ANNE CLEMENTS & ASSOCIATES PTY. LIMITED (ABN 41 077 242 365, ACN 077-160-939) Environmental and Botanical Consultants PO Box 1623, North 2059 Phone: (02) 9955 9733, Facsimile: (02) 9957 4343 Email: [email protected]

7 September 2010

RE: Southern Highland Regional Shooting Complex at Hill Top

Framework as per Roslyn McCulloch of Pikes Lawyers: 1. Whether irreparable environmental harm may occur if the site is cleared in accordance with the current Approval 2. Whether clearing of the land is likely to have a significant impact on the Leafless Tongue Orchid

Prepared by: Dr AnneMarie Clements Polly Simmonds with soil material and Soil Landscape discussion by Dr Pamela Hazelton

Prepared for: Peter Jackson Pikes Lawyers Level 3, 50 King Street, Sydney NSW 2000

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Contents

1.0 The area proposed to be cleared in accordance with the current Approval ..... 3 2.0 Environmental setting of the Site...... 3 2.1 Elevation, drainage and watercourses ...... 3 2.2 Geology and Soils ...... 3 2.3 Vegetation ...... 5 2.3.1 Commonwealth listed Shale Sandstone Transition Forest ...... 5 3.1 Problems with GHD methodology ...... 11 3.1.1 Low percent of species recorded...... 11 3.1.2 Area covered by surveys ...... 12 3.1.3 Flora species “targeted”...... 12 3.1.4 Threatened flora species omitted from GHD targeted survey ...... 14 4.0 Conclusions...... 17 References...... 19

Figures 1. The Site and areas to be cleared on 2010 GoogleMap image 2. The Site and areas to be cleared on 1: 25 000 topographical map (Department of Lands 2007) 3. Approximate location of the Site and areas to be cleared overlaid on Geology mapping (Geological Survey of NSW 1966) 4. Threatened flora species records from NPWS wildlife atlas within approximately 5 km of the Site, overlaid on DECC (2004) significant location mapping 5. GHD flora survey 2006 and 2008 (Figure 2 of GHD Supplementary Ecological Assessment, dated July 2008) overlaid on the DECC (2004) mapping of Significant Plant Locations showing location of Vulnerable species in relation to proposed clearing on the Site

Tables 1. Recorded species other than those listed in paragraph 4 of NSW Scientific Advisory Committee (1998)

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1.0 The area proposed to be cleared in accordance with the current Approval

The current approval (Determination of Major Project No. 06_0232, dated 1 March 2010) is for:

These facilities are shown on Figure 7.1 Proposed site Layout (GHD February 2008).

GHD (2007 in Executive Summary) states that: The total area to be impacted [is] (approximately 16 ha) ..

2.0 Environmental setting of the Site

The Site is located in Wingecarribee Local Government Area (LGA), in the Hawkesbury Nepean Catchment Management Area (CMA). The Site supports pristine bushland adjacent to and Bargo State Conservation Area (Figure 1).

2.1 Elevation, drainage and watercourses

The proposed area of clearing is located on a flattened ridgetop at an elevation of approximately 600 - 620 m AHD and slopes steeply down to a series of creeklines occurring at approximately 500 m AHD (Figure 2). These creeklines flow to Rocky Waterholes Creek, located approximately 1 km downslope of the proposed clearing. Rocky Waterholes Creek then flows for approximately 2 km before meeting the (Department of Lands 2007).

The Nattai River is a major tributary flowing into , the major reservoir for Sydney's water supply. 98% of the length of Nattai River has been classified as near intact (Hawkesbury Nepean Catchment Management Authority website: http://www.hn.cma.nsw.gov.au/topics/2046.html, accessed 30 August 2010).

2.2 Geology and Soils

House and Gillies (June 2003) performed vegetation surveys and mapping as part of the Wingecarribee Biodiversity Strategy. They found that there were 5 main vegetation communities that accounted for over half of the remnant vegetation in the

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Shire and covered more than a third of the Shire, namely Sandstone Woodland, Hawkesbury Sandstone Woodland, Wingecarribee Woodland and Bindook Porphyry Dry Woodland and communities of the Woronora Plateau.

They also found 5 Endangered Ecological Communities (EECs) in the Shire which are highly fragmented, making up 21% of the vegetation patches but only 6% of the area of the Shire. The EECs recorded were Mt Gibraltar Forest, Robertson Basalt Rainforest, Robertson Basalt Tall Open Forest, Southern Highlands Shale Woodland and Shale/Sandstone Transition Forest.

GHD (November 2007) in the Water and Contamination Assessment identifies: The three main groups of soils within the region (NPWS 2001); • Sandstone tableland soils; • Valley soils (sandstone derived); and • Soils associated with nutrient rich shales and igneous rocks. .. These soil landscapes types are unstable when disturbed. .. If rain then follows shortly after fire, there is a resulting increase in surface run-off, causing increased erosion, and reduction in plant propagules and animal habitats.

Rose (1966) on the Wollongong 1:250 000 sheet mapped outcrops of Map Unit Rwl shale with some sandstone beds (Liverpool subgroup) along Wattle Ridge Road and on the site (Figure 3).

Herbert and West (1983) mapped the geology of Sydney. Herbert described the presence of the Mittagong Formation as a stratigraphic layer occurring between Hawkesbury Sandstone and Wianamatta Group Shales. Mittagong Formation is described as Interbedded shale, laminite, and medium-grained quartz sandstone.

Hazelton and Tille (1990) mapped the Soil Landscapes of the Wollongong/ Port Hacking area, with Hill Top located 4 km southwest of the mapped area. For this region, Hazelton and Tille (1990, p.3) reported:

The Mittagong Formation occurs as passage beds between Hawkesbury Sandstone and the overlying Ashfield Shales of the Wianamatta Group. It consists of interbedded and laminated, fine to medium grained quartz sandstone and black shale. Its main surface expression occurs between Thirlmere and Appin in the south-west of the mapped area. In this region it is is considered that the many areas of “ironstone gravels” reflect the original presence of the Mittagong Formation.

