RISK ADVISORY SERVICES

PURO.EARTH AND BIOMASS PROJECTS

Facility Design Review of Mardie Station Carbon Dioxide Removal (CDR) Project
Independent Assurance Report

December 2023
Contents
AUDIT SUMMARY ...................................................................................................................................2

PROJECT BACKGROUND ......................................................................................................................3

OBJECTIVE .............................................................................................................................................4

SUMMARY OF PROCEDURES UNDERTAKEN ...................................................................................... 4

VALIDATION AGAINST THE PURO STANDARD GENERAL RULES AND BIOCHAR METHODOLOGY4

OTHER MATTERS ................................................................................................................................. 13

OUR INDEPENDENCE AND QUALITY CONTROL ............................................................................... 13

MANAGEMENT RESPONSIBILITY........................................................................................................ 13

RSM’S RESPONSIBILITY ...................................................................................................................... 14

INHERENT LIMITATIONS ...................................................................................................................... 14

USE OF OUR REASONABLE ASSURANCE ENGAGEMENT REPORT ............................................... 14

CONCLUSION ....................................................................................................................................... 14

APPENDIX A – EXPECTED STATUTORY APPROVAL REQUIREMENTS AND TIMELINES ............... 16

APPENDIX B – BASELINE AND FINANCIAL ADDITIONALITY ASSESSMENT .................................... 19

APPENDIX C – CARBON FOOTPRINT CALCULATIONS ..................................................................... 20

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FACILITY DESIGN REVIEW OF MARDIE STATION CDR PROJECT –
INDEPENDENT ASSURANCE REPORT

Audit Summary

Unique Identification Number: 95660401212

Project proponent(s): Biomass Projects

Planned Facility name: Mardie Station Carbon Dioxide Removal (CDR) Project

Project Location: Mardie, Western Australia, Australia

Carbon Removal Methodology: Biochar

Decision:

☒ The submission is validated against the rules set out in the Puro Standard General Rules v3.1 and Biochar
Methodology 2022 v2.

☐ The submission requires revisions before validation against the rules set out in the Puro Standard Puro
Standard General Rules v3.1 becomes possible.

☐ The submission requires major revisions and consolidation of the project before validation can be
reconsidered.

Findings:

General Rules

- Complies with additionality requirement, as it is dependent on carbon finance.

Methodology requirements

- Planned facility complies with technical and project eligibility requirements.

- Project proponent is knowledgeable regarding both biochar production and methodology requirements.
- The Life Cycle Analysis (LCA) developed by Biomass Projects is in line with the methodology requirements.

Non-Delivery Risks

- Non-compliance with environmental and social safeguards: Timely and successful completion of environmental
and social standards legislative approval processes
- Non-compliance with environmental and social safeguards : Adherence to planned long term arrangements with
Traditional Landowners
- Financial and environmental concerns associated with excess methane mitigation – inadequate quantification of
methane emissions and management of the process plant accordingly

Other matters

- Biomass Projects have provided adequate explanation to support assurance that livestock arrangement on the
property will remain of destock nature and no additional cattle will be introduced.

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FACILITY DESIGN REVIEW OF MARDIE STATION CDR PROJECT –
INDEPENDENT ASSURANCE REPORT (CONT.)

Audit Summary (Cont.)

Predicted Net Carbon Sequestration Over 100 Years (tonne CO2e. per tonne biochar)

CORCs – Carbon Estored Ebiomass Eproduction Euse

Dioxide Removal
Certificates

2.77 2.84 0.03938 0.02062 0.00787

Predicted volume of carbon dioxide removed (net), in tonnes per year in the new facility over the first five
years

Year 2023 2024 2025 2026 2027 2028

CORCs Nil 30,000 60,000 300,000 500,000 500,000

Project Background
Biomass Projects (Supplier) is an Australia project developer within the biomass space who help connect companies
with a biomass supply and provides the expertise to process it into carbon products, clean energy and carbon credits.
The Mardie Station CDR Project is a biomass project which is designed to quantify the net carbon dioxide removal
achieved over the time horizon of 100 years by the production of biochar, when used in applications placed in the soil
environment. The Project for which the Supplier is seeking of CO2 Removal Certificate (CORC) from Puro.earth will
involve production of biochar near Mardie, Western Australia.

