vegetation Assessment
Survey of the entire Project envelope (May 2017 and September 2017)
EPA Guidance for the Assessment of Environmental Factors: Terrestrial Flora and Vegetation Surveys for Environmental Impact Assessment in WA No. 51 (EPA 2004a)
Technical Guidance – Flora and Vegetation
Appendix D
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FACTOR CONSULTANT SURVEY NAME STUDY AREA, TYPE AND
TIMING STUDY STANDARD,
GUIDANCE, LIMITATIONS APPENDIX
Surveys for Environmental Impact Assessment (EPA 2016)
Subterranean Fauna
Bennelongia Environmental Consultants (2017)
Detailed desktop risk and impact assessment
October 2017 Technical Guidance – subterranean fauna survey (EPA2016a),
September 2017 Technical Guidance – Sampling of short range endemic invertebrate
Appendix H
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FACTOR CONSULTANT SURVEY NAME STUDY AREA, TYPE AND
TIMING STUDY STANDARD,
GUIDANCE, LIMITATIONS APPENDIX
fauna (EPA 2016u).
Hydrological Processes
GHD (2017c) Design Report (Drainage and Coastal Engineering)
Drainage catchments surrounding Proposal development footprint, July 2017
NA NA
GHD (2017d) Potable water supply and Treatment Options – Addendum Report
Bore locations within vicinity of development footprint, September 2017
NA
NA
Social Surrounds
NA Heritage Survey to be completed in last quarter of 2017 once agreement in place (in consultation with the Gnulli Working Group)
To be completed NA NA
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7 Assessment on Preliminary Key Environmental Factors
The referral form and this supporting document have been prepared in accordance with the EPA’s Environmental Impact Assessment (Part IV Divisions 1 and 2) Procedures Manual 2016 and take into account the guidance provided in the:
Instructions on how to prepare an Environmental Review Document (EPA 2016)
Instructions for the referral of a Proposal to the Environmental Protection Authority under Section 38 of the Environmental Protection Act 1986 (EPA 2016); and
Instructions on how to define the key characteristics of a proposal (EPA 2016).
All other relevant EPA guidance material consulted in the development of the Proposal and in undertaking the environmental impact assessment are summarised in Table 4 of Section 4.
7.1 Preliminary Key Environmental Factors
On the basis of the EPA’s ‘Environmental Principles, Factors and Objectives’ guidance, and in consultation with the EPA Service Unit, the following preliminary key environmental factors have been identified for the Proposal:
Benthic Communities and Habitats;
Coastal Processes;
Marine Fauna;
Subterranean Fauna; and
Hydrological Processes.
A table of the preliminary key environmental factors and environmental aspects of the Proposal with potential to have an impact on the environment are provided in Table 7.
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Table 7: Preliminary Key Environmental Factors
FACTOR ENVIRONMENTAL ASPECT IMPACT
Benthic Communities and Habitats (BCH)
Bundle launchway construction
Bundle launch
Direct BCH loss
Direct BCH loss during Bundle launch
Indirect impacts to BCH adjacent to launchway during launchway construction and following seabed disturbance during Bundle launch
Coastal Processes Operation (presence) of Bundle launchway
Changes due to intertidal/subtidal infrastructure
Marine Fauna Bundle launchway construction
Bundle launch and tow
Vessel movements
Loss of foraging habitat
Vessel/Bundle strike
Potential for Introduced Marine Species (IMS) introduction/spread
Subterranean Fauna Construction of infrastructure
Operation (presence) of infrastructure
Groundwater abstraction
Brine and TWW discharges
Clearing of native vegetation, sealing of surfaces
Modified surface water infiltration
Risk of groundwater contamination
Modified groundwater hydrology or quality
Hydrological Processes
Operation (presence) of infrastructure
Modified surface water infiltration
Barrier to surface water flow
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7.2 Assessment of Preliminary Key Environmental Factors
The following tables provide information specific to these preliminary key environmental factors, including:
An outline of the policy context against which the significance of the impacts can be assessed;
A summary of the potential impacts on the environment;
A summary of the proposed mitigation measures;
Details of how the proposed mitigation measures can be regulated; and
An assessment of whether the EPA objectives will be met.
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Table 8: Benthic Communities and Habitats
ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION
MEASURES TO
ADDRESS IMPACTS
PROPOSED
REGULATORY
MECHANISMS FOR
ENSURING
MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
EPA Objective: To protect benthic communities and habitats so that biological diversity and ecological integrity are maintained. EPA Policy and Guidance: Environmental Factor Guideline: Benthic Communities and Habitats (EPA 2016d) Technical guidance – Protection of Benthic Communities and Habitats (EPA 2016h) Existing Environment
Three intertidal BCH types recorded within/adjacent to the Project envelope: Fine sand, Pavement reef and Reef with macroalgae (Figure 7, Appendix A);
Six subtidal BCH types recorded within the LAU: Soft sediment, Soft sediment with turf algae, Soft sediment with spare seagrass, Soft sediment with filter feeders, Reef with macroalgae and Reef with macroalgae and filter feeders (Figure 7, Appendix A);
Within the Bay of Rest several mangrove species were recorded; Grey Mangrove (Avicennia marina), Stilted Mangrove (Rhizophora stylosa) and the Club mangrove (Aegialitis annulata) (Appendix A);
Ten subtidal infauna samples were collected from sites across the LAU using a Van Veen grab. Multi-Dimensional Scaling (MDS) analysis and dendrogram indicated that no site was clearly different from the rest, nor were any sites particularly similar to each other. The inshore sites at Heron Point (IS-1 and IS-2) were around 38% similar and sites IS-7 and IS-11 (both ~3.5 km offshore) were approximately 60% similar (Appendix A); and
No vegetated habitats are present within the Bundle laydown area (Appendix A).
The BCH types identified are all likely to be well represented elsewhere in Exmouth Gulf, although surveys have generally been limited to
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION
MEASURES TO
ADDRESS IMPACTS
PROPOSED
REGULATORY
MECHANISMS FOR
ENSURING
MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
those targeting seagrass habitats, targeted research projects, or those undertaken in support of other infrastructure projects. The inshore filter feeder community (present within the ‘Reef with macroalgae and filter feeders;’ habitat) is likely to be tolerant to short-term extremes in water column turbidity as such events occur under natural conditions. In studies to investigate the tolerance of sponges in the north west of Western Australia, it has been noted that “most sponges survived under low to moderate turbidity scenarios (suspended sediment concentrations of ≤ 33 mg/L, and a daily light integral of ≥0.5 mol photons/m2/day) for up to 28 days” and “all three sponge species exhibited mechanisms to effectively tolerate dredging-related pressures in the short term (e.g. oscula closure, mucus production and tissue regression)” (Pineda et al. 2017). Bundle launchway construction
Based on a 50 m wide disturbance corridor (considered an over-estimate of the potential impacts given the launchway width of 15 m) losses of BCH within the LAU were calculated as follows (Figure 8): Pavement reef (0.2 ha, 5.4%);
and Reef with macroalgae (1.1 ha,
0.3%). Pavement reef habitat is described as ‘Unvegetated pavement reef
Bundle launchway located to avoid high value habitat
Construction material to be screened to remove ‘fines’ (particles <63 μm in diameter)
Construction Environmental Management Plan (CEMP)
The Bundle launchway construction will take up to 6 months, during which periodic, local, impacts to water quality will occur.
