SIS Manly Vale Public School Review – Prepared by Renata Bali

This review has been prepared by Dr Renata Bali from Ecosense Consulting Pty. Ltd. I was asked by EDO NSW, on behalf of the Save Manly Dam Catchment Committee, to conduct a brief ecological review of the following report:

Species Impact Statement Manly Vale Public School (Kleinfelder 2016), including documents attached in Appendix 7.

I previously undertook a detailed ecological assessment of the Preliminary Species Impact Statement (SIS) prepared by Kleinfelder (2015) and relevant documentation (Bali 2015 provided as Attachment 1).

As part of the present review, I also considered the following:

 OEH Referral response to Preliminary SIS dated 30 September 2015; and  Proposal for a Biobank Site at Galston Park Bushland prepared by Hornsby Shire Council (November 2016).

I note that, as a result of a reconfiguration of the school buildings, the amount of vegetation to be cleared has decreased (3.65 ha vs 4.37 ha). Similarly the amount of vegetation to be managed as an Asset Protection Zone (APZ) has decreased (3.34 ha vs 4.01 ha). More extensive survey work was undertaken by Kleinfelder within the subject site and the surrounding APZ in 2015-6. In the case of flora, this included the analysis of 2 additional 20 X 20 m quadrats and 8 hours targeted search for threatened species. In the case of fauna, this included an additional 7 hours of amphibian survey, 442 remote camera nights and ~1000 arboreal trap nights (discrepancy between Table 7 in the SIS and Table 1 in Appendix 7(2). These were aimed primarily at detecting the Eastern Pygmy Possum and the Red-crowned Toadlet. Overall 14 flora species and 18 fauna species were considered as ‘subject species’.

The SIS identifies three vegetation community types as being present on the subject site (p. 53) but refers to a fourth community Sandstone Gully Forest in Tables (e.g. Table 11) and maps (e.g. Appendix 7).The Preliminary SIS identified 4 vegetation communities.

The SIS assessed vegetation community significance on the subject site as being Moderate for all native communities and Low for disturbed vegetation (Table 11). The Preliminary SIS ranked vegetation significance as High for all native communities and Low for disturbed vegetation (Table 11). No justification was given for this change in status.

Overall, I am concerned that the SIS has not taken into account many of my previous comments, nor does it address some issues raised by OEH. In general, these are:

Survey for Terrestrial Fauna

Terrestrial fauna survey does not appear to be adequate considering that it was undertaken less than 5 months post-fire (Bali 2015, OEH Referral response). The Preliminary SIS excluded most terrestrial species on the basis that they were not detected by 10 hair tubes and 4 cameras distributed over the 7.6 ha subject area. However, it appears that no additional survey work was undertaken in late 2015 or 2016 even though quolls, bandicoots and the New Holland Mouse have a medium probability of occurrence on the subject site. Similarly only 2 hours of bird surveys were conducted

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SIS Manly Vale Public School Review – Prepared by Renata Bali less than 5 months post-fire on a 7.6 ha site. In this case a precautionary approach is recommended such that any species not adequately surveyed are assumed to possible occur on-site.

Impact Assessment

Impacts should be assessed for the removal of 6.34 ha of vegetation because the area assumed in the SIS to have ‘no impact’ (2.64 ha) will be subject to edge effects due to the removal shrub and canopy layers within the adjacent APZ. Although the extent of edge effects may vary, an extensive literature review has shown that they can be expected to extend at least 50 m (Bali 2005). Edge effects may include direct (e.g. microclimate and soil moisture changes) and indirect impacts (e.g. increased access to introduced predators, weed invasion). There has been no consideration of the viability of retained habitat ‘islands’ subjected to edge effects.

The SIS fails to describe in detail site-specific direct and indirect impacts that would be expected. Furthermore, impacts associated with the required bushfire access roads and Ausgrid’s proposed sub-station have not been considered as part of the proposal (see OEH Referral response).Amelioration measures proposed represent standard practices which could be applied to virtually any site, and do not take into account the high vegetation significance, high quality habitat and the presence 5 threatened species. The effectiveness and viability of retained habitat ‘islands’ are not assessed with respect to providing habitat and movement corridors for threatened species.

