This research was undertaken by associate lecturer and PhD student, Stacey Porter, Murdoch University.

Recommendation:
That a further assessment of any future documentation produced by Striker be assessed.

Prepared by Stacey Porter
Environmental Accounting.
Commerce Department
Murdoch University
Perth WA

Authors Note: Any views expressed or conclusions reached are those of the author and not necessarily those of Murdoch University.

It would appear that Striker Resources NL has followed correct procedures for their proposed development of a barge landing site and laydown area in Gumboot Bay and the road construction to their Ashmore facilities. However, the Environmental Protection Authorities (EPA) decision not to formally assess Strikers’ Environmental Management Plan (EMP) raises a number of issues that are of great concern. Although the EPA has attempted to cover many of these issues by making the EMP legally binding and have stated a number of restrictions on Strikers operations (EPA, February 23, 2001) there are discrepancies and anomalies in the EMP which would allow for different interpretations. In addition, the information and procedures leading to the selection of Gumboot Bay as the preferred site have a number of flaws that need to be addressed.

Flora Surveys:

Strikers’ EMP quotes numerous publications from various surveys, but most of these surveys are not in the immediate (or near) surrounds of the proposed barge landing, laydown and road construction areas, and in some instances are hundreds of kilometre’s away. Whilst these ‘distant’ surveys may have been conducted in the same biogeographic region and be representative of the flora to be found in the region, it does not explain the discrepancies found in surveys conducted in the more immediate vicinity as evidenced by the following facts.

• Two surveys conducted by CALM in the search region (Atkins 1999 and 2000) found Rare or Priority taxa (EMP:16).
• Two surveys, one in the Ashmore project area (Ecologia 1999) and one in the immediate surrounds of the proposed development (Striker personal 2000) found no rare or priority taxa.
• Ecologia also conducted literature searches of CALM and WA Herbarium flora databases and found no Rare or Priority taxa (Ecologia:v).
• Ecologia acknowledge the limitations of their survey. These limitations include that the survey:
• Was not in the landing, laydown or proposed road route;
• Was undertaken in one and half days;
• Was conducted some two weeks after ‘seasonal burns’ had been through the sampling area.

Striker’s heavy reliance on the report and Ecologias’ acknowledgement of the survey limitations raise the following issues.

• The literature search conflicts with the findings of the CALM surveys. This may simply have been a matter of timing and the databases had not been updated.
• Obvious concerns with limitations 1 and 2 above include the short time frame and that the survey was not conducted in the proposed site.
• Limitation 3 is of particular concern. The lack of vegetation due to burning severely hampers the accuracy of the results. In addition, there is no seasonal burning in the Faraway Bay / Gumboot Bay area. A fire had swept the area prior to Ecologias’ survey, however, this was the first fire in some 10 to 11 years as evidenced by the vegetation in the vicinity of Faraway Bay that had not been burnt by the fire (as well as information from the owners of the Bush Camp and confirmed by visiting researchers with backgrounds in Botany and Environmental Sciences).

• The following information from Ecologias’ biological report also presents some important issues:
• 122 taxa were identified, which is a moderate number but as acknowledged by Ecologia it is probably due to the limitations of the survey (limited time, 1 1/2 days, and recent fire).
• 27% of the taxa found ‘have not previously been recorded from the Central Gardner biogeographic district. This is “undoubtedly a reflection of the sparsely distributed floristic collection for the entire Kimberley region and the lack of any previous collection in the immediate vicinity of the study area”(pagev).
• There is little comment on the existence of a substantial mangrove swamp adjacent to the landing site.

In other words, there have been few flora surveys in the Kimberley region and no previous collection in the study area, thus it is not possible to state that no Rare or Priority flora exist in the proposed construction area.

Other issues include:

• The limited surveys previously conducted with regard to sensitive vegetation given that the area was designated a Class B reserve in 1974 and is part of the proposed Londenderry National Park (PNP/215).
• Striker do not elaborate on the Ecologia survey but indicate that further surveys are planned prior to construction commencing (EMP:16). However, Table 6 ‘Summary of Management Commitments’ states that these further surveys will be for un-surveyed sections of the alignment. Given the limitations of the Ecologia survey, further surveys restricted to only un-surveyed sections appear problematic.