The total loss of BCH is minor with a minimal disturbance footprint and thus a significant impact is not expected.
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION
MEASURES TO
ADDRESS IMPACTS
PROPOSED
REGULATORY
MECHANISMS FOR
ENSURING
MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
within the upper littoral zone’ (360 Environmental 2017a) and provides little ecosystem value. Thus a loss of local ecosystem integrity associated with this loss is not expected.
Silt curtains deployed as required to ensure environmental objectives as defined within Construction Environmental Management Plan (CEMP) are achieved.
Biological diversity and ecological integrity of BCH is expected to be maintained for the duration of this Proposal.
Bundle launch/initial tow As the Bundle moves beyond the end of the launchway, the towheads on either end of the Bundle will skid along the seabed. As the towheads move in to deeper water, the buoyancy of the Bundle and towheads increase. Full buoyancy required to float the towheads (so they are no longer in contact with
Pre-determined tow route to minimise width of disturbance corridor during multiple launches.
NA It is expected that an average of two Bundle launches will occur per year (with a maximum of three), however this is subject to client uptake and project pipelines. It is expected that the macroalgae and filter
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION
MEASURES TO
ADDRESS IMPACTS
PROPOSED
REGULATORY
MECHANISMS FOR
ENSURING
MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
the seabed) occurs at a depth of 6 m. This depth mark (at mean sea level) occurs within 1,500 m of the shoreline, and 1,220 m from the offshore end of the Bundle launchway. Bundles will always be launched on a rising (flood) tide. Based on a 50 m wide disturbance corridor (considered an over-estimate of the potential impacts given the Bundle towhead skid approximate width of 6 m) losses of BCH within the LAU were calculated as follows: Reef with macroalgae and filter
feeders (1.7 ha, 0.8%) (Figure 8).
An analysis of surface sediment particle sizes indicated that the sediments along the tow route (sites SQ5 and SQ8) are sand-dominated
feeders on reefs adjacent to the tow route will be tolerant of isolated, short-term, ‘pulses’ of elevated turbidity and as such will not be significantly impacted. Biological diversity and ecological integrity of BCH is expected to be maintained for the duration of this Proposal.
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION
MEASURES TO
ADDRESS IMPACTS
PROPOSED
REGULATORY
MECHANISMS FOR
ENSURING
MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
(70-80%) with a ‘fines’ (<63 μm) content of approximately 10-17% (Appendix C). Therefore significant turbidity plumes following disturbance of the sediment are not expected.
Bundle tow Chains suspended from Bundle will contact the seabed within the Bundle ‘Laydown Area’ (as the Bundle is gently lowered in the water column as the tow is re-configured)
Bundle laydown area located within prawn trawling area and devoid of vegetated habitats
NA Biological diversity and ecological integrity of BCH is expected to be maintained for the duration of this Proposal.
Bundle launch and tow (vessel operations)
Potential for tugs or support vessels to bring introduced marine species (IMS) into Exmouth Gulf
Most, if not all, vessels to be sourced locally.
IMS Risk Assessment procedure for all non-local vessels
Biosecurity Act (2015)
Biological diversity and ecological integrity of BCH is expected to be maintained for the duration of this Proposal.
COPYRIGHT: THIS DOCUM ENT IS AND SHALL REMAIN THE PROPERTY OF 360 ENVIRONMENTAL. THIS DOCUMENT MAY ONLY BE USED FOR THE PURPOSE FOR WHICH IT WAS COMM ISSIONED AND IN ACCORDANCE WITH THE TERMS OF ENGAGEMENT FOR THE COMMISSION. 360 ENVIRONMENTAL DOES NOT HOLD ANY RESPONSIBILITY FOR THE MISUSE OF THIS DOCUMENT.
a 10 Bermondsey St, West Leederville, 6007 WAt (08) 9388 8360f (08) 9381 2360w www.360environmental.com.au
- NOTE THAT POSITION ERRORS CAN BE >5M IN SOME AREAS
Benthic HabitatSoft sedimentSoft sediment with turf algaeSoft sediment with filter feedersSeagrassPavement reefReef with macroalgaeReef with macroalgae and filterfeedersMangrove
COPYRIGHT: THIS DOCUM ENT IS AND SHALL REMAIN THE PROPERTY OF 360 ENVIRONMENTAL. THIS DOCUMENT MAY ONLY BE USED FOR THE PURPOSE FOR WHICH IT WAS COMM ISSIONED AND IN ACCORDANCE WITH THE TERMS OF ENGAGEMENT FOR THE COMMISSION. 360 ENVIRONMENTAL DOES NOT HOLD ANY RESPONSIBILITY FOR THE MISUSE OF THIS DOCUMENT.
