Tyers River Audit

TYERS RIVER CATCHMENT

Findings and Recommendations

July 2001

ENVIRONMENTAL AUDIT

TYERS RIVER CATCHMENT

Findings and Recommendations

Environment Protection Authority 40 City Road, Southbank Victoria 3006 AUSTRALIA

July 2001

Publication 782 ISBN 0 7306 7600 5

TYERS RIVER CATCHMENT

ENVIRONMENT PROTECTION ACT 1970 STATEMENT OF ENVIRONMENTAL AUDIT I, Scott Edward Maloney of the Environment Protection Authority, a person appointed by the Environment Protection Authority ("the Authority") under the Environment Protection Act 1970 ("the Act") as an Environmental Auditor for the purposes of the Act, having:- 1. conducted an environmental audit in relation to surface waters within the Tyers River Catchment in Gippsland ("the catchment"), defined as all surface waters of the Tyers River and Jacobs Creek and their tributaries, upstream of the wall of the Moondarra Reservoir; 2. had regard to, amongst other things, - (i) the beneficial uses that may be made of the catchment; and (ii) relevant State environment protection policies/industrial waste management policies, namely the State environment protection policy (Waters of Victoria) and the State environment protection policy (Waters of Victoria) – Schedule F5 Waters of the Latrobe and Thomson River Basins and Merriman Creek Catchment (“the Policy”), in making an assessment, based on, - (i) the scope, approach and methodology, and findings included in the environmental audit report; and (ii) observations made between May 2000 and November 2000 and a review of water quality monitoring data undertaken between June 1999 and October 2000, of the nature and extent of any harm or detriment caused to, or the risk of any possible harm or detriment which may be caused to, any beneficial use made of the catchment by any land use or activity; and 3. completed an environmental audit report; HEREBY STATE that, I am of the opinion that: Surface waters within the Tyers River Catchment are not detrimental to or potentially detrimental to the following beneficial uses: · Maintenance of natural aquatic ecosystems and associated wildlife; natural ecosystems (Only for areas within the Baw Baw National Park) · Agricultural water supply (stock watering and irrigation).

The condition of the catchment is detrimental or is potentially detrimental to the following beneficial uses of the catchment:

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· Maintenance of natural aquatic ecosystems and associated wildlife; natural ecosystems with occasional disturbance due to human activity (for areas outside of the Baw Baw National Park) · This beneficial use is impacted upon or potentially impacted upon by sediment and nutrients. · Potable water supply, with treatment (disinfection only) · This beneficial use is impacted upon or potentially impacted upon by sediment, nutrients and faecal contamination. Water from the catchment used for potable water supply must be treated to remove suspended solids prior to disinfection. · Recreation (primary and secondary contact, and aesthetic enjoyment) · This beneficial use is impacted upon or potentially impacted upon by sediment, faecal contamination (primary contact only), and nutrients. · Industrial water use · This beneficial use is impacted upon or potentially impacted upon by sediment. Treatment is required to lower turbidity levels to meet most industrial user’s requirements. It is noted that the Policy does not specify whether any treatment should be associated with this beneficial use. · Fishing and aquaculture · This beneficial use is impacted upon or potentially impacted upon by sediment, nutrients and faecal contamination. · Aquifer recharge · This beneficial use is impacted upon or potentially impacted upon by faecal contamination. Recommendations to improve water quality and restore these beneficial uses are contained within the environmental audit report Environmental Audit Tyers River Catchment, July 2001. DATED: 5 July 2001 Signed:

SCOTT EDWARD MALONEY

ENVIRONMENTAL AUDITOR

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EXECUTIVE SUMMARY

Background

Scott Maloney, an Environmental Auditor appointed under section 57 of the Environment Protection Act 1970, has completed a statutory environmental audit of land uses, activities and associated impacts on water quality within the Tyers River Catchment. This environmental audit report forms the basis of a Statement of Environmental Audit, issued in accordance with the Environment Protection Act 1970, in relation to the beneficial uses of water within the catchment.

This environmental audit report identifies hazards affecting water quality and provides a qualitative risk assessment of the impacts of various land uses and activities on the beneficial uses of waterways within the catchment. Beneficial uses of water in the catchment are identified in the State environment protection policy (Waters of Victoria) – Schedule F5. Waters of the Latrobe and Thomson River Basins and Merriman Creek Catchment (hereafter referred to as “the Policy”) and include uses such as maintenance of natural aquatic ecosystems and potable water supply.

Audit Findings

The primary hazard identified as having a high risk of impact on water quality and the beneficial uses identified in the Policy was sediment run off. Faecal contamination from the unsewered township of Erica was also found to present a high, but localised, risk of impact on water quality.

The following land uses and activities (in no order of priority) were identified as having a high risk of localised or more general impact on water quality due to sediment run off:

· agricultural land around Jacobs Creek;

· existing unsealed roads throughout the catchment;

· construction and, to a lesser extent, use of the South Face Road; and

· pine plantations and a network of poorly maintained unsealed roads located on Gippsland Water land around the Moondarra Reservoir.

Potential impacts of sediment run off varied across the catchment. At the top of the catchment, the primary potential impacts were on aquatic invertebrate life due to coarse sediment deposits and/or short term elevated turbidity levels. At the bottom of the catchment, the main potential impact of sediment run off was treatment costs associated with potable water supply.

Impact on water quality due to sediment run off was primarily measured in terms of turbidity. While the monitoring results were obtained from a network that was not geographically comprehensive and during a period of relatively low rainfall, and therefore may not have identified all impacts, the following observations were made.

Turbidity levels in some areas of the catchment met the Policy’s long term objectives, however some areas of non compliance were observed. Turbidity levels at “Morgans” in the upper catchment met the Policy’s annual 50th and 90th percentile objectives. At “Browns”, on the Tyers River where it enters the Moondarra Reservoir, turbidity levels complied with the annual 50th percentile objective in the Policy, but not the 90th percentile objective. At the downstream end of Jacob’s Creek, where it enters the Moondarra Reservoir, turbidity levels exceeded both annual percentile objectives of the Policy. These impacts on Jacobs Creek were most likely due to run off from agricultural land and to a lesser extent, unsealed roads. Turbidity levels at the outlet of the Moondarra Reservoir met both of the Policy’s annual percentile objectives.

Short duration peaks of a few hours or days that exceeded the acceptable variation from background level specified in the Policy were observed at all locations. This included areas of the upper catchment where monitoring results demonstrated compliance with the Policy’s long term objectives Evidence of impact was also found after performing biological sampling in the Tyers River West Branch which is located in the upper catchment. Road construction works had the potential to contribute to these impacts.

Although water quality monitoring information was not sufficient to draw comprehensive conclusions regarding impacts from nutrients and faecal contamination, some potential for impact was identified, principally in Jacob’s Creek. This is sufficient to justify further investigations and improvements to management of relevant land uses and activities.

Risk levels are influenced by the standard of management practices associated with land uses and activities. Existing management practices were assessed against relevant legislative requirements, codes of practice, and accepted best practice. This report identifies where existing management practices do not meet standards or prescriptions contained in relevant standards or legislative requirements. Where standards are met, but a significant risk to water quality still exists, best practice management solutions are proposed.

TYERS RIVER CATCHMENT management framework allowed the auditor to complete a detailed assessment of these systems and their implementation. This management framework contrasts with a lack of management systems in place for some other land uses, such as agriculture, where although management systems are under development they are not yet implemented and therefore could not be audited. This difference is reflected in the environmental audit report which presents detailed findings and recommendations in relation to timber harvesting in State Forest, consistent with the principle of continuous improvement. In the case of agricultural land the environmental audit report simply states that systems are required.

Observations and Recommendations

The audit identified opportunities to reduce risks to water quality through the improvement of existing management practices. In some areas, programs are already in place to improve environmental management practices, and have been partially or fully implemented. Arising out of the audit, key actions have been identified to address specific issues in the catchment. Where issues are applicable across the State, recommendations have been framed to address the issues at this level.

Overall, there is a high level of stakeholder interaction and a partnership approach to managing the catchment, as well as a high level of understanding of the threats to water quality that catchment activities pose. This audit identified opportunities for improvement of overall catchment management processes, based on risk assessment outcomes.

To ensure ongoing compliance with the Policy and sustainable use of the catchment, the following key actions are recommended:

· further development of the strategic management framework so that significant risks to water quality are effectively managed;

· application of an improved water quality monitoring program that will detect problems, and that will provide reliable data on which action can be based;

· improved assessment of the impacts of all land uses and activities on water quality through direct water quality monitoring and through surrogates such as stream index assessment or benchmarking of management practices;

· provision of adequate guidance for the management of unsealed roads, and the development of a prioritised program to address areas which pose a high risk to water quality;

· continued development and implementation of the South Face Road Environmental Management System;

· inclusion of assessment of environmental outcomes in NRE’s supervision and auditing of forestry activities;

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· finalisation and implementation of the draft Central Gippsland Water Quality Management Plan;

· continued development of the Landcare group; and

· inclusion of objectives and procedures for the management of land around the Moondarra Reservoir in Gippsland Water’s Environmental Management System.

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EXECUTIVE SUMMARY

TABLE OF CONTENTS

1 INTRODUCTION ...... 1

2 TERMS OF REFERENCE ...... 2

3 SCOPE ...... 2

4 APPROACH AND METHODOLGY ...... 3

4.1 Hazard Identification ...... 3

4.2 Risk Assessment...... 3

4.3 Compliance Criteria ...... 5

4.4 Methodology...... 7

4.5 Presentation of Audit Findings...... 7

4.6 Presentation of Observations and Recommendations ...... 8

5 AUDIT FINDINGS...... 9

5.1 Baw Baw National Park...... 9

5.2 Upper Tyers...... 12

5.3 River Flats below Tyers Junction...... 26

5.4 Beynon Creek Sub-catchment...... 29

5.5 Hotel Creek Sub-catchment ...... 32

5.6 Jacobs Creek Sub-catchment...... 37

5.7 Stockyard Creek and Smile of Fortune Creek Sub-catchment...... 43

5.8 Moondarra State Park...... 44

5.9 Land Surrounding Moondarra Reservoir...... 48

5.10 Boola State Forest...... 53

5.11 Forestry...... 54

5.12 Existing roads...... 56

5.13 Agriculture ...... 60

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6 OBSERVATIONS AND RECOMMENDATIONS...... 61

6.1 Forestry...... 62

6.2 Existing Roads...... 72

6.3 Agriculture ...... 78

6.4 Other Land Uses and Activities...... 79

6.5 Overall Catchment Management ...... 80

6.6 Catchment-wide Water Quality Monitoring...... 84

7 CONCLUSIONS...... 86

8 REFERENCES...... 89

APPENDIX 1 MAP OF THE TYERS RIVER CATCHMENT

APPENDIX 2 RESULTS OF RAPID BIOLOGICAL ASSESSMENT OF STREAMS IN THE SOUTH FACE ROAD AREA – JULY AND AUGUST 2000

APPENDIX 3 RECOMMENDED WATER SAMPLING PROGRAM, SOUTH FACE ROAD

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1 INTRODUCTION

The Tyers River Catchment is located in West Gippsland and extends from alpine native forest in the Baw Baw National Park to areas of river flats and agricultural activities lower in the catchment. The catchment covers an area of approximately 275 square kilometres. The Moondarra Reservoir is located at the bottom of the catchment. This reservoir is managed by Gippsland Water and supplies potable water to the Latrobe Valley. Most of the water from the reservoir is used by industry but it also supplies approximately 50,000 people with water for domestic use.

This environmental audit report provides an assessment of the risk that land uses and activities within the catchment present to the beneficial uses of waterways. These land uses and activities include urban land, roads, agriculture, timber harvesting, recreational use of state forest and national park, and water supply collection points. Beneficial uses of waterways within the catchment are identified in the State environment protection policy (Waters of Victoria) – Schedule F5. Waters of the Latrobe and Thomson River Basins and Merriman Creek Catchment (“the Policy”).

The environmental audit was undertaken by assessing water quality data and management practices against relevant standards, legislation, and accepted best practices. This assessment was performed over May and November 2000 and the audit provides a “point in time” assessment of the condition of the catchment over this period. Although some limited water quality monitoring was performed as part of the audit, the audit’s conclusions are based mainly upon existing water quality data and the auditor’s assessment of management practices. Audit findings, including risk assessment outcomes, are presented in section 5.

Observations made by the auditor during the course of the audit, opportunities for improvement, and recommendations made as a result of the audit are presented in section 6. Where generic issues or opportunities for improvement have been identified these have been highlighted by recommendations that go beyond the Tyers River Catchment.

The audit process is different from a purely scientific study in that its assessment involves comparing water quality and management practices with standards and legislation. An assessment of risk is then made based on this evidence and on the opinion of the Environmental Auditor appointed under the Environment Protection Act 1970. A scientific study involves the author drawing conclusions based primarily on data gained through experimental work or field studies. Further details regarding the audit’s approach and methodology are contained in section 4.

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A Statement of Environmental Audit, in accordance with the provisions of the Environment Protection Act 1970, has been issued following completion of this environmental audit report. The Statement of Environmental Audit is based upon the findings of the environmental audit and identifies those beneficial uses which are or are potentially impacted upon by the condition of the catchment.

2 TERMS OF REFERENCE

The terms of reference are to undertake an audit of the Tyers River Catchment in relation to the beneficial uses identified in the Policy, particularly in relation to ensuring the sustainability of the catchment.

3 SCOPE

Land uses and activities have inherent hazards that may pose a risk to surface water quality. These risks can be reduced through effective land-use planning, and through the application of best practice management techniques.

This audit assessed the risk to water quality associated with land uses and activities within the Tyers River Catchment in terms of the beneficial uses contained in the Policy. The risk assessment included consideration of the effectiveness of existing management practices in reducing risks.

Only management aspects necessary to ensure protection of the beneficial uses identified in the Policy were assessed in the audit.

Catchment activities have the potential to affect water yield by reducing the quantity of water running off a particular area of land. This issue was beyond the scope of this audit and was not investigated. Issues associated with biodiversity, and historical values were also beyond the scope of the audit.

Aquatic life in streams was considered where relevant to water quality.

For the purposes of this audit, the catchment is defined as those waters upstream of the offtake of the Moondarra Reservoir and excludes the section of the Tyers River downstream of the reservoir. This is consistent with the Policy which includes “Tyers River and Jacobs Creek and their tributaries upstream of the wall of the Moondarra Reservoir” in segment B. It is also consistent with other studies of the catchment.

The risk assessment was conducted in relation to risks to beneficial uses identified in the Policy. This related to all waterways within the catchment. It was not the intent of the audit to estimate the relative amounts of sediment run off generated by various land uses or activities.

This report provides an assessment of the catchment over a certain period of time. Although some historical information and events are referred to, the report provides an assessment of risk which applies to the period over which the audit

Environmental Audit 2 TYERS RIVER CATCHMENT was conducted. Water quality monitoring has been reviewed from June 1999 to September 20001. Observations of the catchment were made and interviews were conducted over a period between May 2000 and November 2000.

4 APPROACH AND METHODOLGY

4.1 Hazard Identification

Each of the major land uses and activities within the catchment has associated hazards that have the potential to impact on water quality and compromise the beneficial uses identified in the Policy. These hazards are listed in Table 1.

4.2 Risk Assessment

A qualitative assessment of the level of risk to water quality posed by the land uses and activities within the catchment has been performed. Risk levels are expressed as low, moderate or high and represent the risk of the objectives contained with the Policy being breached or of the beneficial uses identified in the Policy being compromised.

The risk assessment was based, in part, on the results of various water quality monitoring programs that have been undertaken within the catchment. Recent continuous turbidity monitoring was a valuable component of these programs. It is noted that the monitoring data cannot be considered to be comprehensive as it is geographically disparate, and incorporates a number of discontinuous time series and once off sampling events. Rainfall during the period over which monitoring results were reviewed was relatively low and did not reflect worst case conditions conducive to sediment run off. There were also deficiencies with the quality assurance procedures used in collecting these data. Therefore the data may not have identified all actual or potential impacts on water quality. However, the data available together with observations made during site visits were sufficient to perform a qualitative risk assessment.

The risk assessment also considered the management systems and other measures employed to minimise the risk to water quality associated with various land uses and activities. These risk mitigation measures were compared with applicable legislation, codes of practice and established best practices.