Corridor Significance

The assumption is made repeatedly throughout the Preliminary and Final SIS that, given that the study site adjoins Manly Dam Reserve and contains over 600 ha of ‘potential’ habitat and extending over 4.2 km to the northwest, the proposal will not result in fragmentation of habitat for threatened species. This same argument has been repeated for plants, birds, bats and small more sedentary species such as the Eastern Pygmy Possum and Red-crowned Toadlet. While this may be true for mobile fauna with broad habitat requirements, in my opinion, the removal of the subject site may significantly increase habitat fragmentation for small less mobile species. In my opinion, corridor values should be assessed at a much finer (local) scale for these species (i.e. adjacent Crown Land, Condover Reserve). Alternatively, it would be useful to include a map of all historic and current threatened species records from Manly Dam Reserve as evidence that suitable habitat exists there.

The assumption is also made that the Manly Dam Reserve is ‘secure’ in terms of conservation. A rapid internet search will reveal that many vegetated areas in the locality are under threat of rezoning, development and/or commercialization. Aerial photographs of the site may lead to an assumption that Crown Land and Council- managed lands surrounding the subject site were ‘secure’, but in my opinion, this can not be guaranteed. Cumulative impacts associated with the proposal have not been assessed as per DGRs Section 5.5.1.

Eastern Pygmy Possum (Appendix 7)

While I am encouraged to see that the Eastern Pygmy Possum (EPP) was recorded outside the study area, the records appear to be concentrated around the subject site

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SIS Manly Vale Public School Review – Prepared by Renata Bali and do not extend north of the Water Research Laboratory buildings or further to the west although these areas were targeted for survey. The SIS concludes that:

“Considering that the species was detected both within and outside the study area during the surveys, the presence of potential habitat for this species on the subject site, and the relatively large area of potential habitat on secure lands to the north-west of the study area, the habitat loss on the subject site is considered to be of some (low) significance for this species in the locality.”

I strongly disagree with this conclusion based on the lack of evidence provided to support it. In my opinion, the EPP records as shown on Figure 1 may indicate the presence of a viable local population that does not extend further into Manly Dam Reserve for any one of a number of reasons (i.e. historic, movement barriers, stochastic events). Based on the information provided, it is impossible to confirm that the population extends further to the north and west (or that any other populations occur in Manly Dam Reserve). I would have expected more detailed analysis of the recent and historical records, including:

 A map showing all historic and current records for this species in and around Manly Dam Reserve;  An updated map showing the reconfigured school buildings and up-to-date APZs;  Consultation with pygmy-possum experts;  Impact assessment assuming worst-case scenario (removal of majority of habitat for a local population);  Impact assessment for removal of a known den tree or, if the tree is to be retained, the impact of removing most of the habitat around it;  Assessment of all potential impacts on the population, including maintenance of the APZ with fire (as requested by OEH); and  Assessment of the likely effectiveness of habitat ‘islands’ in maintaining the local population of pygmy-possums.

The presence of a local viable population of Eastern Pygmy-possums adjacent to an urban area is highly significant and should not be assumed to be ‘low’ without sound scientific evidence.

Red-crowned Toadlet (Appendix 7)

Many of the points raised above in relation to Eastern Pygmy Possums also apply to the Red-crowned Toadlet. This is a small sedentary species that is dependent on very specific habitat requirements. It appears that populations may be widely separated and it is unclear if the individuals recorded on the subject site are from the same population. As for the EPP, I would expect the SIS to contain:

 A map showing all historic and current records for this species in and around Manly Dam Reserve;  An updated map showing the reconfigured school buildings and current up-to- date APZs;  Consultation with Red-crowned Toadlet experts;  Assessment of the impact of removing 0.5 ha of suitable habitat for a small relatively sedentary species; and

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SIS Manly Vale Public School Review – Prepared by Renata Bali

 Assessment of the impact of removing surrounding vegetation and/or altering drainage patterns on retained toadlet habitat islands (What is the long-term viability of these ‘protection’ areas?).

Without sound scientific evidence it cannot be assumed that the population of toadlets will persist on the subject site.

Offsetting (Appendix 7)

Offsetting should only be applied to residual impacts after every effort has been made to avoid, minimise and mitigate potential environmental impact. In the case of the redevelopment proposal for Manly Vale Public School, this does not appear to have been done.