a 10 Bermondsey St, West Leederville, 6007 WAt (08) 9388 8360f (08) 9381 2360w www.360environmental.com.au
- NOTE THAT POSITION ERRORS CAN BE >5M IN SOME AREAS
Benthic HabitatSoft sedimentSoft sediment with turf algaeSoft sediment with filter feedersSeagrassPavement reefReef with macroalgaeReef with macroalgae and filterfeedersMangrove
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Table 9 : Coastal Processes
ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION
MEASURES TO
ADDRESS IMPACTS
PROPOSED
REGULATORY
MECHANISMS FOR
ENSURING
MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
EPA Objective: To maintain the geophysical processes that shape coastal morphology so that the environmental values of the coast are protected. EPA Policy and Guidance: Environmental Factor Guideline – Coastal Processes (EPA 2016) Existing Environment
It is recognised under State Planning Policy 2.6 (WAPC 2006) that in the circumstances development may need to occur within an area identified to be potentially impacted by physical coastal processes within the planning time frame. The Proposal is demonstrably dependent on a foreshore location. Suitable management and adaptation planning measures will be developed prior to construction;
Eliot et al (2012) described the susceptibility of coastal landforms to change in the western Exmouth Gulf as low due to partial sheltering from swell and the presence of subtidal terraces and rocky features. Eliot et al (2012) also described the landform instability of Western Exmouth Gulf’s landforms to be low due to sheltered beachfaces and the perching of beaches on inshore rock and moderately stable foredunes;
360 Environmental (2017a, Appendix A) and GHD (2017c) identified the presence of a rocky shore platform in the intertidal zone, as well as a cemented rock-like material along the high tide mark of the beach and that these layers are likely to be shallow, superficial deposits. These layers of rock are likely to increase the stability of the foreshore in this area;
MP Rogers (2017) evaluated the Learmonth Jetty sediment transport regimes and erosion patterns over the last 60-70 years and used it as an appraisal for the proposed Bundle launchway site, since both sites are similar in exposure, aspect and nearshore bathymetry. Shoreline movement assessment based on the Learmonth Jetty indicates there has been some degree of fluctuation in the shoreline
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION
MEASURES TO
ADDRESS IMPACTS
PROPOSED
REGULATORY
MECHANISMS FOR
ENSURING
MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
position, the shoreline adjacent to the abutment has experienced a net accretion trend. The extent of the accretion is much greater on the northern side of the abutment than on the southern side (MP Rogers 2017, Appendix B);
Shoreline movement assessment based on the proposed Bundle facility location has indicated that the shoreline has experienced a long term accretion trend, with an average of around 30 m of accretion occurring in the period between 1949 and 2001. This accretion trend is similar to that experienced at the Learmonth Jetty, although the construction of the jetty abutment resulted in increased accretion rates on the northern side of the abutment due to the partial capture of the southerly longshore sediment transport (MP Rogers 2017, Appendix B); and
Particle size distribution analysis indicates that the shoreline is predominately comprised of medium grained sands with median grain sizes (d50) ranging from 0.15 to 0.5 mm. The predominately sandy nature of these beach materials, together with their medium size, means that longshore sediment transport processes would be expected along these shorelines, although the sediment transport quantities would be expected to be small given the calm nature of the site (MP Rogers 2017, Appendix B).
Bundle launchway construction and operation
Potential changes to sediment transport patterns, as follows:
Accelerated accretion on the shoreline north of launchway (possibly along a 1 km length or more in the long-term);
The shoreline south of the launchway would likely
Design launchway to minimise impacts to long-shore sediment movement. Sand bypassing in the event of significant impact leading to risk to infrastructure,
Annual beach profile monitoring and vegetation line survey to the north and south of the Bundle launchway to assess shoreline changes.
The Learmonth shoreline has experienced net accretion over the longer term. The Bundle launchway is not expected to cause accretion or erosion rates greatly in excess of the historical trends although
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION
MEASURES TO
ADDRESS IMPACTS
PROPOSED
REGULATORY
MECHANISMS FOR
ENSURING
MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
experience a degree of erosion in the first 1 to 2 decades following construction, but this would be limited by the underlying pavement rock outcrops; and
At some stage after the construction it is expected that the shoreline south of the launchway would begin to accrete and any previous erosion trends would be reversed.
recreational values of the shoreline or dune stability.
some local-scale changes may occur. No significant impacts on geophysical processes are expected, such that the social and environmental values of the coast will be protected.
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Table 10: Marine Fauna
ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
EPA Objective: To protect marine fauna so that biological diversity and ecological integrity are maintained. EPA Policy and Guidance: Environmental Factor Guideline Factor – Marine Fauna (EPA 2016) Existing Environment
The migration of humpback whales both north and south past Exmouth Gulf follows predictable but complicated patterns each season. Humpback whales are found in Exmouth Gulf from early August until late November each year (CWR 2004 & 2005);
Whale numbers have historically peaked inside the Gulf during the first two weeks of October, coinciding with the arrival of southbound cow/calf pods from the Kimberly. Cow/calf pods can rest and nurse inside the Gulf for periods of between one and two weeks before continuing their southern migration. This makes the Gulf a critical resting area for this portion of the population (CWR 2004 & 2005);
Whales are predominantly found in water depths greater than 7 m with the greatest number of whales being sighted in the deepest (~20 m) portions of the Gulf (CWR 2004 & 2005). The rate of post-whaling population increase for the west coast populations is thought to be the highest in the world at a rate of between 9.7-13% (Salgago Kent et al. 2012);
Quantitative aerial surveys indicated (in 2004) a minimum Dugong population estimate of approximately 1000 individuals in Exmouth Gulf during winter; a regionally significant population (Oceanwise 2005);
Dugong activity is thought to be focused on the east coast of the Gulf associated with the shallow seagrass habitat in this area; however there is a lack of understanding regarding fine-scale movements and the importance of various habitats for resting, breeding or feeding (Oceanwise 2005); and
Aerial surveys have shown that turtles occur throughout Exmouth Gulf, with densities greatest in the shallow southern and eastern
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
portions of the Gulf. The majority of animals sighted were identified as Green turtles (Oceanwise 2005, Oceanica 2006).
Construction of Bundle launchway
Direct loss of foraging habitat
Minimisation of disturbance footprint
CEMP The habitats within the launchway footprint are well represented elsewhere and do not represent key foraging habitat (seagrass or coral habitat). Biological diversity and ecological integrity of marine fauna will be maintained.
Increase in water column turbidity adjacent to work site causing indirect impact to foraging habitat
Construction material to be ‘clean rock’ rubble
Silt curtains deployed as required (Plate 4)
CEMP The construction of the Bundle launchway is estimated to take up to 6 months. Elevated turbidity is expected to be limited to the immediate surrounds (< 50 m) of the work site. The adjacent habitats are
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
expected to be tolerant of short-term pulses in turbidity and suspended sediment. Biological diversity and ecological integrity of marine fauna will be maintained.
Increase in water column turbidity adjacent to work site causing displacement from key foraging habitat
Construction material to be ‘clean rock’ rubble
Silt curtains deployed as required (Plate 4)
MFMP Elevated turbidity is expected to be limited to the immediate surrounds (< 50 m) of the work site. The adjacent habitats are well represented elsewhere and do not represent key foraging habitat (seagrass or coral habitat), although marine turtles were recorded offshore of Heron Point. Biological diversity and
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
ecological integrity of marine fauna will be maintained.
Low level noise leading to potential local behavioural response during launchway construction (<6 months)
No blasting, piling or rock excavation proposed (rock dumping only)
NA Negligible risk of a significant impact given the low level of underwater noise expected.
Bundle launch Direct loss of foraging habitat as Bundle skids along seabed to floating depth
Towheads and Bundle buoyant once water depth exceeds 6 m.
