How to appeal the EPA’s Report on the Blue Hills Mungada East Expansion Project

The information below has been prepared by Sinosteel Midwest Corporation (SMC) to assist those who wish to make an appeal against the Report and recommendations of the EPA on the company’sBlue Hills Mungada East Expansion Project.

The EPA has recommended that the extension of the existing Blue Hills Project not be approved. The recommendations are based on the EPA conclusions thatthe key environmental factors of Landforms, Flora and Vegetation, and Social Surroundings impacts are not manageable and remain significant.

A copy of the EPAs Report can be found here:

The Blue Hills Mungada East Expansion Project is an important project for the continued development of the Mid West region, so we encourage you to review the EPA’s Report and formally express your views prior to the end of the appeal period at 5.00pm on 12 July 2017.

To be considered by the Appeals Convenor, your appeal must clearly state the grounds of appeal, including reasons why you believe the Minister for Environment should approve the expansion project and the outcome you seek. To assist you, SMC has outlined grounds for appeal below which you may choose to use.

Appeals may be lodged by going to the Office of Appeals Convenor website and clicking on the “Appeal Form” link on the home page. The Appeals Convenors website can be accessed by clicking here: appealsconvenor.wa.gov.au/

Alternatively, you may wish to write to the Appeals Convenor. To assist you, SMC has drafted a letter (attached) that outlines the key grounds of appeal and outcome sought. The letter is a guide only and may be amended to better reflect your concerns.

Letters of appeal will not be accepted by the Appeals Convenor unless they:

are in writing;

specify the name of the EPA Report: Blue Hills Mungada East Expansion, EPA Report 1598;

clearly identify the matter or decision being appealed (see ‘Grounds of appeal’ below);

state the outcome being sought e.g. the project be approved;

are accompanied by a $10 appeal fee made payable to the ‘Appeals Convenor’ (Payment can be made by Visa, MasterCard, cheque, cash (only if the appeal is hand delivered) or money order);

are signed by the appellant; and

are lodged before 5.00pm on 12 July 2017.

Letters of appeal must be addressed to the Minister for Environment and be posted to:

The Honourable Stephen Dawson MLC, Minister for Environment

Office of the Appeal Convenor

Level 22 Forrest Centre, 221 St George's Terrace

Perth WA 6000

Alternatively, you can lodge your appeal by fax on (08) 6467 5199 or by email to

GROUNDS OF APPEAL

GROUND 1: LANDFORM IMPACTS

The EPA has not objectively and fairlyassessed the impact on the Mungada Ridge landform in that:

  1. The impacts to landform from the Project are not significant. SMC has undertaken major changes to its project and these have reduced landform impacts to a level which should be satisfactory to the EPA. SMC’s has located its processing area and waste dump off of Mungada Ridge and outside the Blue Hills Priority Ecological Community, proposed to backfill the existing pit, relocated the proposed pit abandonment bund and significantly reduced the size of its proposed pit. All of these changes have resulted in a very significant reduction to impacts on the Mungada Ridge landform to what should be an acceptable level of impact.
  2. The impact to the Mungada Ridge landform is very low. SMC has calculated that a total of only 2% of the ridge will be permanently impacted. This will leave 98% of Mungada Ridge remaining intact, which is a significant portion of the ridge.
  3. Mungada Ridge is not a significant or unique BIF landform in the Mid West as there are hundreds (362) of others in the region that share the same or similar landform values. Generally speaking, the EPA has overstated the landform value of Mungada Ridge in the Mid West and the impacts the proposal will have on it.

Outcome sought: the above ground appeal is upheld and the Project be approved with appropriate conditions.

GROUND 2: FLORA AND VEGETAITON IMPACTS

The EPA’s Report has not objectively and fairlyassessed the impact on flora and vegetation in that:

  1. The impacts to flora and vegetation from the Project are not significant. SMC has undertaken significant changes to its project and these have reduced flora and vegetation impacts to a level which should be satisfactory to the EPA. SMC’s has located its processing area and waste dump off of Mungada Ridge and outside the Blue Hills Priority Ecological Community, proposed to backfill the existing pit, relocated the proposed pit abandonment bund and significantly reduced the size of its proposed pit. All of these changes have resulted in a very significant reduction to impacts on the Mungada Ridge flora and vegetation to what should be an acceptable level of impact. In addition, the impacts to flora and vegetation are similar to other projects that have been approved recently e.g. the Mt Gibson Iron Hill Project.
  2. The scientific studies undertaken by SMC (with the Botanic Parks and Gardens Authority, Kings Park Science Division) over the past five years show that restoration of the BIF ecosystem can be fully achieved. The BGPA has stated that there doesn’t appear to be any significant barriers to restoration and with ongoing management, biodiversity levels should be maintained.
  3. In addition to rehabilitation research work undertaken by SMC, recent flora surveys proved that the Acacia woodmaniorum (as a disturbance species) naturally thrives in disturbed ground and is already regrowing and self-sustaining in rehabilitated areas. In addition the proposed offsets provides an additional level of confidence that Acacia woodmaniorum, can be re-grown and the original population can be restored.

Outcome sought: the above ground appeal is upheld and the Project be approved with appropriate conditions.

GROUND 3: SOCIAL SURROUNDINGS

The EPA’s Report has not objectively and fairlyassessed the impact on social surroundings in that:

  1. The conclusions of the Ecoscape “Visual Landscape Evaluation and Visual Impact Assessment” Report appear not to have been consider appropriately. SMC’s expert consultant has undertaken a peer reviewed impact assessment that concluded that the development area is unlikely to be at variance with the visual management objectives for the study area;
  2. There is already mining on Mungada Ridge and in the Blue Hills area. The additional 1% impact from the proposal will not significantly add to the existing mining operations or the area in general; and
  3. The proposed mine can hardly be seen from public view points. The photographs in the Visual Landscape Evaluation and Visual Impact Assessment Report show that, even up close to the proposed mine, the pit is not overly visible and the waste dump is small in comparison to Mungada Ridge.

Outcome sought: the above ground appeal is upheld and the Project be approved with appropriate conditions.

FIND OUT MORE!

For more information,please visitSMC’s website at:

For further information or assistance, please contact:

Wayne Ennor

Sinosteel Midwest Corporation Limited

Phone: 08 9429 4888

Email: