Version No: 1
Issue Date: Jan 14
Review Date: July 14
Technical Authority: ASEE
Subject Matter Expert: DEPA
GUIDANCE ON THE
PREPARATION OF AN
ENVIRONMENTAL REPORT
Purpose of this Document
This document provides guidance on the minimum requirements for preparing an
Environmental Report (ER) for the Department of Defence.
What is an Environmental Report (ER)?
An ER evaluates the potential environmental impacts of a Defence action, the significance of
those impacts and any relevant management measures to avoid, minimise or offset
environmental harm.
ER’s have replaced Initial Environmental Reviews (IERs) and Environmental Scoping
Studies (ESSs). An ER does not replace a more detailed Environmental Impact Assessment,
Environmental Impact Study or Public Environment Report. ER’s are not the sole document
pathway for environmental impact assessment in Defence – but they will be the most
common starting point for major projects or those actions likely to disturb environmental or
heritage values on the Defence estate.
An ER determines whether significant impacts on matters protected by the Environment
Protection and Biodiversity Conservation Act 1999 (EPBC Act) are likely to occur as a result
of the Defence action. The ER therefore informs Defence’s position on whether the action
requires formal referral to the Australian Government Minister for the Environment (the
Environment Minister). The ER also assists Defence determine whether the action requires
more detailed impact assessment. Note that these two outcomes can be independent of
each other – Defence may commission further studies without ultimately referring the action
in question and Defence may also refer the action at this point without conducting any further
impact assessments. Where a referral is required, the information prepared for the ER will
form the basis of the referral.
Similar to IERs and ESSs, the preparation of an ER usually involves a desk-based review of
existing documentation. However, an important distinction in the move to ERs is that it will
not be uncommon to include targeted surveys. The surveys may be included in the scope of
work for the ER or may be recommended by the consultant undertaking the ER (see Do’s
section on page 3 for further information).
Matters protected under Part 3 of the EPBC Act and requiring consideration within an ER
include:

World Heritage properties (refer to sections 12 and 15A of the EPBC Act);

National Heritage places (sections 15B and 15C);

Wetlands of international importance (Ramsar) (sections 16 and 17B);

Listed threatened species and communities (sections 18 and 18A);

Listed migratory species (sections 20 and 20A);

Protection of the environment from nuclear actions (sections 21 and 22A);

Commonwealth marine environment (sections 23 and 24A);

Great Barrier Reef Marine Park (sections 24B and 24C);

The environment, if the action involves Commonwealth land (sections 26 and 27A),
including:
o
actions that are likely to have a significant impact on the environment of
Commonwealth land (even if taken outside Commonwealth land), and
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o
actions taken on Commonwealth land that may have a significant impact on
the environment generally.

Commonwealth Heritage places outside the Australian jurisdiction (sections 27B and
27C); and

The environment, if the action is undertaken by a Commonwealth agency (section
28).
The development of an ER must include use of the following Australian Government
resources:

Department of the Environment (DoE) policy statement titled Significant Impact
Guidelines 1.1 – Matters of National Environmental Significance (hereafter SIG 1.1).

DoE policy statement titled Significant Impact Guidelines 1.2 Actions on, or impacting
upon, Commonwealth land, and actions by Commonwealth agencies (hereafter SIG
1.2).

DoE interactive mapping tool (the Protected Matters Search tool) to identify known
EPBC protected matters relevant to the action (results of the search should be
attached as an Appendix in the ER).

DoE website, which provides extensive information on threatened species, ecological
communities, survey methodologies, permitting requirements and other
environmental aspects covered under the EPBC Act.

Defence Estate Quality Management System (DEQMS) website1, which provides
resources on Defence environmental policies and registers, base zone plans and
other environmental quality assurance documentation.

Environmental Planning Implementation Tool (EPIT), which provides information on
the existing reports available for each Defence site across Australia. The EPIT tool
can be found at
http://intranet.defence.gov.au/estatemanagement/planning/document_directory/epit/m
ain.htm. Access to Defence’s electronic filing system (referred to as ‘Objective’) via
the Defence Restricted Network (DRN) is required to access the EPIT.

Senior Environment Managers (SEM) or Regional Environmental Officers (REO) for
each Defence site affected by the project, who can provide information on the site,
detail other relevant impact assessments and input generally into the environmental
considerations for the project.
What information does an ER need to contain?
The ER must contain the information as outlined in this guidance document.
While this document will guide the scope of the ER, it should not be seen as exhaustive or
limiting. If during the preparation of the ER, previously unforeseen matters not addressed in
this guidance document are found to be relevant, those matters are to be included in the
main body of the ER.
1
The DEQMS website is available to users external to Defence. Some documents on the DEQMS
website can only be accessed via the Defence Restricted Network (DRN). Consultants should request
a copy of such documents via their Defence project manager or utilise their company’s DRN access.
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The Do’s and Don’ts of an ER
Do:
 Do contact the Directorate of Environmental Protection and Assessment (DEPA) at
the beginning of the contract to discuss the proposed action and the ER. This is
particularly important for actions that affect multiple sites or actions that are mobile.
 Do submit to Defence an ER that has been critically peer reviewed.
 Do provide an ER written in plain English with limited technical terminology. Where
required, discussions on technical matters are expected to utilise accurate
terminology relevant to each particular field of science and consider including a
glossary.
 Do provide an ER that is as concise as possible without omitting critical information.
The ER must be ‘to the point’ with key messages presented up-front.
 Do provide a significant impact self-assessment for each matter protected by Part 3
of the EPBC Act.
 Do provide an ER that has clear and definitive recommendations and conclusions.
 Do provide an ER that is comprehensive, accurate and defensible in a court of law.
The methodology to achieve this must be robust and repeatable. The basis for each
finding and recommendation, including significance determinations, should be stated
clearly and concisely.
 Do include all of the sections outlined in the ER content guidance below.
 Do discuss the project with DEPA at your earliest convenience if you perceive an
opportunity to close out the environmental impact assessment process for a Defence
action by conducting additional straightforward surveys or analyses, the findings of
which could be incorporated into the ER. Tender documentation for future ER’s will
include a milestone requirement for the consultant to discuss this matter with DEPA
prior to delivery of a draft ER.
 Do be mindful that the ER may end up supporting a referral and become accessible
to the general public.
 Stick closely to the layout of the ER template. Where it is necessary to include a lot of
text under a particular heading, it is appropriate to either use subheadings or include
an executive summary of the relevant information and include the balance as an
attachment (such as a heritage or ecological impact report).
Don’t:
 Don’t over-scope the ER by pursuing irrelevant or marginal issues.
 Don’t submit an ER that has large ‘cut and paste’ sections from previous reports.
 Don’t be overly repetitive in the ER or bury key messages in lengthy commentaries.
 Don’t leave out sections of the ER report just because it has been labelled ‘Draft’.
Draft ER reports must contain all sections outlined in the ER content guidance below.
 Don’t pre-empt a decision by Defence to prepare more substantial environmental
impact documents after the ER. Whilst the ER may recommend this (and Defence
may support it), the ER must stand on its own merits as Defence may conclude its
impact assessment process for any given action at this point.
 Don’t depart substantially from the format of the ER as laid out in this template
without seeking Defence’s concurrence.
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Supporting Documentation
Documentation relied upon to support the analysis, recommendations and conclusions, such
as environmental reports and the results of targeted surveys, including heritage
assessments, should be referenced within and attached to the ER. Large attachments may
be provided in digital form only, provided they are adequately referenced within the ER.
Coloured maps, figures or photographs that help explain the action, its location or the
analysis should also be submitted with the ER. Figures and maps should be of a high quality.
Maps should be at a scale that clearly shows the location of the proposed action and any
relevant environmental factors.
Deliverables
All spatial data generated or modified for the ER, such as monitoring data and maps, must
be done in a manner consistent with the Defence Spatial Data Management Plan (in
particular, Chapter 13 Environmental Data), which is available on the DEQMS website.
Monitoring data, maps and associated data files (e.g. shape files, CAD files) must be
provided to DEPA on a disk with the final ER.
A map/aerial photograph depicting the physical area covered by the ER must be provided
unless otherwise agreed by Defence. This requirement does not apply to capability
acquisition projects provided that adequate written descriptions are given for any typical or
envisaged use scenarios.
Both the draft and final ERs must be provided to Defence in an unlocked Portable Document
Format (PDF) and Microsoft Word format (compatible with version 2003). The consultant
must also ensure that the consultant's name, logo and any other identifying material has
been removed from the Contract Material.
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STRUCTURE AND CONTENT OF AN ENVIRONMENTAL REPORT
The structure of an Environmental Report is provided in a table of contents below. Refer to
Annex A for further instructions on how to address each heading.
PROJECT TITLE
EXECUTIVE SUMMARY
ABBREVIATIONS AND DEFINITIONS
1 SUMMARY OF PROPOSED ACTION
1.1 Description of the action
1.2 Locality and property description
1.3 Size of the development footprint or work area
1.4 Time frame
1.5 Alternatives to taking the action
1.6 Alternative locations, time frames or activities that form part of the action
1.7 A staged development or component of a larger action
1.8 Relationship of the action to other developments or actions
2 METHODS
2.1 General
2.2 Environmental risk assessment
3 CONTEXT
3.1 Context, planning framework, legislation and policy requirements
3.2 Previous environmental impact assessment
3.3 Consultation
4 DESCRIPTION OF ENVIRONMENT
5 MEASURES TO AVOID OR REDUCE IMPACTS
6 EPBC ACT SIGNIFICANT IMPACT TESTS AND PERMITS
6.1 Matters of National Environmental Significance
6.1(a) World Heritage properties
6.1(b) National Heritage places
6.1(c) Wetlands of international importance (declared Ramsar wetlands)
6.1(d) Listed threatened species and ecological communities
6.1(e) Listed migratory species
6.1(f) The Great Barrier Reef Marine Park
6.1(g) Nuclear action
6.1(h) Commonwealth marine areas
6.2 The whole of environment on Commonwealth land or Commonwealth agency
action
6.2(a) Impacts on landscapes and soils
6.2(b) Impacts on coastal landscapes and processes
6.2(c) Impacts on ocean forms, ocean processes and ocean life
6.2(d) Impacts on a water resource
6.2(e) Pollutants, chemicals, and toxic substances
6.2(f) Impacts on plants
6.2(g) Impacts on animals
6.2(h) Impacts on people and communities
6.2(i) Impacts on heritage
7 OTHER COMMONWEALTH OBLIGATIONS UNDER THE EPBC ACT
7.1(a) Critical Habitat
7.1(b) Recovery and Threat Abatement Plans
7.1(c) Wildlife Conservation Plans
7.1(d) World Heritage Areas
7.1(e) Ramsar Wetlands
7.1(f) Biosphere Reserves
7.2(g) Commonwealth Reserves
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8 EPBC ACT PERMIT REQUIREMENTS
9 SUMMARY AND RECOMMENDATIONS ON THE LIKELIHOOD OF SIGNIFICANT
IMPACTS
10 CONCLUSION
11 REFERENCES
12 ATTACHMENTS AND APPENDICES
- Specific information for listed marine species
- Specific information for Commonwealth heritage values
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ANNEX A
STRUCTURE AND CONTENT OF AN ENVIRONMENTAL REPORT
Instructions for the users of this guideline are provided in green. If the  icon appears next
to a section, it is mandatory that this information is provided. The acronym NfC – Not for
Capability - will identify those sections not to be completed for capability acquisition ERs
(henceforth referred to as capability ERs). Please note that the
construction/alteration/demolition of facilities associated with a capability project (for example
new storage or range facilities) will be treated as a standard infrastructure project.

PROJECT TITLE

EXECUTIVE SUMMARY
This section should provide a concise summary of the ER. It should read as a stand-alone
document that provides a broad overview of the whole report, including methodology, results
and recommendations, highlighting the main issues associated with the action and the
proposed mitigation and management measures to avoid or minimise potential impacts.
 ABBREVIATIONS AND DEFINITIONS

1 SUMMARY OF THE ACTION
Maps clearly showing the expected location and boundaries of the action and alternatives
considered (if applicable) should be provided in this section. The maps should clearly show
land tenures and the extent of any surveys/field investigations undertaken as part of the ER.
Where the action is at an early development stage or where certain elements of the action
are yet to be determined – such as the size of vegetation to be cleared, the Training Area
where the action is to take place or the specific model of a capability acquisition – the ER
must utilise as much information as is available. The ER must identify which information may
change as the action progresses through the design phase and the consequence of this
change in terms of environmental impact (to the extent this can be forecast).
 1.1 Description of the action
Provide a description of the proposed action, including its current status, as well as all
relevant activities and aspects of the action that have the potential to impact on the
environment. Include figures and/or attachments as appropriate. Include a site plan
where relevant.
 1.2 Locality and property description
Provide a brief physical description of the site (or site options) that the action will impact
upon (i.e. study area). Provide a description of the regional context of the study area, as
well as a description of the Defence Base/s (and precinct if known) or Training Area/s
where the action will take place. Capability ERs must respond to this requirement to the
extent that information is available and must also present typical usage scenarios.

Latitude and longitude details of the boundary of the action must be shown (NfC unless
clearly relevant). If the area is less than 5 hectares, provide the location as a single pair
of latitude and longitude references. If the area is greater than 5 hectares, provide
bounding location points.
1.3 Size of the development footprint or work area
Provide information on the development footprint or work area, for example, the specific
location and area (in hectares) of disturbance or works (such as vegetation to be
cleared, the area of hard stand to be created and the area of potential contamination to
be disturbed, etc). For capability acquisitions it is relevant to provide information on
training area requirements (physical area, terrain type etc) for each Training Area to be
used.
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
1.4 Time frame
Specify the time frame in which the action will be taken, including the estimated
start date of construction and operation. Provide a timeframe for any additional
proposed studies recommended in the ER. For capability acquisitions it is relevant
to specify known testing, initial operational capability, final operational capability and
decommissioning and disposal timeframes.
 1.5 Alternatives to taking the action
Detail any alternatives to the action proposed during the project’s design and
development and provide an analysis of these alternatives that demonstrates why
the current action and associated options have been chosen. Include alternative
structures and designs, alternative management, etc. Discuss the consequences of
not proceeding with the action overall.
1.6 Alternative locations, time frames or activities that form part of the action
(if applicable)
If the action includes alternative time frames, locations or activities, you must
complete this section. Describe any alternatives related to the physical location of
the action, time frames affecting the action and alternative methods or activities for
undertaking the action (only to the extent they differ from the action proposed in
section 1.1). Highlight the consequential impacts of these alternatives compared to
the proposed action. For capability ERs this section would also include options for
acquiring larger numbers or different configurations of equipment.
1.7 A staged development or component of a larger action (if applicable)
If the action is a staged development or a component of a larger action provide
information about the larger action and details of any interdependency between the
two. If applicable, summarise why the ER only includes the smaller proposed action,
for example, as there is a distinct spatial and/or temporal separation, distinct
potential environmental impacts due to the nature of specific works at that site or
because works will be conducted in a particularly sensitive area. For capability ERs,
summarise the relationship between this particular acquisition and the broader
capability it will support.
 1.8 Relationship of the action to other developments or actions
Outline the relationship between the action and any other developments or actions
that may result if the proposed action were undertaken, whether or not they have
been approved. Also describe the key environmental aspects likely to be impacted
by other projects occurring in a similar temporal and spatial space. This section is
intended to address upstream, downstream, facilitated or cumulative impacts
associated with the proposed action.
2 METHODS

2.1 General
Provide a description of the steps taken to prepare the ER, including the resource
tools utilised, field work methods, other studies or surveys undertaken to inform the
ER and consultation that has occurred. Describe the qualifications and experience
of the study team, specialist sub-consultants and expert reviewers. Cite the version
number and publication date of the ‘Guidance on the Preparation of an
Environmental Report’ document used to guide the report.
2.2 Environmental risk assessment (Optional)
Please note that the conduct of an environmental risk assessment is no longer a
mandatory inclusion within an ER. Defence will identify within scoping
documentation those projects that require completion of a risk assessment. Where
a risk assessment is required, please follow the guidance provided below.
Detail the methods used to undertake the environmental risk assessment, of which
the analysis and outcomes are to be described in summary at section 5 and in full in
table format as an appendix.
The ER risk assessment must be undertaken in accordance with the Defence
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Support Organisation (DSO) Regional Risk Management Framework (RRMF),
endorsed on 18 December 2012. The DSO RRMF is available from the DSO
website on the Defence Restricted Network (DRN), or from the Defence Project
Manager. While some terminology within the DSO RRMF, in particular, within the
Consequence Table, may be DSO-centric, it can still be applied to non-DSO
actions.
At a minimum, the ER risk assessment must assess the ‘Environment’ and ‘Safety’
consequences of each environmental aspect associated with the action. The
consultant may, upon occasion, be directed through scoping documentation to
complete the assessment for any of the other six consequence categories where
they are considered relevant.
Both Initial Risk (unmitigated risk) and Residual Risk (mitigated risk) must be
assessed and a description of each mitigation measure provided. Cumulative
impacts must also be considered and where applicable assessed.
Potential impacts associated with the whole lifecycle of the action must be
assessed.
For infrastructure project lifecycles this includes the following stages: design,
construction, operation, maintenance and, ultimately, decommissioning and
disposal.
For capability project lifecycles this includes: acquisition, assembly, testing,
introduction into service, operation, maintenance, training, transportation and,
ultimately, decommissioning and disposal.
Present a detailed summary of the risk assessment outcomes, with the focus on
medium, high and very high initial and residual risk scores.
Include a summary of this information in a table format, showcasing the potential
environmental impacts (risks), a summary of the mitigation measures to avoid or
minimise the impacts and risks ranked from very high to low.
3 CONTEXT