The auditor’s judgement was used when determining risk levels and presenting some of the findings in the report, and the risk levels provided are based on the opinion of the auditor in his capacity as an Environmental Auditor appointed under the Environment Protection Act 1970. Qualifications and assumptions are noted in the report as appropriate.

1 Detailed monitoring data was not available between 1991 and 1999. Detailed monitoring data prior to 1991 is available, however this was not reviewed as it is considered unlikely to provide information about potential impacts from current land uses and activities. In addition, information about conditions and exact activities occurring at the time of sampling is insufficient to draw conclusions from the data. Environmental Audit 3 TYERS RIVER CATCHMENT

Hazard Source Potential water quality impacts Cause (land use/ activity/event) Sediment Soil erosion. Increased suspended solids and turbidity. Increased - Forestry turbidity interferes with the transmission of light and - Roads, affects the growth of plants as well as reducing visibility particularly for aquatic fauna. Turbidity impacts upon uses of water unsealed roads for recreation and increases treatment costs associated - Agriculture with potable water supplies. - Fire Elevated levels of suspended solids can result in siltation of waterways which can smother stream beds and affect flora and fauna. Solids can be resuspended after being deposited, and increase turbidity levels potentially along the length of the catchment. Nutrients Nutrient run off from fertiliser application to agricultural Nutrient run off can create nuisance plant growth in the - Agriculture land. Run off from septic tanks can also contribute to form of algal blooms, low dissolved oxygen and result in - Urban nutrient loads. fish kills. development Nutrient run off is associated with soil erosion and - Forestry sediment run off as soil particles can carry nutrients and other toxicants into waterways. Faecal Poorly maintained or designed septic tanks and cattle May increase microbiological levels in waterways. The - Urban contamination grazing on stream banks. main beneficial uses impacted by this hazard are potable development water supply and recreational uses. Faecal contamination is generally measured by the indicator bacterium E coli. - Agriculture Pesticides Run off or overspray. May increase waterway toxicity and affect flora and fauna. - Agriculture pH variation There is an overall trend of decreasing pH in the pH changes may affect the toxicity of various pollutants - Unknown catchment. Comparable trends are occurring across south- already in waterways and impact on aquatic life. eastern Australia. The cause of these trends is currently unknown. Table 1: Primary hazards to water quality identified within the Tyers River Catchment

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4.3 Compliance Criteria

The environmental quality of the Tyers River Catchment was audited against the beneficial uses, water quality indicators and objectives contained in the State environment protection policy (Waters of Victoria). The Tyers River Catchment falls into Schedule F5 Waters of the Latrobe and Thomson River Basins and Merriman Creek Catchment.

The Policy identifies beneficial uses to be protected in various segments of the Schedule area.

Surface waters within the Baw Baw National Park are classified within Segment A (predominantly reserves and conservation areas) of the Schedule and the remainder of the catchment is classified within Segment B (predominantly forests and forestry activities) of the Schedule. The beneficial uses identified in the Policy for these areas are:

· Maintenance of natural aquatic ecosystems and associated wildlife: - Natural ecosystems (Baw Baw National Park only) - Natural ecosystems with occasional disturbance due to human activity (excluding Baw Baw National Park) · Potable water supply: - With treatment (disinfection only) · Recreation: - Primary contact (eg. swimming, water skiing) - Secondary contact (eg. boating, fishing) - Aesthetic enjoyment (eg. walking by the waters) · Agricultural water supply: - Stock watering and irrigation (excluding Baw Baw National Park) · Fishing and aquaculture · Industrial water use (excluding Baw Baw National Park) · Aquifer recharge.

The Policy provides specific water quality indicators and objectives. These include annual percentile objectives, which allow long term water quality to be evaluated, as well as objectives for acceptable variations from background levels, which allow short term changes in water quality to be evaluated and compared to Policy objectives.

The Policy also provides an attainment program which provides a framework to manage actions to protect beneficial uses.

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Land management practices within the catchment were also audited against the following key legislation, standards and codes:

Forests Act 1958 - NRE’s Forest Management Plans. Forest Management plans establish broad aims, guidelines and actions for the management of State Forest in various Forest Management Areas. Forest Management Plans divide State Forest into three zones. These are Special Protection Zones, where timber harvesting is excluded, Special Management Zones, where timber harvesting is carried out under certain conditions, and General Management Zones where timber harvesting is a priority. Conservation Forests and Lands Act 1987 - NRE’s Code of Forest Practices for Timber Production 1996. The Code provides goals and guidelines for the conduct of all commercial timber production activities that occur in Victoria, on public and private land.

- NRE’s Gippsland Region Management Prescriptions for Timber Production and Other Forest Uses 1998. These Management Prescriptions apply to all activities and operations managed by the Department of Natural Resources and the Environment in State Forests of Gippsland Region. They provide regionally based prescriptions which detail how works and activities are to be carried out in accordance with the Code’s goals and guidelines. Catchment and Land Protection Act 1994 - Tyers River Water Supply Catchment, Notice of Determination of Land Use 1975 (now referred to as a Special Area Plan). The document designates suitable land uses for different areas of the catchment aimed at reducing soil erosion. Environment Protection Act 1970 - EPA Publication 480 Environmental Guidelines for Major Construction Sites 1995. The Guideline provides Best Practice Environmental Management guidance aimed at minimising environmental impacts from major construction activities. National Parks Act 1975

- Moondarra State Park and Tyers Park Management Plan, May 1991.

- Baw Baw National Park Management Plan, September 1992. These Management Plans include specific actions to be taken by Parks Victoria in managing land uses and activities in these Parks.

Planning and Environment Act 1987 - The Baw Baw Planning Scheme. This Scheme sets out requirements for the use, development and protection of private land. It is administered

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by the Responsible Planning Authority who are the Baw Baw Shire Council.

4.4 Methodology

This audit was undertaken using the methodology set out below:

· Identifying land uses and activities within the catchment and their associated hazards that pose a risk to water quality; · Assessing the risk to water quality associated with these land uses and activities against the beneficial uses identified in the Policy; · Auditing the management of land uses and activities within the catchment for compliance with relevant legislative requirements, codes of practice and accepted best practices. This was based on inspections, interviews and review of existing data2; · Providing recommendations for best practice management solutions where there is an unacceptable risk to water quality, or existing management practices do not meet relevant legislative requirements or codes of practice. As sediment was identified as the major risk to water quality, the audit focused on sources of sediment run off and management practices aimed at minimising the associated risk. Other hazards assessed as posing a lesser, but still significant, risk to water quality were pesticides, nutrients, faecal contamination, and pH variation.

The audit was conducted by identifying the hazards which, in the opinion of the auditor, are most likely to impact upon water quality. Risk assessment was then carried out by assessing representative portions of the catchment selected on the likely risks to water quality. Not all contaminants that could potentially impact upon water quality were assessed, nor were all areas or waterways within the catchment audited. This Environmental Audit Report and the associated Statement of Environmental Audit should be considered in the context of this methodology.

4.5 Presentation of Audit Findings

Audit findings and risk assessment outcomes are presented in section 5. Audit findings consist of assessment against compliance criteria and best practice. The level of risk associated with each area or activity is influenced by the standard of the management practices associated with the land use or activity undertaken.

2 Land uses and sediment runoff sources within the Tyers River Catchment are currently being investigated as part of a project partly funded by the National Heritage Trust. The project aims to establish a Landcare Group in the Tyers River Catchment and to formulate a “whole of catchment” plan of management. The project commenced in April 1999, is being undertaken in conjunction with Gippsland Water, and is expected to be completed in 2002. Environmental Audit 7 TYERS RIVER CATCHMENT

4.6 Presentation of Observations and Recommendations

Observations made and opportunities to improve management practices identified during the audit (not necessarily related to assessment against a standard) are presented in section 6. Recommendations to ensure compliance with the Policy, and to enable continuous improvement are also included in section 6.

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5 AUDIT FINDINGS

Audit findings and risk assessment outcomes are presented in this section. Audit findings consist of assessment against compliance criteria and best practice. The management practices associated with the land use or activity undertaken were also considered in the risk assessment.

A map of the catchment is presented in Appendix 1.

5.1 Baw Baw National Park

The land at the northern portion of the Tyers River Catchment is part of the Baw Baw National Park. The border of the Park generally follows the 1220 metre elevation contour, but extends down to lower elevations in the north east corner of the Catchment. This area is primarily used for recreational and conservation purposes.

Findings

1. The activities in this segment generally have a low environmental impact3.

2. There is a limited potential for erosion from scouring of entrenched streams in bogs and from sheet erosion of some steep hillsides within this area. This is not expected to contribute a significant sediment load to the catchment.

3. With the exception of the Tyers River East Branch at the south east end of the Park (see later findings), the auditor’s observations of waterways within the Baw Baw National Park did not detect any visible increase in turbidity or impact upon the beneficial uses identified the Policy4.

4. Gippsland Water uses a small offtake on Trigger Creek by the Tyers River East Branch to supply drinking water to Erica and Rawson. Gippsland Water’s monitoring data for their Trigger Creek offtake has consistently shown compliance with the Policy objectives, however samples are collected after water has passed through sediment settlement basins and hence are not representative of in stream water quality.

5. The maintenance standards of the Mt Erica Road, which drains into the upper reaches of the Tyers River East Branch were observed to be adequate and in particular the gravel surface of the road was well maintained. There is an opportunity to provide a higher standard of sediment control measures at

3 The Baw Baw Alpine Resort and associated ski village drains to the west, outside of the catchment, and therefore has no impact on water quality in the Tyers River Catchment.

4 This finding is based mainly on observations, as in stream water quality monitoring data was unavailable for most of the waterways in this area. Environmental Audit 9 TYERS RIVER CATCHMENT

stream crossings along this road in order to further reduce the risk of impact on the high quality water in this area.

6. Storm event grab samples taken at the downstream end of O’Sheas Mill Site Camping Area have demonstrated high turbidity levels that were in the order of ten times the typical background levels measured at this location5. This campsite is located on the Tyers River East Branch, on the south east boundary of the border of the Baw Baw National Park. This site is not considered representative of other land uses in this area.

7. The elevated turbidity event noted above could not be definitively linked to any particular event or location. However, the O’Sheas Mill Site Camping Area was observed to be in a degraded condition and is considered likely to have contributed to this event. Eroding river banks in the campsite, a four wheel drive track that fords the river and a small waterfall may contribute to sandy soils becoming suspended and elevating turbidity levels. Parks Victoria are responsible for the maintenance of this campsite. There are also some minor unsealed roads that run alongside the west side of the Thomson Valley Road which have the potential to contribute sediment to the Tyers River East Branch. These roads are also not considered typical of the majority of land in the Baw Baw National Park.

It is also noted that the Tyers River East Branch has a sandy base and sand deposits existed around its banks in places (see Photograph 1).

5 Michael Bannon, personal communication, Gippsland Water sampling results 1999. Environmental Audit 10 TYERS RIVER CATCHMENT

Photograph 1 : Tyers River East Branch at O’Sheas Mill Site Camping Area

8. While there is little ongoing monitoring of water quality in this area, the low risk to water quality means monitoring is considered a low priority in the context of the whole Tyers River Catchment. However, further storm event based turbidity monitoring, completed at locations upstream of the O’Sheas Mill Site Camping Area would be worthwhile to determine the cause of elevated turbidity levels at this point.

Risk Assessment

The risk of sediment run off from this part of the catchment affecting water quality and the beneficial uses identified in the Policy is considered low. However it is noted that elevated turbidity levels at O'Sheas Mill Site Camping Area require further investigation.

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5.2 Upper Tyers

The Upper Tyers area consists of land to the north of Tyers Junction, the Tyers River East Branch and the Tyers River West Branch.

Findings

9. The activity in this area with the greatest potential to impact on water quality is construction of the South Face Road (see Photograph 2). Timber harvesting in State Forest, and the ongoing use of the South Face Road and other unsealed roads also present a potential for impact on water quality.

Photograph 2: South Face Road at Christmas Creek

10. Approximately 80% of the water collected in the Moondarra Reservoir comes from the Upper Tyers area, and the south face of the Baw Baw National Park, described in section 5.16. The use and management of this land may impact upon water quality in the Reservoir as well as local waterways.

11. It is the auditor’s opinion that significant sediment discharges to Christmas Creek and the Tyers River West Branch have occurred over the last few years. While breaches of the annual percentile objectives of the Policy were not detected, there have been observations of sediment deposited on stream

6 Flow measurements are performed at the bottom of the Upper Tyers area, and the amount of water collected in the Baw Baw National Park can not be excluded from this estimate. Environmental Audit 12 TYERS RIVER CATCHMENT

beds and of short term high levels of turbidity (in excess of the acceptable variation from background in the Policy). The construction of the South Face Road had the potential to contribute to these sediment discharges.

12. Recent water quality monitoring in this area consists of:

- continuous turbidity monitoring performed at “Morgans” on the Tyers River West Branch (Gippsland Water/NHT7);

- grab sampling for turbidity performed at Tyers Junction at bottom of this sub-catchment (Gippsland Water/NHT);

- grab sampling for turbidity at various locations directly upstream and downstream of the South Face Road (NRE and Gippsland Water/NHT);

- biological sampling at locations upstream and downstream of the South Face Road (EPA).

13. In interpreting monitoring data, it should be noted that:

- Rainfall over the period (between June 1999 and September 2000) was low and the results may not reflect all potential impacts of high intensity rainfall events; and

- As the sampling locations at Morgans and Tyers Junction are downstream of the high risk areas of the South Face Road (Christmas Creek and Tyers River West Branch sections), monitoring conducted at these points will detect persistent impacts to water quality. However, they are too far downstream of the South Face Road to detect all potential impacts from the South Face Road as sediment can settle out locally.

14. Observations of this area were made by the auditor between May and November 2000. Water quality monitoring results from between June 1999 and September 2000 were reviewed. Forestry coupes were being harvested over this period, with the exception of the annual winter closure between June and October. Construction activities on the South Face Road only occur during summer. Over the 1999/2000 summer, works were undertaken to complete the bridge deck and sections of road on either side of Christmas Creek. The eastern approach to the Tyers River West Branch was formed in the previous summer, and road surfacing works were undertaken over the 1999/2000 summer.

15. Continuous8 turbidity monitoring at “Morgans”, located upstream on the Tyers River West Branch was conducted by Gippsland Water between November

7 National Heritage Trust/Gippsland Water Tyers River Catchment Project.

8 Continuous turbidity monitoring at this site was only established in November 1999. Environmental Audit 13 TYERS RIVER CATCHMENT

1999 and May 20009. Because of faulty monitoring equipment, only 5 months data could be obtained. Without a full year’s worth of data, compliance with the annual percentile requirements of the Policy could only be estimated rather than demonstrated. It is also noted that the data encompasses a potential worst case period of summer when forestry and associated activities occur, but also misses a potential worst case period of winter when rainfall, and potential for erosion, is highest. On the basis of the available results and these qualifications, it is considered likely that the Policy’s 50th and 90th annual percentile objectives, of 5 NTU and 10 NTU respectively, are being achieved at this location.

16. At times short duration events of elevated turbidity levels recorded at Morgans exceeded the Policy’s objectives for acceptable variation from background levels. This included, in particular, results of a short duration event in December 1999 which peaked at 172 NTU. Sediment run off from a South Face Road batter potentially contributed to this elevated turbidity level10.

17. Single storm event water quality monitoring found elevated turbidity in Christmas Creek on one occasion during August 1999. The in-situ turbidity measurements increased from 14 NTU immediately upstream of the bridge to 695 NTU approximately 200 metres downstream of the bridge. This was attributed to run off from the South Face Road near the Christmas Creek bridge10.

18. Once off biological sampling in the Tyers River West Branch performed in July 2000, showed a substantial downstream reduction in the quantity and diversity of stream bed fauna compared to an upstream sample (details are presented in Appendix 2). The results are indicative of an impact between the two locations. This is likely to be due to slugs of eroded sediment but could also be due to trout predation.

Deposits of coarse sediment were observed at the downstream site and in places the sediment had buried moss covered rocks, suggesting that it had been recently deposited. The presence of this sediment is consistent with eroded material being deposited in the river.

Sediment from the South Face Road had the potential to contribute to these observations, but other influences cannot be ruled out. It is noted that forestry and the South Face Road construction are the only activities occurring along this portion of the river. Riparian buffer zones between the river and adjacent forestry coupes were relatively large and appeared intact, suggesting run off from the forestry coupes had not caused an impact. Further study here and at other locations along the road would assist in evaluating impacts.