Fauna Survey

The limited section on fauna information is based on Ecologias’ 1999 report. However, Ecologia did not conduct any fauna field expedition, fauna was observed as part of the flora survey. The following information is contained in Ecologias’ report (page 26):

• One Schedule 1 and one Schedule 4 avian (bird) species may potentially occur in the project area.
• Two Schedule 1 mammals may potentially occur.
• Several priority fauna and a single avian species protected under international agreements also potentially utilize the project area.

• The fact that no fauna field expedition has been conducted and the possibility that any Schedule 1 to 4 fauna may be found in the area indicates that an immediate field survey should be conducted. This is reinforced by the fact that the waterway entry to the barge landing site is the home of a nesting pair of osprey and that a nesting pair of white breasted sea eagles reside at Faraway Bay (visually sited). There is no express commitment by Striker to undertake a fauna field survey.

Heritage Issues

Striker states (EMP:12) that there is a “well established site heritage clearance protocol in place…undertaken in advance of construction activities…[and that]…heritage clearance has been received for Gumboot Bay”.

• Details of this agreement are not forthcoming in the EMP. Further investigation reveals that an agreement was entered into with the Balanggarra Aboriginal Corporations in 1997 (Striker Annual Report, June 2000:11). Information from the June 2000 Annual Report reveals a native title accord with the Balanggarra native title claimants was signed in August 1997 (page 32, note 16). The agreement relates to native title, heritage, culture, training and employment (page 11), covering both mining and exploration activities over 27,000 sq.km. in the north Kimberley (page 32).
• As part of the agreement Striker employed 5 Balanggarra people; senior staff undertook a cross cultural awareness training programme; and trainees from Balanggarra successfully completed a 3 day course in Marcsta and St John Ambulance basic first aid training and a two week on-site work experience programme (page 11).
• The Balanggarra claimant group will receive a fee based on a % (not stated) of on-ground costs as compensation for disruption and impact on the land (page 32).
• The Balanggarra claimant group will receive a payment equal to 1.5% of the capital costs on building and plant if a mining operation is established (page 32).
• The Balanggarra claimant group will receive a % (not stated) of sales proceeds generated from the mining operation (page 32).

Whilst Striker is to be commended for their co-operative approach with the Balanggarra group, there is no doubt that this same group benefit financially from Strikers operations, regardless of whether Striker commence mining operations or not.

• Striker state that minor deviations of the road construction can be accommodated where the current route affects “…heritage sites, substantial rock outcrops or environmentally sensitive areas…such as riparian areas or escarpment jumpups” (EMP:24). The construction plan states that ‘clearance protocols’ have been established with the Balanggarra Traditional Owners over the barge site, laydown areas and sections of the road up to the escarpment (EMP, Appendix A:13).
• Table 3 shows that Heritage Clearance has been given for Gumboot Bay, however Table 6 (Management Commitments) state that site surveys will be undertaken by the Traditional Owners. Although protocols have been established, this is an indication that clearance has not been given if heritage surveys are yet to be undertaken or alternatively clearance has been given without following the protocols. Either way, full disclosure should be required.
• A field expedition (24-26/4/2001) identified a series of Aboriginal middens, which lay directly in the path of the proposed road (as per Surveyors tags). This directly impacts on heritage clearance.
• Evidence of Aboriginal art sites were found in close proximity to the laydown area and proposed access road. This also directly impacts on heritage clearance.
• A direct descendant from the Traditional Owners accompanied us on the field trip. This person was not previously aware of the sites found but is opposed to the development based on these finds and concerned that the surveyed area directly impacts on these sites and yet this is not acknowledged in Strikers’ EMP.
• It is also stated that route changes have been proposed since the original survey in June 2000. These changes are not detailed in the January 2001 EMP.

The obvious concerns are destruction of these sites given the surveyed access route and laydown area. These heritage findings indicate that much more comprehensive survey work needs to be conducted before any project approval is given.

Alternative Site Assessment

There are a number of references to Strikers requirements for a suitable barge landing site. Primary amongst these is cost reduction. This includes reducing the distances traveled and continual upgrading of long expanses of road as well as a secure facility to bring in bulk amounts of fuel and supplies in order to extend the length of the field season by eliminating the need to cross major rivers (p.6 and15 ). Whilst not attempting to criticize Striker for seeking cost cutting alternatives, (a responsibility of all good management), there are concerns over the selection process and criteria used in eliminating alternative sites without due consideration.

