Management of potential environmental impacts

Outcome:

The water quality of surface and groundwater systems is maintained or improved.

Management 1: The dairy complex should be located at least 100 metres from a waterway and relevant WaterNSW licences are in place where necessary. Where this distance is not met, protection measures have been identified to justify development within this location.

Management 2: The dairy complex should not be located within areas prone to flooding, high-water table, salinity risk or acid sulfate soils. Where this outcome is not achievable, protection measures have been identified to justify development within this location.

Management 3: Dairy complex water requirements during operation should be determined, including an assessment of total water supply requirements against water licences, together with maximum daily demand and annual use limits. Siting should consider water access and transfer from water sources, and the impacts of these activities.

Outcome:

Impact to surface and groundwaters from nutrient run-off or leaching is avoided.

Management 1: The dairy complex manure management system (liquids, slurry, solids, bedding) is located, designed and operated under a fit for purpose Manure and Effluent Management Plan (MEMP) prepared by a trained effluent system designer or professional with demonstrated experience in applying Australian Standards and climatic data to system design.

Management 2: Dairy facilities and the manure management system are designed and operated in accordance with:

• cow numbers and time spent in the dairy complex
• percentage of excretion to be managed within the system, separated into manure streams (liquids, slurry, solids, bedding) and volumes
• entire dairy complex water balance including determination of water volumes likely to enter and be used from the system
• allowances for future growth of cow numbers and dairy complex modifications.

These numbers must be clearly identified in any completed assessment.

Management 3: Design of the dairy complex collects all run-off from within the complex by determining appropriate slope requirements and use of controlled and impermeable capture systems.

Management 4: Dairy complex areas used to:

• contain and accommodate cows
• store and manage manure
• store and process stockfeed

are designed to prevent storm and run-off water from the surrounding landscape entering the facilities.

Management 5: The design of the manure management system includes determination of capture, separation and storage infrastructure and associated capacities in order to manage determined volumes of Management 1.

Management˛6: Application to land management includes appropriate reuse of each manure stream (liquids, slurry, solids, bedding) based on site specific variables such as topography, soil type and fertility targets, and determined buffer requirements.

Outcome:

The dairy complex is designed and operated to prevent off-farm impact to surface or groundwater from nutrient run-off as a result of unexpected operational failure or rainfall events.

Management 1: The manure management systems capture, holding and treatment capacities and design standards are outlined in the Manure Management and Effluent Plan prepared by a trained effluent system designer or professional with demonstrated experience. This includes a design for a 90th percentile rainfall contribution to the complex.

Management 2: Effluent (liquid) is frequently applied at appropriate timings to maintain a minimum of 600mm ‘freeboard’ in manure treatment and holding ponds. This includes periodic desludging of ponds as well as ongoing irrigation or application to identified manure reuse areas.

Management 3: Rainwater management systems are designed and installed within the dairy complex to maximise management opportunities. This may include separation of clean water and surface water systems so that use of the water can be determined by quality parameters.

Management 4: The system minimises stormwater entering the dairy complex by providing diversion structures upslope from facilities, using natural topographic features where possible.

Management 5: The system considers extreme emergency events and contains filtration capabilities where discharge from site to an approved stormwater discharge point is allowed, or for emergency storage drawdown procedures.

Outcome:

The dairy operation considers the ability to recycle liquids. Where feasible, liquids are efficiently used for washing concreted facilities and/or treated as a valuable nutrient source for agronomic purposes.

Management 1: A nutrient management plan (NMP) is prepared within the MEMP to detail nutrients from manure sources (liquids, slurry, solids, bedding materials) and to specify appropriate application to identified manure reuse areas at the right rate and time to meet calculated plant demands and regional soil fertility targets. Where applicable, applications to land, monitoring and reporting are undertaken in accordance with EPL conditions.

Management 2: Manure management systems have been designed to consider, and where appropriate, allow for the recycling of liquids as reuse washdown water for cleaning purposes on concreted areas within the dairy complex as part of the MEMP.

Outcome:

Manure solids and spent organic bedding materials (for example, woodchip, sawdust, straw, sands) generated are managed as a nutrient source for agronomic purposes, recycled or reused.

Management 1: Bedding systems are managed for cow or calf occupation number and density, facility type, temperature and moisture content. Best management practices are undertaken as relevant in accordance with Section 9.7 of the National Guidelines for Dairy Feedpads and Contained Housing.

Management 2: Organic bedding is managed to ensure a healthy surface condition. Where compost bedding is used, aeration (turnover) is undertaken 2 to 3 times as a part of daily operations. Where other bedding management systems are used, the type and volume are considered in the MEMP.

Management 3: Manure solids are removed from hard surfaces or separated by the manure management system from liquids to be used as a valuable nutrient source for agronomic purposes.

Management 4: Storage of spent organic bedding and manure solids is on impermeable flooring with drainage directed into the manure management system.

Management 5: Where possible, immediate application to land of manure solids and organic bedding upon removal should be undertaken to avoid double handling, reduce the need for impermeable storage and maximise the nutrient value of the materials. When required, storage should promote drying and composting processes (if applicable), with consideration of decreasing nutrient value as storage time increases.

Management 6: Applications to land are made in accordance with the MEMP, which specifies management actions for environmentally sustainable use of the material. Where appropriate, monitoring and reporting is undertaken in accordance with the MEMP and EPL conditions.

Outcome:

Irrigation water use efficiency reduces loss of water, nutrient and sediment to local catchments and optimises crop and pasture production in irrigated dairy systems.

Management 1: Design of a new or modified irrigation system is undertaken by a certified irrigation designer (CID) or suitably experienced person in collaboration with the farm agronomist.

Management 2: The irrigation system is maintained to ensure effective and efficient operation.

Management 3: Crop water requirements are determined to avoid over or under-watering, and to optimise soil moisture for strategic and efficient manure and nitrogen applications.

Management 4: The irrigation system manager has capability to monitor water application rates and total crop use to adjust applications in accordance with plant uptake and forecasted weather.

Management 5: Where a liquid manure (effluent) mix is applied through the irrigation system, water application decisions factor soil fertility levels to minimise nutrient build-up. These applications are in accordance with the MEMP.

Outcome:

Ancillary infrastructure is located, constructed and managed to reduce the risk of nutrients or sediment entering surface or ground waters via runoff or leaching.

Management 1: Siting of the dairy ancillary infrastructure considers surrounding environmental features such as topography, drainage and soil characteristics to avoid manure and sediment accumulation, and uncontrolled nutrient run-off.

Management 2: Stormwater is diverted away from ancillary areas to avoid water pondage and nutrient and sediment run-off.

Management 3: Commodity sheds and washing areas for feed equipment, machinery or vehicles are designed to retain water run-off for storage and reuse on the site, including being contained within a bunded area and constructed with an impermeable floor. Where possible, these should be located within the dairy complex controlled drainage area.

See Section 8 – Traffic for more information on ancillary works related to roads.

Note: Appropriate dairy guidance can be found in Victoria’s Impermeable lining design in animal production requirements (Victorian Department of Energy, Environment and Climate Action, 2023 (in review)).

Outcome:

The likelihood of risk to the environment from impacts to soils is reduced through sound design and management. Use of natural site characteristics is optimised to minimise soil disturbance.

Management 1: Assessment is undertaken to identify existing site and surrounding features to be optimised, protected or managed in the design and operation of the dairy development. This should consider historical land use mapping to identify potentially contaminated, acid sulphate, saline and prone to waterloging.

Management 2: The dairy development considers soil type, soil capabilities and site constraints in siting, design and operation. Soils are assessed to determine suitability and to choose site-specific construction materials and methods.

Management 3: Consideration of related principles for surface and ground water and Aboriginal heritage are undertaken.

See Chapter 5 – Site investigation and earthworks – of the National Guidelines for Dairy Feedpads and Contained Housing.

Outcome:

Risks to the environment from soil and sediment loss are minimised.

Management 1: Earthmoving and construction works are undertaken in accordance with a site-specific Soil and Water Management Plan or Erosion and Sediment Control Plan, prepared in accordance with

Volume 1: Managing Urban Stormwater: Soils and construction, 4th edition (“Blue Book”) (Landcom, 2004). The plan considers the scope of works and is specific to the soils and geotechnical investigation recommendations of the development.

See Guidelines for Erosion & Sediment Control on Building Sites (DLWC, 2001) and Chapter 5 – Site investigation and earthworks of the National Guidelines for Dairy Feedpads and Contained Housing.

Outcome:

Soil and sediment runoff is prevented, or measures are in place to control and minimise impact to the environment.

Management 1: High risk erosion areas are identified, and management strategies are in place to control or minimise the risks of runoff. Management strategies and physical features include (but are not limited to): laneway cut-outs, sediment bunds, concrete nib-walls and sloping/re-contouring the land.

Management 2: Stock grazing and movements are managed to reduce the risk of erosion and sediment generation, especially during heavy rainfall or prolonged wet weather events. Management strategies include (but are not limited to): reduced stocking densities, containing cows on feed pads to avoid pugging and damage to vegetative cover, grazing alternative paddocks, and for improved long-term management, fencing and revegetation of high-risk erosion areas (gullies, riparian areas and drainage lines).

Outcome:

Dairy operations minimise contributions to landfill and reduce potential impacts to waters and land.

Management 1: Purchase decisions are made to avoid excessively packaged and single-use products. Priority is given to reusable, repairable, refillable or recyclable products.

Management 2: Rubbish is frequently sorted in a contained area to be reused, recycled or disposed to landfill without impact to sensitive receptors, waters or land.

Outcome:

Dairy operations minimise contributions to landfill and reduce potential impacts to waters and land.

Management 1: Silage plastics and polypropylene twine are packed in separate UV stable plastic bags (for example, Plastic Forest), or reusable or recyclable bags that can exclude rain and pests. Preparation, including residue cleaning, storage and transport is undertaken in accordance with local council advice or Dairy Australia’s national Silage Plastic Recycling Scheme.

Outcome:

Dairy operations minimise waste to landfill and reducing potential impacts to waters, soil and biodiversity.

Management 1: Non-returnable metal or plastic containers, with an eligible drumMUSTER logo and declared content capacity of between 1L/kg to 205L/kg are prepared, including residue cleaning, stored and transported in accordance with eligibility and cleanliness standards.

Management 2: Intermediate bulk containers (IBCs) are returned, for reconditioning and recycling through proprietary programs where available (for example, Schutz Australia).

See www.drummuster.org.au/container-recycling/the-abcs-for-youribcs.

Outcome:

Management 1: Tyre piles and silage are stored to minimise impacts:

• Located on a level site away from surface watercourses, flood zones and powerlines.
• Minimised in size to restrict available fuel in the event of a fire, formed as a long and narrow pile with recommended maximum dimensions of 20m long x 6m wide x 3m high.
• All-weather vehicle access is maintained.
• Vegetation or other fuel materials are controlled on and around the site with a 10m mineral-earth fire break around it during the bush fire danger period.
• Potential sources of ignition or heat, including flammable or combustible liquids, are kept away from the site.
• Maintained with sufficient separation distances from buildings and boundaries and between individual tyre piles.

See Fire Safety Guideline – Guideline for bulk storage of rubber tyres (Fire & Rescue NSW, 2014).

Management 2: Volume and number of tyres stored on farm is undertaken in accordance with relevant consent from the EPA and/or local council.

Outcome:

Dairy operations have sound contingency plans for the safe disposal of milk unsuitable for human consumption without impact to environment, human health and animal health.

Management 1: Milk is diluted to a ratio of 1-part milk to 10-parts water and irrigated to dry, recently grazed pasture to allow for optimal soil penetration prior to next grazing.

Management 2: Irrigation areas should be well clear of waterways and moved frequently to avoid run-off and off-farm impacts. A general approach is not within 20 metres of a waterway and not to paddocks that are likely to flood, have a steep slope or that are irrigated over community drains and waterways.

Management 3: Where milk is free from antibiotics, it may be fed to livestock. The milk must be contained, stored and fed so it remains on-farm and does not spoil.

See Chapter 5.1. Milk and other dairy products of the AUSVETPLAN Operational Manual: Disposal (AHA,2021) for emergency animal disease response.

Note: Directing milk to manure holding ponds should be avoided as it can produce odours and reduce optimal functioning of the system. If there is no alternative, a properly designed 2-pond system can cope with milk from 2 consecutive milkings.

Outcome:

Dairy operations are conducted in regional communities with minimal disturbance to the local people and their environment.

Management 1: The dairy complex or new facilities within an existing dairy complex are sited in consideration of sensitive receptors and, where relevant, in accordance with the separation distances as determined. Where calculated separation distances are not met, agreements between parties may be considered to justify a reduction in distance.

Management 2: Where relevant or identified as required via the DA pathway, an Odour impact assessment and management plan (Odour Report) is prepared by a suitably qualified and experienced provider in accordance with the Technical Notes- Assessment and management of odour from stationary sources in NSW (DEC,2006). The relevant separation distances from sensitive receptors should be clearly identified.

Management 4: Manure management and composting systems are designed to effectively manage the determined annual and seasonal peak manure and organic matter volumes outlined in the MEMP, with contingency allowance, to prevent off-farm odour impacts.

Management 5: Siting and design consider annual and seasonal prevailing winds, including the need for noise and odour barriers (vegetative or material), if required and in accordance with the Technical Notes – Assessment and management of odour from stationary sources in NSW (DEC, 2006) or the Noise Guide for Local Government (Section 2.1 – Agricultural noise, NSW EPA, 2023) and local Development Control Plans. If the premises requires an EPL, noise is assessed according to the Noise Policy for Industry (NSW EPA, 2017).

Outcome:

Dairy operations are conducted in regional communities with minimal disturbance to the local people and their environment.

Management 1: Dairy complex facilities, manure management system and manure reuse areas are managed to minimise air quality impacts to the surrounding environment and where relevant in accordance with the Odour Report.

Management 2: Manure reuse areas, manure application rates, and timing of manure application to land are made and monitored in accordance with the ongoing MEMP or NMP. Wind direction and velocity, daily temperature and time of day are considered when scheduling application to manure reuse areas. Optimal application conditions are downwind of sensitive receptors, or preferably midmorning to afternoon with no heavy rainfall forecast. If the premises holds an EPL, licence conditions for air quality must be complied with.

Management 3: Generation of dust is minimised by managing vegetation cover on paddock surfaces, maintaining protective cover over feed storage facilities and minimising traffic movements on dry and windy days. Surfaces of high traffic laneways, holding yards, parking areas and loading areas are maintained to allow safe entry, all weather access and minimise dust and sediment generation.

Management 4: Spoiled feed, milk unsuitable for human consumption and general waste (see Section 9.4) is removed as soon as possible following generation from storage areas to reduce the intensity and duration of odour exposure to potential sensitive receptors.

Management 5: System design and operation considers regular and suitable cleaning and management intervals to manage and reduce odour on site. This includes undertaking maintenance of manure and composting systems and applications to avoid early mornings and late nights, and reviewing prevailing winds prior to commencing activities.

Outcome:

Dairy operations are conducted in regional communities with minimal disturbance to the people, native fauna and environment.

Management 1: Dairy complex facilities, access points, high traffic laneways and car parks are located to prevent or minimise noise impacts to sensitive receptors. Where sensitive receptors may be impacted, minimum separation distances and buffers may be determined by a noise impact assessment and management plan (Acoustics Report).

Management 2: Noise rating is considered in purchase of vehicles, machinery and equipment. Maintenance is scheduled to ensure optimal operational performance.

Management 3: Dairy complex operations are conducted to minimize activities and traffic movements during times when receivers are more sensitive. Schedule deliveries during daylight hours or as specified in any conditions of consent. Where this is not possible (for example, milk tanker pick-ups), mitigation and management measures detail how impacts to sensitive receptors will be minimized and managed.

Management 4: Where identified as advised or required, an Acoustic Report is prepared by a suitably qualified or experienced consultant in accordance with the Noise Policy for Industry (NSW EPA, 2017).

Management 5: Where an Acoustic Report is prepared and approved, noise mitigation and management measures are implemented in accordance with the recommendations. Guidance for the management of noise includes: the Noise Guide for Local Government (Section 2.1 Agricultural noise, NSW EPA, 2023), and the Noise Policy for Industry (NSW EPA, 2017) associated with agricultural industries. If the premises holds an EPL, licence conditions for noise must be complied with.

Management 6: Surfaces of internal vehicle high traffic lanes, loading areas and car parking spaces are maintained to allow safe entry, all weather access and minimise generation of noise and vibration.

Outcome:

Dairy operations are conducted in regional communities with minimal disturbance to the local people, native fauna and environment.

Management 1: Buildings and works are sited and designed to:

• maximise screening of buildings from the surrounds using natural features of the land, including topography and vegetation
• visually integrate with the surrounding landscape, using materials that are non-reflective and finished in natural colours and muted tones
• consider Australian Standard AS/NZ 4282:2019 Outdoor Lighting Obtrusive Effects and the Dark Sky Planning Guideline (DPE, 2023), where relevant.