Irrespective of the reconfiguration of buildings considered in the SIS, in my opinion the proposal does not go far enough to avoid ecological impacts on adjacent lands. Building lay-outs shown in Figure 3.1 of the Statement of Environmental Effects (NSW Public Works 2015) would seem to have far fewer environmental impacts but were never considered further. The scale of the current proposal is clearly too large for surrounding ecologically sensitive habitats.

Impact assessments in both the Preliminary and the Final SIS have not considered site- specific direct and indirect impacts. Amelioration measures proposed represent standard practices which could be applied to virtually any site. Future management of the area will be dictated by bushfire management risk and not with the aim of protecting threatened species habitat.

It appears that the offset package is still being negotiated between the proponent and OEH. It is clear from the OEH letter dated 2/8/16 that OEH had not endorsed the offset proposal up to that time. The Offset Strategy (Kleinfelder 2016) provides minimal information about the environmental values of Galston Park. It does not even contain a map to clearly indicate its location in relation to the Manly Vale site or vegetation mapping to indicate like-for-like compensation.

Conclusion

Based on the information presented in the 2016 SIS, it is my opinion that the proposal should not proceed in its present form.

References

Bali R. (2005) Discussion Paper – Compensating for Edge Effects. Report prepared for the NSW Roads & Traffic Authority, Sydney.

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Attachment 1 Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali

REVIEW OF THE PRELIMINARY SPECIES IMPACT STATEMENT –

MANLY VALE PUBLIC SCHOOL

INTRODUCTION

This review has been prepared by Dr Renata Bali from Ecosense Consulting Pty. Ltd. As a member of the EDO NSW Register of Experts, I was asked to undertake an ecological review of the following report for the Save Manly Dam Catchment Committee:

 Preliminary Species Impact Statement Manly Vale Public School Development Application (Kleinfelder 2015).

In preparing this review, I have also referred to the following documents:

 Preliminary Flora and Fauna Assessment Manly Vale Public School (Total Earth Care 2015);

 Manly Vale Public School Redevelopment – Statement of Environmental Effects (NSW Public Works 2015);

 Bushfire Threat Assessment – Manly Vale Public School Redevelopment (Kleinfelder 2015);

 Landscape Management Plan – Manly Vale Public School Redevelopment (Kleinfelder 2015);

 Urban Bushland Reserves Plan of Management for: Anembo Reserve, Bantry Bay Bushland Reserves, Condover Reserve, Lillihina Reserve, Rhoker Reserve (Warringah Council 2008);

 Manly Warringah War Memorial Park Plan of Management (Gondwana Consulting 2014);

 Manly Warringah War Memorial Park Fire Regime Management Plan (EcoLogical 2006); and

 Warringah Natural Area Survey: Vegetation History and Wildlife Corridors (P & J Smith Consultants 2005).

I am familiar with the DECCW (now OEH) survey and assessment guidelines as I reviewed earlier drafts of these documents for the Department. This review comprises a desktop study only and no site visit was undertaken.

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali

GENERAL COMMENTS 1. Land tenure within the study area is not clearly delineated in the text nor in figures and it is therefore difficult to determine exactly where survey work was undertaken. The offsite APZ areas were not surveyed by TEC (2015) and do not appear to have been surveyed by Kleinfelder in March 2015. 2. No information is provided about the survey dates, weather conditions or suitability for flora/fauna survey work. No proforma data sheets have been appended to the SIS. 3. Flora survey effort up until March 2015 does not cover adjacent Council/ Crown land (Fig. 5). 4. Fauna survey effort in the study area is not considered to be adequate. It does not cover adjacent Crown/Council land and was conducted in only 2 stratification units within the subject site. The SIS does not justify the use of only 2 survey methods where a wide variety of techniques is recommended. 5. Targeted searches were not undertaken for most species identified as being potentially significantly impacted by the proposal. 6. The SIS failed to assess threatened flora/fauna species in the context of local and regional populations in the locality. 7. The impact assessment did not consider potential effects on those threatened flora/fauna species that were not detected but for which suitable habitat occurs onsite and within the locality. 8. Species diversity for birds, amphibians and reptiles appears to be relatively low and it is uncertain if this is due to: survey effort; time since fire; weather conditions during the survey; methodology used; and/or observer experience. 9. The SIS does not assess the site-specific direct and indirect impacts of the proposal on threatened flora and fauna species. 10.Cumulative impacts have not been adequately assessed within the context of other known and proposed developments within the locality. 11.The local population of Eastern Pygmy Possum may be at the risk of extinction as a result of this proposal. More information is required regarding the significance of this local population within the context of the locality in order to properly consider potential impacts. 12.From the point of view of the reader, all information necessary to properly consider impacts needs to be summarised within the SIS for easy reference. All survey information needs to be stated upfront and not hidden away in various tables and appendices. 13.A biodiversity offset strategy has not been developed as part of the SIS.