Three coastal zones were initially targeted in a ‘desktop’ survey covering 3 areas, the Berkeley River, Faraway Bay and surrounds, and the Kalumburu site on the mouth of the Prince Edward River. Five criteria were used in a screening matrix to assess sites in these areas (EMP:17).

Barge Site Assessment and Road Access Route

• The five criteria outlined on page 17 were in fact split into seven for the barge sites and seven for the access sites according to Table 3 (EMP). In total 13 criteria were used with one the same (Company Tenured) for the barge site and access road. There is no supporting documentation to determine how criteria such as Presence of Sensitive Ecosystems (for Barge sites) or Heritage Considerations (for Access Road) were determined from a ‘desktop’ survey.
• A Heritage Clearance criteria was used for the Barge site and yet Heritage Considerations were given to the road access. This distinction is not clear and no information is forthcoming on the documentation used in the absence of a field survey to assess this distinction.
• There is no indication as to any ranking or weighting of the criteria, yet the Berkeley River Access Road has been ranked Low Suitability based on the Heritage Consideration criteria having No Information. If Heritage Considerations had returned a Yes, this site would have been ranked high suitability. As the ranking stands, the Berkeley should have been ranked neutral not Low.
• There are several critical errors in Table 3.
• The Berkeley River Barge Site has been rated No for the Dry Door Access and Laydown criteria. This clearly contradicts information in the EMP stating that the “Berkeley River and Whiskey Creek sites possess several suitable dry door barge sites” with the Berkeley being “…used previously by other mineral explorers” (EMP:17). This is particularly relevant given the majority of tenements and discovered Kimberlite pipes exist closer to the Berkeley River area (refer next section on ‘Purpose of Project’).
• Whiskey Creek has not been included in the assessment for the Barge Site and Access Road but Cape Whiskey has, whereas Whiskey Creek has been assessed in terms of environmental impacts but Cape Whiskey has not (EMP:Table 4). This would indicate that these sites have been assessed as the same site when in fact they are two separate sites with barge access available at Cape Whiskey (not Whiskey Creek) and sensitive rainforest vegetation at Whiskey Creek). At the very least there has not been a full assessment of either site with Cape Whiskey assessed in Table 3 and Whiskey Creek assessed in Table 4.
• Table 3 shows Faraway Bay rates No for Heritage Clearance, yet Table 4 shows Not Recorded for the Heritage element. What is the criteria used for this distinction?
• The EMP states that the Berkeley River and Whiskey Creek sites are “not directly linked by existing roads to the project area” (page 17).
• This is clearly incorrect. There is an existing road from the project area airstrip right through to the Berkeley and a track from the project area to Cape Whiskey. The Berkeley road is clearly visible from the air with the Cape Whiskey track obscured for the last few kilometers near the coast. Both were confirmed visually by a flight out of Faraway Bay on April 26, 2001.

One of the criteria used for assessment was the requirement not to cross any major rivers. The Berkeley and Cape Whiskey sites would cross the King George River. The road from Gumboot Bay does not, indicating that this site is more favourable based on this criteria. However, several points need to be noted:

• It is considered by Striker that no sensitive eco-systems exist at Gumboot Bay (EMP:Table 3). This is disputed in previous sections of this report. Despite the supposed non-existence of sensitive eco-systems, Striker has addressed the concerns and consequences of a spillage at Gumboot Bay as outlined in the EMP and Emergency Plan Appendices. These measures can be applied equally well to the King George crossing.
• With at least 70% of Strikers tenements and 71% of Kimberlite pipes discovered to the East and South East of the King George (refer next section), it is not possible for Striker to access these sites without crossing the King George River. If this is already being done, why is it now an issue and does this mean that Striker will no longer access the majority of their tenements from their existing Ashmore site?