9 pp 8 and 9, Bannon M. (May 2000) Tyers River Catchment Annual Report, Year One.

10 pp 8 and 9, Bannon M. (May 2000) Tyers River Catchment Annual Report, Year One. Environmental Audit 14 TYERS RIVER CATCHMENT

19. Biological sampling at Christmas Creek and Growlers Creek, performed upstream and downstream of the South Face Road construction in August 2000 showed no change in fauna between upstream and downstream locations. Slightly more sediment was observed at the downstream location on Christmas Creek than at the upstream location.

20. Turbidity levels obtained by grab sampling in the three branches of the Tyers River at Tyers Junction indicated that water quality at these locations was likely to comply with the annual percentile objectives of the Policy11. However some peak values demonstrated breaches of the Policy’s objectives for acceptable variation from background levels.

21. Peak values were noted to be higher in the Tyers River East Branch (compared to the other two branches of the Tyers River), which could be attributed to impacts at O’Sheas Mill Camping Area (see section 5.1). Unsealed roads, timber harvesting areas, and a limited amount of agricultural land are also located within the catchment of the Tyers River East Branch in between O’Sheas and Tyers Junction. Each of these activities have the potential to contribute sediment run off.

22. Soil types in the Upper Tyers area, including along the route of the South Face Road, vary between coarse granitic soils and more clay-rich soils12. Erosion of these coarse-grained soils is likely to result in localised effects such as smothering of stream beds because the relatively large sediment particles will settle out of suspension quickly. Erosion of the finer grain size clays is more likely to result in elevated turbidity levels that persist further down the catchment. Sediment run off from the Upper Tyers area has the potential to impact on waterways both locally and further down the catchment.

Forestry

23. General observations of sediment pathways and deposits, made during inspections of the Upper Tyers area indicate that the potential for sediment run off from unsealed roads, including those accessing forestry coupes, is much greater than from the forestry coupes themselves.

This assessment is supported by experimental work performed in other forestry areas. Such work has indicated that, during rain, unsealed forest roads generate an order of magnitude more sediment than snig tracks, and

11 Approximately 22 results, collected between June and November 1999, were available for each of the three branches of the Tyers River. As the results were not collected over a full year, compliance with the Policy’s annual percentile objectives could only be estimated rather than demonstrated. It is further noted that the samples were taken over the winter period which is a worst case period in terms of rainfall, but at the same time minimal activity occurs over this period which lessens the risk to water quality.

12 Bannon M. Tyers River Catchment Annual Report, Year One, May 2000, pp 14. Environmental Audit 15 TYERS RIVER CATCHMENT

snig tracks generate an order of magnitude more sediment than general harvesting areas13.

24. No water quality monitoring is performed to assess potential impacts from forestry coupes in the Upper Tyers area, or elsewhere in the Tyers River Catchment. Ambient water quality monitoring currently performed around the South Face Road is not sufficient to detect impacts from adjacent forestry coupes. This is not a requirement of the Code of Forest Practices for Timber Production, November 1996 (“the Code”), but is a gap in the data available for this audit.

25. A representative coupe in the Upper Tyers was inspected and in general was found to be managed well, and in accordance with the Code14. However, the following opportunities to improve the management of this coupe and associated temporary roads were identified:

- Under road culverts on the access road to the coupe were generally well constructed, however a build up of silt in the culverts was observed indicating a possible lack of attention to maintenance of these roads.

- Snig tracks had been breached and barred but it appeared that this had been done without recognition of grade steepness. An example was sighted where a steep section had few bars (at least 100 metres between bars) while a less steep section was frequently barred. This reflects the ease of placing bars but not the environmental risk.

South Face Road – Route Planning

26. It is the auditor’s opinion that the overall location of the South Face Road presents an inherently high level of risk to water quality. It is noted that the detailed route of the South Face Road was formulated to minimise crossings of waterways15. Although this reduced the risk associated with the road’s route, it is considered that an inherently high risk still remains due to the road’s location on the south face of Mt Baw Baw. Factors that contribute to this risk include the high rainfall in this part of the catchment, the steep terrain, the erodible nature of some of the soils, and the proximity of the road to major watercourses.

27. A particularly high standard of environmental management, including road engineering, that exceeds the minimum standards of the Code is considered

13 Croke J., Managing Sediment Sources and Movement in Forests: The Forest Industry and Water Quality, November 1999.

14 This coupe was inspected through participation in an NRE Forest Management Branch audit of Coupe number 482/501/39 in the Upper Tyers area as part of NRE’s Annual Code Compliance Audit in August 2000.

15 Personal communication with NRE staff. Environmental Audit 16 TYERS RIVER CATCHMENT

necessary to reduce this risk to water quality. Although NRE has successfully employed measures, including implementation of the Environmental Management System, to reduce this level of risk there are still further opportunities for improvement.

28. In the auditor’s opinion, the environmental risks associated with the selected route of the South Face Road could have been better assessed during the planning phase. In particular:

- alternatives to the construction of the South Face Road such as the upgrade of roads further south and in less steep terrain, such as the Tanjil Bren Road, that would pose lesser risks to water quality could have been better assessed and the process documented;

- risk reduction measures to manage the inherent risks to water quality associated with the route were not identified initially and incorporated into design, construction and maintenance standards for the road;

- better information regarding environmental issues associated with the road could have been provided to the public or other stakeholders to allow for informed comment.

29. The purpose of the South Face Road is to provide a permanent transport route to move timber from coupes to the west of the Tyers River Catchment to mills located on the eastern side, as well as to access and transport timber from coupes in the Upper Tyers area. Use of the road as a tourist road to access Mt Baw Baw is a possible additional use after the road is fully completed.

30. In 1988 NRE16, completed a major study to identify a permanent road network in the Central Highlands17. This study formulated the broad route of the South Face Road. An assessment of environmental issues such as the potential impacts on water quality associated with this broad choice of route compared with possible alternative routes at lower elevations was not documented in the study.

31. In 1989, a public discussion paper18 was published which identified, among other roads, the proposed route of the South Face Road, and outlined a process for planning the road. For the South Face Road it proposed a detailed investigation to “identify whether the road can be accommodated with careful planning to ensure that the area or feature of environmental significance is

16 Then the Department of Conservation Forests and Lands.

17 Department of Conservation Forests and Lands, A Permanent Road Network for the Ash and Associated Mixed Species Forests of the Central Highlands and Eastern Strzeleckis. Internal Technical Report, May 1988.

18 Department of Conservation Forests and Lands, Discussion Paper Processes for Development of Timber Harvesting Plans Central Highlands Roads, October 1989. Environmental Audit 17 TYERS RIVER CATCHMENT

not compromised, or whether the road alignment has to be relocated”. No documentation of the outcomes of such an investigation into the overall route of the South Face Road could be located.

The auditor observed evidence of ongoing, documented assessment, which included environmental issues, during the detailed route planning process for the South Face Road. This process determined the exact route, including aspects such as steepness, width and where streams would be crossed as opposed to the decision to locate the road on the south face of Mt Baw Baw. Input was provided (verbally and by internal memos) to the forestry section of NRE by the sections of NRE responsible for catchment management and flora and fauna protection.

32. The Code provides guidelines aimed at locating roads in order to minimise their potential impact on water quality. These include locating roads so as to avoid steep slopes and areas prone to landslips. However, neither the Code nor NRE’s Gippsland Region Management Prescriptions for Timber Production and other Forest Uses, October 1998 (the “Regional Prescriptions”) contain requirements that formal assessments of the environmental risks associated with road siting are conducted. This is considered to be a gap in these standards.

South Face Road – Construction

33. Substantial construction works on the road started in 1995. Works have now been completed on approximately 75% of the length of the South Face Road that lies within the Tyers River Catchment19. Construction of the bridge over the Tyers River West Branch, and realignment of a section of road around Buckles Spur are still to be completed20.

34. The inherent risk of sediment run off affecting water quality during the remaining South Face Road construction works is considered to be higher than from the rest of the road because of the location of the remaining works. The Tyers River West Branch is the largest river along the length of the road and the proposed crossing is located in very steep terrain. Existing batters on the east approach to the creek are steep and are constructed in highly erodible soil. The Buckles Spur realignment is also in steep terrain and involves crossing numerous tributaries of Pittmans Creek.

19 When completed, the South Face Road will be 39 kilometres long. The section of road within the Tyers River Catchment (from the Thomson Valley Road to just after the Tyers River West Branch) accounts for approximately half this length.

20 The Tyers River West Branch bridge construction is planned to occur over the 2001/2002 and 2002/2003 summers and the Buckles Spur realignment is planned to occur over the 2000/2001 summer. Environmental Audit 18 TYERS RIVER CATCHMENT

35. Not all aspects of the design and construction of the road comply with the guidelines within the Code and the Regional Prescriptions21. These aspects include provision of cut off drains above batters, stabilisation of batters, and culvert spacing22. Where differences between the guidelines in the Code and the actual road design exist, risks need to be reduced by improved maintenance practices, more frequent use of secondary control devices such as sediment control structures, and use of documented contingency plans. Although some risk reduction measures have been successfully implemented by NRE, it is the auditor’s opinion that there is further opportunity for improvement.

36. The major sediment run off risk associated with the South Face Road is posed by road batters where these are very steep and are constructed in highly erodible soils. This assessment is supported by the results of water quality monitoring, field observations of slumping and erosion of batters along the road, and by observations of large quantities of sediment build up in sediment traps. Batters with a shallower grade would pose a reduced risk of collapsing or slumping and be more likely to recover and revegetate. Where steep batters exist, other risk reduction measures such as effective stabilisation are needed to reduce the risk of sediment run off.

Although hydromulching trials conducted this year have demonstrated some success, further work is required to achieve long term stability of these batters23. Photograph 3 shows an unstabilised South Face Road batter on the approach to Tyers River West Branch. Photograph 4 shows an eroding batter on the South Face Road uphill and to the west of the Christmas Creek bridge. Further stabilisation and vegetation works are planned for these batters, however it is noted that the these batters have been unstabilised as illustrated in the photographs for at least two winter periods.

21 NRE Gippsland Region, Management Prescriptions for Timber Harvesting and other Forest Uses, October 1998.

22 The Code allows for judgement in application of some of its guidelines subject to local conditions. NRE’s Environmental Management System documents some areas where the road design differs to the guidelines in the Code and the Regional Prescriptions and explains the reasoning and judgement behind these differences. However, in the opinion of the auditor, these aspects still do not comply with the guidelines in the Code and justify a higher than usual standard of risk mitigation.

23 The lower section of the South Face Road (from the Thomson Valley Road to the Tyers River) has been completed for three to four years, and batters appeared generally stable. However it should be noted that this section of road has been constructed in flatter country and on less erodible soils than the other end of the South Face Road. Despite the reduced risk associated with these batters the lack of vegetation on the low batters will lead to ongoing slow erosion of exposed subsoils. Environmental Audit 19 TYERS RIVER CATCHMENT

Photograph 3: South Face Road batter on approach to Tyers River West Branch

Photograph 4 : South Face Road Batter on west side of Christmas Creek crossing

Environmental Audit 20 TYERS RIVER CATCHMENT

37. Clearing widths for road construction have been established in consultation with NRE Flora and Fauna officers so as to minimise the amount of clearing required. In some cases this has led to compromises in terms of increasing batter angles and not being able to provide catch drains above batters24.

38. In some areas, batter slopes are limited to very steep grades by the topography. Other areas are not limited to the same degree, however the same steep batter grades have been maintained. These grades are steeper than those recommended in the Regional Prescriptions (which acknowledge that steeper batters may be appropriate based on experience of working with similar roads). In some areas, these batters could presumably be laid flatter in consultation with NRE Flora and Fauna officers.

39. It was noted that although batters on the South Face Road were stepped and had catch drains on the steps, there were no catch drains above batters. Batters not high enough to have steps also did not have catch drains on top. The failure to divert overland flow away from batter faces is a non compliance with the Code, the Regional Prescriptions and the South Face Road Environmental Management System25. It has the potential to increase the risk of slumping, erosion and sediment run off.

40. Springs and soaks were observed at various locations along the length of the road, particularly adjacent to the Christmas Creek bridge. These were observed to be undermining the stability of the road surface and hence increasing the risk of sediment run off. Neither the Code nor the Regional Prescriptions provide specific guidance for such a situation. In the opinion of the auditor, best practice involves the provision of an improved road surface and drainage at these points. Suggested improvements are contained in section 6.1.

South Face Road – Environmental Management System and road maintenance

41. Preliminary construction of the road commenced in 1988, but substantial construction works did not commence until 1995.

42. In response to impacts from sediment runoff, NRE put in place an

24 In British Colombia, Canada, the Forest Practices Code specifies a standard clearing width of 3 metres from standing timber to the shoulder-of-cut (to prevent undermining of tree root systems). Although this is based on different forest types and is not directly relevant to our conditions, allowance of such a width would promote batter stability and the installation of catch drains.

25 The Code guidelines require “catch drains above batters to minimise erosion, as appropriate”. The Regional Prescriptions require catch drains to be constructed along the contour and no more than 6 metres above the top of the batter where cut batters exceed 50 metres in length and are stepped. The absence of catch drains is also not in accordance with NRE’s Environmental Management System for the South Face Road. The EMS identifies diversion of surface water away from the top of batters as the preferred method of erosion control for batters that are steeper than those recommended in the Regional Prescriptions. Environmental Audit 21 TYERS RIVER CATCHMENT

environmental management system (EMS). This included the application of site specific construction techniques to minimise erosion risks such as rock lining table drains and installing a greater number of sediment traps and silt fences. It has also resulted in a demonstrated improvement in the standard of inspections and maintenance on the road. It is noted that the EMS was developed in an open and transparent manner involving a range of external stakeholders. This included the involvement of these stakeholders in a number of associated site inspections.

43. The higher level of control implemented through the EMS was initiated in response to NRE’s recognition of the inherently high level of risk of soil erosion associated with the route of the South Face Road.

44. In the auditor’s opinion, the EMS provides an appropriate framework for managing the potential impacts of the South Face Road, and a number of its provisions have resulted in noticeable improvements. There are a number of opportunities for further improvement that have been identified in this audit. These include aspects such as improved documentation, checklists, timelines and review systems. Specific recommendations are included in section 6.1.

45. There are opportunities to improve design and maintenance of silt traps. This assessment is based on the following observations:

- The build up of sediment in silt traps reducing their capacity and therefore effectiveness;

- Cutting holes into the silt fences to ‘let the water out’, which largely defeats the purpose of installing silt fences and should not be necessary;

- Poor locations of some sediment traps which do not facilitate regular cleaning because of the difficulty of access;

- Poorly maintained silt fences. For example, on 3 November 2000 the auditor observed a poorly maintained silt fence (see Photograph 5) on the downstream side of the Tyers River East Branch crossing. This was observed to be a critical silt fence as run off from the South Face Road had formed a channel through the vegetation and deposited sediment above the silt fence.

Environmental Audit 22 TYERS RIVER CATCHMENT

Photograph 5 : Poorly maintained silt fence at downstream side of South Face Road crossing of Tyers River East Branch

Water Quality Monitoring Program

46. To meet the EMS requirement that stream turbidity measurements are taken at Christmas Creek and the Tyers River West Branch, NRE installed a continuous turbidity meter upstream of the Tyers River West Branch crossing and in November 2000 were in the process of installing another meter downstream of the crossing26. This is appropriate and the implementation of continuous monitoring at the Tyers River West Branch would address deficiencies with regard to the timing of grab sample collection27. Continued storm event sampling is proposed for Christmas Creek.

47. The existing downstream site used by NRE at Christmas Creek is considered too close to the road to detect all impacts on water quality as some run off from the road may enter Christmas Creek downstream of the monitoring site.

26 In order for the information from the downstream meter to be valid it must be situated far enough downstream of the crossing to identify all run off from the road. Both meters will also need to be checked and their probes cleaned at least once per week.