NA The habitats along the tow route are well represented elsewhere and do not represent key foraging habitat (seagrass or coral habitat), although marine turtles were recorded offshore of Heron Point. Biological diversity and ecological integrity of marine fauna will be maintained.
Increase in water column NA NA The adjacent habitats are
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
turbidity adjacent to Bundle launch route (Figure 8) causing indirect impact to foraging habitat
expected to be tolerant of occasional short-term pulses in turbidity and suspended sediment during a Bundle launch (on average 1-2 , up to 3, Bundle launches will occur per year). Biological diversity and ecological integrity of marine fauna will be maintained.
Direct interaction between marine fauna and tow vessel or bundle during bundle launch/tow (1-2 on average, up to 3 Bundle launches will occur per year)
Bundle launch speed not to exceed 5 knots
Bundle tow speed not to exceed 8 knots
No bundle launches during period of main Humpback whale usage of Exmouth Gulf (nominally mid-September to mid-
MFO
MFMP
Low risk of a significant impact (i.e. direct physical interaction) with marine fauna. Biological diversity and ecological integrity of marine fauna will be maintained.
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
November*)
Marine Fauna Observer (MFO) on board lead support vessel, to identify marine fauna within 500 m ahead of tow, to allow avoidance measures to be implemented (as possible)
Bundle tow Direct interaction between marine fauna and Bundle or tow vessel
As above MFO
MFMP
Low risk of a significant impact (i.e. direct physical interaction) with marine fauna. Biological diversity and ecological integrity of marine fauna will be maintained.
*To be accurately determined through survey prior to initial Bundle launch.
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Table 11: Subterranean Fauna
ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
EPA Objective: To protect subterranean fauna so that biological diversity and ecological integrity are maintained. EPA Policy and Guidance: Environmental Factor Guideline – Subterranean Fauna (EPA 2016k) Technical Guidance – Subterranean fauna survey (EPA 2016s) Technical Guidance - Sampling methods for Subterranean fauna (EPA 2016t) Existing Environment
The "Cape Range Subterranean Waterways", part of the Nationally Important Wetlands (EPA 2017), occurs both within and immediately adjacent to the Project area. This wetland was listed because it is potential stygofauna habitat;
It is considered unlikely that either of the two Threatened Ecological Communities (TECs) – the stygofaunal Cape Range Remipede Community (Bundera Sinkhole) and the troglofaunal Camerons Cave Troglobitic Community – are represented in the Project envelope (Bennelogia 2017, Appendix E);
The three listed troglofauna species that may occur in the Project area will only occur if there is karstic habitat above the watertable. On the basis of existing information, this is considered to be unlikely. The occurrence of other troglofauna species is probably unlikely unless karstic habitat is present (Bennelogia 2017, Appendix E);
Six listed subterranean species may possibly occur in the Project if there is local occurrence of suitable habitat. This includes two stygofaunal fish, the blind gudgeon and blind cave eel, both of which have wide ranges on the peninsula and are quite likely to extend south to the Project area. The stygofaunal shrimp Stygiocaris stylifera, which is a priority 4 species under an informal listing process of the Department of Biodiversity, Conservation and Attractions (DBCA) and subject to slightly less conservation focus, is perhaps even more likely to extend south to the Project area. The shrimp will occur in areas with much smaller voids (i.e. less karstic) than the two fish
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
species; and
Subsea 7 will undertake a geological assessment and sampling for stygofauna within the onshore Project envelope and proposed production bore area(s) once an agreement with the Gnulli has been reached. Following this sampling programme, and further discussions with the technical consultants and stakeholders, including the DBCA, Subsea 7 will finalise the strategies for the proposed groundwater abstraction, RO plant discharge and TWW discharge, taking into account the sampling results and technical advice received. Options for the mitigation of any predicted impacts to subterranean fauna may include the use of a low groundwater abstraction rate across several, widely-spaced bores, and the retention of liquid waste streams within lined ponds.
Construction of Bundle site
Impact to soil or groundwater quality
Ensure vehicles and machinery are regularly maintained to minimise risk of hydrocarbon spills
All chemicals transported in accordance with Australian Codes of Practice
Bunded storage of chemicals
Storage of dangerous goods in accordance with ‘Storage and handling of dangerous goods’ Code of Practice (DMP 2010)
The biological diversity and ecological integrity of subterranean communities will be maintained.
Indirect impacts due to Minimise vegetation CEMP
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
the reduction of organic matter input into the subterranean fauna environment via vegetation clearing or buildings
clearing
Minimise changes to surface water flows and infiltration patterns
Progressive rehabilitation
Operation of Bundle site Approximately 1 km of the bundle track will intersect part of the nationally important Cape Range Subterranean Waterways, as does approximately 2 km of the more northern access road to the launching facility.
Ensure vehicles and machinery are regularly maintained to minimise risk of hydrocarbon spills
All chemicals transported in accordance with Australian Codes of Practice
Bunded storage of chemicals
Storage of dangerous goods in accordance with ‘Storage and handling of dangerous goods’ Code of Practice (DMP 2010)
The biological diversity and ecological integrity of subterranean communities will be maintained.
Abstraction of 16 ML per Abstraction in Rights in Water and
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
annum of groundwater could potentially lower the watertable and lift the underlying saline water, impacting subterranean fauna habitat.
accordance with 5c licence
Groundwater monitoring program (quality and levels)
TWW discharge The irrigation, injection or infiltration of TWW (approximately 16 kL/day) has the potential to substantially alter the composition of any stygofauna community present
Waste water will receive secondary treatment in a containerised plant using a submerged air filter
Alternate disposal method depending upon outcomes of subterranean fauna sampling
Department of Water and Environmental Regulation approval (e.g. Nutrient Irrigation Management Plan)
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- NOTE THAT POSITION ERRORS CAN BE >5M IN SOME AREAS
Subsea 7Bundle Site, LearmonthEPA ReferralFigure 9Subterranean fauna habitat mapping and surface hydrology in relation to the Project Envelope
1:80,000 @ A3
PREPARED FOR
±
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Table 12: Hydrological Processes
ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
EPA Objective: To maintain the hydrological regimes of groundwater and surface water so that environmental values are protected. EPA Policy and Guidance: Environmental Factor Guideline – Hydrological Processes (EPA 2016) Existing Environment
Topography and Geogology
The elevation of the site ranges from about 25 m Australian Height Datum (AHD) at the inland end to 0 m AHD at the coast and generally slopes from the south west end to the north east;
The Phase 3 Geotechnical Desk Study (GHD, 2017) reported the majority of the site to be built on an area characterised by a series of parallel network dunes and residual sand plains made up of red brown to yellow quartz sand. The dunes are approximately 5 m in height and are stabilised by light vegetation comprising grasses and small shrubs; and
Closer to the coast the alignment crosses areas of beach and coastal dunes and areas of supratidal flats which contain mixes of mud and silt where regularly inundated and calcareous clay, silt and sand with some deposits of gypsum and salt where the inundation is more sporadic (limited mainly to high storm surges).