Preferred Landing Site, Laydown Area and Road Construction

Much discussion and correspondence has resulted from interested parties regarding the proposed Striker project, with emphasis on the visual and noise impact to the area as well as safety issues. Striker have addressed many of these concerns in their EMP (refer EMP AppendixA, Construction Management Plan). Although there is a reasonable amount of detail in the EMP it is scattered throughout the report and appendices. When all of this information is compiled there is the impression that the project is larger than that outlined in the early stages of the EMP. The gradual compilation of information is outlined below and in addition some anomalies are highlighted.

Purpose of Project

• Lengthen the annual period when the project area can be accessed and generally reduce road building costs. The proposed site is within 25 km of the company’s operation (Striker Annual Report, June 2000:1).
• By stating that the site is within 25 km of their operations is somewhat misleading. The road construction is a total of 39.6km (3.6 km of this in PNP/215) to their existing plant facilities according to the EMP (with 42km or 50km stated in other correspondence). This is a discrepancy of at least 18.6 km.

• By Strikers own account, supplies are currently brought in via the Gibb River/Kununurra and Kalumburu and Carson River Station Network (some 700km from their operations). However, there is some confusion over the route used as they also state on page 6 of the EMP that fuel supplies, consumables and heavy equipment are barged to Longini Landing near Kalumburu then by road across Drysdale River (185km). It is probable that both routes have been used depending on the weather and road conditions, and regardless of whether one or both are used, it must be acknowledged that the costs associated with either would undoubtedly be reduced by the use of a barge landing site much closer to their operations, even with the road length discrepancy noted above. However, the choice of Gumboot Bay may not achieve the reduced costs they are seeking.
• Allowing for a margin of error, (the information in Strikers 2000 Annual Report does not supply sufficient information to be 100% accurate), a conservative estimate of approximately 70% of tenements and correspondingly 70% of square kilometers lie to the south or south east of the Beta Creek and King George tenements (refer Map p.5 and Tenement Schedule p.12). The majority of their tenements lie closer to the Berkeley River site than the Gumboot Bay site.
• The EMP state that 5 diamondiferous Kimberlite pipes have been discovered (p.5). The June 2000 Annual Report show seven, with 5 of these south and south east of the Ashmore project area (Map, p.5). Therefore, 71% are closer to the Berkeley River area.

Landing Site and Laydown Area

• Barge access will occur at high tide for durations of 3-4 hours (or as tides permit), up to 30 times during the field season (EMP:5). Daytime access is preferred but supply requirements, suitable tides and barge availability will result in some night operations. Faraway Bay will be notified 24 hours prior to estimated time of barge arrival (p.21).

These comments seem to be reasonable and express concern over the intrusion of the barge operations. However, several points need to be raised.

• The majority of visitors to Faraway Bay book months in advance with many coming from overseas destinations. Visitors would not be able to alter bookings given 24hr notice and would therefore be disturbed by the noise factor. This is particularly relevant at night, where sound can travel for up to 5km. The generators at Faraway Bay are turned off at 9pm every evening, therefore the noise from nighttime activities could not be disguised even given the ridge separating the landing site from Faraway Bay (1.5km away).

• It would be reasonable to assume that Striker would be aware of their supply requirements well in advance and that more than 24 hours notice could be given.

• There is no indication that Striker has assessed the availability of only daytime barge landings. This could be a consideration given local knowledge of tides and recorded tides for the area.

• A 50m long, 6m wide access road will be constructed from the beach landing site to the laydown area (EMP:5). Beach access will be controlled by a locked gate.
• Appendix A discusses that additional clearance is required for road construction taking the width from 6m to 10m (page 5). Presumably this applies to the 50m road as well as the 3.6km and 36km road. This increases the visual aspect from the seaward end and disguising this road has not been fully addressed in the EMP.
• There is no indication of the size of the gate or how this can or will be camouflaged.