A LCA was conducted according to ISO 14040/44:2006 Standard and Puro Earth Biochar Methodology to determine the
climate impacts associated with the production of biochar derived from mesquite biomass waste from cradle-to-grave.
The project is in the engineering design phase and under permitting or construction stage. This means the facility is not
yet commissioned and is not in operation producing biochar. Puro.earth has conducted am initial high-level review of the
project and raised concerns over the compliance areas below for RSM to consider in the course of this engagement:

 Process emission concerns - concerns regarding the potential for excessive methane gas emissions from the
proposed standard equipment indicated in the Supplier’s Pre CORCs certification submission; and
 The end use of the biochar - livestock arrangements on property, native title rights and interests.

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INDEPENDENT ASSURANCE REPORT (CONT.)

Objective
Puro.earth engaged RSM to provide a reasonable assurance opinion over the facility design compliance of Mardie Station
CDR Project, in line with the applicable sections of Puro.earth’s General Rules and Biochar Methodology.
Specifically, the scope of the engagement was to conclude on whether the information declared in the design phase
Validation Questionnaire met the applicable compliance requirements under the Rule and Methodology, and relevant
evidence exists to support the information provided. Due to the facility being in design phase and not being operational,
there were a few responses in the questionnaire for which definite evidence does not exist yet. We have accordingly
conducted our assurance based on assumptions stated in various documentation and written confirmation from the
Supplier during the course of the assurance engagement.
The assurance report evaluates the plans and evidence provided by the project proponent, at the time of issuance of the
report. The assurance report was made as a desktop review. No field visits were conducted in relation to the planned
facility. The project proponent has read the report and has provided comments to it.
The assurance engagement followed a risk-based approach and is based on information available to us at the time of
the engagement. RSM relied on the project proponent for the correctness of the provided information during the time of
the audit and will make no representation as to the accuracy or completeness of this report. For full disclaimer, please
see the end of the report.

Summary of procedures undertaken

The procedures performed in conducting the engagement included:
 Held an entry meeting to discuss and confirm procedures to be performed, timing and deliverables;
 Risk assessment and preliminary assessment of the Project submission documentation, and documentation of the
specific compliance requirements each scope of work is to be verified against; and
 Review and asses all primary and supporting documentation to verify compliance requirements in line with applicable
sections of the Rules and Methodology.
Validation against the Puro Standard General Rules and Biochar Methodology
RSM has reviewed Biomass’ responses in the Validation Questionnaire and verified them by reviewing sufficiency and
accuracy of supporting information provided.
Table 1 Requirements in Puro.earth Biochar Methodology

Requirement Requirement Requirement Evidence Findings/Observations Potential Non-

number met Documentation Delivery Risks
Provided

1 Thermochemical Y Geo-tagged The activity intends to N/A

activity photos of produce biochar for end
Mesquite in use in non-oxidative
planned facility applications (application
to soil) and is based on
thermochemical
(pyrolysis, gasification,
or similar) treatment of a
biomass feedstock
(mesquite)

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INDEPENDENT ASSURANCE REPORT (CONT.)

Validation against the Puro Standard General Rules and Biochar Methodology (Cont.)
Requirement Requirement Requirement Evidence Findings/Observations Potential Non-
number met Documentation Delivery Risks
Provided

1.1.1 Non-Oxidative Y LCA The biochar derived N/A

applications from Mesquite will be
applied directly to the
soil where the biomass
was harvested to
improve soil health. This
rehabilitation of the land
will provide both soil
health improvements for
the sandy based soil,
and removal of an
introduced invasive
species that has
infested the 250,000 Ha
Station.

Daily delivery and

application records will
be kept and the weight
of each truck load of
biochar deliveries will
be recorded.

1.1.2 Biomass Y Geo-tagged The biomass feedback N/A

feedstock photos of used will be Mesquite, a
sustainability Mesquite in woody invasive weed
planned facility species sourced from
and LCA Mardie Station in the
Pilbara region of
Western Australia. The
LCA outlines the
process steps to
properly harvest the
Mesquite without
harming native trees
and bushes on the land.