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali

DETAILED COMMENTS

Table 1 It is not clear from the SIS which areas/types of vegetation will not be impacted on the site. Even if vegetation is not removed, impacts would be associated with vegetation management (mowing, removal of dead wood), fragmentation, edge effects (i.e. increased weeds, predation), etc. Only areas which presently are built on or cleared would have no additional impacts.

Page 8 There is a discrepancy in the timing of the prescribed burn. Total Earth Care (TEC 2015) states that this occurred on or around 11 October 2014; the SIS describes its occurrence as November 2014.

Section 2.3.2 Land Zoning and Tenure/Fig. 4 I would expect more detail about land tenure adjacent to the subject site as surrounding areas would be significantly affected as a result of the proposal. It is not sufficient to show a single boundary around the outside of the study area as this implies that the entire area is under sole ownership. The study area includes the subject site, Council land and Crown land:  Crown land to the northwest managed by Warringah Council (Lot 1549 DP752038);  Crown land Trig Station to the west(Lot 7074 DP1029974);  Crown land road reserve to the south and west: and  Warringah Council land to the east Lot 1 DP433773 and Lot 1 DP1146289.

Similarly, Fig. 4 should clearly delineate tenure boundaries.

The proponent will need to engage into negotiations with adjacent landholders on this matter.

Land immediately to the west of the subject site falls within the ‘Bushland’ Management Zone of the Park (Section 5.2.1 & Figure 10, Manly Warringah War Memorial Park Plan of Management 2014). Condover Reserve located to the south is ‘community land’ and is considered to be “an important area of core bushland”; Council’s primary management intention for the reserve is to conserve it while providing for recreation and education opportunities which do not compromise its ecological integrity.

It should be noted that adjacent lands are managed by Warringah Council according to the aims set out in the Manly Warringah War Memorial Park PoM and the Urban Bushland Reserves PoM. These are not consistent with the implementation of APZs.

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali

Page 17

The SIS does not cite any relevant assessment reports, natural area surveys, biodiversity plans, management plans or conservation initiatives relevant to the locality (Appendix 6, DGRs Section 4.1). Additional documentation is necessary to determine the ecological importance of the study area in the context of the locality.

Page 39 There is very little detail regarding the flora/fauna survey methods used (Appendix 6, DGRs 4.2.2).  No specific survey dates are mentioned apart from March 2015 and November 2015. TEC survey dates are not repeated in the SIS.  Weather conditions and/or suitability for general/targeted survey are not described.  Stratification units are not identified – I would assume that, at the very least, there should be 4 stratification units corresponding to each of the vegetation communities described.

Figure 5 It appears that no flora quadrats were analysed in adjacent Council/Crown land. Very limited random meanders were undertaken in adjacent lands. As the Council land to the south of the subject site does not appear to have been burnt (Fig. 3), this area could have been surveyed in 2014.

Section 4.2.3.1 - Fauna This section summarises the total fauna survey effort, but the reader needs to refer to Appendix 1 in order to determine the details. Much of the information in Appendix 1 needs to be stated upfront in the report. Methodology needs to be justified where it varies from the DECCW guidelines. Any limitations associated with methodology need to be discussed.

Page 46/Table 7 In my opinion, the fauna survey conducted is not adequate because:  It does not adequately cover adjacent Council/Crown land (Fig. 6);  It only covers 2 stratification units, Coastal Sandstone Heath Mallee and Sydney North Exposed Sandstone Woodland (see Appendix 1);  The SIS did not adequately justify the use of only 2 survey techniques when the DECCW guidelines recommend that a wide range of techniques be used;  It only used 20 hair tubes and 10 remote cameras over the entire 7.6 ha study area. Terrestrial fauna were surveyed using 10 hair tubes and 4 cameras; arboreal fauna were surveyed using 10 hair tubes and 6 cameras.