• A 50m by 50m laydown area that would contain unidirectional tower lighting, graded hardstand area and a bunded compound for 2 by 20,000 litre fuel storage tanks (EMP:5). A 15 metre wide perimeter fire buffer zone and water storage tank (EMP:5). Tank facilities will be no higher than 4m and painted natural colours (EMP:25). Water tank will be low profile (Appendix A:4). Tower lighting will be low (EMP, Appendix A:4). Facility lighting will be confined to the laydown area although solar power security cameras and telemetry may be installed on poles (EMP:25). Subsequent to the ‘proposal’ for security cameras it is stated on the same page that they will be used.
• There are various clearances given throughout the report, 4ha in PNP/215 (EMP:5); 2500 square meters for the laydown area (p.23); less than 4ha. for the ‘facility’ (p.25); approximately 3.6 ha within the PNP/215 (Appendix A:4). Although the area is not large and the discrepancies relatively minor, they are nonetheless discrepancies.
• There is no indication of the height or dimensions of the tower lighting.
• There are no details on the security cameras or height and dimensions of the poles for the telemetry installation.
• Presumably the water tank will also be a maximum height of 4m? This is not clearly stated.
• Warning devices for tank overfill is only a ‘consideration’ (Appendix A:5).

• Barge to shore fuel unloading infrastructure including fuel spillage containment equipment (EMP:5). Details of the containment equipment can be found at pages 22-23.
• No detail is provided on the unloading infrastructure – size, dimensions etc.
• No information is provided on how the spillage containment (and disposal) equipment will be stored (open air, shed etc.). Does this entail the construction of more infrastructure to house the equipment?

Road Construction and Transportation Issues

• Proposed restricted access road (to rural road standard), 3.6km in PNP/215 plus 36km to mining operations with a trafficable width of 6m (EMP:5). Budget of $60,000 for construction of laydown area and 42km new road (Letter from Striker dated March 14, 2001).
• Vegetation clearance either side of the road will produce a 10m wide right of way (EMP, Appendix A:5).
• The budget of $60,000 must be considered extremely conservative. On average, it is estimated that maintaining an existing (rural) road in the region costs approximately $5,000 per km (labour, fuel, depreciation of equipment etc.). At 42 km this is $210,000 for maintenance - not construction.

• Fuel, equipment and supplies to be transported as required by modified prime mover and 20,000 litre tanker unit, on average twice a week during daylight hours (EMP:5 and 25). Tanker loading facilities will be provided adjacent to the storage tanks.
• No detail is provided on the tanker loading facilities, dimensions, visual impact etc.

• Access road to be gated, Faraway Bay – Carson River Road to be gated EMP:Table 6). Limit off-road driving to that which is unavoidable during the course of normal safe exploration and mining operations (Ecologia, 1999:34).
• Possible safety measures, however it does not prevent off-road driving which is presently at a minimum but may increase given the creation of new roads and additional use of existing roads in the area.
• It is uncertain how the provision of one or two gates situated at the very northern end of the Kalumburu-Carson River Road will control the level of tourist access along this road as stated in Strikers EMP (page 8).

• “Existing roads and exploration tracks to Faraway Bay area have existed for many years…..with several road sections located in drainage lines and basalt derived grey soil units” (EMP:8).
• The existing track from the airstrip to the Bush Camp does cross a gully, however, the surveyed route for the proposed new road is directly aligned in a gully before it crosses the existing track for the second time.
• Existing roads to Faraway Bay do exist (EMP:8), one of these is via the Berkeley River, a fact denied by Striker (EMP:17) and not shown on their Tenement Map (Annual Report, June 2000:5).

“The Bush Camp” Faraway Bay

There appears to be confusion regarding the operations in existence at Faraway Bay, some 1.5km west of the proposed development. This confusion and concerns over the future existence of the camp (if the proposed project goes ahead) have been addressed in correspondence to the EPA and various government ministers. Some of these issues have been incorporated into previous sections of this report (visual aspects, noise pollution, heritage considerations etc.). It is not the intention to redress these issues here but to highlight a number of concerns not raised previously.

• Striker consistently refers to ‘the Bush Camp’ as a ‘boat-based guest site seeing and recreational fishing’ site (EMP:11 and 24).
• Faraway Bay is an established nature based development with low environmental impact with an international clientele. It meets all the requirements of Eco-tourism and Ecologically Sustainable Development as outlined by the Western Australian Tourism Commission (WATC, July 2000). Fishing is one activity that is offered but it could not be classified as a recreational fishing site.
• Tourism ranks second behind the mining sector in contributing to the Kimberley Regions economy. Tourism is a longer term proposition with Faraway Bay one development that meets the criteria of the WATC direction for creating “sustainable and interactive wilderness/nature-based experiences” (WATC, April 2001).
• Faraway Bay is dependent on its reputation as a serene, isolated, visually pleasing aesthetics – it will not be able to retain these features with the closeness of the proposed site. Letters to Faraway Bay from existing clientele confirm they will not return if the proposed project goes ahead. The financial viability of Faraway Bay will be threatened.