3.1 Context, planning framework, legislation and policy requirements
Explain the context in which the action is proposed. This should include relevant
planning frameworks – for example, Defence Zoning Plans or Training Area
Capability Board (TACB) decisions, the Defence Capability Plan, Australian
Government legislation and policies and Defence Instructions, Orders or policies.
Describe State and Territory environment legislation and standards that are relevant
to the action.
Specific information on how each requirement applies to the proposed action, and
what must be done to comply with each requirement, must be provided.
Note. Defence environment and heritage policies are available on the DEQMS
website.

Note. Defence has a “good neighbour” policy on the environment (Defence
Environmental Strategic Plan 2010-2014). Where appropriate Australian
Government environmental legislation and policies do not exist, Defence aims to
comply with the intent and spirit of relevant State and Territory environment
legislation and related standards.
3.2 Previous environmental impact assessment
Provide a desktop review of previous environmental assessments that are relevant
to the action (i.e. that have been conducted at the property or sites, or relate to this
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

or a similar action). Identify the key environmental issues and protection measures
in these previous studies where they are applicable to the action.
3.3 Consultation
Detail the outcomes of consultation with Defence personnel such as the project
team, SEM or REO.
Public consultation may be required during the preparation of the ER, for example,
consultation with Indigenous stakeholders. The ER must provide details of any
public consultation that has been undertaken, including the outcomes of the event/s,
and details of public consultation that is planned for the future. Identify the relevant
stakeholders and the status of consultations at the time of the ER being finalised.
4 DESCRIPTION OF ENVIRONMENT
Provide a comprehensive description of the environment that may be affected by the
action. This should include specific consideration of all Matters of National Environmental
Significance (MNES), the whole of the environment and other Commonwealth obligations
under the EPBC Act.
MNES
The DoE Protected Matters interactive tool should be utilised to identify any MNES
protected by the EPBC Act within the area in which the action will be undertaken. When
utilising the tool, draw a shape around the area likely to be directly affected by the action
and use a 10 km buffer (this is the same distance the Department of the Environment will
use in any subsequent referrals). If specific locations for the deployment of a capability
acquisition are not available, the use of this tool is not required. The ER must still
consider the different life phases of the capability acquisition for their potential to impact
individual MNES under typical usage scenarios.
Present a table upfront that summarises the EPBC protected matters relevant to the
proposed action. The table must cover the EPBC Act controlling provision and any key
environmental values relevant to the matter protected.
WHOLE OF THE ENVIRONMENT
The information presented on the environment as a whole (i.e. non-MNES matters)
should cover the following topics as a minimum:












Flora (incl. native/endemic/declared weed/environmental weeds/community
types/successional stages and vegetative condition) and fauna (incl.
native/endemic/feral/pest species and any known and relevant abundances)
Hydrology
Soil and Vegetation characteristics
Outstanding natural values
Gradient (or depth range if action undertaken in a marine environment)
Current state of the environment
Commonwealth Heritage Places or other places recognised as having heritage
values
Indigenous heritage values
Built heritage values
Other important or unique environmental values of the area
Existing and proposed land/marine uses
Any previous approvals and ongoing conditions/offsets/conservation areas that may
apply to or be impacted by the action that is the subject of the ER.
OTHER COMMONWEALTH OBLIGATIONS UNDER THE EPBC ACT
The biodiversity conservation provisions of the EPBC Act place obligations on
Commonwealth agencies to comply with instruments prepared under the Act in relation to
species, habitat and protected areas. In describing the whole of the environment, the ER
must identify those obligations that may influence the action (e.g. the presence of Critical
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Habitat) and those obligations that may fail to be upheld as a result of undertaking the
action (e.g. the requirement to not contravene a management plan for a RAMSAR site in
a Commonwealth area). In describing the existing environment the ER must identify the
presence/relevance of the following obligations:







Critical Habitat (EPBC s. 207B - C)
Recovery and Threat Abatement Plans (s. 268)
Wildlife Conservation Plans (s. 286)
World Heritage Areas (s. 318/322)
Ramsar Wetlands (s. 330/334)
Biosphere Reserves (s. 339)
Commonwealth Reserves (s. 362).
An analysis of these obligations must be presented in section 7 of the ER.
OTHER CONSIDERATIONS
Previous environmental impact assessment reports and other literature, including
relevant State or Territory databases and DoE policy statements, plans or profiles should
also be consulted and identified in the ER, as they relate to the environment that may be
affected by the action.
The Defence Contaminated Sites Register provides coverage of both contamination and
unexploded ordnance and should be consulted during the preparation of an ER. It can
only be accessed through the DRN
(http://intranet.defence.gov.au/im/environment/Programs/Contamination/csr.htm).
Where there is no information or only unreliable information available on an element of
the environment, the ER must identify this as a knowledge gap and, where it is necessary
to inform the significant impact tests at section 6, provide a recommendation at section
7.1 to address this gap.
Note: Even if an action is not taking place in a World Heritage Area, Ramsar wetland, the
Great Barrier Reef Marine Park or Commonwealth Marine Area, it may still impact upon
these areas. When assessing impacts on the receiving environment, consider both the
immediate site of the action and adjacent, surrounding, downstream and downwind areas
that may be directly or indirectly affected by the action. A discussion of the intervening
land use should be included in the ER. This includes Commonwealth land outside of the
project footprint that may be impacted.
Where a MNES or an element of the environment is not applicable, provide an
explanation of why, for example, “No listed National Heritage places are located within or
near the project footprint”.
Note: The Defence Offsetting Framework is currently being developed by the Directorate
of Heritage and Biodiversity Conservation (DHBC). Under this framework, an
environmental offset is likely to be required for any action that involves native vegetation
clearing or that impacts on World, Natural or Commonwealth Heritage Listed natural
areas, a Ramsar wetland, or a listed migratory species, threatened species or ecological
community. Using this framework, the ER must clearly demonstrate, for each siting option
assessed, where an offset is likely to be required. This information may inform the
Defence Site Selection Board process (NfC – but will apply to facility
construction/adaptation associated with those projects).
Note: Where the action may interact with a contaminated site, the Directorate of
Environmental Remediation Program (DERP) must be contacted for advice and to gain
access to the Contaminated Sites Register (NfC - but will apply to facility
construction/adaptation associated with those projects).
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
5 MEASURES TO AVOID OR REDUCE IMPACTS
Provide clear, unambiguous descriptions of mitigation measures that will be implemented
to avoid, reduce, manage or offset the impacts of the action. Include, if appropriate, any
relevant reports or technical advice relating to the feasibility and effectiveness of the
proposed measures. For capability ERs this may take the form of restrictions on usage,
creation/alteration of SOPs/SOs etc.
Ensure that any alternatives that may have been identified in relation to the location, time
frame or components of the action are discussed where they offer notable mitigation of
impacts compared to the preferred option.
For any measures intended to avoid or mitigate significant impacts on matters protected
under the EPBC Act, the ER must specify:
• what the measure is
• how the measure is expected to be effective
• the timeframe for the measure; and
• the likelihood of the proposed measure achieving the desired outcome.
Examples of relevant measures to avoid or minimise impacts may include the timing of
works, avoidance of important habitat, specific design measures or the adoption of
specific work practices. All measures proposed must be measurable and auditable.
Please note that whilst discussion of Ecologically Sustainable Design elements
incorporated into a given project may be discussed throughout the ER, it is expected that
commitments made by the project team will be discussed in detail within this section.
Recommendations by the consultant to improve the ESD outcomes for the project should
be included in section 9 of the ER report as relevant.

6 EPBC ACT SIGNIFICANT IMPACT TESTS
In accordance with Part 3 of the EPBC Act, activities undertaken on Commonwealth land
or by a Commonwealth agency must be approved under the Act if they are likely to
significantly impact the environment.
The purpose of Section 6 of the ER is therefore to document the assessment undertaken
to determine the potential significance of the proposed action on MNES (at section 6.1)
and the environment as a whole (at section 6.2).
In addition to general guidance, the EPBC Act SIG 1.1 and SIG 1.2 provide criteria on
what constitutes a Significant Impact (SI) on a MNES or the environment (hereafter
referred to as SI Criteria). However, the SI Criteria are not exhaustive and the ER should
consider all relevant facts and circumstances specific to the proposed action when
making a significance determination.
In addition to the Australian Government resources described on page 1, the following
specific resources (available primarily from the DoE website) must be consulted and
referenced, as applicable:
• Specific values of individual World Heritage properties and National Heritage
places and the ecological character of Ramsar wetlands
• Profiles of relevant species and communities and whether the action is likely to
have a significant impact
• Relevant policies available on the DoE web site
• Species-specific significant impact guidelines
• Survey Guidelines for Nationally Threatened Species
• Great Barrier Reef Marine Park Authority website regarding environmental
management of Defence activities.
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In this section of the ER, assessments regarding the significance of impacts should be
made based on the assumption that all mitigation measures described in section 5 are
properly implemented, that is, the significance determination should be based on the
post-mitigation scenario.
Potential impacts associated with the whole lifecycle of the action must be assessed.
For infrastructure project lifecycles this includes the following stages: design,
construction, operation, maintenance and, ultimately, decommissioning and disposal.
For capability project lifecycles this includes: acquisition, assembly, testing, introduction
into service, operation, maintenance, training, transportation and, ultimately,
decommissioning and disposal.
 6.1 Matters of National Environmental Significance
In sections 6.1(a) – 6.1(h), present the EPBC Act significant impact test in the
following way.
Description
Describe the location of the action relative to identified MNES.
Where a MNES is not applicable to the action, provide an explanation of why, for
example, “No declared World Heritage properties or values are located within or
adjacent to (i.e. immediately surrounding, downstream or downwind from) the
project area. The nearest World Heritage property is XX kilometres north-east of the
project area and, given the distance and nature of the action, it is considered
unlikely that the action would significantly impact on this site.”
Nature and extent of likely impact
Where the proposed action has the potential to impact on the MNES, undertake an
assessment using the relevant SI Criteria and document the outcome (i.e. a ‘yes’ or
‘no’ answer) and provide an analysis (i.e. the reasons why) for each.
Consider the potential severity of the impact (i.e. the scale, intensity, duration and
frequency).
The SI criteria for World Heritage properties from SIG 1.1 are provided below as an
example only.
“An action is likely to have a significant impact on the World Heritage values of a
declared World Heritage property if there is a real chance or possibility that it will
cause:
• one or more of the World Heritage values to be lost,
• one or more of the World Heritage values to be degraded or damaged, or
• one or more of the World Heritage values to be notably altered, modified,
obscured or diminished.
Where the action may impact on values associated with geology or landscape:
An action is likely to have a significant impact on the natural heritage values of a
World Heritage property if there is a real chance or possibility that it will cause:
• damage, modify, alter or obscure important geological formations in a World
Heritage property,
• damage, modify, alter or obscure landforms or landscape features, for example, by
excavation or infilling of the land surface in a World Heritage property,
• modify, alter or inhibit landscape processes, for example, by accelerating or
increasing susceptibility to erosion, or stabilising mobile landforms, such as sand
dunes, in a World Heritage property,
• divert, impound or channelise a river, wetland or other water body in a World
Heritage property, and
• substantially increase concentrations of suspended sediments, nutrients, heavy
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metals, hydrocarbons, or other pollutants or substances in a river, wetland or water
body in a World Heritage property.”
6.1(a) World Heritage properties
Refer to the SI criteria (SIG 1.1) on page 16.
6.1(b) National Heritage places
Refer to the SI criteria (SIG 1.1) on page 19.
6.1(c) Wetlands of international importance (declared Ramsar wetlands)
Refer to the SI criteria (SIG 1.1) on page 13.
6.1(d) Listed threatened species and ecological communities
Refer to the SI criteria (SIG 1.1) on pages 8-11.
6.1(e) Listed migratory species
Refer to the SI criteria (SIG 1.1) on page 12.
6.1(f) The Great Barrier Reef Marine Park
Refer to the SI criteria (SIG 1.1) on page 24.
6.1(g) Nuclear action
Refer to the SI criteria (SIG 1.1) on page 23.
6.1(h) Commonwealth marine areas
Refer to the SI criteria (SIG 1.1) on page 14.
6.2 The whole of environment on Commonwealth land or Commonwealth
agency action
Do not copy and paste directly from Section 6.1 into this section.
In sections 6.2(a) – 6.2(i), present the EPBC Act significant impact test in the
following way.
Description
Describe the location of the action relative to identified environmental values.
Where a set of SI Criteria is not applicable to the action, provide an explanation of
why, for example, “The nearest coastline is 200km west of the project area and,
given the distance and nature of the action, it is considered unlikely that the action
would significantly impact on coastal landscapes and processes.”
For capability projects it will be more relevant to consider the potential impacts of
the use of the new capabilities in proximity to all aspects of the whole of the
environment, as precise locations for their use are typically not fixed.
Nature and extent of likely impact
Where the proposed action has the potential to impact on the environment,
undertake an assessment using the relevant SI Criteria and document the outcome
(i.e. a ‘yes’ or ‘no’ answer) and provide an analysis (i.e. the reasons why) for each.
The SI criteria for impacts on landscapes and soils from SIG 1.2 are provided below
as an example only.
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“Is there a real chance or possibility that the action will:
• substantially alter natural landscape features;
• cause subsidence, instability or substantial erosion; or
• involve medium or large-scale excavation of soil or minerals?”
6.2(a) Impacts on landscapes and soils
Refer to the SI criteria (SIG 1.2) on pages 14-15.
6.2(b) Impacts on coastal landscapes and processes
Refer to the SI criteria (SIG 1.2) on page 15.
6.2(c) Impacts on ocean forms, ocean processes and ocean life
Refer to the SI criteria (SIG 1.2) on page 15.
6.2(d) Impacts on water resources
Refer to the SI criteria (SIG 1.2) on page 15.
6.2(e) Pollutants, chemicals, and toxic substances
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Refer to the SI criteria (SIG 1.2) on page 15.
6.2(f) Impacts on plants
Refer to the SI criteria (SIG 1.2) on pages 15-16.
6.2(g) Impacts on animals
Refer to the SI criteria (SIG 1.2) on page 16.
6.2(h) Impacts on people and communities
Refer to the SI criteria (SIG 1.2) on page 16.
6.2(i) Impacts on heritage
Note. This refers to Commonwealth heritage places, Indigenous heritage places or
other places that may be culturally significant or recognised as having heritage
value. Where available, relevant Heritage Management Plans must be consulted.
Additional information on how Commonwealth heritage values should be addressed
in the ER is provided at the back of this guidance document.
7 OTHER COMMONWEALTH OBLIGATIONS UNDER THE EPBC ACT
In sections 7.1(a) – 7.1(g), present an analysis of any relevant obligations in the following
way.
Description
Describe the location of the action relative to Commonwealth areas with management
plans in place or containing critical habitat.