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali

DECCW guidelines recommend a sampling effort of at least 124 Elliot trap- nights, 24 cage trap-nights and 80 hair tube-nights per stratification unit. Due to a discrepancy between Table 7 and Appendix 1, it is uncertain over how many nights the hair tubes were deployed (15 vs 10 nights). We can be certain that only two survey techniques were used for mammals and that they were deployed in two stratification units. The choice of techniques is alluded to in Appendix 1 where the authors state that cameras were used instead of Elliott traps “as a preferred method to detect the Pygmy Possum for which habitat has already been identified within the study area”. The authors also state that the use of cameras ‘exceeded’ DECCW guidelines (Section 4.2.4.3); in fact, cameras are recommended for targeted surveys for some species.

Although the SIS provides some information on the placement of hair tubes, there are no details about the placement of cameras except to say that they were associated with bait stations. The reader has to refer to Appendix 1 to find out that 4 cameras were located on the ground and 6 were placed in trees within the study area. Information about transects and the spacing of hair tubes/cameras is not reported in the text. According to Table 15, another 5 terrestrial species were being targeted by remote cameras, including quolls, bandicoots and New Holland Mouse. As these species are rare and camera coverage was very limited (only 4 used), it is very unlikely that they would have been recorded even if they were present in the study area.

The DECCW guidelines stress that it is important to include a wide variety of methods when surveying. This is because all methods are biased towards certain fauna groups. Any species that are averse to hair tubes would not have been recorded. It is not possible to counteract this aversion by leaving hair tubes out for longer (10 or 15 nights) as the bait is likely to break down and become less attractive and the tapes are more likely to become contaminated and/or lose their tackiness over time. DECCW recommends that they remain out for 4 nights.

Table 8 This table summarises the “additional methods used and the total number of hours surveyed over all survey periods”. What does this mean? How was the latest survey effort divided between the subject site (that has already had some survey work done) and adjacent Crown/Council land (that was not previously surveyed)? Why is the TEC survey effort summarised here in hours but marked as ‘unknown’ in Appendix 1?

The DGRs require that targeted surveys are conducted for all threatened species and that appropriate justification for reducing recommended levels of survey effort is required to show that impacts are not likely to be significant (Appendix 6, Section 4.1). This has not been done.

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali

Why were there no targeted searches undertaken/described for some of the species identified as being potentially significantly impacted by the proposal: Red-crowned Toadlet, Southern Brown Bandicoot, Glossy Black Cockatoo, Heath Monitor and Giant Burrowing Frog (TEC 2015)? The authors identified suitable habitat for these species in the study area and observed bandicoot diggings, cockatoo feed trees and potential Giant Burrowing Frog tadpoles during surveys in 2014. They stated that these species were unlikely to be detected immediately post-fire and provided targeted survey guidelines for each species in Table 6 (TEC 2015).

The SIS does not specifically discuss survey methods aimed at targeting these species. No justification was given for not using large Elliot traps or cage traps to target Southern Brown Bandicoots and Spotted-tailed Quolls. Table 15 discounts all of these threatened species from further assessment on the basis that:

“Comprehensive targeted surveys were conducted across areas of potentially suitable habitat for this species. This species was not detected in the study area during the surveys. As the species is conspicuous and readily identifiable by camera trapping, it is unlikely to have been overlooked during the surveys. As such, the species is considered unlikely to be affected by the proposal.”

Given that most of the fauna survey has been undertaken immediately post-fire (2-4 months) and that the survey methods used did not adequately cover the study area or target significant fauna species, it is my opinion that these species could well have been overlooked because they are, by definition, rare. Even if additional surveys failed to detect these species, they still have to be considered as occurring in the study area if suitable habitat is found there. They must also be considered in the impact assessment.

Although information provided in Section 4.2.3.1 and Appendix 1 suggests that survey effort may have been sufficient to detect Powerful Owls (4 nights), it was not adequate to detect Sooty Owls (6 nights) or Masked Owls (8 nights). ‘Targeted’ searches for threatened frog species involved searching “to assess the quality of the habitat” (p. 48). This is clearly not enough and call playbacks during suitable conditions are recommended to detect the Red-crowned Toadlet and Giant Burrowing Frog.