• Gates located on the Faraway Bay and Kalumburu – Carson River Road will control the level of tourist access along this road (EMP:8 and Table 6).
• The Faraway Bay lease does not allow visitors to drive in, they must fly in or arrive by boat. This severely curtails any tourist traffic and raising the issue of reducing tourist access appears irrelevant.
• The gates also produce a safety issue (as well as a visual detraction) as the proposed access road crosses the existing track twice with heavy haulage vehicles and Faraway Bay visitors using sections of the same road.

The issues raised in this report are by no means exhaustive, but they highlight some of more serious concerns by assessing some of the conflicting information contained in Strikers EMP. It may be that the issues raised throughout this report have been addressed by Striker but this is not evidenced in their EMP. In the absence of additional information, it is recommended that the EPA reassess their position on Strikers EMP until such time as all interested parties are satisfied that the information is complete and accurate.

References:

Striker Resources NL, January 2001, Environmental Management Plan (and Appendices), document ref. STREMP1840.

WATC, 2001, Kimberley Region Tourism Infrastructure & Product Development Plan 2001-2005: An initiative of Partnership 21, Western Australian Tourism Commission, WA. (Draft Publication, April, 2001).

WATC, 2001, Designing Tourism Naturally: A review of World Best Practice in Wilderness Lodges & Tented Safari Camps, Western Australian Toursim Commission, WA. July 2000, WATC, Perth, WA.

Various correspondence from and to Faraway Bay. Note: no correspondence has been cited that specifically states it is prohibited correspondence or correspondence that could not be obtained in the normal course of investigations.

Faraway Bay: Vegetation Report and Fire Management Suggestions.

David Harrington: Botanist. MSc. Student. Macquarie University.

Over the period of April 24 th to April 26 th an assessment of the vegetation around the lease at The Bush Camp, Faraway Bay was carried out. This was done using visual sampling taking in those representative vegetation associations immediately obvious. The area sampled included the flat areas around and just below the airstrip, the gullies to the north and south of the road, the ridge vegetation to the south of the road, the vegetation on the slopes above Gumboot Bay, the vegetation along the watercourses leading down to Gumboot Bay, the vegetation immediately behind and above the camp and the littoral and sub-littoral vegetation behind and adjacent to the beach. Eight distinct vegetation associations became apparent during this survey, on a range of substrates ranging from sandstone and quartzite, through to basalt and associated metamorphics, sand dunes and mudflats.

This survey predominately focussed upon what significant vegetation associations were present. Wherever possible vegetation was identified to species level, but due to the limited time available for the study and the recent fire at Faraway Bay, this was could not always be achieved. In these cases an informed assessment was made as to the family to which the specimen belonged, or a note made as to the form of the plant in question. The diversity of the vegetation was very high throughout, and a truly comprehensive assessment would involve more time than I had available. The fact that this diversity was present when the vegetation was recovering from a severe fire is important to note.

The Faraway Bay area was subject to a severe fire event late in 2000. This fire covered an area of more than 10,000 square km. Faraway Bay had not experienced a fire for approximately 11 years, so this fire was particularly severe. This could be seen by the effects it had on the vegetation. There was high mortality in canopy species overall, estimated at close to 80% in some areas. The surviving canopy species, including Eucalyptus terminalis, Eucalyptus grandifolia, Terminalia canescens and Acacia pacyphloia, showed signs of recovering from fire including epicormic growth and coppicing. Considering that the fire occurred almost 6 months ago the perseverance of this epicormic growth is indicative of its severity. The impact of the fire was not consistent across the area and was clearly influenced by aspect, slope and soil moisture. As a result vegetation was affected to varying degrees.