5.2.1 Availability of Y N/A Certificates are not N/A

certificates for required as it is not a
biomass feedstock forest biomass.

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INDEPENDENT ASSURANCE REPORT (CONT.)

Validation against the Puro Standard General Rules and Biochar Methodology (Cont.)
Requirement Requirement Requirement Evidence Findings/Observations Potential Non-
number met Documentation Delivery Risks
Provided

1.1.4 No co-firing of Y LCA Once biochar production N/A

fossil fuel with is running, no external
biomass energy will be required
to maintain production
process as part of the
thermal energy
generated from the
pyrolysis oil and gas
combustion is used to
sustain the pyrolysis.

1.1.5 Gases and tars Y Engineering and Pyrolysis gas and oil N/A
are treated Process obtained during biochar
description production will be
outlined in the combusted, with energy
LCA, email recovery. Net process
correspondence flue gas emissions after
between condensation and
Supplier and combustion of syngas
Puro.earth will be treated via a dust
discussing collection system.
Syngas
management Beston machinery to be
system and used in the production
methane process typically
emissions and condenses oil instead of
photographic burning it, which creates
evidence of a waste disposal issue.
Beston However , the oils from
machinery. the syngas will not be
separated and Biomass
have engaged Bestons
to conduct redesign
work for the equipment
to ensure the blowers
form part of the syngas
handling system.

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INDEPENDENT ASSURANCE REPORT (CONT.)

Validation against the Puro Standard General Rules and Biochar Methodology (Cont.)
Requirement Requirement Requirement Evidence Findings/Observations Potential Non-
number met Documentation Delivery Risks
Provided

N/A Mass and energy Y Projected Mass and energy N/A

balance Material and balance for the biochar
documentation Energy Balance production system is
summary in LCA included in the LCA.

1.1.6 Molar H⁄C_org Y Ideas H/Corg is 0.19 which is N/A

ratio of the biochar Engineered significantly lower than
5.3.3 determined by Solutions the maximum 0.7 ratio
laboratory analysis Laboratory in the standard
Report

5.4.2 Biochar end-use Y N/A N/A

The biochar will be used
documentation
on the same land that
and statements
the biomass was
harvested from and will
be used for soil
improvement together
with native grass
seeding for the purpose
of land rehabilitation. It is
not intended to be sold
or delivered to third party
users.
5.5.2 No double- Y N/A N/A
The Supplier does not
counting or
intend to use it in
5.5.3 marketing CO2
marketing the carbon
removal
removal capability or the
“negative emissions” of
the biochar.
The Supplier will take
measures (such as
implementation of a
tracking and verification
system) to ensure that
the CORC is only used
and retired once, and
not by several parties in
the supply chain.

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INDEPENDENT ASSURANCE REPORT (CONT.)

Validation against the Puro Standard General Rules and Biochar Methodology (Cont.)
Requirement Requirement Requirement Evidence Findings/Observations Potential Non-
number met Documentation Delivery Risks
Provided

1.1.7 Safe working Y Safety Data There has been no N/A

environment & Sheet training on site yet as the
1.2.2 safe biochar facility has not yet been
handling built. The Supplier has
also developed a SDS
(Safety Data Sheet) in
accordance with Safe
Work Australia standard
and has planned several
measures through which
they intend to meet safe
working environment
and biochar handling
requirements, such as
provision of safety
training and quality
maintenance of
equipment.

1.1.7 Biochar quality N/A N/A This can only be verified N/A
(Testing for Heavy after the Biochar
5.3.4 metal, production has started.
Polyaromatic
hydrocarbon
(PAH) and other
heavy metal
contents).

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FACILITY DESIGN REVIEW OF MARDIE STATION CDR PROJECT –
INDEPENDENT ASSURANCE REPORT (CONT.)

Validation against the Puro Standard General Rules and Biochar Methodology (Cont.)
Requirement Requirement Requirement Evidence Findings/Observations Potential Non-
number met Documentation Delivery Risks
Provided

1.2.2 Environmental and Partially met Biomass The project requires Timely and
Social Safeguards Projects several approvals and successful
– required permits Environmental permits from various completion of
Approvals stakeholders, which the environmental
Framework April Supplier is in the and social
2023 included in process of acquiring. standards
the See Appendix A for legislative
questionnaire. details on the list of approval
An updated copy permits/approval processes.
of the framework required and the
(Biomass status/expected timeline
Projects to acquire them, as
Environmental stated in the validation
Approvals questionnaire.
Framework
October 2023)
was also
provided during
the course of the
audit.