27 The EMS requires grab samples to be taken each Monday, but in practice samples are taken after rainfall (which is actually more appropriate). A lack of clarity on when to take grab samples means that the procedure is variable, and is not necessarily representative of the stream condition. Environmental Audit 23 TYERS RIVER CATCHMENT

Other issues in the Upper Tyers

48. The auditor observed an example of a degraded campsite on the Christmas Creek Road. A secondary branch of the Christmas Creek Road passes directly through the Tyers River West Branch at this point, despite the presence of a bridge directly adjacent to the crossing. Photograph 6 shows this campsite and road. It was unclear how often this four wheel drive track is used, but it appeared to have been used recently and was very rutted. Any traffic passing across the river at this point would be expected to contribute significant amounts of sediment to the River. The impact will be localised but severe.

Photograph 6 : Degraded campsite and river crossing on Christmas Creek

Environmental Audit 24 TYERS RIVER CATCHMENT

49. The Christmas Creek Road, among other unsealed roads in the area, is subject to seasonal closures. These vary from year to year but during 2000 extended from 15 June to 2 November. Although the closure will reduce some of the risk to water quality associated with the river crossing on the Christmas Creek Road, this measure is not considered sufficient. It is also noted that the gate on the Christmas Creek Road was removed by vandals this year resulting in unrestricted access.

Risk Assessment

Risks from various activities in this segment were assessed against water quality objectives and the beneficial uses identified in the Policy.

The risk of sediment run off from general harvesting areas in the Upper Tyers impacting on water quality is considered low. This is consistent with literature studies that have estimated quantities of sediment run off from harvesting areas.

The risk of sediment run off from general forestry roads (constructed in accordance with the Code) is considered moderate. There is an opportunity to reduce this risk through the use of improved maintenance and construction techniques.

The risk of sediment run off from the construction of the South Face Road is considered high. Although considered a lesser risk than the construction, the ongoing use of the road, particularly in the steeper sections, is still considered to present a high risk of sediment run off. As with any road this risk is highest where the road crosses waterways. This risk includes a high potential for degradation of stream and aquatic habitat integrity.

The risk of both the construction and, in particular, the ongoing use of the South Face Road could be reduced through improvements in maintenance practices, batter design, batter stabilisation and by upgrading the road’s surface adjacent to the major stream crossings. The EMS provides an appropriate framework to deliver these improvements.

The risk of sediment run off from old roads constructed prior to the introduction of the Code and of degraded campsites impacting on water quality is considered high. Maintenance of unsealed roads in this sub-catchment is similar to other areas of State Forest in the Tyers River Catchment. This is discussed further in section 5.12.

Environmental Audit 25 TYERS RIVER CATCHMENT

5.3 River Flats below Tyers Junction

The east, west and middle branches of the Tyers River meet at Tyers Junction. This junction forms a natural division between the upper and lower parts of the catchment

Findings

50. Water quality downstream of this area does not consistently comply with the water quality objectives contained in the Policy. This water quality is influenced by upstream areas, as well as by the land uses and activities on the River Flats below Tyers Junction.

51. Stream bank erosion is considered to be the major source of sediment run off in this sub-catchment. The river flats adjacent to the Tyers River south of Tyers Junction have been cleared and are used to graze cattle, see Photograph 7. In some areas, cattle can directly access streams and banks which causes erosion and increases the risk of elevated turbidity.

Photograph 7 : River flats on Tyers River, illustrating direct cattle access to river

52. Although crown frontage exists on the Tyers River, riparian vegetation is often absent and in some cases streambank erosion is prevalent, particularly below Phillip’s Bridge. The risk of streambed erosion is further elevated because the river is large and has significant erosive power at this point.

53. The relatively flat terrain in this area reduces the risk of sediment run off from surrounding land. Environmental Audit 26 TYERS RIVER CATCHMENT

54. Water quality data for this area is not directly available. However continuous turbidity monitoring is carried out by Gippsland Water a short distance downstream of this area at “Browns” where the Tyers River enters the Moondarra Reservoir. The water quality monitoring results obtained at “Browns” provide an indication of water quality at the downstream end of the river flats below Tyers Junction. However, as the results are influenced by flow from other areas they can not be directly used to assess the risk to water quality associated with land uses and activities on the River Flats below Tyers Junction.

55. Results of turbidity monitoring performed at “Browns” between September 1999 and September 2000 indicated that average turbidity levels were acceptable but that there were frequent intervals of higher turbidity levels. This is indicative of the influence of erosion caused by rain events. As monitoring results from Browns were not available for August 2000 (due to a breakdown in equipment) compliance with the annual percentile objectives contained within the Policy could only be estimated. It is considered likely that water quality at this location complied with the Policy’s annual 50th percentile turbidity objective (5 NTU), but did not comply with the annual 90th percentile turbidity objective (10 NTU).

56. Turbidity monitoring at “Browns” showed frequent short term high levels of turbidity, in excess of the acceptable rise above background in the Policy.

57. Australian Paper Plantations owns several uncleared properties close to the Tyers River, and upstream of the Moondarra Reservoir. Uncleared, these properties do not constitute a risk to water quality. However, at the time of this audit this land was for sale and possible future uses (and risks to water quality) were unknown. This land is covered by an Erosion Management Overlay in the Baw Baw Planning Scheme and hence timber harvesting requires a planning permit and referral of any such application to NRE28. Council officers advised that such an application would also be referred to the Catchment Management Authority and Gippsland Water.

An appropriate framework exists to regulate the management of this land. Combined with the above referral provisions, this consists of requirements to obtain a planning permit and to submit a Timber Harvesting Plan to the Baw Baw Shire Council. These measures will reduce risks to water quality providing that the Timber Harvesting Plan is assessed adequately and is enforced through a Planning Permit. Opportunities to improve this assessment process are discussed in section 6.1.

28 It is noted that this requirement was added to the Baw Baw Planning Scheme in an amendment dated 2 November 2000. Environmental Audit 27 TYERS RIVER CATCHMENT

58. The Mountain Rivers Landcare Group has allocated funding and made an agreement with the West Gippsland Catchment Management Authority to complete stabilisation works on problem stream frontages along the Tyers River over the 2000/2001 summer. This will also involve performing a stream frontage survey to identify further sites needing work. This proposal is considered appropriate.

Risk Assessment

The risk of sediment run off from the River Flats below Tyers Junction impacting on water quality and the beneficial uses identified in the Policy is considered to be low to moderate. Landcare works planned for the 2000/2001 summer have the potential to reduce this risk.

The risk of nutrient run off impacting on water quality and the beneficial uses identified in the Policy is considered low to moderate.

Environmental Audit 28 TYERS RIVER CATCHMENT

5.4 Beynon Creek Sub-catchment

The Beynon Creek sub-catchment is located on the western side of the Tyers River Catchment and feeds the Tyers River West Branch. Most of the land in this sub- catchment is State Forest.

Findings

59. Much of the land is uncleared and is accessible by a network of unsealed roads. NRE are responsible for maintenance of most of the unsealed roads in this part of the catchment. There is an opportunity to for NRE to reduce risks to water quality by improving ongoing maintenance works and programs for the upgrade of old roads to meet standards required by the Code and the Regional Prescriptions29.

60. Beynon Creek Road is an example of a road in poor condition in terms of both trafficability and environmental acceptability (see Photograph 8). The road has been formed from yellow silty clay, which is prone to erosion. Although not located directly next to Beynon Creek it generally runs parallel to the creek and at times runs within only 75 metres of the creek. The road is degraded to the extent that deep wheel ruts and pot holes exist over much of the 4.75 km length of the road. NRE have management responsibility for this road. It is noted that a gazetted seasonal closure of this road does not occur, despite its poor condition.

29 It is noted that the audit methodology involved inspection of only a representative selection of roads, including some that were likely to present a high risk to water quality because of their location. Other unsealed roads exist in this sub-catchment that may present similar risks to water quality. Generic findings and recommendations about roads are presented in section 6.2. Environmental Audit 29 TYERS RIVER CATCHMENT

Photograph 8 : Beynon Creek Road

61. Beynon Creek Road presents a high risk of sediment run off to Beynon Creek, and the fine dispersible silts and clays have the potential to raise turbidity levels in downstream waterways, principally the Tyers River West Branch30. The distance from the road to the Creek may lessen the risk to water quality, however, neither the integrity of this buffer nor the presence of minor tributaries of Beynon Creek alongside the road were investigated.

62. The Tyers River Road31 is a poorly maintained four wheel drive road that runs along the south side of the Tyers River West Branch (and crosses Beynon Creek where it intersects with the Tyers River West Branch). The road is poorly located as, at times, the road surface directly abuts the stream bank, and it is often within 25 metres of the river. This proximity to the river increases the risk of sediment run off from the road affecting water quality. Numerous bog holes also exist along the road which vehicles divert around resulting in a widening of the road.

63. The Tyers River Road is managed by NRE and was gazetted for seasonal closure between 15 June 2000 and 2 November 2000. In the opinion of the auditor, this seasonal closure does not provide a sufficient reduction in the risk to water quality posed by the location of the road and its poor

30 Available water quality monitoring data is not sufficient to determine if sediment run off from the road has affected water quality, however in the opinion of the auditor, water quality impacts are likely given the condition of the road.

31 Some maps also refer to this road as the Western Tyers River Road. Environmental Audit 30 TYERS RIVER CATCHMENT

maintenance.

Risk Assessment

The risk of sediment run off from the Beynon Creek Sub-catchment impacting on water quality and the beneficial uses identified in the Policy is considered to be moderate, principally because of the poorly maintained unsealed roads that are located near waterways.

Environmental Audit 31 TYERS RIVER CATCHMENT

5.5 Hotel Creek Sub-catchment

The Hotel Creek sub-catchment includes Johns Creek and Middle Creek and feeds the Tyers River downstream of Tyers Junction.

Findings

64. The catchment is largely made up of State Forest and agricultural land. The agricultural land includes cattle grazing and potato farming.

65. Short term high levels of turbidity, in excess of the acceptable variation from background in the Policy, have been observed in Hotel Creek at the Telbit Road bridge during storm flow events32. This point is at the bottom of this sub-catchment.

66. Poorly maintained unsealed roads, particularly where they cross waterways are considered to be the major source of sediment run off in this part of catchment. Responsibility for maintenance of most of these tracks lies with NRE.

67. South-west of O’Keefes Road is an example of a poorly maintained four wheel drive track. During the audit, runoff laden with soil was observed running from this track down the slope into the west side of Hotel Creek. No creek crossing structure or sediment controls were in place at this location. Sediment was observed on the creek bed both upstream and downstream of this creek crossing. Photograph 9 shows this creek crossing.

32 Based on observations made during this investigation and grab samples taken by EPA in 1995. Environmental Audit 32 TYERS RIVER CATCHMENT

Photograph 9: Four Wheel Drive track crossing Hotel Creek

68. It was unclear how often the track in Photograph 9 is used, however vehicle tracks observed during the audit suggested recent usage. Given the lack of sediment controls and poor maintenance, any usage of the track is considered to present a high risk to water quality. The road appears to be kept open for recreational four wheel drive use, as well as for fire management purposes.

69. NRE (Fire Management) records show that maintenance works were performed on the length of the four wheel drive track discussed above during 1998/1999. The current condition of the track is an indication that the maintenance works were focused on maintaining vehicle access and do not appear to have addressed potential environmental impacts.

70. From this same track, narrow side tracks were observed which are being used by motor bikes. These tracks displayed ruts and loose soil and are typical of other tracks in the general area. Such tracks, particularly where they are close to waterways and on steep slopes present a high risk of sediment run off.

Environmental Audit 33 TYERS RIVER CATCHMENT

71. There is an annual motorbike enduro which is held in the area which is a potential source of sediment run off. Motorbike use can cause significant damage to tracks and necessitate high levels of maintenance and remedial works. The Gippsland Forest Management Prescriptions refers to such events being conducted in accordance with NRE’s Draft Guideline, Motorcycle Enduros on Public Land. A permit from NRE is required to hold such an event. NRE issued a permit for the event in 2000, but withdrew the permit prior to the event because conditions were too wet.

72. In addition to the annual enduro, the uncontrolled use of such roads by individual motorbike riders and four wheel drivers presents a high level of risk to water quality. It is acknowledged that attempting to restrict the activities of individual motorbike riders is very difficult.

73. Photograph 10 shows an example of sediment run off from a poorly maintained four wheel drive track off Telbit Road following a rain event. A narrow strip of riparian vegetation was observed to be filtering the run off from this track prior to it reaching Hotel Creek. However, the risk off sediment run off from this road affecting water quality is still considered to be high.

Photograph 10 : Sediment run off flowing to Hotel Creek from four wheel drive track off Telbit Road

Environmental Audit 34 TYERS RIVER CATCHMENT

74. An example of a potato farm at the top of this sub-catchment was observed where there were opportunities to improve land management. Fields had been ploughed with furrows running up and down the hill rather than following contours33 or providing grassed strips at intervals across the slope which are recognised best practice measures to minimise erosion. Photograph 11 shows this property. Minimal buffers to watercourses exist at the bottom of the slopes. The intensive land use associated with potato farming is considered to present a higher risk to water quality than that posed by other agricultural land uses in the Tyers River Catchment. It is noted that this particular property is not involved in the Landcare program. Two other potato farming properties exist in the catchment and they are both involved in the Landcare program.

Photograph 11 : Potato farming property at top of Hotel Creek Sub-catchment

33 It is recognised that ploughing across the contour can be difficult or dangerous in some situations and other measures may be more appropriate. Environmental Audit 35 TYERS RIVER CATCHMENT

75. Photograph 12 shows an example of a property where Landcare has assisted with the construction of a weir to minimise erosion. Construction of the weir is regarded as a best practice measure.

Erosion from cattle passing through a gate close to the creek can be observed in the background of the photo, and illustrates ongoing work is needed to further reduce risks to water quality. Such a gate should ideally be located further up the hill, away from the waterway.

Photograph 12 : Example of Landcare works in the Hotel Creek sub-catchment

Risk Assessment

The risk of sediment run off from this part of the catchment impacting on water quality and the beneficial uses identified in the Policy is considered high. This risk is primarily due to the unsealed roads adjacent to and crossing waterways, and to a lesser extent due to cleared agricultural land which is managed in a manner that increases the risk of sediment runoff.

The risk of nutrient run off impacting water quality is considered low.

Environmental Audit 36 TYERS RIVER CATCHMENT

5.6 Jacobs Creek Sub-catchment

The Jacobs Creek sub-catchment makes up the eastern section of the Tyers River catchment. Approximately 7% of the inflow into the Moondarra Reservoir is attributable to the Jacobs Creek sub-catchment (the remaining flow comes from the Tyers River and the land directly surrounding the Reservoir).

Findings

76. Gippsland Water has conducted continuous turbidity monitoring in Jacobs Creek where it enters the Moondarra Reservoir since September 1999. Results between September 1999 and September 2000 show that turbidity levels in Jacobs Creek have exceeded both the 50th and the 90th annual percentiles34 in the Policy.

77. High turbidity levels, that exceeded the acceptable variation from background levels specified in the Policy have been observed at the Bluff Road bridge over Jacobs Creek during peak flow events35.

78. Agricultural land, particularly where its land management could be improved and where it is located in steep terrain, is the main source of sediment run off in this sub-catchment.

79. The majority of land in the Jacobs Creek sub-catchment, particularly above track W32 and Bluff Road, is used for agriculture. This consists of beef cattle grazing and various horticultural uses.

80. The Policy includes this area in Segment B (predominantly forests and forestry activities) rather than in Segment C (mixed forestry and agricultural activities) which would be more consistent with the actual land use. Stricter water quality objectives are set for Segment B and this area was included in Segment B because it is in a water supply catchment (proclaimed under the Land Conservation Act 1970). The Policy recognises that this land needs to managed to a high standard to protect the beneficial use of potable water supply, with treatment (disinfection only).

81. In some areas agricultural land directly fronts waterways and an adequate buffer of riparian vegetation does not exist. This presents a risk to water quality because the vegetation will not allow sediment to settle or be filtered

34 All the monthly 50th percentile values exceeded the yearly 50th percentile objective of NTU. 6 out of 12 of the monthly 90th percentile values exceeded the yearly 90th percentile objective of 10 NTU.

35 Bannon M., Tyers River Catchment Annual Report, Year One, May 2000, pp 14. Environmental Audit 37 TYERS RIVER CATCHMENT

out before reaching waterways. Photograph 13 shows such a property in the Jacobs Creek catchment with uncontrolled stock access to a waterway.