In the north and westerly facings effects were the most severe, with large trees killed and almost all ground cover species removed. Tussocking perrenial grasses were especially sensitive to high fire intensities, with almost 100% mortality in those areas worst affected. In some gullies and on wetter soils fire effects were moderated evidenced by the survival of fire sensitive species such as Terminalia canescens, Melaleuca viridifolia, Callitris columellaris, Acacia tumida and closed forest and vine thicket associations. The regeneration in less fire affected areas was vigorous, with high numbers of various forbs and regeneration of tussocking grasses.

The vegetation associations present were as follows. A note is included as to how severely the fire affected each association listed.

• Low open woodland on rocky sandstone ridges and slopes. Canopy dominated by Terminalis canescens, Hakea arborescens and Acacia pachyphloia. Occasional Eucalyptus terminalis. Understorey dominated by Hibiscus minutibractiolis, Ehretia saligna, Grevillea refracta and Grevillea pteridifolia with many forbs, including Gomphrena sp. Major grass species Triodia bitextura. Severely affected by fire.
• Low open woodland on poorly drained clay soils. Canopy dominated by low Melaleuca viridifolia and taller Eucalyptus grandifolia and Eucalyptus terminalis. Understorey dominated by forbs including Drosera sp. and a great many others. Affected by fire to a moderate to high degree, depending on the dampness of the substrate.
• Tall shrubland on basalt. Canopy dominated by Erythrophleum chlorostachys, Terminalia canescens and Acacia pachyphloia. Understorey dominated by grasses including Aristrida and Sorghum species. Shrubs include Cochlospermum fraseri and Grewia retusifolia. Affected by fire to a low to moderate degree. Also contains low closed forest elements (vine thickets) on seasonal watercourses. Canopy dominated by Terminalia volucris, Gyrocarpus americanus, Strychnos lucida and other species. Understorey dominated by various creepers including Ampelocissus acetosa, Passiflora foetida and Flagellaria indica amongst several others. These zones appear to have largely escaped fire damage.
• Low open woodland on sandstone ridges and scree slopes. Canopy dominated by Eucalyptus miniata, Eucalyptus brevifolia, Eucalyptus polycarpa and Owenia vernicosa. Understorey dominated by Acacia tumida and other Acacia species, Leptospermum sp., Distichostemon hispidulus, Clerodenrum tomentosum, Grevillea wickhammii, Bossiaea bossiaeoides, Calythrix exstipulata and Hakea arborescens. Scattered Callitris columellaris and Ficus leucotricha on slopes, often in association with other vine thicket species and vines such as Flagellaria indica and Smilax australis. Affected by fire to a low to moderate degree.
• Tall closed forest on sheltered creek lines and slopes. Sandstone and alluvium substrate. Canopy dominated by very tall Melaleuca argentea, lower Callitris collumellaris, Callophyllum sil, Pandamus spiralus and Ficus leucotricha as well as other closed forest species. Understorey dominated by vines, predominately Flagellaria indica and Ampelocissus acetosa. Unaffected by fire.
• Low closed forest on creekline. Sandstone and alluvium substrate. Rainforest type vegetation, canopy species include Callophyllum sil, Pandamus spiralus, Ficus coronulata, Melaleuca argentea and other rainforest species. Understorey dominated by vines, ferns and groundcover plants such as Lindsaea ensifolia, Flagellaria indica, Commelina ensifolia, Cayratia trifolia, and Ampelocissus acetosa. Unaffected by fire.
• Littoral mudflat vegetation dominated by Avicenia marina. Unaffected by fire.
• Sublittoral sanddune vegetation, including two Triodia species, one Triodia epactia and the other unknown, Impomea pes-caprae, a sedge species and Tecticornia verrucosa. Associated with this zone is a restricted sublittoral low closed forest growing on the rocky slopes. This association includes Ficus opposita and Brachychiton tridentatus with an understorey of Passiflora foetida, Fluggea virosa, Grewia retusifolia, Abrus precatorius, Cucumis melo and other vines. Both of these vegetation associations were unaffected by fire.

The wide range of vegetation associations covered above show that this area is highly diverse, with vegetation that is complex in both floristics and structure. As stated my survey was quite perfunctory and based around visual observations. Considering the relatively small area I traversed it is quite possible that a longer survey might have uncovered still more species. Striker mining could be involved in making further studies of this area, both before and during the construction of their access road. This information could be used as a resource for ongoing monitoring of vegetation responses to the disturbance resulting from the road development, as well as from other disturbances such as fire.