1.2.2 Environmental and Partially met Biomass Some of the expected Timely and
Social Safeguards Projects aspects or factors to be successful
– environmental Environmental specifically considered completion of
aspects Approvals under the EP Act 1986 environmental
considered in Framework April and the EPBC Act 1999 and social
permitting 2023 included in are Flora and standards
the Vegetation and legislative
questionnaire. Subterranean Fauna approval
An updated copy (potentially), Terrestrial processes.
of the framework Fauna and Social
(Biomass Surroundings and
Projects Greenhouse Gas
Environmental Emissions.
Approvals
Framework
October 2023)
was also
provided during
the course of the
audit.

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FACILITY DESIGN REVIEW OF MARDIE STATION CDR PROJECT –
INDEPENDENT ASSURANCE REPORT (CONT.)

Validation against the Puro Standard General Rules and Biochar Methodology (Cont.)
Requirement Requirement Requirement Evidence Findings/Observations Potential Non-
number met Documentation Delivery Risks
Provided

1.2.2 Public stakeholder Partially met Biomass Stakeholders including Adherence to

consultation Projects local and state planned long
process Environmental government bodies, term
Approvals Project land owners and arrangements
Framework April Traditional Owners with Traditional
2023 included in have been engaged as Owners in the
the validation part of the public future.
questionnaire(a stakeholder consultation
new version process. The Biomass
updated in Projects Environmental
October 2023 Approvals Framework
was also April 2023 document
provided during outlines process to
the course of the continue consultation.
audit), Mardie Refer to Appendix A
Project for more details.
Indigenous
Engagement
Strategy,
Memorandum of
Understanding –
Mardie Station
Sub Lease, and
Consultancy
agreement
between
Biomass
Projects and
Wirrawandi
Aboriginal
Corporation

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FACILITY DESIGN REVIEW OF MARDIE STATION CDR PROJECT –
INDEPENDENT ASSURANCE REPORT (CONT.)

Validation against the Puro Standard General Rules and Biochar Methodology (Cont.)
Requirement Requirement Requirement Evidence Findings/Observations Potential Non-
number met Documentation Delivery Risks
Provided

1.2.3 Financial Y Baseline and This project is N/A

additionality Additionality completely dependent
Assessment of the sale of CORCs,
Questionnaire the remote location
Response, prohibits cost effective
Biomass production and
Projects transport of the biomass
Financial Model to other markets. An
and Mardie additionality statement
Station Breeder has been provided
model outlining how the
Supplier/Project meet
additionality
requirements. Refer to
Appendix B.

5.4.3 Soil temperature Y LCA and Based on the lack of N/A

selection and correspondence available data for the
justification exchanged location, the Supplier’s
between discussions with
Supplier and Puro.earth and further
Puro.earth recommendations from
LCA designs, a value of
25 degrees Celsius will
be used as applied
average soil
temperature. The
decision was made to
use the highest soil
temperature under the
methodology guidelines
until there is enough
data on site to determine
actual soil temperature.

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FACILITY DESIGN REVIEW OF MARDIE STATION CDR PROJECT –
INDEPENDENT ASSURANCE REPORT (CONT.)

Validation against the Puro Standard General Rules and Biochar Methodology (Cont.)
Requirement Requirement Requirement Evidence Findings/Observations Potential Non-
number met Documentation Delivery Risks
Provided

5.3.1 Dry mass Y Detailed dry The Supplier intends to N/A

determination of mass use the mass - based
5.3.2 biochar production determination method to determine dry
procedure mass of the biochar
provided in produced. The wet
Validation weight of the biochar
Questionnaire production batch will be
measured with a scale,
and simultaneously, the
moisture of a
representative sample of
the batch will be
determined via oven-
drying, on site. The
procedure followed to
determine dry mass will
be based on the
Sartorius Moisture
Analyzer Models MA100
Electronic Moisture
Analyzer.