The SIS did not estimate the local and regional abundance of flora or fauna threatened species. The DGRs require that the SIS provide a “discussion of other known populations in the locality” (Appendix 6, Section 5.2.1). I would have expected that the number and locations of threatened species records (recent or historic) would have been discussed in order to assess the likelihood of those species being found on the study site and to assess the importance of their populations in the locality. There is not enough information included in the

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali

SIS in order for the reader to form an opinion as to how likely it is for species to be present in the study area.

Section 4.2.4 – Survey Techniques and Effort Although previously burnt areas were ‘extensively surveyed’ for threatened flora species in March 2015, the same cannot be said for fauna (see above). Limitations relating to flora and fauna surveys are not discussed. How is species abundance/composition in the study area related to time elapsed since fire? What were the weather conditions during surveys and were these ‘ideal’ for the targeted searches undertaken (e.g. after heavy rains for frogs)? Was access denied to trap/survey within Crown/Council lands? The limitations of not being able to complete initial flora/fauna surveys prior to prescribed burn should be emphasised.

Section 4.3.3 – Survey Results In my opinion the diversity of diurnal birds (18 species), amphibians (2 species) and reptiles (4 species) within the study area appears to be relatively low. This may be due to other factors such as: time since fire; weather conditions during the survey; methodology used; and/or observer experience. However, fauna surveys were undertaken in only 2 stratification units. It appears that frog searches were undertaken for 6 hours (3 hours in each of 2 communities) whereas reptile searches were undertaken for a total of 2 hours (1 hour in each of 2 communities). This level of effort would be more acceptable if pit-falls had been used within each stratification unit. What is the justification for not using pit-fall traps to survey amphibians and reptiles?

Diurnal birds were surveyed for 40 minutes in total (20 minutes in 2 communities). This survey effort is not adequate for a study area measuring 7.6 ha and covering at least 4 vegetation communities.

Section 4.3.3.5 - Connectivity Discussion of the connectivity of the study area to surrounding vegetation is inadequate. The DGRs specify that the SIS should assess the “potential of the proposal to increase fragmentation of the habitat or decrease the ability for movement of individuals and/or gene flow between habitats or populations”. This has not been done. The SIS assumes that, as the study site falls between 2 National Parks and is connected to Manly Dam Reserve, that loss of the site would not “significantly reduce overall vegetation connectivity within the locality”. I do not agree with this finding.

Although not identified as Priority 1 or Priority 2 wildlife corridors (P & J Smith Ecological Consultants 2005), Council-managed Condover Reserve represents a “priority area for maintaining or reinforcing wildlife corridors or bushland links” (Manly Warringah War Memorial Park PoM, Action BL2, p. 94). Similarly the Urban Bushland Reserves Plan of Management (2008) recommends combining

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali the management of Condover Reserve with Manly Dam so that “a holistic approach to the entire area can be taken”. Thus, both management plans recognise this area as being an important local corridor.

The clearing and significant vegetation management required to maintain APZs in perpetuity on Council/Crown lands is not consistent with the maintenance of habitat linkages to the south. Presently, the corridor is more than 250 m wide (given that much of the school site remains undeveloped) and comprises high quality habitat and vegetation communities with few weeds. With the implementation of the APZs, the corridor width would be restricted to about 50m with most of it comprising weed-infested fair to poor quality vegetation (Map 5, Urban Bushland Reserves Plan of Management). In my opinion, this would have a significant impact on connectivity and fragmentation in the locality, especially for less mobile species like the Eastern Pygmy Possum.

Section 5/Table 15 – Assessment of Likely Impacts The SIS lists all the direct and indirect impacts associated with vegetation clearing as a threatening process. It rightly considers, for the purposes of the impact assessment, that all native vegetation on the site would be removed, including all vegetation strata (p.64). The substantial clearing and the significant vegetation management required to maintain APZs in perpetuity will essentially modify all threatened species habitat in the study area to such an extent that it could be considered ‘removed’. Thus the SIS is assessing the removal of 7.6 ha of vegetation on threatened flora and fauna species.

The SIS then goes on to say that only 4.37 ha of native vegetation would be removed but fails to describe in detail site-specific direct and indirect impacts that would be expected. What are the areas that will be directly impacted by construction, installation of services, stockpiles and work depots? What are the indirect impacts of fragmentation, edge effects, increased predation, noise, vibration and human disturbance likely to affect Eastern Pygmy Possums, for example? How will the altered drainage within the study area affect habitat for threatened flora/fauna species onsite and offsite?