Where an obligation is not applicable to the action, provide an explanation of why, for
example, “The nearest critical habitat is located 100km south of the project area and,
given the distance and nature of the action, it is considered unlikely that the action would
significantly damage the critical habitat.”.
For those obligations requiring compliance with instruments that have become manifest
as plans (for example recovery plans or management plans), the analysis must include a
close-out statement such as “The proposed action does/does not contravene the
approved recovery plan for the species”.
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7.1(a) Critical Habitat
Refer to EPBC s. 207B - C.
7.1(b) Recovery and Threat Abatement Plans
Refer to EPBC s. 268.
7.1(c) Wildlife Conservation Plans
Refer to EPBC s. 286.
7.1(d) World Heritage Areas
Refer to EPBC s. 318/322.
7.1(e) Ramsar Wetlands
Refer to EPBC s. 330/334.
7.1(f) Biosphere Reserves
Refer to EPBC s. 339.
7.1(g) Commonwealth Reserves
Refer to EPBC s. 362.
8 EPBC PERMIT REQUIREMENTS
Part 13 of the EPBC Act prohibits the killing, injuring, taking, trading, keeping or moving
of a member of the following in or on a Commonwealth area:
 Listed threatened species (except a conservation dependent species) or ecological
community (refer to sections 196 and 196A-196E of the EPBC Act)
 Listed migratory species (sections 211, 211A-211E)
 Listed marine species (sections 254 and 254A-254E).
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Where the proposed action is to be undertaken in or on a Commonwealth area, and has
the potential to kill, injure, take, trade, keep or move (referred to hereafter as take) a
member of one of these listed species or communities, an EPBC permit to undertake the
proposed activity may be required.
Note that where the species or community is also a MNES – that is, a member of a listed
threatened species, ecological community or migratory species – a significant impact
assessment should have already been undertaken at section 6.1 of the ER.
Defence may need to apply for a permit under Part 13 of the EPBC Act if:
 The significant impact test undertaken for that particular species or community
found the proposed action is unlikely to have a significant impact, even though it
may take individuals of that species or community; or
 An action has been referred to the Environment Minister and despite the potential
to take - has been deemed a not-controlled action (that is to say a significant
impact is unlikely and no Part 9 approval under the EPBC Act was required or
obtained).
The ER must therefore determine if a permit is required. By following this guidance
and presenting the information requested, the ER will provide Defence a basis from which
a permit application can be prepared.
The consultant must refer to and consider any approved conservation advice for the listed
species or communities concerned (available through the DoE website). The consultant
must also consider whether the proposed activity qualifies as an action deemed not to be
an offence under the Act (provided under “certain actions are not offences” throughout
Part 13). All of this information must be included in the ER to the extent relevant.
Considerations for exemptions from Part 13 of the Act (refer section 303A) would occur
only in extremely rare cases and relate to matters of National Security. Consultants and
their Defence project managers must discuss this matter with DEPA if they believe an
exemption is applicable.
The ER must provide specific detail on the species or communities that the proposed
activity may take. The ER must also detail the actions that may cause this to occur. When
determining the nature and severity of the potential adverse impacts on the members of
these species or communities, on-site and off-site impacts must be considered, as well as
direct, indirect, facilitated and cumulative impacts.
The ER must also describe why the taking of the action will not adversely affect the
survival or recovery in nature or the conservation status of the listed species or ecological
community.
Permits will only be issued by the Environment Minister under certain circumstances
(sections 201(3), 216(3), 238(3) and 258(3) of the EPBC Act are relevant to Defence and
are collated below). The ER must therefore determine which circumstance will support a
Permit application for each species or community concerned.
Permits will only be issued by the Environment Minister if:
1. The proposed activity will contribute significantly to the conservation of the listed
threatened species or ecological community, the listed migratory species, or the
listed marine species concerned, or other listed migratory or marine species; or
2.
The potential impact of the proposed activity – on a member of a listed threatened
species or ecological community, listed migratory species or listed marine species –
is incidental to, and not the purpose of, undertaking the activity and:
a. Will not adversely affect the survival or recovery in nature of the listed
threatened species or ecological community or the conservation status or
population of the listed migratory species or listed marine species; and
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b. Will not be inconsistent with a recovery plan that is in force for the listed
threatened species or ecological community or a wildlife conservation plan
that is in force for the listed migratory species or the listed marine species;
and
c. The holder of the permit take all reasonable steps to minimise the impact
of the activity on the listed threatened species or ecological community,
the listed migratory species or the listed marine species; or
3.
The proposed activity is of particular significance to indigenous tradition, and will not
adversely affect the survival or recovery in nature of the conservation status of the
listed threatened species or ecological community, the listed migratory species
(including any population) or the listed marine species concerned; or
4.
The proposed activity is necessary in order to control pathogens, and is conducted
in a way that will, so far as is practicable, keep to a minimum any impact on the
listed threatened species or ecological community, the listed migratory species or
the listed marine species concerned.
The analysis provided for criterion 2a above must include a description of:
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The likely short and long term impacts of the proposed activity on:
o Individual members of the listed species (including number of
individuals expected to be affected)
o
The population of which they form a part
o
The species as a whole
o
The ecological community (including an estimate of the area to be
affected).
The analysis provided for criterion 2c must include a description of:
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The steps that will be taken to comply with the EPBC Regulations1 and minimise
adverse impacts on each species or community, including:
o Timing and design of the activity to minimise adverse impacts,
particularly in relation to known migratory movements or aggregations
of animals
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Contingency plans to be followed in the case of events that may
adversely affect members of the species or the community.
Additional information on how listed marine species should be addressed in the ER is
provided at the back of this guidance document.
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9 SUMMARY AND RECOMMENDATIONS OF THE LIKELIHOOD OF
SIGNIFICANT IMPACTS
Provide a summary of the key outcomes in the ER. This will include a summary of the
likely environmental impacts associated with the action, as well as the outcomes of the
EPBC Act significant impact tests and how particular conclusions or decisions were
determined during the assessments against the SI Criteria.
Provide a summary of how the potential impacts might be avoided or minimised. Where it
is found that the potential impacts cannot be avoided or minimised, provide clear
recommendations to Defence on alternative options. Where relevant, include
recommendations to improve the ESD outcomes for the project.
Where further studies are required to determine whether or not the proposed action is
likely to have a significant environmental impact, provide details on what these studies
1
Environmental Protection and Biodiversity Conservation Regulations 2000 (Cth).
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are and a justification as to why Defence should consider undertaking them.
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10 CONCLUSION