1.1.3 Net-negativity of LCA and working The Supplier has N/A

5.2.2 biochar production documents performed a carbon
5.3.2 and disaggregated footprint calculation or a
5.4.1 reporting of LCA of their biochar
impacts activity in the design
phase. CORC value is
high due to the high
Carbon content 89-91%.
Refer to Appendix C for
further details on LCA
calculations presented y
the Supplier and verified
by RSM.

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FACILITY DESIGN REVIEW OF MARDIE STATION CDR PROJECT –
INDEPENDENT ASSURANCE REPORT (CONT.)

Other matters
Process emission concern
 Puro.earth had raised concerns regarding the potential for excessive methane gas emissions from the proposed
standard equipment indicated in the Supplier’s Pre CORCs certification submission. The Puro-earth- Process
emissions concern – response documentation states that the emission management of the proposed equipment
(Beston syngas burner syngas) will be managed by Biomass projects irrespective of what the equipment supplier
provides. Budgets and contingencies have been made for modifications to the proposed Beston Equipment in order
to meet the emissions requirements.
 A Biomass Material Test Report has been obtained to detail the expected syngas composition and the proposed Air
Fuel Ratios (AFR) to ensure stoichiometric combustion. The actions will ensure that methane and carbon monoxide
are well maintained within acceptable limits if at all in the exhaust of the syngas burner system:
- Provide regular combusted syngas gas composition test to establish baseline indicators for management and
repairs of the burners and their management systems.
- Redesign the burners to accept modifications that will ensure capacity for complete gas combustion.
Although, there is clarity around the steps that the Supplier will take to manage process emissions, as the facility
is still in design place, RSM is unable to provide positive assurance over process emissions management that
the Supplier might take in the future.

The end use of the biochar - livestock arrangements on property, native title rights and interests
 Mardie Station was destocked in 2018 and the remaining 700 head of cattle on the property were missed during that
time. The Supplier has no plans to reintroduce livestock onto the property and will maintain the destocked nature of
the property, which is allowed under the current lease, so long as it is part of the management plan. The Traditional
Owners have showcased their interest to keep about 50 head on the property to provide training course for young
personnel within the community, but this arrangement has not been confirmed yet.
 Interest Holder approvals have not been formally acquired yet. However, adequate arrangements are in place to
acquire approvals with relevant interest holders through a public consultation process. See Appendix A section for
more details.
Our independence and quality control
We have complied with the relevant ethical requirements for assurance engagements, which include independence and
other requirements founded on fundamental principles of integrity, objectivity, professional competence, due care,
confidentiality and professional behaviour. In accordance with Australian Standards on Assurance and Advisory
Engagements including Australian Standard ASQM 1 Quality Management for Firms that Perform Audits and Reviews of
Financial Reports and Other Financial Information, or Other Assurance or Related Services Engagements, RSM
maintains a comprehensive system of quality control including documented policies and procedures regarding
compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.
Management responsibility
The Management of Biomass Projects (Supplier) are responsible for the preparation of the Design Phase Validation
Questionnaire and supporting documentation. The responsibility included the design, implementation and maintenance
of internal controls relevant to the preparation and presentation of the information in the documentations that is free from
material misstatement whether due to fraud or error, the Supplier’s compliance with the relevant sections of the Puro .
Earth Rules and Biochar Methodology. The results of our tests, inspections and observations, the responses to our
enquiries and the written representations from management comprise the evidential matter RSM has relied upon in
forming our opinion on the audited body’s compliance with the Puro Standard General Rules and the Biochar
Methodology.

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FACILITY DESIGN REVIEW OF MARDIE STATION CDR PROJECT –
INDEPENDENT ASSURANCE REPORT (CONT.)