2.2.1 Site specific soil sampling

Soil samples were collected from the Site during survey by Anne Clements & Associates (ACA) on 27 May 2008. Soil samples to a depth of 5-10 cm were collected from each of four re-surveyed flora quadrats (20m x 20m in size). The vegetation in the four Quadrats 1 to 4 had previously been surveyed in October 2006 by GHD (2007).

The soil field texture, colour and the presence of inclusions were examined by Dr Pamela Hazelton. Dr Hazelton described the soil samples as follows:

Sample 1 Quadrat 1 Light sandy clay loam with silt, reddish brown 5YR 4/3 Presence of “ironstone” nodules

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Positive dilatency test - presence silt

Sample 2 Quadrat 2 Silty clay loam, dark reddish brown 5YR 3/3 Presence of “ironstone” nodules Positive dilatency test - presence silt

Sample 3 Quadrat 3 Silty clay loam with sand, dark reddish brown 5YR 3/4 Presence of “ironstone” nodules Positive dilatency test - presence silt

Sample 4 Quadrat 4 Clayey sand, dark reddish grey 5YR 4/2 Presence of small shale fragments and “ironstone nodules” Positive dilatency test - presence silt

Dr Hazelton concluded that the soil field properties, especially the presence of the “ironstone” nodules and shale fragments, were indicative of shale / sandstone transition soils.

Shale sandstone transition soils are exemplified by Lucas Heights Soil Landscape (Map Unit lh). The soils and the soil landscape in the area of the proposed clearing at the Hill Top site are most likely to be of the Lucas Heights Soil Landscape (Dr Hazelton, pers comm, 31 August 2010).

The erodibility of layers in the Lucas Heights Soil Landscape are described by Hazelton and Tille (1990) as moderate to high. The soil erosion hazard is described as: …for non-concentrated flows is generally moderate but ranges from slight to extreme. Calculated approximate soil loss during the first 12 months of development ranges up to 100t/ha for both topsoil and exposed subsoil. Soil erosion hazard for concentrated flows is moderate

2.3 Vegetation

Anne Clements & Associates (ACA) found that the vegetation of the proposed extension to the Southern Highlands Regional Shooting Complex at Hill Top is pristine bushland with high native species diversity and all species observed being local native species. Even along the disturbed verges of the adjacent road, exotic species were virtually absent.

2.3.1 Commonwealth listed Shale Sandstone Transition Forest

A search report for Wingecarribee LGA, generated by the EPBC Act Protected Matters Tool, (accessed from DEWHA website 31 August 2008 at www.environment.gov.au/) lists Shale Sandstone Transition Forest (SSTF) as a Commonwealth protected matter occurring in Wingecarribee LGA. The proposed area to be cleared at the Site has confirmed shale sandstone transition soils. The Commonwealth listed Shale Sandstone Transition Forest may occur on the Site including in the area to be cleared.

The Commonwealth listing information for the endangered ecological community Shale/Sandstone Transition Forest (DEWHA website:

Anne Clements & Associates Pty Ltd 5 www.environment.gov.au/biodiversity/threatened/communities/shalesandstone.html, accessed 1 September 2010) states that: The ecological community Shale/Sandstone Transition Forest is restricted to transitional areas between the clay soils derived from the Wianamatta shale and the sandy soils derived from Hawkesbury sandstone within the Sydney Basin Bioregion.

The Site at Hill Top is within the Sydney Basin Bioregion and the soils and the soil landscape in the area of the proposed clearing at the Site occur on transitional areas between the clay soils derived from the Wianamatta shale and the sandy soils derived from Hawkesbury sandstone.

Attachment (i) Summary description for the Commonwealth determination states that: The determination for the ecological community Shale / Sandstone Transition Forest includes those areas identified by the NSW Scientific Advisory Committee (1998) and subsequent advice regarding locational information (NSW NPWS, 2000).

The reference for NSW NPWS (2000) is the Native Vegetation of the Cumberland Plain, Western Sydney, Technical Report. The final edition of the interpretation guidelines report is National Parks and Wildlife Service (2002) (Mark Bourne, Project Officer, Ecological Communities Section, Department of the Environment, Water, Heritage and the Arts, pers. comm., 2 September 2010).

The NSW Scientific Advisory Committee (1998) is the author of the Final Determination under the NSW Threatened Species Conservation Act 1995 for the endangered ecological community Shale/sandstone transition forest (SSTF). It states in paragraph 2 that: SSTF occurs or has occurred in the Bankstown, Baulkham Hills, Blue Mountains, Campbelltown, Hawkesbury, Liverpool, Parramatta, Penrith, and Wollondilly Local Government Areas (LGAs).

The Site is in the Wingecarribee LGA, which is not included in the listed LGAs. The EPBC Act Protected Matters Tool lists Shale Sandstone Transition Forest as a protected matter occurring in Wingecarribee LGA. House and Gillies (June 2003) performed vegetation surveys and mapping as part of the Wingecarribee Biodiversity Strategy. They found five EECs in the Shire, including Shale/Sandstone Transition Forest.