Groundwater
The Phase 3 Geotechnical Desk Study (GHD 2017a) reported that groundwater levels at the site are expected to be at 0 mAHD, or ranging from 2 m to 25 m depth below the land surface; and
Samples from Wogatti Well to the north west of the Project envelope (Figure 9) returned a total dissolved solids (TDS) concentration of 510mg/L.
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
Surface Water and Drainage Catchment
A defined streamline intersects the site approximately 2 km along the proposed bundle track/road corridor from the fabrication facility. The stream has an upper catchment extending approximately 10 km to the west of the site, with a catchment area of 1689 ha (Figure 9);
Another smaller drainage catchment (approximately 155 ha) to the south of the site discharges into the fabrication facility via flow paths between the dunes (Figure 9);
Areas along the bundle track/road corridor and the majority of the northern access track are located in the supratidal flats, do not appear to have any external drainage lines leading in/out, and may be prone to localised flooding following heavy rainfall events; and
A previous hydrological study (Hyd2o 2013) identified that the modelled 100 Year ARI flood extent intersects with much of the Project envelope.
Presence of bundle launchway
Alteration of natural surface water flows
Drainage design to minimise disruption to natural flows
Minimise footprint to minimise changes to water infiltration
NA The proposal will potentially alter surface water flows following construction of the Bundle track. Impacts will be managed through appropriate drainage design. Significant impacts to surface water flows are not expected.
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ENVIRONMENTAL
ASPECT INHERENT IMPACT MITIGATION MEASURES
TO ADDRESS IMPACTS PROPOSED REGULATORY
MECHANISMS FOR
ENSURING MITIGATION
OUTCOME TO MEET EPA
OBJECTIVE
Impact to Bundle site infrastructure during/following flooding
Cyclone preparations completed across site ahead of forecast cyclone/extreme event
Bundle and Bundle track can be flooded without damage
NA It is expected that the groundwater and surface water regimes will be preserved so that environmental values are protected.
Operation of Bundle Site Abstraction of groundwater affecting groundwater recharge regime
Operate within limits of water abstraction licence
Re-use of hydrotest water
Minimise water use on site
DWER Licence to abstract water under Section 5C of the Rights in Water and Irrigation Act 1914.
It is expected that the groundwater and surface water regimes will be preserved so that environmental values are protected.
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8 Other Environmental Factors
The EPA Scoping Guidelines identifies ‘other’ environmental factors that are not considered key factors, but have the potential to be affected by the Proposal. For this Proposal, these include:
Flora and Vegetation
Terrestrial Environmental Quality
Terrestrial Fauna
Inland Waters Environmental Quality
Social surroundings
These factors are not expected to be assessed in detail by the EPA due to the very low likelihood of impact, the low level of impact and the mitigation measures that Subsea 7 will implement to manage any aspects. Table 13 outlines the considerations of these factors relevant to the Proposal.
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Flora and Vegetation EPA Objective: To protect flora and vegetation so that biological diversity and ecological integrity are maintained.
A total of 74 taxa (including species, subspecies, varieties and forms) from 56 genera and 25 families were identified in the Survey Area.
Three introduced species were recorded within the Survey Area;
One species Corchorus congener a Priority 3 listed species was recorded in multiple sites across the Survey Area, and is considered likely to occur commonly outside of the Survey Area; and
The vegetation condition ranged from Very Good to Completely Degraded (Appendix D).
Construction of Bundle site
Clearing of vegetation Loss of native vegetation
Loss of individuals of a priority 3 flora species
Increased dust leading to reduced vegetation health
Spread or introduction of weeds
Minimise clearing
Progressive rehabilitation will be undertaken on any temporary construction areas as they become available
Topsoil and vegetation will be retained in low stockpiles, to be respread over rehabilitation areas
Clearing will result in the loss of vegetation. The majority of clearing being within the Sheppard et al. vegetation association: Coastal Dunes 662 which is well represented at a state, regional and subregional level with more than 99% remaining at all levels. Progressive rehabilitation will be undertaken.
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CEMP to include procedures for equipment hygiene management
Water cart on site during clearing
Cleared surfaces to be stabilized as soon as possible to minimise wind erosion
One priority 3 species will be impacted (Corchorus congener), however it is widespread within the wider environment and not confined to the Project envelope. Flora and vegetation will be protected so that biological diversity and ecological integrity are maintained
Terrestrial Environmental Quality EPA Objective: To maintain the quality of land and soils so that environmental values are protected
Low risk of contaminated soils across the Project envelope;
Acid Sulphate Soils unlikely to occur;
Minimal excavation required for the Proposal.
Construction of Bundle site
Clearing of vegetation Increased soil erosion following rainfall
Minimise clearing
Appropriate drainage design to manage
Impacts to terrestrial environmental quality are expected to be minimal
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with appropriate drainage design and chemical storage and handling procedures in place. The quality of land and soils will be protected so that environmental values are protected.
Construction and Operation of Bundle site
Storage of hydrocarbons Soil contamination due to spill/leak
Bunded storage
Weekly inspections
Spill kits at all chemical storage sites
Construction and Operation of Bundle site
Handling of hydrocarbons Soil contamination due to spill/leak
Re-fuelling procedure
Designated, bunded, re-fuelling areas
Spill kits available at re-fuelling areas
Terrestrial Fauna EPA Objective: To protect terrestrial fauna so that biological diversity and ecological integrity are maintained
A total of 47 conservation significant species (including Priority species) were considered from desktop assessment to potentially occur in the Survey Area;
During the field assessment 40 species from 29 families were recorded ( five reptile species from five families, 29 bird species from 20 families and six mammal species from four families);
Six conservation significant species were recorded; the Osprey, Lesser Sand Plover, Caspian Tern, Lesser Crested Tern, Crested Tern
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No ‘critical habitat’ for any of these species was recorded within the Survey Area (Appendix G); and
The potential for impacts to SRE fauna, if present, are currently considered low from the proposed development (Appendix H).
Construction of Bundle site
Clearing of vegetation Loss and/or fragmentation of fauna habitat resulting in displacement of fauna;
Introduction of new weeds species or attraction of feral animal species impacting native fauna
Minimise clearing
Domestic waste facilities and putrescible waste will be secured to prevent pest fauna entry
The movement of larger fauna across the Bundle track will be prevented, via fencing which is a requirement of the Department of Lands and considered beneficial for safety reasons. Vehicle strikes within the Project envelope are unlikely given the required fencing and slow speeds on site. Terrestrial fauna will be protected so that biological diversity and ecological integrity are maintained.