RSM’s responsibility
Our responsibility is to express an opinion on the Design Phase Validation Questionnaire and supporting documentation,
as to whether the Project’s facility design compliance is in line with the applicable sections of the Rules and Methodology,
based on the evidence we have obtained.
The following Standards on Assurance Engagements were used in undertaking the assurance engagement:
 ASAE 3000 Assurance Engagements Other than Audits or Reviews of Historical Financial Information; and
 ASAE 3100 Compliance Engagements.
A reasonable assurance engagement, in accordance with ASAE 3000 and ASAE 3100 involves performing procedures
to obtain evidence about the facility design compliance and related information in the Design Phase Validation
Questionnaire, and about whether the Supplier met the requirements of the relevant legislation. The nature, timing and
extent of procedures selected depend on the Audit Team Leader’s judgement, including the assessment of the risks of
material misstatement or material non-compliance of the matter being audited, whether due to fraud or error.
In making those risk assessments, we consider internal controls relevant to all relevant documentation and the Project in
order to design assurance procedures that are appropriate in the circumstances; but not for the purpose of expressing
an opinion on the effectiveness of the Supplier’s internal control processes. We believe that the evidence we have
obtained is sufficient and appropriate to provide a basis for our reasonable assurance opinion.
Inherent limitations
There are inherent limitations in performing reasonable assurance engagements. For example, reasonable assurance
engagements are based on selective testing of the information being examined, and it is possible that fraud, error or non-
compliance may occur and not be detected. A reasonable assurance engagement is not designed to detect all instances
of non-compliance with the legislation, because such an engagement is not performed continuously throughout the
reporting period being examined, and because the procedures performed in respect of compliance with the legislation
are undertaken on a sample basis. The conclusion expressed in this report has been formed on the above basis.
Additionally, non-financial data may be subject to more inherent limitations than financial data, given both its nature and
the methods used for determining, calculating, and sampling or estimating such data.
Use of our reasonable assurance engagement report
This report is intended solely for the use of Biomass Projects (Supplier) and Puro.earth. Accordingly, we expressly
disclaim and do not accept any responsibility or liability to any party other than the Supplier and Puro.earth for any
consequences of reliance on this report for any purpose. However, we note the audited body may be required to share
our report with third parties such as buyers and/or investors, which we approve. Any other use of the information in the
report is prohibited without our express written consent.
Conclusion
Based on the work performed, in our opinion, in all material respects, the design of the Mardie Station Carbon Dioxide
Removal (CDR) Project:

 is in line with the applicable sections of Puro Standard General Rules; and
 is in with the applicable sections of the Puro Standard Methodological requirements.

Yours faithfully,

TIM PITTAWAY
Director
RSM Australia Pty Ltd
Sydney
6 December 2023
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 Disclaimer

 RSM is acting in reliance on the accuracy of information supplied by the Supplier and other 3rd Parties without
independent verification. RSM will make no representation as to the accuracy or completeness of this report, or any
document or analysis prepared, or caused to be prepared by it.
 It is understood that the readers will perform their own independent investigation and analysis of any Supplier and
Facility as they deem relevant and without reliance on RSM. The information contained in any correspondence with
RSM is not a substitute for the reader’s independent investigation and analysis.
 Nothing in this report or any of RSM’s correspondence should be construed as an advice to proceed or not to proceed
with a purchase or with any specific course of action.
 RSM does not operate as a law firm in any jurisdiction and is not representing itself as giving legal advice in respect
of the laws of any country.

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APPENDIX A – EXPECTED STATUTORY APPROVAL REQUIREMENTS AND
TIMELINES

The Biomass Projects Environmental Approvals Framework October 2023 lists the statutory and environmental approvals
required for the project and the timeframes planned to acquire them:

Required Approval Status/Steps Taken to Acquire Approval

Initial discussions have commenced with the Department

of Planning, Lands and Heritage of the Government of
Diversification Permit – Lands Administration Act 1987 Western Australia (DPLH) and the Pastoral Lands Board.
(State) Applications cannot be initiated until the Sub-lease
documentation has been lodged by Citic Pacific, which is
expected imminently.

Permits to move a Declared Pest will be sought if and as

Permit to move a Declared Pest – Biosecurity and
required during the planning phase. As the proposal is to
Agriculture Management Act 2007 (State)
chip and pyrolyse the mesquite on-site, a permit to move
a declared pest is unlikely to be required during
operations.

An EPBC Act referral will be submitted if required following

completion of the flora and fauna biodiversity surveys
scheduled for early to mid-2024, following the cessation of
the northern wet season. Biodiversity reconnaissance
Environmental approval – Environment Protection and
surveys are scheduled for the last quarter of 2023, to be
Biodiversity Conservation Act 1999 (Commonwealth)
undertaken by qualified and experienced botanists and
ecologists through consulting firm Ecosystem Services.
The reconnaissance surveys will inform all future
environmental approval requirements and will be used in
direct engagement with regulators prior to referrals being
lodged.