Management 2: Access points, high traffic laneways and car parks are located or screened to prevent stray lighting from vehicles to nearby sensitive receptors. If necessary, vegetation, earthen banks and constructed walls are used.

Management 3: Lighting for dairy operations and security is strategically located and shielding is used, if required, to prevent light spill to surrounding sensitive land uses. Where possible, sensors are used to control lighting durations. Lighting should be designed and installed in accordance with relevant Australian Standards.

Outcome:

Dairy operations are conducted in regional communities with minimal disturbance to the local people and their environment.

Risk to the dairy operation and production is reduced through good design and management systems.

Management 1: The design of dairy complex facilities includes best management practices to prevent and monitor livestock disease incursion and spread, drawing upon guidance from the Managing biosecurity risks in land use planning and development guide (NSW DPI, 2020).

Management 2: The design of dairy complex facilities includes areas for quarantine and safe management of livestock demonstrating irregular health conditions.

Outcome:

Dairy operations protect property, livestock, the dairy industry as well as the broader community from the spread of disease, pests and weeds.

Management 1: A biosecurity management plan is prepared and implemented using Dairy Australia’s readily available biosecurity resources. The plan is reviewed and updated annually in accordance with the review requirements.

Note: There are specific requirements relating to signage and people entering a farm in NSW that has a biosecurity management plan in place. See: https://www.dpi.nsw.gov.au/biosecurity/your-role-inbiosecurity/primary-producers/biosecurity-management-plan.

Management 2: Staff and visitors to the site are inducted and are aware of their obligation to comply with the biosecurity management plan, including hygiene protocols such as parking/walking in designated areas and washdown/bathing of footwear and vehicles/machinery.

Management 3: A weed management plan is prepared and implemented including consideration of state and regional priority weeds declared under the Biosecurity Act 2015 and integrated pest and disease management principles integrated wherever possible. The plan is reviewed and updated annually.

Management 4: The farm business maintains accreditation under the requirements of their processor or individual Quality Assurance Program.

Management 5: The farm business meets requirements of the National Livestock Identification Scheme (NLIS).

Outcome:

Chemical storage, transport and use does not impact the health of humans, animals or the surrounding environment. The dairy is able to supply a quality product for the market.

Management 1: Pesticide use meets the requirements of the Pesticides Act 1999 (NSW) and the Pesticides Regulation 2017 (NSW).

Management 2: Veterinary medicine use meets the requirements of the Stock Medicines Act 1989 (NSW) and the Stock Medicines Regulation 2019 (NSW).

Management 3: Only chemicals registered or permitted by the Australian Pesticides and Veterinary Medicines Authority (APVMA) are used in accordance with the product label and/or APVMA permit (MRL) for the product.

Management 4: Products are stored bearing the approved label in appropriately bunded, aerated and locked storage facilities. Records are maintained in accordance with the relevant regulation.

Management 5: Product mixing, application/use and disposal is undertaken in accordance with the product label and recorded in accordance with the Pesticides Regulation 2017 (NSW) (Part 4, 36 & 37, Part 6 52-55) and/or the relevant QA program of the dairy business.

Management 6: Those handling chemicals have a current ChemCert AQF 3 Accreditation recognised by the EPA to use, purchase and spray restricted chemicals under the Pesticides Act 1999 (NSW).

Management 7: All activities regarding storage, transport and use of chemicals and veterinary medicines on farm are in accordance with the requirements of the Work Health and Safety Act 2011 (NSW) and meet the specific hazard and risk requirements of the Work Health and Safety Act Regulation 2017 (NSW). Procedures are guided by WorkCover NSW’s information guides, Code of Practice 2006: Safe Use and storage of chemicals (including pesticides and herbicides) in Agriculture (WorkCover NSW, 2006) and Code of Practice 2005: Storage and handling of dangerous goods (WorkCover NSW, 2005).

Outcome:

Dairy operations reduce risks to livestock through safe use of farm generated organic materials used within the complex or on the milking platform.

Management 1: Stockpiling of farm generated organic matter is isolated from livestock areas and monitored and managed to prevent disease or weed incursion. If transferred off-site, please refer to EPA Resource Exemption – The compost exemption 2016.