Section 7.1.1 refers the reader to the Landscape Management Plan for details about APZs but this information needs to be summarised in Section 5 to allow the reader make an informed decision as to the impacts of APZ maintenance and management on threatened flora and fauna.

The Landscape Management Plan (Kleinfelder 2015) identifies only 0.37 ha of vegetation (or 11%) of native vegetation that is able to be retained as vegetated ‘islands’ and canopy trees. The optimal vegetation structure within an APZ would be a woodland canopy covering grassland/sedgeland to a height of 100 mm. The management actions proposed - including significant tree clearing and pruning, the removal of shrubs, logs and dead trees and mowing - are not compatible with the conservation of biodiversity. Will the retention of small

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali vegetated islands across the site (see Figure 5) provide adequate cover and/or habitat linkages for small sedentary species vulnerable to predation (e.g. Eastern Pygmy Possum, Southern Brown Bandicoot)? How will direct and indirect impacts of altered drainage, exacerbated by vegetation clearing on steep slopes, affect threatened frog species?

While results of future flora surveys are still pending, the SIS only considers those four fauna species actually detected on the subject site as ‘likely’ to be affected by the proposal. However, the impact assessment must also consider potential effects on those threatened flora/fauna species for which suitable habitat occurs within the study area but that were not necessarily detected.

Furthermore, the loss of good quality habitat in the study area must be assessed in relation to other similar areas of habitat in the locality (Appendix 6, DGRs Section 5.5.1):

“The significance of impacts in the study area for conservation of affected threatened species or endangered populations in the locality must be discussed. An assessment of the significance of such impacts must compare and take into account the differences in the type, condition, and the tenure and long-term security of other areas of known habitats in the locality with those of the study area.”

This type of information has not been provided in the SIS for any threatened flora or fauna species.

The DGRs require that the cumulative effects of the proposal be assessed (Appendix 6, Section 5.5). The SIS refers to cumulative impacts on page 89 and in Table 16. The text broadly states that the majority of the 600ha Manly Dam Reserve is vegetated with plant communities that are floristically similar to those represented within the study area. The underlying assumption is that vegetated land in the locality is secure with respect to conservation status.

In fact, many vegetated areas in the locality are under threat of development, including:  Crown land zoned Residential north of Manly Creek;  Sydney Water surplus land at Kirkwood Street, Bantry Bay is for sale;  Land adjacent to Bantry Reservoir, Killarney Heights to be rezoned; and  Bushland next to Warringah Aquatic Centre to be leased for commercial interests.

I would expect any assessment of cumulative impacts to include discussion of known and potential loss of habitat in the locality.

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali

Section 5.3.2 and Section 8.3.4 – Eastern Pygmy Possum Based on the information provided in the SIS, I am not convinced that the local population of Eastern Pygmy Possums (EPP) would not be threatened with local extinction by the proposal. Although we know that 82 records have been collected within a 10-km radius, we do not know if they are recent or historical occurrences or their distribution in relation to the study area. Are the records clustered or widely dispersed? We do not know the size or extent of the local EPP population, but it surely does not extend over a 10-km radius. It might be that the study area is connected to a large reserve to the north, but this is a species with limited mobility that is vulnerable to predation. The SIS has not provided any justification for the conclusion that the site is of “low relative significance for the species in the locality (p. 77).”

Although there is some discrepancy over the area used by pygmy possums (4.22 ha vs 7.6 ha on p. 77; 4.37 ha elsewhere), let us assume that they occur over the entire 7.6 ha. With non-exclusive home ranges varying from 0.35-0.68 ha, it is conceivable that the study area could provide habitat for a local interbreeding population (or at least a significant part of one). We can assume that most of this habitat would be removed (including dead wood, trees, shrubs, feed trees) and that a relatively continuous vegetation cover would be completely fragmented. The 250+ m vegetated corridor that currently connects the study area to other vegetation (north and south) would be reduced to approximately 40 m of poor quality vegetation next to a sports ground. This could effectively sever gene flow in a north-south direction.

The presence of EPP populations in the Sydney Region is significant and should not be discounted on the basis of insufficient information. Its habitat within the study area has been assessed as high quality with very low levels of fragmentation and a high abundance of feed trees and shelter. This species is at particular risk from clearing, removal of dead wood and trees and increased predation associated with the proposal.