Preliminary discussions have been held with the WA

Department of Water and Environmental Regulation
Environmental approval or clearing permit –
(DWER), which is responsible for the implementation of
Environmental Protection Act 1986 (State)
the EP Act 1986 on behalf of the Environmental Protection
Authority. Reconnaissance assessments to be
undertaken by Ecosystems Solutions in November 2023
will inform ongoing referral discussions with the DWER.

Aboriginal Heritage Act compliance is mandatory in

Western Australia. Consultancy and Royalty Agreement
Aboriginal Heritage Act 1972 (State)
with the Traditional Owners, Wirrawandi Aboriginal
Corporation has been executed

Consultancy and Royalty Agreement with the Traditional

Native Title Act 1993 (Cth) Owners, Wirrawandi Aboriginal Corporation has been
executed.

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APPENDIX A – EXPECTED STATUTORY APPROVAL REQUIREMENTS AND
TIMELINES (CONT.)
Required Approval
Rights in Water and Irrigation Act 1914 – permits unlikely
but will be determined as project progresses.
Planning and Development Act 2005 – development
approval for processing facilities.
Biodiversity Conservation Act 2016 – permit may be
required if listed conservation species are identified on
site.
Building Act 2011 – local and State government building
approval
 Expected aspects or factors to be specifically considered under the EP Act 1986 and the EPBC Act 1999 are:
- Flora and Vegetation
- Landforms
- Subterranean Fauna (potentially)
- Terrestrial Environmental Quality
- Terrestrial Fauna
- Social Surroundings and Greenhouse Gas Emissions.
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Status/Steps Taken to Acquire Approval
The Act permits are not anticipated. The impact of this
proposal on groundwater and surface water will be
considered under the State and Commonwealth
environmental approvals. However the impact
assessment is expected to lead to a positive outcome as
there is evidence that the Mesquite has lowered the
groundwater table under the core infestation
Experienced town planning consultants Rowe Group are
expected to lead the Planning and Development Act
approvals process. Rowe Group is currently assessing the
detailed planning requirements of the Mardie mesquite
proposal
The fauna and flora surveys are scheduled to be
undertaken by Ecosystem Solutions in November 2023,
and in approximately March - April 2024 will inform any
requirements under the Biodiversity Conservation Act
2011.
Building Act 2011 approvals will be sought from the City
of Karratha in conjunction with the Planning and
Development Act approval process.
APPENDIX A – EXPECTED STATUTORY APPROVAL REQUIREMENTS AND
TIMELINES (CONT.)

 The Sub-lease will be held by Mardie Pastoral Co which is a Joint Venture between the Supplier and Wirrawandi
Aboriginal Corporation as the Traditional Owners, in order to take formal possession of the site. There is a
Memorandum of Understanding in place for the sub-lease arrangement.The Traditional Owners hold forty nine
percent shareholders interest in Maride Pastoral Co. Ten percent on founding of the project entity will also be held
by Traditional Owners, through their commercial arm Manarri Enterprises WA Pty Ltd. Wirrawandi and its members
will also be offered contracting and employment opportunities within the project. BMP is also working on an
Indigenous Engagement Strategy which outlines establishes commitments, approaches and initial targets for the
inclusion of Yaburara and Mardudhunera peoples and other First Nations community members in the delivery of and
outcomes from the Mardie Project. If they get any commonwealth finance that requires an Indigenous Engagement
Strategy, Biomass will have annual compliance reporting obligations to maintain the finance conditions. These current
arrangements are in line with the purpose and projected outcomes of the project, and evidence adequate stakeholder
engagement with the Traditional Owners currently in existence. However, there is a risk of non-execution or non-
compliance of stakeholder engagement strategy with the Traditional Owners in the future.