There are two different purposes this information could serve. Firstly it would allow Striker to assess and moderate the impact their activities were having on vegetation communities. Secondly this information could contribute to the overall information base on vegetation in this area of the Kimberley. Kimberley vegetation is not adequately surveyed and there are many gaps in the information base concerning the distribution of various species and vegetation associations. For a mining company to be contributing to this type of research would be a positive public relations activity. The benefits would flow to both the company and the community at large.

In reference to the surveying undertaken to date. Striker Mining’s Environmental Management Plan (EMP) relies predominately on surveying carried out by Ecologia. As I see it this information was limited in three ways. It was collected in areas away from the proposed barge-landing site. It was undertaken in one and a half days and it was undertaken shortly after “seasonal burns”. On the first and second points my concerns are the relevance of vegetation surveys carried out in other places and the short time frame of the study. On the third point, even months after the fire event the vegetation was still obviously recovering. Anecdotal evidence indicates that this fire was the first to affect the area for 10 years. The vegetation would have been in the first stages of regeneration and many species would have been absent from the record.

Striker states in their EMP that further surveys will be carried out prior to the commencement of work. These will be focused on unsurveyed sections of the road corridor. As is stated in the EMP, floristic collection in the Kimberley is sparsely distributed. Considering this fact and taking into account the recent fire for the survey to conclude that there are no rare or priority taxa is problematic. Considering the limitations raised I believe that this ongoing survey work should be applied to the areas already covered as well. Apart from ascertaining whether there are in fact rare or priority taxa present this information would show the vegetation responses six months after fire.

The effects of fire upon Kimberley vegetation are poorly understood. I t is reasonable to expect that the danger of fire would substantially increase with the mine road. Fire dangers associated with high traffic and the permanent barge site would include discarded cigarette butts, campfires, sparks from heavy machinery and other factors. It might also be expected that management of the areas adjacent to the road would include fire mitigation burns. Unless carefully planned and controlled, it would be inevitable that fire would adversely affect fire sensitive vegetation associations. One species found in the area, Callitris columellaris, is contracting due to poor fire management across the whole Kimberley. Another serious consideration would be destabilisation of soils consequent with a reduction in ground cover. Considering the effects of one severe fire on tussocking grasses this will become a problem if fire is frequently repeated.

In respect to these problems ongoing monitoring and careful planning of fire management by Striker Mining could also make a positive contribution. The knowledge base with regards to vegetation responses and the consequences of particular fire management strategies is poor. A good set of monitoring tools employed by Striker to address these issues could only be beneficial to the scientific community and result in better public relations overall. The proximity of other landuses to the Striker road means that public safety is also an issue when designing fire management strategies. Good communication with these landusers and the scientific community would be an ideal way of avoiding conflict in the future.

In conclusion, the vegetation of Faraway Bay is of a type with others well represented across this area of the North East Kimberley. As such I cannot say that the activities proposed by Striker Mining will adversely affect any particularly sensitive vegetation associations, except for the possibility of fire impacting on Callitris. The issues raised above and the solutions proposed would help to mitigate any adverse effects of Striker’s activities. I found the area to be of great natural beauty and the vegetation to be very interesting. It would be hoped that an activity of this kind could be designed so as to minimise disturbances and positively contribute to the knowledge base concerning the Kimberley environment.

The Gardner Botanical District is a sub unit of the North Kimberley biogeographic region using the IBRA system as detailed in Strikers EMP report (p.9).

Class B reserves “are seen as warranting higher protection than usual, but not to the extent of Class “A”. Class “B” reserves may be varied by Governor in Executive Council, but amendment must be notified to the Parliament”. Class A reserves “forever remain dedicated to the purpose declared …where there is a need perceived for the highest form of protection…” DOLA, www.dola.wa.gov.au, 2001:1

Classification of rare and endangered fauna under the Wildlife Conservation (Specially Protected Fauna) Notice (1998) recognizes four distinct schedules (for example) Schedule 1 fauna are ‘rare or likely to become extinct, and are declared to be fauna in need of special protection’ ; Schedule 4 fauna are ‘in need of special protection, otherwise than for the reasons mentioned in paragraphs a, b and c.