Provide a preliminary determination to Defence on whether or not the action is likely to be
significant under the EPBC Act. This determination must be based on the outcome of the
SI Criteria tests. Describe the reliability of this preliminary determination, making
particular reference to any further studies that may have been recommended.
The recommendation must not state whether a referral to the Environment Minister is or
is not required; this decision will be made by Defence.
Provide the final recommendations for the project. The conclusion must be concise and
definitive.
 11 REFERENCES
Provide information on the reliability of the information referenced during this study, and
any uncertainties in the information.
Please ensure that all abridged references in the body of the report are included here in
full and that there are no references here which are not referred to in the report. Harvard
style referencing is preferred.
 12 ATTACHMENTS AND APPENDICES
This should include, for example, the full risk assessment (where conducted), any
supporting documentation, the report provided by the Protected Matters Search tool, an
outline of further studies recommended in section 9 and/or any relevant survey results.
Please ensure all attachments are correctly referenced within the body of the report.
Specific information for listed marine species
Where the proposed activity is likely to interact with a listed marine species, which includes,
among other things, bird species that occur naturally in Commonwealth marine areas, the
consultant must identify this and provide a list of the marine species of concern in the ER.
Listed marine species that are also classified as listed threatened species or listed migratory
species should have already been considered in previous sections of the ER – for example,
under the relevant MNES significant impact test (section 6.1) or under the listed threatened
species or migratory species permit assessment (section 7) - and, therefore, should not be
assessed again as a marine species.
It should be noted that where the proposed activity is to be undertaken on the Defence estate
in reasonable proximity to a marine environment, an EPBC Protected Matters Online Search
may still identify listed marine species within, for example, 10km of the project area. The
consultant must consider the likelihood of the proposed action killing, injuring, taking, trading,
keeping or moving a member of a listed marine species. Other environmental literature, for
example fauna survey data or empirical evidence, should be consulted where available.
Clear and definitive reasons why the proposed activity is likely (or unlikely) to either have a
significant impact on the species or kill, injure, take, trade, keep or move a member of a
listed marine species must be provided in the ER.
Specific information for Commonwealth heritage values
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Under section 341ZC of the EPBC Act, Defence must not take an action that has, will have
or is likely to have an adverse impact on the Commonwealth heritage values of a
Commonwealth heritage place, unless:
(a) There is no feasible and prudent alternative to taking the action; and
(b) All measures that can reasonably be taken to mitigate the impact of the action on
those values are taken.
Commonwealth heritage places on the Commonwealth Heritage List (CHL) comprise natural,
Indigenous and historic heritage places which can be entirely within a Commonwealth area
(note this includes leased land), or outside the Australian jurisdiction but owned or leased by
the Commonwealth.
Where it is identified that the proposed action may impact on a Commonwealth heritage
place or value, this must be described in detail at section 6.2(i) of the ER. Impacts to either
World or National heritage values must be described in sections 6.1(a) and (b) respectively
as they are MNES.
The consultant must undertake a significant impact test, in accordance with both the process
and specific criteria (partially reproduced below) from the following DoE publications:
 Australia’s Commonwealth Heritage – Working together: managing Commonwealth
heritage places (2008).
Is there a real chance or possibility that the action will cause:
 One or more of the heritage values to be lost;
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One or more of the heritage values to be degraded or damaged; or
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One or more of the heritage values to be notably altered, modified, obscured
or diminished?
 SIG 1.2
Is there a real chance or possibility that the action will:
 Permanently destroy, remove or substantially alter the fabric (physical material
including structural elements and other components, fixtures, contents, and
objects) of a heritage place
 Involve extension, renovation, or substantial alteration of a heritage place in a
manner which is inconsistent with the heritage values of the place
 Involve the erection of buildings or other structures adjacent to, or within
important sight lines of, a heritage place which are inconsistent with the
heritage values of the place
 Substantially diminish the heritage value of a heritage place for a community
or group for which it is significant
 Substantially alter the setting of a heritage place in a manner which is
inconsistent with the heritage values of the place, or
 Substantially restrict or inhibit the existing use of a heritage place as a cultural
or ceremonial site?
The consultant must document an outcome (i.e. ‘yes’ or ‘no’ answer) and provide analysis
(i.e. reasons why) for each of these criteria.
The ER must describe in detail any proposed action/s that has, will have, or is likely to have
a significant impact on a Commonwealth heritage place. In providing this description, the
consultant must be cognisant of the following Commonwealth Heritage Management
Principles (available through the DOE website):
 The objective in managing Commonwealth Heritage places is to identify, protect,
conserve, present and transmit, to all generations, their Commonwealth Heritage
values.
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The management of Commonwealth Heritage places should use the best available
knowledge, skills and standards for those places, and include ongoing technical and
community input to decisions and actions that may have a significant impact on
Commonwealth Heritage values.
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The management of Commonwealth Heritage places should respect all heritage
values of the place and seek to integrate, where appropriate, any Commonwealth,
state and territory and local government responsibilities for those places.
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The management of Commonwealth heritage places should ensure that their use and
presentation is consistent with the conservation of their Commonwealth Heritage
values.
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The management of Commonwealth Heritage places should make timely and
appropriate provision for community involvement, especially by people who:
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have a particular interest in, or associations with, the place, and
may be affected by the management of the place.
Indigenous people are the primary source of information on the value of their heritage
and the active participation of Indigenous people in identification, assessment and
management is integral to the effective protection of Indigenous heritage values.
Heritage Management Plans
Consideration must also be given to any plan for managing the Commonwealth heritage
place (Heritage Management Plans), irrespective of whether the plan has been endorsed
under the EPBC Act or not. The ER must outline whether or not the proposed action is
already provided for within the plan, will be taken in accordance with that plan or will follow
guidance or managing principles within the plan.
When assessing a site that is not listed but may have heritage values
When determining whether a place has Commonwealth or National Heritage values,
consultants must use either the Commonwealth or National Heritage Criteria included at
Regulations 10.03A or 10.01A of the Environment Protection and Biodiversity Conservation
Regulations 2000 (Cth). Please note the differing thresholds – Commonwealth Heritage
values require a place to have significant heritage value to the nation, whereas National
Heritage values operate at a higher level - requiring a place to have outstanding heritage
value to the nation.
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