 The Biomass Projects Environmental Approvals Framework April 2023 also lists the overall timeframes and budget
of the environmental approvals process for the project:

18 | Facility Design Assurance Report – Mardie Station Carbon Dioxide Removal (CDR) Project
APPENDIX B – BASELINE AND FINANCIAL ADDITIONALITY ASSESSMENT

Baseline additionality
A baseline is a scenario that reasonably represents the natural and anthropogenic carbon removals to a permanent
storage (storage durability over 100 years ) in the absence of the carbon removal activity proposed by the CO2 Removal
Supplier.

The baseline activity is the use of bulldozers and chains to clear weed infested areas, then pile into windows and burn
the material to ash. This activity caused no removals to storage due to project activity (human activity) or natural activity.
The project activity converts the biomass to biochar then stores it in the ground which produces 100% more carbon
removals than burning the biomass in field to ash which adds CO2 to the atmosphere.

Financial additionality

This project is completely dependent of the sale of CORCs, the remote location prohibits cost effective production and
transport of the biomass to other markets. A substantial (very large) investment is required to build the large processing
facility at the site in order to rehabilitate the property over the next 20 years. A carbon finance facility will be required to
underwrite the investment for project execution.

The current baseline is a straight cost of weed removal. There is no opportunity of recovery other than land remediation
benefits of improved pasture and higher grazing capacity. The cost of clearing is modelled to be $1.20/tonne with 10
million tonnes of weed to be removed. This equates to AUD $12 million dollar of clearing cost. The offset against this cost
is increased cattle carrying capacity from the current 750 head to an estimated 7500 head, a net difference of
approximately 7000 head. The current Earnings Before Interest, Tax, Depreciation, Amortization (EBITDA) based on
current carrying capacity is approximately AUD $900K. The Potential EBITDA based on cleared land and full carrying
capacity is approximately AUD $4 million.

The Supplier has undertaken a sensitivity analysis and indicated the sensitivity to the market price for CORCs in Euro
terms, ranging from 120 to 100. With a 10-year Principal and Interest loan at 6% interest, producing CORCs on this
property will provide a great financial return on investment. Some of the sensitivities and relevant financial opportunities
are as below:

 When CORC price is at 100 Euros, the result is AUD$488.8 million Net Present Value (NPV) at 10% discount
 When CORC price is at 110 Euros, the result is AUD$571.2 million NPV at 10% discount
 When CORC price at 120 Euros, the result is AUD$653.6 million NPV at 10% discount

19 | Facility Design Assurance Report – Mardie Station Carbon Dioxide Removal (CDR) Project
APPENDIX C – CARBON FOOTPRINT CALCULATIONS

Only biochar production that is “net negative” is eligible for CORCs. “Net negative” means that the amount of carbon
sequestered in biochar is larger than the emissions arising along the supply chain of biochar (upstream and downstream)
as determined by the product LCA following the system boundaries described in the Puro Standard. The Supplier has
performed a carbon footprint calculation or a LCA of their biochar activity in the design phase and the results are as
follows:

Overall Net Carbon Sequestration Over 100 Years (tonne CO2e. per tonne biochar)

CORCs – Carbon Estored Ebiomass Eproduction Euse

Dioxide Removal
Certificates

2.77 2.84 0.03938 0.02062 0.00787

Relative to the carbon sequestered in the biochar, the process emissions led to a reduction by 2% from 2.84 tonne CO2e
(Estored) to 2.77 tonne CO2e (CORC). The CORC value represents the sequestered carbon of 2.77 tonne CO2e per
tonne biochar applied to the soil. The CORC value would vary based on harvesting location, moisture content, and
carbonization plant efficiencies.

Observation: CORC value is high due to the high Carbon content 89-91%. The input calculations for the Ebiomass,
Eproduction and Euse are limited in the report. However, it has been determined that this is due to the LCA taking a
more conservation approach. Once the facility is in operation, there will be real data which will aid in validation of
requirements under a production facility audit.

The volume of carbon dioxide removed (net), in tonnes per year in the new facility over the first five years of production
is predicted to be as follows:

Year 2023 2024 2025 2026 2027 2028

CORCs Nil 30,000 60,000 300,000 500,000 500,000

20 | Facility Design Assurance Report – Mardie Station Carbon Dioxide Removal (CDR) Project
21 | Facility Design Assurance Report – Mardie Station Carbon Dioxide Removal (CDR) Project