Photograph 13 : Property in Jacobs Creek catchment with uncontrolled stock access to waterway

82. Planned works programs and the development of Property Management Plans are expected to reduce the risk of sediment run off from properties involved in the Landcare program.

Landcare program involvement in the area around the west branch of Jacobs Creek is good, however there are opportunities to involve further landholders and improve representation in the east branch.

83. Steep areas of agricultural land exist at the top of the sub-catchment, some of which have uncontrolled stock access to waterways, hence elevating the risk of sediment run off in the Jacobs Creek sub-catchment. Cattle tracks have been observed on steep slopes, due largely to inappropriate siting of gateways within subdivisional fence lines. Attempts have been made to involve the relevant landholders in the Landcare program, but continuing work is necessary.

84. It is noted that, although programs are planned and have commenced over the last year, the Landcare group has not yet finished any substantial programs to address the risks to water quality in this sub–catchment. This is considered to be because the group is relatively new (formed in February 2000) and is still implementing programs, rather than because of any particular barriers.

Environmental Audit 38 TYERS RIVER CATCHMENT

85. There is a large landslip on a private property adjacent to a tributary of Jacobs Creek that occurred prior to 1994. Photograph 14 shows this property. This would have contributed a large sediment load to Jacobs Creek at the time of the slip. Although the area of the landslip that occurred prior to 1994 has now been stabilised, areas of surrounding land have the potential to slip if not managed properly by individual landowners. This issue is being addressed with landholders through the Landcare Group, although the site where the slip occurred is not yet involved in the Landcare Group. Timelines for completing such works have not yet been established.

estry block on Jacobs Creek. Rehabilitation works have been undertaken with Gippsland Water providing the landholder with materials and the local Landcare Group assisting the landholder to complete the works which involved revegetation and stabilisation of the banks of the Creek. This Landcare driven rehabilitation work resulted in effective stabilisation and is regarded as best practice management of a former Photograph 14 : Landslip in the Jacobs Creek Catchment

86. One sediment run off source was, until recently, a small private forproblem site.

Environmental Audit 39 TYERS RIVER CATCHMENT

87. Old Traralgon Road is an example of a road that requires maintenance and which, although a relatively small source, presents a high risk of sediment run off to Jacobs Creek. Photograph 15 shows this road. NRE are responsible for maintenance of the road (known as W32) in the Boola State Forest to the east of Jacobs Creek. Council are responsible for maintenance of the road from Old Coach Road to a private property entrance. There is lack of ownership of this road on the west side of Jacobs Creek which needs to be resolved36.

Photograph 15 : Old Traralgon Road

88. The prevalence of agricultural land close to waterways warrants further investigation of possible impacts from nutrient run off, pesticide run off and overspray. A detailed investigation of these aspects was not performed as part of this audit as this would require intensive water quality monitoring which includes storm events. Water quality monitoring is not currently undertaken here and an opportunity exists to undertake this through a Waterwatch program.

36 Approximately one year ago, NRE did perform works on this section of the road to divert flow from the surface of the road. However the owner of the adjacent deer farm complained about the run off being diverted onto his property and the works were removed. Environmental Audit 40 TYERS RIVER CATCHMENT

89. Gippsland Water’s monitoring of phosphorus levels at the offtake of the Moondarra Reservoir between June 1999 and June 2000 demonstrated a slight exceedance of the Policy’s annual percentile objectives. These results are not sufficient to directly assess the quality of water and protection of aquatic ecosystems in Jacobs Creek or its tributaries, but justify further investigation.

90. The Boola State Forest borders the downstream half of Jacobs Creek on the western side. A limited amount of forestry activities are occurring here37. As with the rest of the State Forest areas in the Tyers River Catchment, generic issues associated with the maintenance of unsealed roads have the potential to cause sediment run off and impact upon turbidity levels in waterways.

A detailed investigation of the condition of the roads in this area was not performed in this audit. This is a knowledge gap that could be addressed through the recommendations in section 6.2.

Septic tanks

91. The township of Erica is not sewered and run off from septic tanks poses a risk to waterway quality during rainfall due to bacteriological and nutrient contamination38. The town has a population of around 200 people, and the majority of septic tanks are old. The septic tanks are also unlikely to receive sufficient maintenance.

92. Sampling of stormwater discharges from Erica was performed in 1989 and detected high E coli levels 39. Previous studies of other unsewered towns in Victoria have shown similar contamination levels in adjacent waterways40.

93. The Baw Baw Shire Council do not conduct inspections of older septic tanks. Random checks have been done of permitted septic tanks since approximately 1997 at a rate of around 10 tanks per year. However older, unpermitted septic tanks are likely to pose a higher levels of risk to water quality than these tanks.

37 NRE’s 2000/2001 to 2002/2003 Wood Utilisation Plan only identif ies thinning coupes (as opposed to clearfelling coupes) in this area.

38 Some of the stormwater from the town also drains to Hotel Creek

39 These data are over 10 years old and need to be re-evaluated. The data were collected by a student and the sampling and analysis protocols are unknown.

40 EPA, Impacts of Urban Wastewater on the Upper Yarra River and its Tributaries, SRS 92/001, January 1992. Environmental Audit 41 TYERS RIVER CATCHMENT

94. The Baw Baw Shire Council had not, as at September 2000, submitted an annual return regarding septic tanks as required by July each year under section 53O of the Environment Protection Act 1970.

95. The Environment Protection Act 1970, requires permits to be issued for new septic tanks, but does not provide for approvals or inspections of old tanks.

96. The Council does not have an overall strategy for the management or upgrade of older septic tanks in the shire. The development and implementation of a municipal strategy for domestic wastewater which describes council’s overall strategy for managing domestic wastewater is regarded as best practice. Consideration is currently being given to including provisions for such plans in the Environment Protection Act 1970.

97. Rawson has a small sewage treatment plant which has the capacity to treat sewage from Erica. It is approximately 3.5 kilometres from the centre of Erica to the Rawson sewage treatment plant. However, Gippsland Water do not view the connection of Erica to this point as economically feasible at present. Statewide reticulation connections to unsewered towns are currently focused on towns with populations greater than 500 people.

Risk Assessment

The risk of sediment run off from the upper part of the Jacobs Creek catchment fronted by agricultural land impacting on water quality and the beneficial uses identified in the Policy is considered high.

Below W32, most of Jacobs Creek is fronted by public, forested land and the risk of sediment run off impacting on water quality and the beneficial uses identified in the Policy is considered low.

The level of risk to water quality and the beneficial uses identified in the Policy from nutrient run off in this part of the catchment is considered moderate to high. Further investigation is required to more accurately quantify this risk. Influencing the adoption of best practice farming techniques through the Landcare Group and the Catchment Management Authority is considered to have the potential to reduce these risks.

The level of risk to water quality and the beneficial uses identified in the Policy from pesticide run off in this part of the catchment is considered moderate. Further investigation is required to more accurately quantify this risk.

The level of risk to water quality and the beneficial uses identified in the Policy from microbiological hazards is considered high.

Environmental Audit 42 TYERS RIVER CATCHMENT

5.7 Stockyard Creek and Smile of Fortune Creek Sub-catchment

These creeks enter the Moondarra Reservoir at the Tyers River and north of the Jacobs Creek entrance to the reservoir.

Findings

98. Agricultural land, particularly where its management could be improved and where it is located in steep terrain is the main source of sediment run off in this sub-catchment.

99. There are sections of cleared, agricultural land along the Smile of Fortune Creek which are steep and prone to erosion and land slippage. Photograph 16 shows a property in this sub-catchment where erosion of steep land can be seen. A higher than usual standard of land management is therefore required to minimise the risk of sediment run off from these properties41.

Photograph 16 : Property in Smile of Fortune Creek sub-catchment

41 Although a detailed assessment of land management practices on these properties was not conducted as part of this audit, it is noted that no direct evidence of impact on water quality from this land was observed. Environmental Audit 43 TYERS RIVER CATCHMENT

100. Some of this land was cleared over the last 10 years in accordance with a planning permit42. However the Tyers River Water Supply Catchment – Notice of Determination of Land Use 197543 designates that this land was to be retained in an undisturbed state for the protection of watercourses. Because of the provisions of this Notice of Determination of Land Use, the issue of a planning permit to clear the land in this way appears inappropriate.

This land, and other land included in the Notice of Determination of Land Use, is now covered by an Erosion Management Overlay in the Baw Baw Planning Scheme. The overlay requires a permit to be issued by the Planning Authority prior to clearing of vegetation, and specifies criteria to be considered in assessing such an application. Inclusion of this overlay in the Planning Scheme reduces the risk of inappropriate permits being issued in the future. However, a high standard of land management is required for that land that has already been cleared.

101. Landcare involvement is understood to be excellent in the Stockyard Creek sub-catchment, but poor in the Smile of Fortune Creek Sub-catchment44.

Risk Assessment

The level of risk to water quality and the beneficial uses identified in the Policy from nutrient run off and pesticide run off in this part of the catchment is considered low.

The risk of sediment run off from this area of the catchment impacting on water quality and the beneficial uses identified in the Policy is considered moderate45.

5.8 Moondarra State Park

The Moondarra State Park is located in the south west corner of the catchment and drains to the Moondarra Reservoir via Tea Tree Creek and the Tyers River.

Findings

102. Poorly maintained unsealed roads, particularly where they cross waterways are considered to be the major potential source of sediment run off from this area.

42 Bannon M. Tyers River Catchment Annual Report, Year One, May 2000, p 14.

43 Legal advice has been obtained that states that the Notice of Determination of Land Use is still force (and was in force when the land was cleared).

44 Bannon M. Tyers River Catchment Annual Report, Year One, May 2000, p 17.

45 This risk level is dependent on properties in the area continuing to be managed well. Environmental Audit 44 TYERS RIVER CATCHMENT

103. Erosion from Senini’s Track and Ti Tree Road have the potential to contribute to sediment deposition and elevated turbidity in Tea Tree Creek. Water in cut table drains and concentrating within inadequately maintained road surfaces is contributing to the sediment run off.

104. Senini’s Track is the major road in the park and is unsealed. The auditor observed that Senini’s Track is reasonably well maintained up to the east side of Tea Tree Creek, but is poorly maintained after this (further to the west). Parks Victoria are responsible for maintenance of this track46, and roads within the rest of the Park. They reported that maintenance works on Senini’s Track are performed by a contractor such that the drains are cleared approximately every year and the silt traps are maintained every three years. Photograph 17 shows a poorly maintained section of Senini’s Track on the west side of the Tea Tree Creek crossing.

Photograph 17 : Seneni’s Track at Tea Tree Creek

105. Parks Victoria aim to maintain roads within their Parks in accordance with standards adopted from the NRE Regional Prescriptions. Specific maintenance requirements or frequencies for the roads within the Moondarra State Park are not documented and maintenance is performed on an ad hoc basis. NRE’s Regional Prescriptions do not extend to this level of detail.

46 There is some contention within Parks Victoria that the Baw Baw Shire Council should maintain the road up to the private property between Tea Tree Creek and the campsite located on Senini’s Track adjacent to the Tyers River, however Parks Victoria have assumed this responsibility. Environmental Audit 45 TYERS RIVER CATCHMENT

106. Ti Tree Road is an unsealed road adjacent to Senini’s Track which is not actively maintained. Parks Victoria stated that this road had been maintained only once in the last ten years.

107. The Moondarra State Park and Tyers Park Management Plan, May 1991, contains an “ongoing”47 action to restrict the use of Ti Tree Track to management vehicles only. This road is still open to the public and hence this objective has not been met. Continued use combined with poor maintenance of the road presents a high risk of sediment run off.

108. The Moondarra State Park and Tyers Park Management Plan, May 1991, does not incorporate aims or objectives to protect water quality.

109. No water quality monitoring or inspections to assess water quality are carried out within the Moondarra State Park.

110. The campsite located on Senini’s Track adjacent to the Tyers River has a pit toilet which is pumped out periodically. Anecdotal evidence suggests that, the creek level can occasionally rise sufficiently to flood the toilet at the campsite (1 in 10 year storm). There is a low risk of this pit toilet overflowing during flood events and causing faecal contamination of the creek. Moving the toilet may introduce other risks associated with the ongoing use of the campsite, but there is an opportunity to assess other risk reduction measures.

111. Another example of a poorly maintained road in this area was observed on the south west side of the intersection of Senini’s Track and the Moe – Walhalla road. The road is a power line access road which is used by TXU Electricity. It was very rutted and large quantities of deposited sediment were observed in the table drain downhill of the intersection of the access road and the Moe – Walhalla Road. Photographs 18 and 19 respectively show this road and sediment run off from the road on to the Moe – Walhalla Road. TXU Electricity were unable to confirm what, if any, maintenance is performed on this road.

Risk Assessment

The risk of impact on water quality and the beneficial uses identified in the Policy due to sediment run off from this part of the catchment is considered moderate.

47 The Moondarra State Park and Tyers Park Management Plan, May 1991, contains general aims and then specific actions. The priority of “ongoing” is the description used in the Plan. Environmental Audit 46 TYERS RIVER CATCHMENT

Photograph 18 : Poorly maintained TXU Electricity Road

Photograph 19 : Sediment run off from TXU Electricity road onto Moe – Walhalla Road

Environmental Audit 47 TYERS RIVER CATCHMENT

5.9 Land Surrounding Moondarra Reservoir

Approximately 17km2 of land to the north and the west of the Moondarra Reservoir is managed by Gippsland Water and is restricted from public access. Land directly to the east of the reservoir is within the Boola State Forest.

Findings

Local land uses and activities

112. Sediment run off from poorly maintained unsealed roads, and from any future harvesting of pine plantations constitute the main risks to water quality from land directly around the Moondarra Reservoir.

113. Approximately 20% of Gippsland Water’s land around the reservoir has been used to establish pine plantations. The buffer distances between parts of the plantations and waterways (including the reservoir) are not sufficient for the protection of water quality. In some cases the plantations abut the banks of the reservoir. Future harvesting of areas of such plantations is considered to present an unacceptable risk to water quality.

114. The Tyers River Water Supply Catchment Notice of Determination of Land Use, 1975, states that land within 200 metres of the Moondarra Reservoir foreshore is to be left in an undisturbed state for the protection of watercourses, streams and reservoirs. It is noted that the plantations were originally established to reforest areas of former agricultural land around the reservoir, however ongoing harvesting of these plantations is contrary to the Determination.

115. Gippsland Water have documented their intention to perform works to remove immature pine trees close to waterways and ultimately to establish a buffer of native vegetation between the reservoir and the pine plantations. The native vegetation will be excluded from harvesting in the future. This work was planned to commence in Spring 2000. This is considered appropriate, however the use of appropriate sediment controls and management practices will be critical to ensure that the risk of impact on water quality from these works is minimised.

116. The Code of Forest Practices for Timber Production allows plantation trees to be harvested from buffer strips either mechanically or manually. In the opinion of the auditor, mechanically removing plantation trees abutting the edge of the Moondarra Reservoir presents a high risk to water quality, which should be avoided where possible.

117. Poorly maintained unsealed roads within Gippsland Water’s land surrounding the reservoir are considered to present a high risk of impact on water quality due to their condition and their proximity to waterways including

Environmental Audit 48 TYERS RIVER CATCHMENT

the reservoir. Regular maintenance of these roads does not occur. Examples of poorly maintained culverts and road surfaces adjacent to stream crossings were observed on roads to the north of the reservoir.

118. Gippsland Water expressed their intention (to the auditor) to perform maintenance works on these unsealed roads. They intended to commence this work over the 2000/2001 summer and initially focus on maintenance of culverts and silt traps at stream crossings. Although this work had been budgeted for, specific plans for this work had not yet been made and standards of maintenance or road construction had not been determined.

119. The Zoning and Overlay maps in the Baw Baw Planning Scheme do not show the Moondarra Reservoir, but show the former township of Gould and associated roads. Gould was vacated to make way for the Moondarra Reservoir when it was constructed in 1960. The zoning map could be improved to more clearly delineate the land around the Reservoir.

120. An example of a poorly stabilised batter (see Photograph 20) was observed on the east side of the Moe - Walhalla Road opposite the road’s intersection with Senini’s track. As it is a proclaimed main road, maintenance of this road is the responsibility of VicRoads48. This road borders the area of land around the Moondarra Reservoir and potential run off from the batter would enter this sub-catchment. This unstabilised batter presents a high risk of sediment run off affecting water quality.