Management 2: Composting methods and application to land of the compost as a soil amendment at the generating dairy operation is undertaken in accordance with industry best practice (chapter 7 of National Guidelines for Dairy Feedpads and Contained Housing).

Outcome:

Dairy facilities are designed and operated to safeguard against potential impacts to the environment, human health and animal health.

Management 1: Cause of death is determined by a veterinarian and in the event of suspicious, unexpected or notifiable animal disease, the Local Land Services District Veterinarian is notified and notification is undertaken in accordance with NSW DPI Primefact Notifiable pests and diseases of animals in NSW (Primefact 1565 (edition 4), NSW DPI, 2020).

Management 2: All livestock burial, composting and cremation is undertaken by using the information provided in NSW DPI Primefact Managing animal carcass disposal (Primefact PUB21/202 (edition 2), NSW DPI, 2021).

Management 3: Mortality management areas are assessed and sited to protect sensitive environmental factors particularly local surface and groundwater resources and sensitive receptors.

Management 4: Mass mortality management procedures have been developed and can be efficiently and effectively implemented in an emergency response situation.

See: Biosecurity – Managing significant endemic diseases of animals and Biosecurity - Pests and diseases of animals – investigation and alert phase of an emergency response

Outcome:

Dairy operations minimise the likelihood of impact upon local water catchments and support the protection of native flora, fauna and habitat.

Management 1: The biodiversity conservation mitigation hierarchy* is applied to all dairy development and operational activities in consultation with relevant local council and Local Land Services officers:

• Avoidance
• Minimisation
• Remediation on-site

If any residual impacts remain after the implementation of the first 3 steps, biodiversity offsetting off site is considered.

*International Finance Corporation (2012), Performance Standard 6 – Biodiversity
Conservation and Sustainable Management of Living Natural Resources

Management 2: Pest and weed controls are undertaken, in accordance with the Pesticides Act 1999 (NSW), within 20 metres of sensitive vegetation communities, riparian zones or wetlands, in consultation with relevant local council, catchment management and NSW Local Land Services officers.

Management 3: Nutrient and sediment run-off into areas of native vegetation is avoided through controlled storage, stockpiling, reuse and application management (see Sections 9.2 Surface and Ground Waters and 9.2 Soils).

Outcome:

Proactive planning minimises the likelihood of impact upon local water catchments and supports the protection of native flora, fauna and their habitat.

Management 1: Biodiversity, riparian and wetland sensitive areas, especially those declared as vulnerable or endangered ecological communities under Commonwealth and State Acts, are identified and protected with fencing and management access gates. Fencing is constructed in accordance with best management practice and Allowable activities relating to rural infrastructure (LLS, 2014) under the Land Management (Native Vegetation) Code 2018 (LLS, 2018). Remediation to enhance quality and habitat creation is undertaken through appropriate revegetation techniques with species native to the area and vegetation community.

Management 2: Vulnerable lands such as erodible embankments, gullies and landslips are identified, protected and revegetated using local native and structurally diverse species to provide stabilisation, run-off filtration and habitat services. Works undertaken within these areas should also consider any obligations for a controlled activity
approval (earthworks) and the protection of Aboriginal objects and places (ground disturbance within a landscape feature) (see Section 8).

Outcome:

Dairy businesses know their net greenhouse gas emissions and emission intensity as a benchmark to better understand the farm’s emission profile and reduction management practices available to the business.

Management 1: Use the ADCC to determine current net greenhouse gas emissions and emissions intensity and/or forecast emissions intensity based on the development and operational changes planned for the business.

Management 2: Use supporting Dairy Australia resources to identify and implement changes that will profitably reduce emissions.

Outcome:

Dairy operations identify, consider and minimise the likelihood of impact to Aboriginal objects and places.

Management 1: Ground disturbance activities that are not low impact, trivial or negligible are reviewed in line with the Due Diligence Code of Practice for the Protection of Aboriginal Objects in NSW (DECCW, 2010).

Management 2: Assessments consider impacts to Aboriginal cultural heritage that are appropriate for the location, level of disturbance and potential to impact on sensitive areas are undertaken as part of any application and prior to the activity commencing.

Management 3: Consultation is undertaken in accordance with the SEARs and legislated requirements with Aboriginal Groups as part of any assessment for a greenfield development site.