NSW National Parks & Wildlife Service (2002) describes locational information for two map units of Shale Sandstone Transition Forest; Low sandstone influence (Map Unit 1) and High sandstone influence (Map Unit 2): …Shale Sandstone Transition Forest (Low Sandstone Influence) occurs around the margins of the Cumberland Plain on soils derived from Wianamatta Shale. It is most extensive in the southeastern and southwestern sections of the Study area. The community is only found in close proximity to a transition in parent geology from Wianamatta Shale to high-quartz sedimentary substrates such as the Hawkesbury and Narrabeen group Sandstones, as well as fine to medium grain quartz of the Mittagong formation. In these peripheral areas shale soils form a shallow layer over the underlying sandstone. The majority of sample sites were located within approximately 2km of a sandstone/shale boundary. The community may also be found at greater distances from the sandstone/shale boundary where watercourses have eroded the shale stratum down close to the level of

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sandstone. Map Unit 1 is typically found on the middle or upper slopes of gently undulating land. As distance to the sandstone/shale boundary increases Map Unit 1 grades into Map Unit 10 (Shale Plains Woodland) or, less frequently, Map Unit 9 (Shale Hills Woodland). The boundary between these communities is indistinct by nature, and largely unpredictable at the present time. Presumably, the transition to pure shale communities occurs when the depth of the shale substrate exceeds some critical distance. Map Unit 1 includes areas with only a very slight influence of sandstone. Such areas are exemplified by the sample sites high-lighted in bold text. As distance to the sandstone/shale boundary decreases, Map Unit 1 grades into Map Unit 2, Shale Sandstone Transition Forest (High Sandstone Influence). Again, the boundary between these communities is indistinct and largely arbitrary.

…Map Unit 2 occurs on the margins of the Cumberland Plain in close proximity to the sandstone/shale boundary and is most extensively distributed in the southwest and southeast sectors of the study area. …The majority of sample sites for this community were located within approximately 400 m of the shale/sandstone boundary and varied considerably in the degree of sandstone influence evident in the soil. Map Unit 2 is essentially a shale community, and is most likely to occur on shallow, residual clay soils derived from Wianamatta Shale. However, it may also be found on highquartz sandstone-derived soils where there is a strong colluvial shale influence (eg the upper slopes of sandstone gullies adjoining shale soils), and on outcrops of pure shale soils derived from the Mittagong Formation. Map Unit 2 occurs primarily on upper slopes and ridges on gently undulating terrain. Map Unit 2 grades into Map Unit 1, Shale Sandstone Transition Forest (Low Sandstone Influence), with increasing distance from the sandstone/shale boundary. Sometimes this transition is abrupt, and Map Unit 2 grades directly into Map Unit 10 (Shale Plains Woodland). The transition to the sandstone side of the ecotone was best sampled along the western edge of the Georges river in this survey. Here, Map Unit 2 makes a generally abrupt transition into sandstone communities with a pronounced change in floristic composition

….. Shale Sandstone Transition Forest (High Sandstone Influence) is one of two communities which together correspond to Shale Sandstone Transition Forest as listed on Schedule 2 of the NSW Threatened Species Act (1995).

Species and structural information is only available for the four GHD (2007) quadrats, resampled by Anne Clements & Associates (ACA) in 2008. The data recorded by ACA from these quadrats is compared to Shale/ Sandstone Transition Forest as described in Final Determination (NSW Scientific Advisory Committee 1998).

NSW Scientific Advisory Committee (1998) states that: 1.Shale/Sandstone Transition Forest (SSTF) is the name given to the plant community characterised by the species assemblage listed in paragraph 4, which occurs on areas transitional between the clay soils derived from Wianamatta Shale and the sandy soils derived from Hawkesbury Sandstone on the margins of the Cumberland Plain. All sites are within the Sydney Basin Bioregion.

The Site at Hill Top is in the Sydney Basin bioregion. The mapped boundary of the Cumberland Plain (from DECCW website: www.environment.nsw.gov.au/threatened species/MapOfTheCumberlandPlain.htm, accessed 1 September 2010) is located: • approximately 8 km north of the Site, and

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• less than one km north of the Wingecarribee LGA boundary.

2. SSTF occurs or has occurred in the Bankstown, Baulkham Hills, Blue Mountains, Campbelltown, Hawkesbury, Liverpool, Parramatta, Penrith, and Wollondilly Local Government Areas (LGAs).

The Site is in the Wingecarribee LGA. The EPBC Act Protected Matters Tool lists Shale Sandstone Transition Forest as a protected matter occurring in Wingecarribee LGA.

3.The floristic composition of the community includes species otherwise characteristic of, or occurring in, either sandstone or shale habitats. The structure of the community is forest or woodland

The structure recorded by ACA in the four GHD (2007) quadrats was a woodland with a dense shrub layer in Quadrats 2, 3, 4 and without a dense shrub layer in Quadrat 1. Of the species recorded by ACA in the four re-surveyed quadrats, there were: • 29 species listed as SSTF characteristic species • 17 species typically recorded in both shale and sandstone habitats, and • 69 species typically recorded in sandstone habitats (Table 1).

4.SSTF is characterised by an assemblage of species [listed in paragraph 4] Not all these species will be present in every single stand, and the total species list from all stands of the community is considerably larger than that listed above. Depending on the disturbance history of a particular site a proportion of the species may be present only in the soil seed bank.

There were 29 (34 old) of the 105 characteristic species listed for SSTF (28%) recorded in the four quadrats. The percent of characteristic species recorded of total species recorded in each quadrat was:

Quadrat Total number Number of % of species characteristic characteristic recorded species species of the recorded species recorded 1 59 20 34% 2 43 16 37% 3 54 16 30% 4 65 17 26% Total 94 29 31%

5.Characteristic tree species in SSTF are; , Eucalyptus resinifera, one of the stringybarks (Eucalyptus globoidea, Eucalyptus eugenioides, , Eucalyptus agglomerata). One or more ironbarks (Eucalyptus fibrosa, Eucalyptus crebra, Eucalyptus paniculata, Eucalyptus beyeriana) may be locally important.

Within the four GHD (2007) 20 m x 20 m quadrats resampled by ACA in 2008, characteristic tree species recorded were Eucalyptus globoidea, Eucalyptus punctata and Eucalyptus agglomerata:

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Quadrat Characteristic tree Other tree species species 1 Eucalyptus globoidea Eucalyptus punctata 2 Eucalyptus globoidea Corymbia gummifera 3 Eucalyptus globoidea Corymbia gummifera Eucalyptus sieberi

4 Eucalyptus agglomerata Corymbia gummifera Eucalyptus globoidea Eucalyptus sieberi Eucalyptus sclerophylla

Eucalyptus resinifera, Eucalyptus eugenioides, Eucalyptus sparsifolia, Eucalyptus fibrosa, Eucalyptus crebra, Eucalyptus paniculata and Eucalyptus beyeriana were not recorded.

