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Response to Submissions

Shenhua Watermark RTS

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Q. How Is Shenhua Watermark currently operating the land it owns ?
A. There are several existing agricultural enterprises, operated by licencees who are former owners
utilising traditional grazing and cropping operations on Shenhua Watermark owned land.

Q. What will happen with the agriculturally productive land within the disturbance boundary ?
A. Any land that is situated within the Disturbance Boundary will be removed from agricultural
production progressively over 30 years as a result of the Project. Shenhua Watermark proposes
to reinstate at least 1,000 hectares of the rehabilitated Land Capability Class III land to primary
production.

Q. What is the value of agricultural land that is required for the Project ?
A. In total, the foregone net value of agricultural production from land resources required for the
Project is estimated at a present value of $40 Million.

Q. What mitigation measures will be implemented to maintain and enhance the agricultural
productivity of the land ?

A. To maintain and where possible enhance, the agricultural productivity of Shenhua Watermark
owned land, the following management measures will be applied:

• Minimise the area of disturbance of land at any one time;

• Continue to work with land managers to ensure the highest productivity of
Shenhua Watermark owned land is not directly impacted by the Project;

• Develop and implement a weed and pest management plan to control the distribution of
invasive plant species and feral animals. Implement sustainable farming practices.
Rehabilitate the mining areas to the best possible rural land capability (including not
less than 3,230 ha of Class III rehabilitated land) with slopes less than approximately
10 degrees; and

• Reinstate at least 1,000 hectares of the rehabilitated Class III land to primary production.

Q. Where has BSAL been identified and verified? 
A. The site verification found that approximately 96 ha of BSAL is present within the Disturbance Boundary and 696 ha of BSAL was present within the Onsite Biodiversity Offset Areas (Offset Area 6). No BSAL was verified to occur within the Offsite Biodiversity Offset Areas.

In response to stakeholder concerns, Shenhua Watermark has excluded all of the BSAL that was initially in the Onsite Biodiversity Offset Areas. In this regard, the Project will only impact on approximately 96 ha of BSAL.
 
Q. What is the assessment of agricultural production foregone at a regional scale as a result of the Project, having consideration of the changes to Offset Area 6 and the Additional Offsite Biodiversity Offset Area? 
A. The direct annual agricultural production from the land and water resources that would potentially be impacted by the Project is estimated at approximately $4.5 M. The direct annual output of the Project is estimated at $744 M. This is greater than the annual value of total agriculture production in the local region in 2011.  It is also relevant to note that the rehabilitation of the Project Boundary will reinstate the land for agricultural and biodiversity conservation purposes and as such, is not forgone from agriculture use in perpetuity.
 
Q. What are the predicted changes in groundwater as a result of the Project and the potential impact that this has on external agricultural enterprises?
A. The Project is predicted to result in the annual average relocation of approximately 194 ML/annum of water. The associated draw down is predicted to be less than the 2 m maximum minimal harm criterion as specified by the AIP. This reduction represents a negligible change in groundwater availability to adjacent groundwater users.

The impact of removing 194 ML/annum from agricultural use results in a gross value loss of $104,234 per annum and a net value loss of $56,809 per annum
Shenhua Watermark proposes to utilise nearby available water sources in accordance with the relevant water sharing plans and Water Access Licences (WALs) to account for the predicted groundwater use In this regard, the Project will not place additional pressure on other water users, including those associated with agricultural enterprises, beyond that allocated within the relevant water sharing plans for those water sources.

Q. What are the predicted changes in surface water regimes as a result of the Project and the impact that this has on external agricultural enterprises.
A. The Project will require up to 600 ML of water from external sources to supply operational demands in dry periods (average of 150 ML/annum). A suite of extraction options are available on Shenhua Watermark-owned land to obtain sufficient yield with adequate water quality to provide the maximum external make-up water supply for the Project. Furthermore the Project will result in a reduction in some catchment flows during and post mining.

The Project's predicted use of water will be accounted for by means of WALs for each applicable water source in accordance with the relevant water sharing plan. Such plans consider the cumulative impacts of all water uses in the catchment to ensure the environmental needs of the catchment are satisfied. In this regard, the Project  (when considered alone and cumulatively) will not place additional pressure on other water users, including those associated with agricultural enterprises, beyond that allocated within the relevant water sharing plans for those water sources.

Any release of water from the sediment dams will be of a quality that is similar to the receiving waters in accordance with EPL limits. If the quality of this water is not suitable for release to receiving waters, it will be pumped back into the mine water management system.  On this basis, any release of water from the sediment basins is not expected to impact on the downstream water quality and land resources.

Furthermore, under the full range of historical rainfall conditions, the proposed mine water management system will have sufficient capacity to contain all “mine water” on the site without the need for offsite releases (discharges). The water quality of the surrounding environment will therefore be maintained.
 
Q. What are the predicted dust levels to be generated from the Project and the potential impact that this matter has on external agricultural enterprises?
A. Air quality modelling has indicated that the Project considered cumulatively with other sources is not predicted to contribute to exceedances of the annual average TSP, dust deposition, PM10 and PM2.5 criteria at privately owned receivers (within 5 km of the Project) over the life of the Project. In this regard, the potential for a significant impact of dust on agricultural resources and enterprises in the locality is minimal.

Furthermore, available literature (CSIRO, 2009; Dooley and Rossato, 2010; Andrews and Skriskandarajah, 1992; Kannegieter, 2006) and correspondence from industry experts suggest that the predicted dust deposition rates generated by the Project (2 g/m2/month) will have minimal impact on the productivity or health of cotton or livestock situated in the immediate vicinity of the Project Boundary, including enterprises associated with the agricultural land reserve.
 
Q. What are the predicted noise and vibration levels generated from the Project and the potential impact that this has on external agricultural enterprises?
A. Recent amendments to the mobile equipment fleet have significantly reduced the Project’s noise impact experienced at a number of surrounding receivers, including those associated with agricultural enterprises.

For those receivers in the immediate vicinity of the Project, including livestock on the agricultural land reserve, the predicted noise level will range between 35 to 45 dBA on average under worst case meteorological and operating conditions.

A study by Heffner and Heffner (1983) suggests that noise generated from the Project at 45 dBA correlates with frequencies within the range of hearing for cattle. However, given that these frequencies are not close to the best point of hearing in cattle the Project is not anticipated to have any significant impact on the health or productivity of cattle run on the agricultural land reserve.

Given that there are no other existing significant sources of industrial noise in the vicinity of the Project, cumulative impacts are considered negligible.
 
Q. What is the potential for the Project to impact on the organic standards of agricultural enterprises in the locality of the Project Boundary?

A. Given the environmental mitigation and management measures proposed, the Project will not significantly impact on agricultural enterprises external to the Project Boundary and their production. As such, the Project will not jeopardise the organic standards of agricultural enterprises in the locality of the Project Boundary.

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