Vehicle movements Vehicle/fauna strike causing injury or death
Fencing
Speed limits
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Inland Waters Environmental Quality EPA Objective: To maintain the quality of groundwater and surface water so that environmental values are protected. Construction and Operation of Bundle site
Storage of hydrocarbons Surface or groundwater contamination due to spill/leak
Bunded storage
Weekly inspections
Spill kits at all chemical storage sites
The quality of groundwater and surface water are unlikely to be impacted and the environmental objective will be met.
Construction and Operation of Bundle site
Handling of hydrocarbons Surface or groundwater contamination due to spill/leak
Re-fuelling procedure;
Designated, bunded, re-fuelling areas;
Spill kits available at re-fuelling areas.
Operation of Bundle site Disposal of TWW Discharge causing contamination of surface water and/or groundwater
pending outcomes of subterranean fauna sampling and stakeholder meetings.
Disposal of RO discharge Discharge causing change to quality of surface water and/or groundwater
Water quality monitoring
Implementation of suitable management approach pending outcomes of subterranean fauna sampling and stakeholder meetings.
The quality of groundwater and surface water are unlikely to be impacted and the environmental objective will be met.
Social Surroundings EPA Objective: To protect social surroundings from significant harm
Subsea 7 has one other existing bundle base globally, in Wick, Scotland. This site is the only site of its kind that is permanently operated for Bundle developments. The site has been in long-term operation, and will be celebrating its 40th year in 2018. This site is directly analogous to the goal for the Learmonth development, whereby the site has provided a long-term and stable employment base for local personnel. At present, approximately 95% of the Wick workforce is locally based. Subsea 7 aim is to achieve a similar model at Learmonth where possible.
Other benefits of a Bundle site in Learmonth extend beyond the direct employment opportunities during Bundle projects and, based on
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Subsea 7’s Bundle site at Wick, are likely to include:
o Apprentice Scheme – Subsea 7 have implemented an Apprenticeship Scheme at the Wick Site, providing sponsored opportunities for local school leavers to obtain a trade. Importantly, Subsea 7’s community engagement at Exmouth has identified that one of the key issues for Exmouth residents is the lack of employment opportunities for school leavers, which eventually results in young people having to leave the community in search of employment. Subsea 7 is committed to implementing a similar scheme in Exmouth, and has already begun discussion with the local TAFE on this item;
o Environmental Responsibility – Subsea 7 are acutely aware of the responsibility that comes with proposing a development in the vicinity of the Ningaloo coast. Subsea 7 is committed to ensuring that no harmful impact is made to the environment. In this vein, Subsea 7 have been actively involved in environmental initiatives at the Wick site over a number of years, including:
Tern Relocation Project – Subsea 7 was a major partner and contributor to a tern relocation project at Wick. Subsea 7’s efforts helped to successfully increase the tern population, which had been decreasing over time;
Dune Stabilisation – Subsea 7 worked collaboratively with universities and scientists in order to assist the performance of studies and projects regarding the stabilisation of sand dunes in the area; and
Beach cleans – The bundle site personnel and equipment are regularly utilised to perform beach cleans up and down the Wick coast; and
o Local Expenditure – for a typical Bundle project at Wick, 4-5 million pounds sterling ($6.5m to $8.5m) is typically spent in the local community.
Construction and operation of Bundle Site
Infrastructure presence Fabrication shed visible from Minilya-Exmouth road and from the air
Design of buildings to minimise visual impact
It is expected the EPA objective can be met.
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Plate 5: Conceptual imagery of Bundle fabrication site. Left: elevated view from north-west (Bundle pipe storage racks [black rectangles] will be a maximum of 2 m above ground level]). Right: elevated view of from the north-east)
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9 Principles of the EP Act
Section 4A of the EP Act outlines the objective of the Act and the principles of environmental protection. This section describes how the five principles of the EP Act have been addressed by Subsea 7 in the consideration and design of the Proposal. A description of these principles and how they have been considered is provided in Table 14.
Table 14: Principles of the EP Act
PRINCIPLE CONSIDERATION OF PRINCIPLE IN PROPOSAL
1. The Precautionary Principle Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. In the application of the precautionary principle, decision should be guided by:
a. Careful evaluation to avoid, where practicable, serious or irreversible damage to the environment; and
b. An assessment of the risk-weighted consequences of various options.
Subsea 7 has undertaken comprehensive environmental studies on aspects of the Proposal that may impact the environment, including BCH, terrestrial flora and fauna surveys, coastal processes and marine fauna. These studies have described the existing environment and identified the potential impacts from the Proposal. Further studies on subterranean fauna will be completed when possible.
The Proposal design has taken into account the outcomes of the environmental studies.
The final water source strategy and wastewater discharge strategies will be finalised based on the findings of further studies, in consultation with the relevant agencies.
Management and mitigation measures to minimise potential environmental impacts during construction and operation will be addressed in a Construction Environmental Management Plan (CEMP) and Operational Environmental Management Plan (OEMP).
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PRINCIPLE CONSIDERATION OF PRINCIPLE IN PROPOSAL
2. The Principle of intergenerational equity The present generation should ensure that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations.
Subsea 7 commits to manage environmental impacts within their control, such that adverse impacts are minimised and the quality of the environment is maintained or enhanced wherever possible.
3. The Principle of the conservation of biological diversity and ecological integrity
Conservation of biological diversity and ecological integrity should be a fundamental consideration
Impacts to BCH will be at a local scale and will not impact the biological diversity and ecological integrity of the Heron Point area.
Impacts to marine fauna will be managed through the implementation of a MFMP to maintain the biological diversity and abundance of marine fauna in Exmouth Gulf.
Impacts to terrestrial vegetation, flora and fauna are not expected to be significant, or pose a risk of loss of biological diversity and ecological integrity.
4. Principles relating to improved valuation, pricing and incentive mechanisms a. Environmental factors should be included in the
valuation of assets and services b. The polluter pays principle – those who generate
pollution and waste should bear the cost of containment, avoidance or abatement.
c. The user of goods and services should pay prices based on the full life cycle costs of providing goods
Where possible, Subsea 7 will employ appropriately trained local personnel and source local goods and services.
Subsea 7 will ensure leading best practice standards during construction and operations to minimise emissions and discharges as far as possible and ensure no negative legacies are created.
Where possible Subsea 7 will source goods and services that have the least environmental impact.