48 In this case, VicRoads have contracted the actual maintenance activities to the Baw Baw Shire Council. Environmental Audit 49 TYERS RIVER CATCHMENT

Photograph 20 : Batter on Moe – Walhalla Road

121. The poorly stabilised batter referred to above, and a section of road managed by Gippsland Water are believed to have contributed to a high turbidity event (732 NTU) in Seymours Creek which enters the Tyers River directly upstream of the Moondarra Reservoir. This was observed following a rain event in May 200049.

Whole of catchment influences

122. Water quality in the Moondarra Reservoir is influenced by land uses and activities throughout the catchment. Sediment run off, resulting in increased turbidity levels, is the major hazard to water quality in the reservoir. Impacts on water quality have been demonstrated by Gippsland Water’s ongoing need to remove sediment from the water prior to distribution to domestic customers. This included an extreme case in 1995/1996 when their treatment plant failed and turbid water was distributed to these customers.

123. Water quality monitoring results obtained from the outlet of the Moondarra Reservoir between September 1999 and September 2000, were compared with the annual percentile objectives of the Policy. These results demonstrated compliance with the Policy’s annual 50th percentile turbidity objective (5 NTU), and compliance with the annual 90th percentile turbidity objective (10 NTU).

49 Bannon M. Tyers River Catchment Annual Report, Year One, May 2000, p 9 Environmental Audit 50 TYERS RIVER CATCHMENT

124. The beneficial use identified in the Policy, of potable water supply, with treatment (disinfection only) is not protected for water from the Moondarra Reservoir. Gippsland Water manage this impact through their three treatment plants which supply water to domestic users after disinfection and sediment removal. Increased sediment loads can significantly increase treatment costs50.

125. Gippsland Water treat their potable water supply to achieve water with a turbidity of less than 0.1 NTU51. This is cleaner than the in stream water quality objectives of the Policy, and hence treatment would still be required even if the objectives of the Policy were met.

126. Between October 1995 and January 1996, turbidity levels in the Moondarra Reservoir were particularly high and exceeded the objectives of the Policy. Turbidity levels were generally above 10 NTU for the period and during November 1995 remained at around 50 NTU. These elevated turbidity levels were detrimental to the beneficial use of potable water supply with treatment (disinfection only) as they contributed to the failure of a Gippsland Water treatment plant and the subsequent distribution of dirty water to customers in Traralgon.

127. Continuous turbidity monitoring is conducted by Gippsland Water at three locations upstream of the Moondarra Reservoir (see map in Appendix 1). However these monitoring points were only established between September and November 1999. Although regular sampling of water quality upstream of the reservoir was carried out prior to 1991, it was then discontinued. This represents a significant gap in water quality monitoring and presents difficulties in determining the causes of historical instances of poor water quality.

128. There is insufficient water quality monitoring data available to accurately establish the reasons for elevated turbidity levels in the Reservoir during 1995 and early 1996. However it is noted that a number of activities with the potential to increase turbidity levels in the reservoir (in addition to ongoing

50 Gippsland water report that the annual base cost (for turbidity values less than 10 NTU) of their water treatment chemicals across the three potable water treatment plants is $206,000. Increasing the turbidity to between 10 and 20 NTU increases the cost by 20-30%, to between 20 and 30 NTU increases the cost by 30-80%, and to between 30 and 50 NTU increases the cost by 80-110%.

51 Gippsland Water’s turbidity target is consistent with Australian based standards. The Australian Drinking Water Quality Guidelines, 199651, provide a guideline limit of 5 NTU to protect the aesthetic values of drinking water. The Guidelines also state that if disinfection is required, then a turbidity of less than 1 NTU is desirable at the time of disinfection. The Australian Water Quality Guidelines for Fresh and Marine Waters, November 199251, does not contain a guideline value for turbidity in raw water for drinking water supplies and specifies that this should be site specific depending on the amount of chlorine used in the treatment system. Environmental Audit 51 TYERS RIVER CATCHMENT

potential sources such as unsealed roads) occurred prior to this period. These include:

- harvesting of pine plantations close to the banks of the Moondarra Reservoir in land managed by Gippsland Water;

- construction activities on the South Face Road;

- a large landslip on private property in the Jacobs Creek Catchment; and

- poor practices during the harvesting of a private forest coupe in the Upper Tyers.

129. After 1995, Gippsland Water upgraded the water treatment system at their Traralgon treatment plant and reduced the risk of turbid water “breaking through” the plant’s treatment process and impacting on downstream users.

130. Approximately 85% of the water from the Moondarra Reservoir is supplied, untreated, to industrial users. These users treat water to reduce turbidity levels. Discussions with industrial users indicated that treatment costs increased during the period of elevated turbidity levels in 1995 and early 1996. There was a risk that some operations would have to shut down, however this did not eventuate. Industrial water use is a beneficial use identified in the Policy.

131. E coli levels at the outlet of the Moondarra Reservoir have demonstrated minor non–compliance with the objectives of the Policy. It is noted that the objective is strict and requires no variation from background levels, which for E coli is zero. A mean value of 6 organisms per 100 ml was determined by grab sampling at the reservoir outlet performed by Gippsland Water over the period between January 1995 and July 2000.

132. Whilst the E coli levels measured by Gippsland Water in the Moondarra Reservoir are not considered to present an appreciable risk to the use of the water for potable water supply with treatment (disinfection only), they are indicative of contamination further upstream in the catchment (see section 5.6).

133. Phosphorus levels determined by grab sampling at the reservoir outlet performed by Gippsland Water between June 1999 and June 2000 demonstrated slight exceedances of the long term objectives in the Policy. These results are not considered to present a significant impact to the use of the water for potable water supply, but are indicative of influences on water quality further up the catchment (see section 5.6).

Risk Assessment

The risk of sediment run off from the land immediately surrounding the Moondarra Reservoir affecting water quality and the beneficial uses identified in the Policy is considered high. The factors which contribute to this level of risk are Environmental Audit 52 TYERS RIVER CATCHMENT the proximity of this land to the reservoir, the poor condition of the existing roads and the limited buffer between plantations and the reservoir. Improved management of the land surrounding the reservoir would reduce this risk.

The risk of whole of catchment sources of sediment run off impacting on water quality and the beneficial uses identified in the Policy is also considered high.

5.10 Boola State Forest

The Boola State Forest borders the eastern edge of the Moondarra Reservoir. Some of the waterways drain to Jacobs Creek (see section 5.6) and some directly into the reservoir. The main waterway is Horseshoe Creek, which enters the Moondarra Reservoir next to the Jacobs Creek entrance to the Reservoir.

Findings

134. Some harvesting is occurring in the Boola State Forest at present, however no coupes directly adjacent to the reservoir have been harvested. Harvesting has the potential to increase the risk of sediment run off if coupes are located close to the reservoir.

135. In the current Wood Utilisation Plan, the nearest coupe identified for harvesting is over 2 kilometres from the reservoir.

136. The Tyers River Water Supply Catchment Notice of Determination of Land Use 1975, provides for a buffer (from which clearing, felling, log landing and snigging is excluded) of 200 metres around the reservoir and at least 20 metres from other watercourses.

137. The Central Gippsland Forest Management Plan which includes the Boola State Forest has not yet been prepared. However, the Regional Prescriptions state that operations within the Tyers River Special Water Supply catchment will be in accordance with relevant Land Use Determination and hence will require a 200 metre buffer around the reservoir. The Regional Prescriptions also state that NRE will consult Gippsland Water prior to the commencement of harvesting operations in that part of the Boola State forest that drains into the Tyers River water supply catchment.

138. As found in other areas of the Tyers River Catchment, unsealed roads in this area have the potential to cause sediment run off and impact upon turbidity levels in waterways. A detailed assessment of the condition of these roads was not performed during the audit and is a knowledge gap. This could be addressed through the recommendations in section 6.2.

139. The Moondarra Reservoir Road runs along a ridgeline, and any run off from areas south of this road drains downstream of the reservoir.

Environmental Audit 53 TYERS RIVER CATCHMENT

Risk Assessment

The risk of sediment run off from this part of the catchment impacting on water quality and the beneficial uses identified in the Policy is considered low.

5.11 Forestry

Findings

140. Approximately 70% of the land in the catchment is State Forest. However various operational and environmental restrictions exclude significant areas of this land from actual harvesting of timber. Significant portions of State Forest are also used for recreational purposes such as camping and four wheel driving.

Public Land

141. Forest growing, harvesting and associated activities on public land are carried out by private companies under the supervision of NRE. These activities are managed under a multi-tiered management framework which includes State and local standards.

NRE’s management framework is extensive, and documented management systems have been implemented for the activities that NRE oversees in State Forests. Because such systems are in place the audit report discusses forestry activities in detail and reports audit findings and observations over the following three levels:

- environmental performance;

- appropriateness of management systems; and

- implementation of management systems.

The findings and recommendations in this section reflect the principle of continuous improvement. This contrasts with the assessment of some other activities in the catchment such as agriculture where management systems have not yet been implemented.

142. The Code and associated Regional Prescriptions, which provide more detailed and locally relevant prescriptions consistent with the Code, are implemented on public land through conditions in timber removal licences issued by NRE and through a system of forest operator licences.

143. NRE Forest Officers undertake day-to-day supervision of harvesting operations. Regular inspections of operations are undertaken by these staff in order to assess compliance with the Code and the Regional Prescriptions. These inspections were well documented, with Forest Officer’s findings and any directions given to harvesting contractors recorded in a coupe diary. The coupe diary viewed in this audit was detailed and relevant, identifying many Environmental Audit 54 TYERS RIVER CATCHMENT

site specific areas for management of activities to minimise risks to water quality52. Such coupe diaries are considered to be best practice.

144. Prior to clearance being given for a harvesting contractor to leave a coupe, an inspection is undertaken by Forest Officers. This process is documented and recorded on an ‘Operator Coupe Clearance Certificate’53. This certificate includes a checklist which is considered to incorporate appropriate environmental protection standards.

145. NRE’s Forest Management Branch conducts a series of annual audits of compliance with the Code and associated regional prescriptions. One of these audits was witnessed as part of this investigation (see section 5.2). A selection of coupes from each Forest Management Area is audited on a three year rotating cycle. These audits include an assessment of harvesting practices, temporary contractors’ roads, and sections of permanent roads that provide immediate access to the coupes under consideration. The audit protocol is documented and a summary of the results is published54.

146. NRE’s Forest Management Branch audits provide a strong framework to assess the implementation of the Code requirements and enforcement of these requirements by NRE Forest Officers. Use of a multi disciplinary team to perform the audits and publication of the audit outcomes are particular strengths of the program. This audit identified a number of opportunities through which to improve NRE’s future audits. These are detailed in section 6.1.

Private Land

147. Private forestry occurs within the catchment. This consists of pine plantations owned by Gippsland Water (situated around the Moondarra Reservoir), one plantation owned by Australian Paper Plantations and one plantation managed by a smaller, private operator.

148. Management systems (including management procedures, supervision and enforcement) relating to private forestry operations are less comprehensive than those systems in place for forestry operations on public land. There appear to be significant opportunities to reduce the risk to water quality associated with private forestry operations by improving this management framework. However, as there was only a limited amount of private forestry activity occurring within the catchment over the period of the audit, this activity is not considered in detail.

52 The accuracy of the diaries was not assessed as part of this investigation.

53 The accuracy of these clearance sheets was only assessed for one coupe (see section 5.2). These appeared generally accurate.

54 The 1999 summary has been prepared, but has not yet been published. Environmental Audit 55 TYERS RIVER CATCHMENT

149. Forestry activities on private land must be carried out in accordance with the Code, which contains specific requirements for forestry operations carried out on private land. The Code requires operators to submit Timber Harvesting Plans to the responsible authority, in this case the Baw Baw Shire Council, prior to the commencement of harvesting. These provisions of the Code are given force through the Planning and Environment Act 1987.

Baw Baw Shire Council’s inspections of coupes and enforcement of the requirement to submit timber Harvesting Plans require improvement. The Council does not perform inspections of private forestry areas to determine if Timber Harvesting Plans are being submitted, nor does it routinely seek Timber Harvesting Plans. The council reported receiving four Timber Harvesting Plans in 2000. During 2000, the council did not inspect any private forestry operations in the Tyers River Catchment and only inspected one private forestry operation (as a result of a community complaint) in its municipality.

150. The Baw Baw Shire Council does not have the necessary expertise to assess Timber Harvesting Plans, and no training is provided to relevant staff for the assessment of these plans.

Risk Assessment

Findings in previous sections of this report (in particular section 5.2) have contributed to the risk assessment below.

The risk of sediment run off from forestry activities affecting water quality and the beneficial uses identified in the Policy is considered:

- low for actual forestry coupes;

- moderate for unsealed roads that are associated with forestry areas and have been constructed and maintained in accordance with the Code;

- high for older unsealed roads in forestry areas that have not been built or maintained to Code requirements. Most of these roads would be pre Code roads (see also section 6.2); and

- high for the South Face Road.

5.12 Existing roads

151. Run off from existing unsealed roads (including roads in forestry areas) is considered to be the most significant source of elevated in-stream turbidity events caused by sediment run off. This is supported by previous event monitoring55, observations made at stream crossings during this investigation,

55 Bannon M., Tyers River Catchment Annual Report – Year One May 2000. Environmental Audit 56 TYERS RIVER CATCHMENT

and by relevant literature56. The risk of sediment run off affecting water quality and the beneficial uses identified in the Policy is highest where roads cross or run adjacent to waterways.

152. Road maintenance responsibilities are divided as follows:

NRE have three divisions responsible for road maintenance:

- Forestry Victoria maintain roads on public land that are used for forestry access;

- Forest Management maintain roads on public land that are used for recreational purposes such as four wheel driving; and

- Fire Management maintain roads that are used for fire access and management;

Parks Victoria maintain roads in State and National Parks;

Council maintain roads that access private property;

VicRoads maintain proclaimed main roads and highways, except in the Shire of Baw Baw where Council manages the declared roads on behalf of VicRoads; and

Gippsland Water maintain the roads on the land that they manage around the Moondarra Reservoir.

153. There is a network of permanent roads throughout the catchment. The majority of the roads are unsealed roads, although the bulk of the traffic is carried by the sealed roads, namely the Moe-Rawson (Moe-Wahalla) Road and the Tyers-Thomson Valley (Tyers-Thomson) Road.

154. In general, monitoring of unsealed road and track conditions in the catchment (physical appearance of road and adjacent water quality) in order to determine maintenance requirements requires improvement57.

56 Croke J., Managing Sediment Sources and Movement in Forests: The Forest Industry and Water Quality, Nov 1999.

Grayson R.B., Haydon S.R., Jayasuriya M.D.A. and Finlayson B.L., Water quality in mountain ash forests – separating the impacts of roads from those of logging operations. Journal of Hydrology, 150, pp 459-480, 1993.

57 In 1997 an independent review of Ecologically Sustainable Forest Management in Victoria was conducted. The review examined the Statewide systems and procedures in place to ensure Ecologically Sustainable Forest Management which includes the protection of water quality. One of the findings of the review that has not yet been adequately addressed was that “the monitoring of road and track condition on public land is inadequate, leading to risks to water quality. This is particularly the case for those predating the Code of Forest Practices”. This finding also applied to non forestry roads. Environmental Audit 57 TYERS RIVER CATCHMENT

155. In the opinion of the auditor, there are opportunities to further consider minimising environmental impact when setting priorities for road maintenance works.

156. Apart from the Regional Prescriptions which are used by NRE, there are no consistent environmental standards used by agencies that provide detailed guidance on the planning, design and construction of unsealed roads to minimise their impact on water quality. Adequate guidelines or codes of practice that are able to be broadly applied are currently unavailable.

Natural Resources and Environment (NRE)

157. NRE’s Gippsland Region Management Prescriptions for Timber Production and Other Forest Uses, October 1998, applies to construction and maintenance of all roads managed by NRE in State Forest and is not limited to forestry activities.

158. Three year road construction and maintenance plans for each Forest Service business unit that are required by NRE’s Gippsland Region Prescriptions have not yet been completed. Maintenance is generally performed on an “as needs basis” as a result of observations made by field staff. Maintenance requirements are generally based on maintaining access and safety of roads. More frequently used roads gain more attention.