6. SSTF has an understorey which may be either grassy and herbaceous or of a shrubby nature. In areas that have not been burnt for an extended period of time the understorey may be dense.

Quadrats 2, 3 and 4 had a dense 0.5 m to 1 m high shrub layer dominated by Pultenaea villosa. Quadrat 1 did not have a dense shrub layer.

7. Species composition varies between sites depending on geographical location and local conditions (e.g., topography, relative influence of sandstone or shale).

The quadrats were located on the ridgetop with shale fragments and ironstone nodules present in the soil. The sampled soil varied from light sandy clay loam with silt in Quadrat 1, silty clay loam in Quadrat 2, silty clay loam with sand in Quadrat 3 and clayey sand in Quadrat 4.

8. SSTF provides habitat for a number of plant species recognised as being of national, state or regional conservation significance in UBBS (1997).[listed in paragraph 8]

Eucalyptus globoidea, Thysanotus juncifolius and Thysanotus tuberosus were recorded from the quadrats surveyed by ACA in 2008 but not by GHD in 2007.

9. SSTF generally occurs on soils derived from a shallow shale or clay material overlying sandstone, or where shale-derived materials has washed down over sandstone-derived substrate. Such sites are generally close to the geological boundary between the Wianamatta Shale and the Hawkesbury Sandstone.

The proposed clearing is located on a ridgetop plateau on shale sandstone soils derived from transitional beds of the Mittagong Formation, which occurs stratigraphically between Wianamatta Shale and Hawkesbury Sandstone.

10. SSTF occurs on plateaux and hillsides and at the margins of shale cappings over sandstone.

The proposed clearing is located on a ridgetop plateau on shale sandstone soils derived from transitional beds of the Mittagong Formation.

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11. Many occurrences of SSTF are as linear stands, which may be as narrow as 20 metres. The small size and scattered distribution of the remnant stands of the community makes provision of a comprehensive map of occurrences impractical. Details of the distribution of many stands are provided in UBBS (1997).

GHD did not identify SSTF as a threatened community that may potentially occur on the Site. A large portion of the Site has not been sampled by GHD.

12. Adjacent communities on shale soils are generally Cumberland Plain Woodland, while adjacent communities on sandstone soils are generally part of the Sydney Sandstone Complex (sensu Benson & Howell 1990).

Vegetation on ridgetop plateau is growing in soils derived from shale sandstone transitional beds of the Mittagong Formation, which occurs stratigraphically between Wianamatta Shale and Hawkesbury Sandstone. Downslope of the ridgetop, the vegetation is growing in sandstone-derived soils.

13. Small areas of SSTF are presently included in only three conservation reserves, Blue Mountains National Park, and Gulguer .

Blue Mountains National Park is located approximately 20 km to the north-west of the Site.

14. A large proportion of the area where SSTF occurred in the past has been cleared for agriculture and urban development. Remnants are small and scattered. Identified threats include: clearing, physical damage from recreational activities, rubbish dumping, grazing, mowing and weed invasion.

The proposal is for clearing approximately16 hectares of pristine bushland on the ridgetop with likely impact greater than the 16 ha clearing footprint due to effects including nutrient and weed runoff, additional light from the cleared edge, and the erosion risk of the soil type. The proposal is an increase in intensity of the current recreational land use.

15. In view of the small size of existing remnants the threat of further clearing and other threatening processes, the Scientific Committee is of the opinion that SSTF in the Sydney Basin Bioregion is likely to become extinct in nature unless the circumstances and factors threatening its survival cease to operate and that listing as an endangered ecological community is warranted.

No additional comment.

In conclusion, vegetation occurs on the Site which meets the description of the Commonwealth listed endangered ecological community Shale/Sandstone Transition Forest as: • The Site is within the Sydney Basin bioregion, approximately 8 km south of the DECCW mapped boundary of the Cumberland Plain; • The EPBC Protected Matters search tool shows that SSTF occurs within Wingecarribee LGA; • The soils and geology match the description for the community; • The structure of the vegetation matches the description for the community;

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• From the four quadrats, three characteristic SSTF tree species were recorded; and • 29 of the 105 characteristic species listed for SSTF (28%) were recorded from the 4 quadrats surveyed by ACA in 2008.

The Site needs to be more extensively surveyed to determine the extent of Commonwealth listed endangered ecological community Shale/ Sandstone Transition Forest occurring on the Site, and to determine whether the clearing is likely to have a significant impact on the Commonwealth listed SSTF.

3.0 Threatened species that may be impacted by the clearing

A search of the NPWS Wildlife Atlas database for threatened flora species, recorded since 1980 within the Wingecarribee LGA, returned a total of 641 records of 33 species (http://wildlifeatlas.nationalparks.nsw.gov.au/wildlifeatlas/watlas.jsp. Report generated on 27/08/2010).

Of these species, in particular, records of hirsuta, Persoonia bargoensis, Persoonia glaucescens, and Acacia bynoeana were concentrated around Hill Top and recorded as occurring on or within a few kilometres of the Site (Figure 4).