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PRINCIPLE CONSIDERATION OF PRINCIPLE IN PROPOSAL
and services, including the use of natural resources and assets and the ultimate disposal of any wastes.
d. Environmental goals, having been established, should be pursued in the most cost effective way, by establishing incentive structures, including market mechanisms, which enable those best placed to maximise benefits and/or minimise costs to develop their own solutions and responses to environmental problems.
5. The principle of waste minimisation All reasonable and practicable measures should be undertaken to minimise the generation of waste and its discharge into the environment.
Waste generated from the Proposal will be minimised through the implementation of the hierarchy of waste controls; avoid, re-use, recycle, recover and dispose.
Waste avoidance and minimisation objectives will be outlined in the CEMP and OEMP.
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10 Conclusion
The Proposal is to construct and operate a new Bundle construction facility. The proposal includes access tracks, a storage area where the Bundle materials will be stored prior to use, a Bundle fabrication shed, supporting infrastructure including a Reverse-Osmosis (RO) plant and wastewater treatment plant, and two approximately 10 km long Bundle tracks along which Bundles will be constructed and then launched. A Bundle launchway, crossing the beach and extending into the shallow subtidal area, will facilitate the launch of each Bundle.
The Project envelope (or ‘the Site’), defining the potential maximum extent of physical disturbance, covers approximately 502 ha. In addition, a 2,407 ha Bundle ‘Laydown Area’ has been defined, within which the Bundle may be temporarily held following launch, with chains resting on the seabed. Within the onshore area, a total of 170 ha may be disturbed as a result of the Proposal.
On average one to two Bundles may be constructed and launched each year at the Site.
On the basis of the EPA’s ‘Environmental Principles, Factors and Objectives’ guidance, and in consultation with the EPA Service Unit, the following preliminary key environmental factors have been identified for the Proposal:
Benthic Communities and Habitats;
Coastal Processes;
Marine Fauna;
Subterranean Fauna; and
Hydrological Processes.
The preliminary key environmental factors have been assessed against the EPA objectives and guidelines and it is considered that the Proposal will meet the EPA’s objectives for these factors given the following:
Direct impacts to BCH are limited to a narrow corridor along the Bundle launch route, out to a water depth of no more than 6 m;
Any impacts to water quality during launchway construction or Bundle launch will be limited to short term impacts, unlikely to impact the BCHs that are naturally tolerant to periodic high turbidity and suspended sediment concentrations;
Changes in coastal processes adjacent to the launchway are not predicted to change significantly;
Marine fauna are known to be widespread and abundant within Exmouth Gulf but the risk of significant impact to marine fauna is low given the proposed mitigation
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measures including no Bundle launches during the peak of the Humpback whale southern migration and low tow speeds;
Subterranean fauna is recognised as a potential issue and sampling will be completed prior to finalisation of the final water abstraction, TWW discharge and RO discharge strategies; and
Significant impacts to hydrological processes are not expected given the proposed management of surface water flows and further work to be completed to determine the most suitable option for water abstraction and the licencing process under the RIWI Act.
Significant community and stakeholder consultation has been undertaken to date, and will continue throughout the detailed design, construction and operational phases of the Project.
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11 References
360 Environmental, 2017a. Subsea 7 Learmonth Habitat Surveys. Report on behalf of Subsea 7.
360 Environmental, 2017b. Learmonth Bundle Launch Site Baseline Water and Sediment Quality Assessment. Report on behalf of Subsea 7.
360 Environmental, 2017c. Australian Bundle Site – Detailed Flora and Vegetation Assessment. Report on behalf of Subsea 7.
360 Environmental, 2017d. Learmonth Level 1 Fauna Survey. Report on behalf of Subsea 7.
360 Environmental, 2017e. EPBC Act Referral - Learmonth Bundle Site, WA. Report on behalf of Subsea 7.
360 Environmental, 2017f. Subsea 7 Bundle laydown area BCH survey report. Report on behalf of Subsea 7.
Biosecurity Act 2015. Available at: https://www.legislation.gov.au/Details/C2015A00061 (Accessed: 13 October 2017)
Bureau of Meteorology (BoM) 2017. Weather and Climate Data, accessed 29 May 2017 from http://www.bom.gov.au/climate/data/. Commonwealth of Australia.
Centre for Whale Research (WA) Inc. (CWR) 2004. Current State of Knowledge: Humpback Whale (Megaptera novaeangliae) Survey Report for Exmouth Gulf 1995-2004
Centre for Whale Research (WA) Inc. (CWR) 2005. Distribution and Abundance of Humpback Whales and Other Mega Fauna in Exmouth Gulf, Western Australia, During 2004/2005. Report prepared for Straits Resources. Perth.
Commonwealth of Australia, 2001, National Objectives and Targets for Biodiversity Conservation 2001-2005, Canberra.
Department of Mines and Petroleum. 2010. Storage and handling of dangerous goods — code of practice (2nd edition): Resources Safety, Department of Mines and Petroleum, Western Australia, 111 pp.
Department of Parks and Wildlife (DPaW) 2013b. Weed Prioritisation Process for DPaW – An integrated approach to Weed Management on DPaW managed lands in WA. Government of Western Australia.
Department of Planning (DoP) 1999. Shire of Exmouth Town Planning Scheme No. 3, Scheme Text. Government of Western Australia.
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Department of the Environment and Energy (DotEE) 2017b. EPBC Protected Matters Search Tool, accessed 8 June 2017 from http://www.environment.gov.au/webgis-framework/apps/pmst/pmst.jsf, Commonwealth of Australia.
Department of Transport (DoT), 2009. Coastal Demarcation Lines for Administrative & Engineering Purposes: Delineation Methodology & Specification. Government of Western Australia, Perth
Department of Water (DoW), 2015. RIWI Act Groundwater Areas. GIS Dataset. Government of Western Australia.
Environmental Protection Authority (EPA) 2001. Guidance Statement (1) for protection of tropical arid zone mangroves along the Pilbara Coastline. EPA, Western Australia.
EPA 2009. Environmental Assessment Guideline No. 3. Protection of Benthic Primary Producer Habitats in Western Australia’s Marine Environment. EPA, Western Australia.
EPA 2012. A review of subterranean fauna assessment in Western Australia - Discussion paper. EPA, Western Australia.
EPA 2013a. Environmental Assessment Guideline 12 – Consideration of subterranean fauna in environmental impact assessment in WA, EPA, Western Australia.
EPA 2013b. Draft Guidance Statement No. 54A: Sampling Methods and Survey considerations for subterranean fauna in WA, EPA, Western Australia
EPA 2016a. Statement of Environmental Principles, Factors and Objectives. EPA, Western Australia.