159. NRE’s Gippsland Region Prescriptions require the development of an inventory of permanent roads and tracks. This inventory is required to contain information about the purpose of the road and its maintenance requirements. Each of NRE’s business units have developed an inventory of roads, and commenced documenting road maintenance requirements.

160. NRE’s Gippsland Region Prescriptions require an ongoing program to achieve standards for maintenance of pre-Code non timber utilisation roads and fire tracks. Such roads and tracks require maintenance works that, over time, include surfacing approaches to permanent streams and diverting run off away from permanent stream crossings. A program to achieve these standards has not yet been implemented.

161. Maintenance and retention of road surface material is not discussed in NRE’s Gippsland Region Prescriptions. Prescriptions for road maintenance including standards for road surfacing are discussed, but maintenance and retention of surface material is not. This is particularly important near stream crossings as sediment run off from the surface of roads has a high potential to impact upon water quality.

162. In some areas, there is a lack of agreement as to whether maintenance of particular roads is the responsibility of the Baw Baw Shire Council or NRE (for example, parts of Senini’s Track and Old Traralgon Road). NRE’s Forest Management Plan for the Central Highlands, May 1998 states that NRE, in conjunction with VicRoads and local government, should prepare plans that

Environmental Audit 58 TYERS RIVER CATCHMENT

address the funding and maintenance of roads of mutual interest, including roads that access private property within or adjacent to State Forest. Such plans have not been prepared.

Baw Baw Shire Council

163. The Baw Baw Shire Council’s contracts with road maintenance contractors contain inspection frequencies and standard VicRoads intervention levels for maintenance of unsealed roads. These intervention levels contain objectives (such as retaining the surface of the road and ensuring that culverts and table drains are appropriately maintained) that will reduce sediment run off.

164. The Baw Baw Shire council has developed a Roadside Management Plan, December 1999 which provides broad policies and specific actions for the management and maintenance of roads in the municipality. This contains appropriate aims and actions to minimise sediment run off from roads58.

165. The Roadside Management Plan does not mention a program for assessing, or where necessary, upgrading old roads. This is particularly important in locations such as stream crossings where the environmental risk associated with the road is high.

VicRoads

166. VicRoads only manage sealed roads within the catchment, hence there is a low risk of sediment run off from their roads. Although unstabilised batters on sealed roads still present a risk of sediment run off, this overall risk of run off is still much lower than for unsealed roads. This is due to the obvious advantage of a sealed surface but also because the table drains have a chance to vegetate (and hence filter run off) as the roads are not being graded from time to time.

167. The Tyers-Thomson Valley Road is maintained by VicRoads, and the Moe- Rawson Road is contracted to council for maintenance. Maintenance of Council roads and VicRoads roads is performed using the same intervention criteria, hence there is some duplication with respect to findings.

168. The VicRoads standard contract for routine maintenance, which contains the intervention levels, includes actions to reduce sediment run off from roads.

Other stakeholders

169. Other stakeholders, including private landholders have a responsibility for maintenance of unsealed roads in the catchment. The TXU Electricity road

58 This is a relatively new plan, which has not yet been fully implemented. The implementation of this plan was therefore not assessed as part of this audit. Environmental Audit 59 TYERS RIVER CATCHMENT

discussed in section 5.8 is an example of a poorly maintained road. A system for maintaining these roads does not appear to exist. Gippsland Water also lacks a system or set of standards for maintaining its roads. This is discussed in section 5.9.

170. The draft Central Gippsland Water Quality Management Plan59 states that upgrading road and track drainage throughout the region is a sectoral priority for the period 1998 – 2001, however no programs have yet been initiated.

Risk Assessment

The risk of sediment run off from existing roads impacting on water quality and the beneficial uses identified in the Policy is considered high.

5.13 Agriculture

171. Approximately 10% of the land in the catchment is used for agriculture, and hence its potential for impact across the whole catchment is reduced60. However, the majority of this land is located along Jacobs Creek and the potential for impact on water quality in Jacobs Creek itself is high. This is supported by results of water quality monitoring in Jacobs Creek that do not meet the Policy’s objectives (see section 5.6) and demonstrate the poorest water quality within the catchment. There is also the potential for impact in other areas such as Hotel Creek.

172. The Tyers River Catchment Project is a local project aimed at improved land management and sustainable water quality and quantity within the catchment. The project is being undertaken by one project officer in consultation with a steering committee made up of relevant stakeholders. Its aims were to establish the Mountain Rivers Landcare Group, and to involve all stakeholders in the development of a “whole of catchment” management plan for the Tyers River Catchment. It is a three year project which commenced in April 1999 and is funded mainly by Gippsland Water and the National Heritage Trust. The Project is regarded as having a high potential, and is viewed by the auditor as a best practice which is expected to yield good environmental outcomes61.

The project goes beyond agricultural land, but is the major program in the catchment for delivering improvements to the management of agricultural land.

59 Developed by the West Gippsland Catchment Management Authority, see section 6.5.

60 Of this agricultural land, approximately 80% is used for beef cattle grazing, 10% for potato farming, and the remainder for other uses including vineyards, and deer, sheep and goat grazing.

61 As the project has only been going for around 18 months out of an expected life of three years, there have not yet been substantial on the ground improvements that can be quantified. Environmental Audit 60 TYERS RIVER CATCHMENT

173. The Mountain Rivers Landcare Group was formed in February 2000 and represents approximately 55% of private land within the Tyers River catchment (excluding uncleared land owned by Australian Paper). These properties are in the process of planning and implementing works on their properties to protect water quality, mainly through reducing sediment run off into waterways.

174. Although the Mountain Rivers Landcare Group has begun implementation of appropriate programs, this has not yet been done to the extent of allowing their effectiveness to be assessed during this audit. Apart from highlighting the importance of implementing these systems, this audit has not considered programs to promote best practice management of agricultural activities in further detail.

This contrasts with other activities in the catchment such as forestry where extensive management systems have been implemented and a greater amount of water quality monitoring data is available. This allowed the audit to consider these activities in greater detail.

Risk Assessment

The level of risk to water quality and the beneficial uses identified in the Policy associated with agricultural land, is considered:

- high from sediment run off;

- moderate to high from nutrient run off; and

- moderate for pesticide run off.

These risks are most evident in the Jacobs Creek sub-catchment where a high proportion of land in the sub-catchment is used for agricultural purposes.

6 OBSERVATIONS AND RECOMMENDATIONS

Observations made by the auditor during the course of the audit and opportunities to improve management practices identified during the audit (not necessarily related to assessment against a standard) are presented in this section.

Recommendations to ensure compliance with the Policy, and to enable continuous improvement are also presented. These recommendations build on the audit findings in section 5 and address deficiencies or opportunities for improvement. Some of the recommendations in this section relate to standards or management systems that apply across the State and have relevance beyond the Tyers River Catchment.

The information presented in this section is not intended to be prescriptive, but is intended to add value by suggesting ways of reducing environmental risk, achieving compliance, and continuously improving. Environmental Audit 61 TYERS RIVER CATCHMENT

6.1 Forestry

General Forestry Activities and the Code of Forest Practices for Timber Production

175. The Code applies to forestry activities on both public and private land.

176. The effectiveness of the Code in addressing issues of environment protection is addressed in reviews of the Code that occur approximately every 10 years. The last review process was conducted in 1996. Regional prescriptions are reviewed as necessary. The last revision of the Gippsland Region Management Prescriptions (that apply to Public Land) was in October 1998.

177. In the opinion of the auditor, the provision of water quality performance indicators would greatly improve the Code. Performance indicators for water quality are not incorporated into the Central Highlands Forest Management Plan, the Code or the Regional Prescriptions. These should be drawn from the State environment protection policy (Waters of Victoria).

178. The Code or Regional Prescriptions do not require NRE or contractors to conduct water quality monitoring in drainage lines and streams in logged catchments. In the opinion of the auditor this is a possible improvement as it would allow assessment of the Code’s effectiveness in meeting environmental quality objectives. In addition, the absence of water quality monitoring does not allow poor water quality to be identified as it occurs and contingency plans or remedial actions to be implemented on site immediately.

179. The need for water quality monitoring and performance indicators to evaluate the effectiveness of the Code has also been identified in previous independent reviews of forest management in Victoria. These include:

- An independent review of the Code in 1995 by CSIRO which noted that “observation and measurement (monitoring) of the adequacy of measures to prevent erosion and protect water quality can be used to progressively refine prescriptions such as buffer width, frequency of cross banks on snig tracks etc”62. It also noted that “systematic monitoring of appropriate indicators of environmental goals is required”;

- An independent review of Ecologically Sustainable Forest Management in Victoria conducted in 199763 examined the statewide systems and procedures in place to ensure Ecologically Sustainable Forest Management including protection of water quality. The review

62 The 1996 review of the Code of Forest Practices included an independent review by CSIRO which was completed in 1995. The recommendations of CSIRO’s review were considered by NRE in their production of the current version of the Code. CSIRO Division of Forestry, Review of the Code of Forest Practices for Timber Production – Interim Report, September 1995.

63 Commonwealth and Victorian Regional Forest Agreement (RFA) Steering Committee, 1997. Environmental Audit 62 TYERS RIVER CATCHMENT

recommended that specific indicators for monitoring water quality and stream health are needed, and that Forest Management Plans should include targets for water quality.

180. Water quality monitoring is being completed by NRE’s Forest Science Centre at selected sites for ongoing research purposes (for example to evaluate the effectiveness of varying buffer strip widths). However water quality monitoring is not carried out for the purpose of evaluating Code implementation or environmental performance across forestry (including roads and timber harvesting) areas in general. There is an opportunity to include water quality monitoring as part of the management of all forestry areas. This may not include all streams or coupes, but could include representative points and large forestry areas.

181. In the opinion of the auditor, there is an opportunity for better use of Forest Coupe Plans to establish a coupe layout that will minimise environmental impact. Although the Code considers issues that include water quality when designing the layout of a coupe64, the Code and the Regional Prescriptions are not sufficiently explicit in reflecting concepts such as varying buffer strip widths across a coupe to minimise sediment run off. Existing coupe plans could be expanded to mirror “property management plans” that are commonly used in Victoria for agricultural properties (often as part of Landcare programs). The layout of a coupe could, for example, allow for buffer strip widths above the minimum in areas such as gullies where flows converge and channelling of run off can occur.

Public Land

182. NRE have extensive management systems in place to reduce risks to water quality from forestry activities. These systems are discussed in section 5.11. As a result of this audit, a number of opportunities to further improve and refine these systems were identified.

183. The inspections performed by NRE Forests Officers could, in the opinion of the auditor, be improved by assessing outcomes as well as assessing compliance with the Code and Regional Prescriptions. For example, the inspections do not include direct assessments of impact or potential impact on waterways adjacent to coupes. These inspections could be improved by performing visual assessments of riparian vegetation to look for sediment pathways or channels, by inspecting creeks to look for sediment build up and by performing selective water quality monitoring. This would also provide data on the effectiveness of the Code in providing a sufficient level of environment protection.

184. Maintenance of temporary roads providing access to forestry coupes is the responsibility of the logging syndicate (in this case Syndicated Central

64 The Code provides general guidance on the location of snig tracks to minimise impact. Environmental Audit 63 TYERS RIVER CATCHMENT

Gippsland Logging which is made up of sawmills and Australian Paper) who employ maintenance contractors to perform the work. NRE Forest Officers provide advice on maintenance requirements to the logging syndicate. Neither the logging syndicate nor its road construction contractors perform any inspections or road maintenance during the winter period65. Employing contractors to perform any necessary maintenance works or inspections over the winter period would lessen the risk to water quality from these roads.

185. NRE currently publish information about the intended construction of new forestry roads (and coupes) in Wood Utilisation Plans. Public comment is then invited prior to construction commencing. However, in the auditor’s opinion, the information provided could be expanded to provide greater detail about the environmental issues associated with the construction of a road. The Plans could also be expanded to make the process used to evaluate environmental risk transparent.

186. Future NRE Forest Management Branch audits could be improved by addressing the following points66:

- The audits examine compliance with Code and regional prescriptions only. Like inspections performed by NRE Forest Officers, they do not perform water quality monitoring or specifically assess environmental impacts such as sediment deposition in waterways. Observations are not made beyond coupe boundaries for indicators of possible impacts such as channelised flow through buffer strips. The audits are therefore unable to assess the effectiveness of the Code in providing a sufficient level of environmental protection67;

- The audits do not assess the timeliness of sediment control works and hence the potential for environmental impact at various stages of harvesting. The audits are carried out at the completion of harvesting a coupe and are not performed during preparation or harvesting, or during construction of an access road68. Significant sediment run off may occur

65 Contractors perform works such as cross draining and blocking off the ends of roads at the end of the harvesting season, however no checks on the adequacy of these works are carried out by the contractors or NRE staff during winter.

66 These opportunities for improvement are based upon review of previous published audits and participation in a NRE Forest Management Branch audit of Coupe number 482/501/39 in the Upper Tyers area as part of NRE’s Annual Code Compliance Audit in August 2000.

67 NRE’s lead auditor did indicate that if any particular environmental impact was observed during the course of the inspection, this would be noted in the audit report. Evidence of such observations being recorded was not observed during the sample audit attended as part of this investigation. In the opinion of the auditor, such observations will only be made if inspections of the creek and adjacent riparian vegetation are made part of the audit protocol.

68 Coupe diaries filled out by NRE Forest Officers record any delays in installing works such as silt traps, cross drains or appropriate road surfacing and these diaries are assessed as part of the Environmental Audit 64 TYERS RIVER CATCHMENT

during harvesting operations due to sediment controls being installed after roads are constructed or harvesting commences. An example of a Coupe Diary was viewed that recorded problems with delays in the contractor installing culverts and placing rock on the access track. However these issues were not recorded in the results of the audit;

- In the opinion of the auditor, increasing the number of coupes audited by NRE may help to ensure that all potential issues are identified69. In 1998, 27 coupes were assessed which represented a total of around 4% across the state70. This proportion is considered to be too low. In addition each Forest Management Area is only audited every three years. Expanding the audit protocol to include assessment of coupes during the harvesting phase would provide an opportunity to increase the number of coupes audited and to examine actual harvesting activities as well as the final state of the coupe;

- The findings are not as a matter of course compared with the Operator Clearance Certificates completed by Forest Officers at the end of harvesting. The audit protocol71 states that the auditor should record whether the Operator Clearance Certificate has been completed, but does not explicitly state that the audit should compare the information in the certificate with the audit findings;

audit process. However, if works have been completed satisfactorily by the end of the season, delays will not be recorded in the audit results.

69 In 1997 an independent review of Ecologically Sustainable Forest Management in Victoria was conducted. The review examined the Statewide systems and procedures in place to ensure Ecologically Sustainable Forest Management which includes the protection of water quality. A finding of the review that has not yet been adequately addressed was that the number of coupes audited by NRE may be too small to adequately sample the full range of environmental conditions under which issues may arise.

70 P 6, NRE, Audit of Compliance with the Code of Forest Practices for Timber Production (and Associated Prescriptions) in State Forests of Victoria 1997/1998, December 1998.

71 .P 24, NRE, Audit of Compliance with the Code of Forest Practices for Timber Production (and Associated Prescriptions) in State Forests of Victoria 1997/1998, December 1998. Environmental Audit 65 TYERS RIVER CATCHMENT

- No allowance is made for assessing roads constructed before the Code was published. Principle 5.2.13 of the Audit of Code of Forest Practices - Procedure72 states that permanent roads built after the introduction of the Code should be inspected. Although it is acknowledged that many of the older roads may not comply with the Code, evaluating them would provide an opportunity to assess required programs to upgrade roads to existing standards. NRE’s management of old roads in line with its documented policies73 is a critical issue with respect to risk to water quality.

- Independent auditors from outside of NRE are not involved in the audit process. The audit team is made up of NRE personnel comprising two members with forests expertise, one member with flora and fauna expertise, and/or one member with soils and water expertise. The members with forests expertise are drawn from Forest Management Areas outside of the area being audited and hence do have some, although limited, independence. The inclusion of an auditor from outside of NRE would promote a higher level of independence and provide further opportunities to share new knowledge or ideas as part of the continuous improvement process.

Forestry in the Upper Tyers

187. NRE’s 2000/2001 to 2002/2003 Wood Utilisation Plan identifies coupes to be harvested over the next three years74. Many of the coupes scheduled to be harvested in the Upper Tyers are located near the Tyers River West Branch and Christmas Creek in the vicinity of the South Face Road. Expanded water quality monitoring programs focused on the South Face Road would provide data on any water quality impacts that may result from these harvesting activities.