The following table lists the threatened species known to occur within the LGA, that have potential suitable habitat on the Site and the highest potential to occur on the Site. All of the species are listed under both the TSC Act and the EPBC Act: Species TSC EPBC Preferred Habitat (DEWHA threatened Act Act species profile information) status status Persoonia acerosa V V dry sclerophyll forest, scrubby low-woodland and heath on low fertility soils. E E sandy soils in dry sclerophyll open forest, woodland and heath on sandstone Persoonia E E woodland or dry sclerophyll forest on bargoensis sandstone and on heavier, well drained, loamy, gravely soils. Persoonia E V woodland to dry sclerophyll forest on clayey glaucescens and gravely laterite. The preferred topography is ridge-tops, plateaux and upper slopes Acacia bynoeana E V Occurs in heath or dry sclerophyll forest on sandy soils. Seems to prefer open, sometimes slightly disturbed sites such as trail margins, edges of roadside spoil mounds and in recently burnt patches. parviflora V V G. parviflora subsp. parviflora occurs on sandy clay loam soils, often with lateritic ironstone gravels. Cryptostylis V V Does not appear to have well defined habitat hunteriana preferences and is known from a range of communities, including swamp-heath and woodland

3.1 Problems with GHD methodology

3.1.1 Low percent of species recorded

GHD (2007) recorded a total of 64 plant species, with 29 species recorded in the four 0.04 ha quadrats. More than half (54%) of the plant species (35 species) were

Anne Clements & Associates Pty Ltd 11 recorded as incidental recordings. The number of species recorded per quadrat ranged from 12 to 21, far lower than the average 36 to 56 taxa recorded per 0.04 ha plot for similar sandstone vegetation communities (based on DECC (2004) regional mapping survey data). Rice and Westoby (1983) found that the mean species richness of temperate east coast New South Wales sandstone ridgetop vegetation increased with increased area above 10 m2. Mean species richness recorded at 10 m2 was 30 species, with mean species richness increasing to 50 species at 100 m2.

On 27 May 2008, Tony Rodd and Peter Juniper from Anne Clements & Associates (ACA) relocated the four 20m x 20m quadrats sampled in the GHD (2007) survey and recorded species present in 20 m x 20 m quadrats as well as structural data. The accuracy of relocating the quadrats is expected to be of the order of 10 or 20 m. The bushland was homogeneous in the vicinity of each of the quadrats.

GHD recorded between 26% and 37% of the number of the species recorded by ACA within the re-sampled quadrats, with:

Percent of No. of species number GHD ACA GHD of ACA Quadrat 1 16 59 27% Quadrat 2 12 43 28% Quadrat 3 14 54 26% Quadrat 4 21 65 32% Total recorded in 29 94 quadrats 31%

3.1.2 Area covered by surveys

GHD flora surveying (Figure 5) consisted of: • four quadrats and supplementary threatened flora surveys undertaken on two occasions in October 2006 and October 2007 using 5.5 hours of the random meander technique; • seven quadrats and 13 supplementary random meander surveys undertaken in May 2008.

The area covered by targeted random meander survey is shown on Figure 2.1 of Appendix B Ecological Assessment (GHD 2007) and Figure 2 of the Supplementary Ecological Assessment (GHD July 2008). The area covered by surveys is within the immediate vicinity of the proposed clearing. Large areas of the Site have not been surveyed.

3.1.3 Flora species “targeted”

The flora species “targeted” by GHD surveys were presumably Acacia bynoeana, Persoonia acerosa, Persoonia hirsuta and Persoonia bargoensis, as these are the species listed by GHD (2007) as likely to occur on the Site. No targeted survey was undertaken by GHD during the most likely detection time of Acacia bynoeana, Persoonia acerosa, Persoonia hirsuta and Persoonia bargoensis.

Acacia bynoeana

GHD (2007) states:

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Acacia bynoeana (Bynoe’s Wattle) …..flowers during summer. This is a cryptic species that is difficult to identify when not in flower

No flora survey was conducted during Summer. Acacia bynoeana was therefore not “targeted” by any GHD flora survey.

Acacia bynoena is not a cryptic species, however it is more readily spotted when in flower. DEC Threatened Species Profile (accessed 1 September 2010) states:

Bynoe's Wattle is a semi-prostrate shrub to a metre high. The phyllodes (‘leaves’) are shiny, stiff and narrow, 1.5 - 5 cm long and 1 - 3 mm wide. The single flower heads, on short hairy stems, appear anytime from September to March. … The hairy branchlets distinguish the species from the similar and more common Three-veined Wattle Acacia trinervata.

Acacia bynoena occurs in small fragmented populations (DEC Threatened Species Profile accessed 1 September 2010) and therefore may be missed if not comprehensively targeted over a large search area throughout the time it is most likely to be in flower. Survey undertaken by GHD to “target” this species consisted of non-specific random meander limited to the vicinity of the area to be cleared, in October and May only.

Persoonia acerosa

DECC (2004) mapped the Vulnerable flora species Persoonia acerosa as occurring in the north-east of the Site in the approximate area where the approved pistol and rifle and shotgun ranges are to be located (Figures 4 and 5). DECC (2004) also mapped the Vulnerable species as occurring midway along the eastern boundary of the Site (Figures 4 and 5). The mapping of threatened species were compiled from the Atlas of NSW Wildlife, NSW Herbarium, and all systematic survey site data (DECC 2004, p.53).

The NPWS Wildlife Atlas shows Persoonia acerosa mapped approximately 2 km east of the eastern boundary of the Site. The corresponding sighting information includes a record for a sighting dated 6 November 1986, with the data set name being Royal Botanic Gardens Herbarium specimen register.

Fisher et al. (1995) describe Persoonia acerosa as occurring in “Heath and dry sclerophyll forest on sandstone north of Hill Top”.

It is possible for Persoonia acerosa (and other threatened Persoonia species with potential to occur on the Site) to be currently present on the Site as dormant seed within the soil seed bank. Persoonia species are known for having seed dormancy that often lasts at least 2 to 3 years (Ralph 1994). Seed germination appears to be prevented by a combination of the thick woody fruit, chemical inhibitors and embryo immaturity (Ralph 1997).

Concentrated flora survey and targeted threatened species searches have not been undertaken in the surveys by GHD within the mapped area where the species has been recorded to occur (Figures 4 and 5). Only a small portion of the mapped northern location has been covered by “random meander” and the mapped eastern boundary location has not been surveyed at all (Figures 4 and 5).

