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 1 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 2 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 3 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.