EPA 2016m, Environmental Factor Guideline: Terrestrial Fauna, EPA, Western Australia.
EPA 2016n, Technical Guidance: Flora and Vegetation Surveys for Environmental Impact Assessment, EPA, Western Australia.
EPA 2016o, Technical Guidance: Terrestrial fauna surveys, EPA, Western Australia.
EPA 2016p, Environmental Factor Guideline: Social Surroundings, EPA, Western Australia.
EPA 2016q, Instructions on how to prepare and Environmental Review Document, EPA, Western Australia. Available from: http://www.epa.wa.gov.au/sites/default/files/Forms_and_Templates/PMI_How%20to%20prepare%20Environmental%20Review%20Document_220817.pdf
EPA 2016r, Instructions on how to define the key characteristics of a proposal, EPA, Western Australia. Available from: http://www.epa.wa.gov.au/sites/default/files/Forms_and_Templates/PMI_Define%20Key%20Characteristics%20of%20a%20Proposal_220817.pdf
EPA 2016s. Technical Guidance – Subterranean fauna survey. EPA, Western Australia
EPA 2016t. Technical Guidance - Sampling methods for Subterranean fauna. EPA, Western Australia.
EPA 2016u. Technical Guidance – Sampling of short range endemic invertebrate fauna. EPA, Western Australia.
GHD, 2017a. Report for Subsea 7 Offshore Bundle Fabrication Facility, Phase 3 – Design Geotechnical Desk Study. Perth, Western Australia.
GHD, 2017b. WA Bundle Fabrication Facility Site Design - Cyclonic Storm Study. Perth, Western Australia.
GHD, 2017c. WA Bundle Fabrication Facility - Site Designs. Design Report (Drainage & Coastal Engineering). Perth, Western Australia.
GHD, 2017d. Pipeline Bundle Fabrication Facility – Water Supply and Treatment Options. Perth, Western Australia.
Hydr2o Hydrology, 2014. Exmouth Hydrological Study, Prepared for the Shire of Exmouth.
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Invertebrate Solutions, 2017a. Desktop Assessment of Subterranean Fauna for the Learmonth Bundle Project, Cape Range, Western Australia. Technical Report.
Invertebrate Solutions, 2017b. Desktop Assessment of Short Range Endemic Invertebrates for the Learmonth Bundle Project, Learmonth, Western Australia.
MP Rogers & Associates Pl (MP Rogers), 2017. Subsea 7 Bundle Facility Shoreline Movement Assessment R967 Rev 1. Report prepared on behalf of Subsea 7
Pineda, M., Strehlow, B., Kamp, J., Duckworth, A., Jones, R. and Webster, N. 2017. Effects of combined dredging related stressors on sponges: a laboratory approach using realistic scenarios. Scientific Reports 7: 5155.
Ramsar, 1971. The Ramsar Convention Manual – A Guide to the Convention of Wetlands, No. 6.
Salgado Kent, C., C. Jenner, M. Jenner, P. Bouchet & E. Rexstad (2012). Southern Hemisphere breeding stock D humpback whale population estimates from North West Cape, Western Australia. Journal of Cetacean Research. 12:29-38.
Shepherd, D. P., Beeston, G. R., and Hopkins, A. J. M. 2001. Native Vegetation in Western Australia (Technical Report 249). Perth: Department of Agriculture.
Shute, S. 2017. Principal Environmental Scientist, 360 Environmental. Personal communication reporting observations made during the completion of field studies in December 2016 and May 2017.
State Heritage Office (SHO) 2017. State Register of Heritage Places, Accessed 8 June 2017 from http://inherit.stateheritage.wa.gov.au/Public/. Government of Western Australia.
Straits. 2006. Yannarie Solar Environmental Review and Management Programme.
Subsea 7, 2017. Pipeline Bundle Geographical Migration Study – Pipeline Bundle Fabrication Site Design Basis. LEA-ENG-0001.
Taylor Burrell Barnett (TBB), 2017. Modification Request for Shire of Exmouth Draft Local Planning Scheme No.4. Report prepared on behalf of Subsea 7.
Western Australian Planning Commission. 2006. State Planning Policy No. 2.6.
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12 Limitations
This report is produced strictly in accordance with the scope of services set out in the contract or otherwise agreed in accordance with the contract. 360 Environmental makes no representations or warranties in relation to the nature and quality of soil and water other than the visual observation and analytical data in this report.
In the preparation of this report, 360 Environmental has relied upon documents, information, data and analyses (“client’s information”) provided by the client and other individuals and entities. In most cases where client’s information has been relied upon, such reliance has been indicated in this report. Unless expressly set out in this report, 360 Environmental has not verified that the client’s information is accurate, exhaustive or current and the validity and accuracy of any aspect of the report including, or based upon, any part of the client’s information is contingent upon the accuracy, exhaustiveness and currency of the client’s information. 360 Environmental shall not be liable to the client or any other person in connection with any invalid or inaccurate aspect of this report where that invalidity or inaccuracy arose because the client’s information was not accurate, exhaustive and current or arose because of any information or condition that was concealed, withheld, misrepresented, or otherwise not fully disclosed or available to 360 Environmental.
Aspects of this report, including the opinions, conclusions and recommendations it contains, are based on the results of the investigation, sampling and testing set out in the contract and otherwise in accordance with normal practices and standards. The investigation, sampling and testing are designed to produce results that represent a reasonable interpretation of the general conditions of the site that is the subject of this report. However, due to the characteristics of the site, including natural variations in site conditions, the results of the investigation, sampling and testing may not accurately represent the actual state of the whole site at all points.
It is important to recognise that site conditions, including the extent and concentration of contaminants, can change with time. This is particularly relevant if this report, including the data, opinions, conclusions and recommendations it contains, are to be used a considerable time after it was prepared. In these circumstances, further investigation of the site may be necessary.
Subject to the terms of the contract between the Client and 360 Environmental Pty Ltd, copying, reproducing, disclosing or disseminating parts of this report is prohibited (except to the extent required by law) unless the report is produced in its entirety including this page, without the prior written consent of 360 Environmental Pty Ltd.
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APPENDIX A Learmonth Habitat
Surveys
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APPENDIX B Shoreline Movement
Assessment
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APPENDIX C
Baseline Water and Sediment Quality
Assessment
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APPENDIX D
Detailed Flora and Vegetation
Assessment
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APPENDIX E
Subterranean Fauna Detailed Desktop
Risk and Impact Assessment
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APPENDIX F
Desktop Assessment of
Subterranean Fauna for the Learmonth
Bundle Project
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APPENDIX G
Learmonth Level 1 Fauna Survey
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