Furthermore, no flora survey or targeted survey was conducted at a time when Persoonia acerosa is most readily identified. Persoonia acerosa flowers most

Anne Clements & Associates Pty Ltd 13 frequently appear in summer (DEC NSW threatened species profile, dated 2005, accessed 27 August 2010 at www.threatenedspecies.environment.nsw.gov.au). GHD surveys were conducted in October and May only.

The approved development involves clearing, a listed threat to Persoonia acerosa. Listed threats to Persoonia acerosa include (DEC Threatened species profile accessed 27 August 2010): • Loss of habitat through clearing for urban and small-rural-lot development. • Burning for hazard reduction and other unnatural ignitions have increased fire frequency and may threaten the species’ survival. • Habitat disturbance during road maintenance. • Weed invasion on trail and road margins and on the edge of bushland. • Many Persoonia species are killed following infection by Cinnamon Fungus Phytophthora cinnamomi.

Persoonia hirsuta

Persoonia hirsuta is listed as Endangered under both State and Federal legislation. The species has been recorded at numerous locations within 3 to 10 km of the Site (Figure 4). Its habitat is somewhat variable - sandy soils in dry sclerophyll open forest, woodland and heath on sandstone (DEC Threatened species profile accessed 27 August 2010). Therefore the species could occur almost anywhere on the Site, rather than just the limited area surveyed in the immediate vicinity of the proposed clearing.

Persoonia hirsuta may occur as two different subspecies on the Site. The species is usually present as isolated individuals or very small populations (DEC Threatened species profile accessed 27 August 2010), and therefore may be easily missed unless specifically targeted. Targeted surveys were not conducted during November to January when Persoonia hirsuta is expected to be in flower (DEC Threatened species profile accessed 27 August 2010).

Persoonia bargoensis

Persoonia bargoensis is listed as Endangered under both State and Federal legislation. It has been recorded within 10 km of the Site (Figure 4). Suitable habitat for the species exists on the Site. Populations of Persoonia bargoensis are often very small (DEC Threatened species profile accessed 27 August 2010), and therefore may be easily missed unless specifically targeted. Targeted surveys were not conducted in Summer when Persoonia bargoensis is most likely to be in flower (DEC Threatened species profile accessed 27 August 2010).

3.1.4 Threatened flora species omitted from GHD targeted survey

Persoonia glaucescens

The Ecological Assessment (Table 3.1, p.17, GHD 2007) concluded that Persoonia glaucescens was unlikely to occur on the Site because “the study area falls over sandstone”.

DEWHA Biodiversity Species Profile and Threats Database (accessed 30 August 2010 at http://www.environment.gov.au) states for Persoonia glaucescens — Mittagong Geebung:

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Grows in gravelly well-drained soils (Blombery & Maloney 1992) in dry sclerophyll woodland or forest on sandstone, from 400 to 650 m alt. (Harden 1991; Weston 1995b).

DEC Threatened species profile accessed 27 August 2010 states: The Mittagong Geebung grows in woodland to dry sclerophyll forest on clayey and gravely laterite. The preferred topography is ridge-tops, plateaux and upper slopes.

Given that the Site: • occurs between approximately 500 and 620 m AHD; • vegetation consists predominantly of dry sclerophyll woodland and forest; and • soils are comprised of sand, clay, loam and gravel, with shale fragments and ironstone nodules; derived from clay and sandstone geology of the Mittagong formation; It would appear that the Site is likely to support suitable habitat for Persoonia glaucescens.

Cryptostylis hunteriana The Supplementary Ecological Assessment (GHD July 2008, p.10) stated: An update of the relevant database searches undertaken prior to the supplementary field surveys identified a number of additional threatened flora species within the locality of the study area (DEWHA, 2008a). Only one of these species, the Leafless Tongue Orchid (Cryptostylis hunteriana), was considered a possible occurrence within the study area given the habitats present. (Refer to Table 6 for a more detailed assessment of the remaining species’ habitat requirements and likelihood of occurrence). Cryptostylis hunteriana is a leafless, saprophytic tongue orchid, which is reliant on a symbiotic relationship with the microrrhizal fungus found in decaying plant matter (DEC 2005n). This species was considered unlikely to be detected during the supplementary targeted flora surveys conducted in May given its cryptic nature outside of its flowering period between November and February. Targeted surveys during the species’ flowering period would be required to determine if this species is present at the site and form part of GHD’s recommendations for the site (see Section 7.3.2)

Despite the statement, no targeted flora survey was undertaken for Cryptostylis hunteriana during its expected flowering time between November and February (DEC Threatened species profile accessed 24 August 2010). The survey effort is very unlikely to be sufficient to determine whether any individuals or populations of Cryptostylis hunteriana occur within or proximate to the area to be cleared.

Cryptostylis hunteriana (Leafless Tongue Orchid) from DEC Threatened Species Profile (http://www.threatenedspecies.environment.nsw.gov.au/tsprofile accessed 24 August 2010): • is a listed Vulnerable species under both the NSW TSC Act and the National EPBC Act; • Does not appear to have well defined habitat preferences and is known from a range of communities, including swamp-heath and woodland; • larger populations typically occur in woodland dominated by Scribbly Gum (Eucalyptus sclerophylla), Silvertop Ash (E. sieberi), Red Bloodwood (Corymbia gummifera) and Black Sheoak (Allocasuarina littoralis); appears to prefer open areas in the understorey of this community and is often found in

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association with the Large Tongue Orchid (C. subulata) and the Tartan Tongue Orchid (C. erecta); • Little is known about the ecology of the species; being leafless it is expected to have limited photosynthetic capability and probably depends upon a fungal associate to meet its nutritional requirements from either living or dead organic material; • In addition to reproducing from seed, it is also capable of vegetative reproduction and thus forms colonies which can become more or less permanent at a site; • the main threat to its continued survival appears to be development pressure on sites where it occurs; and • is a leafless plant and is therefore not readily identifiable during an untargeted flora survey.

Targeted threatened species surveys should be carried out during November to February at the time when the species can be more readily identified from the presence of an upright stem and flowers produced during these months.