We need to know much more about the significance of the EPP population in the locality and in the region, including approximate population size and extent before making a considered assessment.

Section 5.5 – Description of Feasible Alternatives The feasible alternatives discussed in the SIS are based on 3 options to build or not to build a new school. Of much more relevance would have been a discussion of the optional building layouts considered by DEC and reported in the Statement of Environmental Effects (Fig. 3.3, Kleinfelder 2015). The option (D) eventually chosen was preferred by DEC but I note that it has been altered substantially in the final plans (i.e. the central building has extended almost to the western site boundary). It would have been much more relevant for the SIS

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali to describe these different configurations with respect to conservation onsite and the extent of the APZs.

Section 7 – Ameliorative Measures The amelioration measures represent standard practices which could be applied to virtually any site. These simply act to limit the extent of habitat damage and fauna deaths during construction, but will do nothing to prevent extensive habitat clearing and extreme vegetation management (e.g. mowing, reducing continuous stands of vegetation to a few ‘islands’) that would be required in perpetuity. They contain no specific measures that recognise the site’s high vegetation and habitat values. Vegetation clearing protocols, pre-clearing surveys and vegetation management plans will do nothing to protect habitat in the study area in the long-term. Translocation protocols should not be considered as amelioration measures (Appendix 6, Section 7.1.4).

Section 7.1.2 – Compensatory Strategies The DGRs (Appendix 6) require that:

“Where significant modification of the proposal to minimise impacts on threatened species or endangered communities is not possible then compensatory strategies should be considered. “

No biodiversity offset strategy was identified in the SIS even though amelioration measures will not minimise impacts of the proposal in the long- term. A long-term biodiversity strategy should form an integral part of the SIS.

Appendix 1 – Sampling Methods Employed Were flora meander surveys undertaken in March or May 2015? Will future flora survey be undertaken in October or November 2015?

The fauna survey table is poorly laid out and difficult to understand. The table should be reconfigured in order to present TEC data as per Table 8 and not as ‘unknown’.

There seems to be overlap in the survey methods. For example, diurnal and nocturnal frog surveys are included within the ‘targeted frog survey’ category. Categories should be condensed and clarified. Nocturnal amphibian surveys are less than requirements (minimum 1 hour). No frog callback recordings used. Why is Sandstone Gully Forest not considered as a stratification unit?

Why was the habitat not suitable for Elliot trapping in Sydney North Exposed Sandstone Woodland?

No proformas were attached to the SIS (nor were these included in the List of Appendices) as required by the DGRs (Section 4.2.2).

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Manly Vale Public School Preliminary SIS Review – Prepared by Renata Bali

MAJOR RECOMMENDATIONS Based on the information presented in the Preliminary SIS, it is my opinion that the proposal should not proceed as it is likely to have a significant impact on threatened species and their habitats.

The SIS in its present form is unacceptable because it does not meet the DGR requirements. Any future proposal for the redevelopment (or modification thereof) of Manly Vale Public School should be accompanied by an SIS based on comprehensive, justifiable and timely field survey work that:

 Includes adjacent Council/Crown lands;  Ensures that fauna abundance/distribution has recovered since fire;  Increases coverage of survey effort within all stratification units;  Uses a wide variety of fauna trapping techniques to avoid biases in the detection of fauna groups;  Targets threatened fauna species, especially Spot-tailed Quoll, Southern Brown Bandicoot, Red-crowned Toadlet, Giant Growling Frog, Glossy Black-Cockatoo and Heath Monitor;  Ensures that adequate effort is spent surveying diurnal birds, amphibians and reptiles over all stratification units; and  Collects additional information on Eastern Pygmy Possum local population (i.e. movement data, population size, limits of distribution).

The presence of any threatened flora or fauna species and/or their habitats in the study area should then be reassessed in the context of other known populations in the locality. If there is any possibility that a threatened species occurs in the study area, the SIS must reassess the site-specific impacts of the proposal on the species and its habitat.

The SIS must demonstrate (i.e. through additional survey work, population parameters, locational records, nearby populations, relevant studies, etc.) why the local population of Eastern Pygmy Possums is not at risk from extinction as a result of the proposal.

The SIS must describe biodiversity offset strategies to mitigate long-term impacts of the proposal.

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