As the species reproduces from seed, loss of any individuals will contribute to loss of genetic diversity within the species, which is already deemed vulnerable. Bell (2001) states: Considering the limited number of known sites of Cryptostylis hunteriana, the apparent small population sizes at most sites, the inconsistent flowering from year to-year, and the inadequate representation in conservation reserves, a comprehensive assessment of all known populations from throughout the State is needed, as well as dedicated survey for the species in appropriate habitat in proclaimed reserves.

The areas to be cleared and adjacent areas need to be surveyed throughout the expected flowering time to locate any individuals. The extent of genetic diversity of Cryptostylis hunteriana should be taken into consideration. The location of any individuals and/ or populations need to be recorded in terms of proximity to other locations of individuals/ populations, and measures implemented to prevent genetic loss, or at least minimise the extent of any loss.

Cryptostylis hunteriana is known to have a fungal associate to meet its nutritional requirements from either living or dead organic material (Bell 2001). Fungal searches in addition to searches for Cryptostylis hunteriana may prove useful for determining the potential extent of the potential occurrence of Cryptostylis hunteriana.

In addition, as very little is currently known about the species, the inadvertent loss of any individuals/ populations from clearing, owing to inadequate survey/ searching, is likely to be a significant loss to the understanding of this species.

Grevillea parviflora

Although has been recorded within 10 km of the Site (Figure 1) and suitable potential habitat occurs on the Site, Grevillea parviflora was neither identified as potentially occurring on the Site, nor targeted by any survey.

Summary

Survey for threatened species that may be impacted by the clearing:

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Species Flowering Surveyed Notes (DEC and DEWHA threatened species profile time during information, plus comments) (DEC flowering threatened time? species profiles) Persoonia Summer No Threats - recruitment is solely from seed - potential loss of acerosa genetic diversity. Susceptible to Phytophthora cinnamomi - may be introduced via increased traffic onsite Persoonia November to No usually present as isolated individuals or very small hirsuta January populations - may be hard to spot unless specifically targeted Persoonia mainly in No Populations are often very small, presenting a threat from bargoensis summer inbreeding depression. may be hard to spot unless specifically targeted Many Persoonia species are killed following infection by Cinnamon Fungus Phytophthora cinnamomi. Persoonia late summer No, not Within its habitat, P. glaucescens is generally rare and the glaucescens to autumn targeted populations are linear and fragmented. may be hard to spot unless specifically targeted Under ideal circumstances, the species can be locally common, though such conditions are very rare.- may be hard to spot unless targeted Acacia anytime from October only Due to the fragmented nature of the populations and their bynoeana September small size the species is susceptible to catastrophic to March events and localised extinction. Grevillea has been No, not It is often difficult to determine the number of parviflora recorded targeted present at a site and population estimates are essentially from a reflection of the number of suckers rather than between individual plants. Populations may be smaller and less July to genetically diverse than they appear. December Likely to be hard to spot unless specifically targeted, and in April particularly if not in flower to May. Cryptostylis between No It has no leaves. It produces an upright flower-stem to 45 hunteriana November cm tall, bearing five to 10 flowers between November and and February. Little is known about the ecology of the species; February being leafless it is expected to have limited photosynthetic capability and probably depends upon a fungal associate to meet its nutritional requirements from either living or dead organic material. Very difficult to spot & identify unless specifically targeted

4.0 Conclusions

Based on the footprint of the proposed facilities, the proposal will require the clearing of approximately 16 ha of native vegetation. The proposed facilities are on ridgelines separated by intact bushland adjoining creeklines. It is likely that the areas impacted would be greater than the area cleared due to effects including nutrient and weed runoff, additional light from the cleared edge, and the erosion risk of the soil type.

• The area to be cleared is pristine bushland in high condition with 100% native species recorded, located on a Site adjacent to National Park and State Conservation Area; • The area to be cleared is on an erodible soil landscape, with subsoils that are highly erodible and/or become highly erodible if disturbed; • The area to be cleared drains down very steep slopes to Nattai River which is described as currently “98% intact”; • The completeness, timing and area covered by the flora surveys is not adequate to provide assurance that irreparable environmental harm will not occur if the site is cleared in accordance with the current Approval:

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o large areas of the Site away from the immediate area of the clearing have not been surveyed at all; o numbers of flora species recorded by GHD were significantly lower than comparable surveys; o GHD did not identify the Commonwealth listed Shale Sandstone Transition Forest as occurring on the Site. o The Site supports suitable habitat for Commonwealth listed Shale Sandstone Transition Forest; o Dr Pamela Hazelton concluded that soil from quadrats 1 to 4 was indicative of shale / sandstone transition soils, especially the presence of “ironstone” nodules and shale fragments; o Vegetation within the sampled quadrats 1 to 4 on the Site, meets the listed criteria for Commonwealth listed Shale Sandstone Transition Forest. This needs to be investigated and a referral to the Commonwealth Minister is required; o DECC (2004) have mapped a Vulnerable flora species as occurring in the north-east of the study area in the approximate area where the currently approved pistol and rifle and shotgun ranges are to be located and thorough concentrated flora survey and targeted threatened species searches have not been undertaken by GHD within this area; o same Vulnerable flora species mapped by DECC (2004) as occurring along eastern boundary, this area was not surveyed by GHD; o three threatened species, all listed under both state and federal legislation, that have suitable habitat on the Site and are known to occur within the area have not been targeted and in some cases were overlooked as being likely to occur on the Site; o remaining threatened species identified as likely to occur were not targeted at a time when they are most readily spotted or identifiable.

Particularly in regard to Cryptostylis hunteriana: • The GHD (July 2008) supplementary Ecological Assessment states (Appendix E p.10): Targeted surveys during the species’ flowering period would be required to determine if this species is present at the site and form part of GHD’s recommendations for the site (see Section 7.3.2). • The extent and significance of the impact on Cryptostylis hunteriana can not be determined without first determining the number and distribution of individuals or populations. It is essential to carry out the target surveys during the expected flowering time of November to February prior to carrying out an assessment of significance of the likely effects of the proposal on Cryptostylis hunteriana; • to be able to quantitatively determine whether clearing of the land is likely to have a significant impact on the Leafless Tongue Orchid, thorough targeted searches during November to February are required prior to any clearing, in both the area to be cleared and adjacent areas which may be indirectly impacted from the clearing. Owing to the inconsistent flowering of individuals from season to season (Bell 2001), these searches should ideally be carried out over a number of consecutive years; • Cryptostylis hunteriana is known to have a fungal associate to meet its nutritional requirements (Bell 2001). Fungal searches in addition to Cryptostylis hunteriana searches may prove useful for determining the potential extent of the potential occurrence of Cryptostylis hunteriana..

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References

Bell, S.A.J. (2001) Notes on population size and habitat of the vulnerable Cryptostylis hunteriana (Orchidaceae) from the Central Coast of New South Wales. Cunninghamia 7(2).

DECC (2004) The Native Vegetation of the Nattai and Bargo Reserves. Conservation Programs and Planning Branch, Metropolitan Environmental Protection and Regulation Division. Dated August 2004

Department of Lands (2007) Hill Top 8929-2N Third Edition Topographic and Orthophoto Map 1:25 000. Land and Property Information, Bathurst.

House, S. and Gillies, C. (2003) The Wingecarribee Biodiversity Strategy Phase 1. Consultants report prepared by Eco Logical Pty Ltd, Sutherland, NSW for the Wingecarribee our Future Environment Program. Dated June 2003.

Fisher, M., Ryan, K. and Lembit, R. (1995) The natural vegetation of the Burragorang 1:100 000 map sheet. Cunninghamia 4(2): 143-215.

GHD (2007) Southern Highlands Regional Shooting Complex: Ecological Assessment. Dated October 2007.

GHD (November 2007) NSW Sport and Recreation Southern Highlands Regional Shooting Complex Water and Contamination Assessment. Dated November 2007.

GHD (February 2008) NSW Sport and Recreation Southern Highlands Regional Shooting Complex Environmental Assessment February 2008 Volume 1 Environmental Assessment

GHD (July 2008) NSW Sport and Recreation Southern Highlands Regional Shooting Complex Supplementary Ecological Assessment

Hazelton, P.A. & Tille, P.J. (1990) Soil Landscapes of the Wollongong-Port Hacking 1:100 000 Sheet. Soil Conservation Service of NSW, Sydney.

Herbert, C. and West J.L. (1983) Geology of the Sydney Basin 1: 100 000 sheet 9130. New South Wales Department of Mineral Resources, Sydney.

Geological Survey of NSW (1966) Wollongong 1:250,000 Geological Series Sheet S1 56-9, Second Edition, 1966. New South Wales Department of Mines.

NSW Scientific Advisory Committee (1998) Shale/sandstone transition forest - endangered ecological community listing

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NSW Scientific Committee - final determination. Accessed 1 September 2010 at: www.environment.nsw.gov.au/determinations/ShaleSandstoneTransitionForestEndC omListing.htm

NSW National Parks & Wildlife Service (2002) The Native Vegetation of the Cumberland Plain, Western Sydney – Technical Report, NSW NPWS, Hurstville.

Ralph, M. (1994) Germination of local native plant seed for revegetation, tree planting and direct seeding. Murray Ralph/ Bushland Horticulture, Fitzroy, Australia.

Ralph, M. (1997) Growing Australian native plants from seed for revegetation, tree planting and direct seeding. Murray Ralph/ Bushland Horticulture, Fitzroy, Australia.

Rice, B. and Westoby, M. (1983) Species richness in vascular vegetation of the West Head, New South Wales. Australian Journal of Ecology, 8: 163-168.

Rose G. (1966) Wollongong 1:250,000 Geological Series Sheet S1 56-9, Second Edition, 1966. Geological Survey of NSW. New South Wales Department of Mines.

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Figures

Tables Table 1. Recorded species other than those listed in paragraph 4 of NSW Scientific Advisory Committee (1998)

Recorded species Shale Sandstone Acacia echinula X Acacia linifolia X Acacia myrtifolia X Acacia suaveolens X Acacia terminalis subsp. aurea X Acacia ulicifolia X X Acianthus exsertus X Amperea xiphoclada X Anisopogon avenaceus X Austrostipa pubescens X X serrata X Billardiera scandens X X Boronia ledifolia X Bossiaea heterophylla X Cassytha pubescens X X Cyathochaeta diandra X Dampiera purpurea X Dampiera stricta X Dianella caerulea X Dianella revoluta X X Eriostemon australasius X Eucalyptus sieberi X Gonocarpus tetragynus X X Gonocarpus teucrioides X Goodenia bellidifolia X X subsp. arenaria X X X Hibbertia cistiflora X Hibbertia empetrifolia X X Hibbertia riparia X Hovea linearis X X Hybanthus monopetalus X X formosa X Lepidosperma viscidum X Leptospermum polygalifolium subsp. X X polygalifolium Lepyrodia scariosa X Lindsaea linearis X Lindsaea microphylla X Lissanthe strigosa X X Logania pusilla X X Lomandra cylindrica X Lomandra multiflora X X Lomandra obliqua X X silaifolia X Mitrasacme polymorpha X Patersonia glabrata X Patersonia sericea X Persoonia laurina subsp. intermedia X X Persoonia mollis subsp. nectens X Petrophile pedunculata X Platysace ericoides X Pomaderris andromedifolia subsp. X andromedifolia Pomaderris lanigera X Poranthera corymbosa X Poranthera ericifolia X Pultenaea retusa X X Pultenaea scabra X X Scaevola ramosissima X X Tetratheca thymifolia X Thelymitra sp. X Thysanotus juncifolius X Thysanotus tuberosus X Viola sieberiana X Xanthorrhoea concava X X Xanthosia sp. aff. pilosa X X