188. Audit findings in section 5.2 regarding the degradation of road surfaces on areas of the South Face Road could be addressed by the provision of asphalt surfacing for 50 - 100 metres on either side of bridged stream crossings. This would increase the stability of the road surface and reduce erosion. It would also allow the installation of grated road cross drains prior to bridges. These measures would decrease the risk of sediment run off from the road surfaces

72 P 22, NRE, Audit of Compliance with the Code of Forest Practices for Timber Production (and Associated Prescriptions) in State Forests of Victoria 1997/1998, December 1998.

73 Both the Central Highlands Forest Management Plan and the Gippsland Region Prescriptions for timber production and other forest uses refer to processes for the upgrade and maintenance of existing roads.

74 Some of these coupes may not be harvested or may be subject to further restrictions due to NRE’s ongoing studies relating to the protection of the Baw Baw Frog, particularly in areas above 1000 metres. Environmental Audit 66 TYERS RIVER CATCHMENT

at the points where there is the most potential for environmental impact. Figure 1 provides an indicative layout of this concept.

100 metres asphalt surface 100 metres asphalt surface

cross drain cross drain

Figure 1: Indicative layout of asphalt surface works at river crossings

189. Specific recommendations to address other opportunities for improvement on the South Face Road are included at the end of this section.

Private Land

190. There is an opportunity to provide more detailed guidance for private forestry operators than that provided in the Code. This level of guidance is provided on public land by NRE’s Regional Prescriptions. Direct application of the NRE’s Regional Prescriptions to private land is not always appropriate. EPA is co-ordinating the development of a Best Practice Environmental Management Guideline for forestry activities on private land and this is considered appropriate.

191. As there was only a limited amount of private forestry activity occurring within the catchment over the period of the audit, this activity is not considered in further detail. Recommendations are provided at the end of this section based on the management systems and activities that were reviewed as part of the audit.

Environmental Audit 67 TYERS RIVER CATCHMENT

Recommendations – Forestry Agency Responsible

General Forestry Activities and the Code of Forest Practices for Timber Production

6. 1. 1 Include water quality performance indicators and targets in the NRE next revision of the Code, and (for public land) in Regional Prescriptions and Forest Management Plans.

6. 1. 2 Through the Code and (for public land) Regional Prescriptions, NRE require Forest Coupe Plans to incorporate the concept of “whole of coupe planning” to minimise impacts on water quality. This should involve pre planning buffer strip widths and locations of snig tracks on the basis of the layout and drainage features of the whole coupe.

Forestry on Public Land

6. 1. 3 Require logging syndicates to retain road maintenance NRE contractors over the winter period when logging is not occurring, so that adequate inspection and maintenance of these roads can be performed over winter periods.

6. 1. 4 Initiate a program of water quality monitoring for general NRE forestry operations on public land (that covers representative points and/or major areas) within the Tyers River Catchment (see also section 6.5). The results of an expanded South Face Road water quality monitoring program could help to supplement the data obtained.

6. 1. 5 Expand the information included in Wood Utilisation Plans to NRE identify particular environmental issues associated with a planned coupe or a road, and to make the environmental assessment performed by NRE during the planning phase more transparent to the public75.

75 This recommendation applies equally to other areas in Victoria. Environmental Audit 68 TYERS RIVER CATCHMENT

Recommendations – Forestry Agency Responsible

6. 1. 6 Expand the scope of NRE’s Code Compliance Audits to: NRE

- Include qualitative assessment of environmental outcomes.

- Perform water quality monitoring and/or stream bed assessments, or review existing data for the area being audited.

- Audit a portion of the coupes and associated roads while they are being harvested or constructed and assess the timeliness of works to reduce environmental impact.

- Inspect roads built before the Code and assess programs to progressively upgrade these roads.

- Review the number of coupes and permanent roads assessed in each area, to determine if there is a wide and frequent enough selection to adequately identify environmental concerns.

- Involve independent auditors, such as Environmental Auditors appointed under the Environment Protection Act 1970, in the audit teams.

South Face Road

6. 1. 7 Provide asphalt surfacing for 50 – 100 metres on either side of NRE bridged stream crossings on the South Face Road and install grated cross drains prior to bridges.

6. 1. 8 Ensure that site specific Environmental Management Plans are NRE prepared as adjuncts to the EMS prior to the commencement of construction works at the Tyers River West Branch bridge and the Buckles Spur realignment. These plans should be reviewed by Gippsland Water, EPA and the West Gippsland Catchment Management Authority.

6. 1. 9 Expand the existing South Face Road water quality monitoring NRE program as detailed in Appendix 3 and clearly document these requirements in the EMS.

Environmental Audit 69 TYERS RIVER CATCHMENT

Recommendations – Forestry Agency Responsible

6. 1. 10 Upgrade the South Face Road Environmental Management NRE System (EMS) to:

- Improve documentation to clarify the inspection and maintenance regime for major stream crossings, large batters, the road’s surface and pollution controls including silt traps. Areas to address include when silt traps need to be emptied, and requirements for ongoing assessments of the adequacy of their position or frequency. Requirements to cease the practice of cutting holes in the fabric should also be included. - Improve inspection checklists for road maintenance to, for example, require recording of the condition of specific locations of the road or of specific silt traps and to include space to record observations of impact, such us silt build up downstream of silt traps. - Include a contingency plan regarding slumping and collapse of batters. - Specify timelines for implementation of measures such as stabilisation of batters, which should reflect risks to the environment. - Improve documentation of water quality monitoring results including any actions triggered by these results. - Expand the pro forma for site specific Environmental Management Plans. This should include inspection and maintenance checklists, and maps of locations of silt traps and other control devices. - Upgrade systems for reviewing performance of the EMS, including reviewing and addressing any deficiencies in contractor performance reports and in water quality monitoring results.

Forestry on Private Land

6. 1. 11 Inspect private forestry areas to ensure that operators are Baw Baw submitting Timber Harvesting Plans. Shire Council

6. 1. 12 Assess and provide formal feedback on Timber Harvesting Baw Baw Plans. External expertise through NRE or private forestry Shire Council contractors is likely to be required.

Environmental Audit 70 TYERS RIVER CATCHMENT

Recommendations – Forestry Agency Responsible

6. 1. 13 Expedite the development of a Best Practice Environmental EPA Management Guideline for forestry on private land to complement guidance provided by the Code of Forest Practices for Timber Production 1996.

6. 1. 14 Progressively establish a permanent buffer of 200 metres of Gippsland native vegetation around the Moondarra Reservoir from which Water the harvesting of timber is excluded76. Buffers of at least 20 metres should be established around adjacent watercourses. Special precautions to protect water quality during these operations should be developed based on a risk assessment and incorporated in an Environmental Management Plan

6. 1. 15 Perform any future harvesting of pine plantations on Gippsland Gippsland Water’s land in accordance with the Code of Forest Practices. Water Provisions for management of harvesting operations and compliance with the Code (NRE’s Regional Prescriptions could also be used to provide more detailed requirements) should be included in Gippsland Water’s EMS.

76 This is consistent with the Tyers River Water Supply Catchment Notice of Determination of Land Use, 1975. Environmental Audit 71 TYERS RIVER CATCHMENT

6.2 Existing Roads

General

192. A demonstration site to compare methods of road drainage to improve water quality at Sayers Track in the Otway State Forest has been set up by NRE, the Corangamite Catchment Management Authority and Barwon Water.77 This is considered an example of best practice. By surfacing the road with crushed rock adjacent to a stream crossing, providing two extra culverts, and installing a diversion hump with the excess fill, sediment run off to the creek was reduced by 90%.

The NRE office in this area are encouraging a program within its region of identifying and prioritising sections of NRE and council roads in need of works such as those demonstrated at Sayers Track.

193. The North East Catchment Management Authority and NRE have implemented a project to assess public roads within their management area and to identify the extent and locations of water quality impacts from such roads. A prioritised works program was then developed to address roads found to be impacting excessively on water quality. These works included upgrading forest tracks within 100 – 200 metres of stream crossings, as this was identified as a cost effective way of improving downstream water quality. The survey methodology has been documented to assist other areas to assess their forest road network, and is regarded as an example of best practice78.

194. There is an opportunity to implement a program of risk assessment and implementation of cost effective works at high risk locations for all unsealed roads across the catchment. This could be based upon the two examples above.

195. The Australian Road Research Board is currently finalising an environmental chapter to supplement its published Unsealed Roads Manual. This may be a suitable basis for the development of best practice guidelines for the planning, design, and construction of unsealed roads to minimise their potential for impact on water quality.

77 Gary Sheridan, personal communication. Forest Science Centre, NRE, September 2000.

78 NRE, North East Catchment Management Authority, Implementation of North East Water Quality Strategies on Public Land. Upper Murray Roads; Water Quality Survey Methodology, August 2000. Environmental Audit 72 TYERS RIVER CATCHMENT

196. NRE’s Powelltown office has successfully implemented the use of “detention holes” in their table drains prior to culvert openings to allow sediment to settle out. These are easier to clean out than the culvert openings. This concept may have some value on the South Face Road and other roads in the area. See Figure 2 below.

Water flow down table drain

detention hole

culvert opening

Figure 2: Indicative layout of table drain with detention hole prior to culvert entrance

Natural Resources and Environment

197. NRE’s Draft Guideline, Motorcycle Enduros on Public Land provides a good framework, but in the auditor’s opinion could be improved in order to provide a higher level of protection to water quality. The draft guideline advises that where creeks are crossed they should be crossed at 90 degrees to the bank, however it does not discourage the crossing of waterways. The guideline provides no requirement for a risk assessment to be undertaken to evaluate the risks to water quality associated with a particular area or route.

Parks Victoria

198. Parks Victoria’s road construction and maintenance standards are adopted from NRE Regional Prescription standards79.

199. Management plans have been published for both the Moondarra State Park, in May 1991, and the Baw Baw National Park, in September 1992. These plans contain broad aims and actions regarding vehicular access to the parks. Maintenance of roads to protect water quality is not mentioned in either of the plans.

200. The section on vehicular access and road maintenance in the Moondarra State Park and Tyers Park Management Plan, May 1991, could be expanded to specifically identify water quality as an aim.

79 NRE, Gippsland Region, Management Prescriptions for Timber Production and Other Forest Uses, October 1998, Appendix 2. Environmental Audit 73 TYERS RIVER CATCHMENT

201. Parks Victoria does not have documented inspection and maintenance requirements for specific roads within the catchment.

VicRoads

202. The VicRoads standard contract for routine maintenance, which contains the intervention levels, includes actions to reduce sediment run off from roads. However the document could be improved by including specific actions for contractors to inspect stream crossings and other high risk areas for sources of sediment run off. This could include inspections for visible impacts on waterways and banks due to sediment run off80.

Baw Baw Shire Council

203. The Baw Baw Shire Council’s contracts with road maintenance contractors could be improved by specifically mentioning an objective of minimising sediment run off from roads and maintenance of sediment controls (such as silt fences).

204. The Baw Baw Shire Council’s Roadside Management Plan, December 1999, could be improved by noting the importance of road surface construction and maintenance in minimising sediment run off.

80 Although many of the actions in the document are intended to maintain the road from a safety perspective, schedule 750.A05 titled Safety Inspections, still provides for general inspections looking at particular aspects of safety. Such a requirement could be included for key areas of potential environmental impact. Environmental Audit 74 TYERS RIVER CATCHMENT

Recommendations – Existing Roads Agency Responsible

Catchment wide recommendations

6. 2. 1 Perform an audit of all unsealed roads within the NRE, Parks Victoria, catchment to determine their condition, Baw Baw Shire environmental risk, ownership and ongoing need. Council, Gippsland Critical locations such as where road lines run Water, West adjacent to, or cross, waterways should be Gippsland identified and targeted for works such as gravelling Catchment stream approaches or providing mitre drains. Management Authority.

6. 2. 2 Develop and implement prioritised road upgrade NRE, Parks Victoria, programs based on the above risk assessment. This Baw Baw Shire should focus on the upgrade of road surfaces and Council the provision of sediment control structures at points adjacent to streams including stream crossings.

It may be necessary to close and revegetate roads that are poorly maintained or pose a particularly high risk of sediment run off (eg some NRE roads in the Hotel Creek area).

6. 2. 3 Formalise and document specific inspection and Parks Victoria, NRE maintenance requirements for roads within the and Gippsland catchment controlled by Parks Victoria, NRE and Water Gippsland Water. Priority needs to be given to sections of road adjacent to and crossing waterways.

Specific management system recommendations

6. 2. 4 Prepare a Best Practice Environment Management EPA Guideline for the design, construction and maintenance of unsealed roads81.

6. 2. 5 Incorporate aims and actions to protect water Parks Victoria quality in the Moondarra State Park in Parks Victoria’s business plans or the next revision of the Moondarra State Park and Tyers Park Management Plan, May 1991.

81 This is included in the draft Central Gippsland Water Quality Management Plan (action AL2) with NRE nominated as the lead agency. It is important to ensure that any such guideline is applicable to and relevant for all stakeholders responsible for road maintenance. EPA may also be able to co-ordinate the preparation of such a document. Environmental Audit 75 TYERS RIVER CATCHMENT

Recommendations – Existing Roads Agency Responsible

6. 2. 6 Formally agree on responsibilities for the NRE and the Baw maintenance of roads, particularly those that access Baw Shire Council private property within or adjacent to State Forest, to ensure that there are no ‘orphan’ roads within the catchment. 6. 2. 7 Baw Baw Shire Council expand their Roadside Baw Baw Shire Management Plan to include a program (with Council timelines) for assessing, or where necessary, upgrading old roads. This is particularly important in locations such as stream crossings where the environmental risk associated with the road is high.

6. 2. 8 That the VicRoads standard contract covering VicRoads routine maintenance82 be expanded to include reference to identifying potential sources of sediment run off during routine inspections. This is particularly applicable to high risk areas such as those adjacent to stream crossings.

6. 2. 9 Finalise NRE’s Draft Guideline, Motorcycle Enduros NRE on Public Land and include actions to protect water quality such as discouraging waterway crossings and to require a risk assessment to ensure the risks to water quality associated with a particular area or route are minimised.

Specific roads

6. 2. 10 Perform maintenance works to minimise sediment TXU Electricity run off from the TXU Electricity access track on the south west side of the intersection of Senini’s Track and the Moe – Walhalla road, and implement a documented maintenance program for this road and other electricity line access roads.

6. 2. 11 Assess the ongoing need for the Tyers River Road NRE and give consideration to permanently closing and rehabilitating the road to form a walking track.

6. 2. 12 Minimise sediment run off from Beynon Creek Road NRE by performing works to upgrade and maintain the Road in accordance with NRE’s Regional Prescriptions.

82 VicRoads, Standard Contract Section 750 – Routine Maintenance, July 1999. Environmental Audit 76 TYERS RIVER CATCHMENT

Recommendations – Existing Roads Agency Responsible

6. 2. 13 Implement road closures and rehabilitation works in Parks Victoria accordance with the Moondarra State Park and Tyers Park Management Plan, May 1991.

Environmental Audit 77 TYERS RIVER CATCHMENT

6.3 Agriculture

205. The Mountain Rivers Landcare Group was formed in February 2000 and represents approximately 55% of private land within the Tyers River catchment (excluding uncleared land owned by Australian Paper). This percentage is likely to increase given the local enthusiasm for this program.

206. Continued implementation of this program and the completion of further water quality monitoring in agricultural areas provide opportunities to reduce risks to water quality from agricultural land.

Recommendations – Agriculture Agency Responsible

6. 3. 1 That the Landcare project being implemented in the Mountain Rivers catchment continue and receive the support of all Landcare Group stakeholders.

6. 3. 2 Co-ordinate the assessment and ranking of farm West Gippsland management practices as a supplement to water quality Catchment monitoring83 (see also section 6.5 regarding water quality Management monitoring). Authority

6. 3. 3 Consult to develop a joint strategy to motivate all Mountain Rivers landholders to join the Landcare group. Landcare Group, West Gippsland Catchment Management Authority and EPA

6. 3. 4 Initiate a Waterwatch program, involving local landholders, West Gippsland to identify sources of high sediment runoff in the top half of Catchment the Jacobs Creek catchment so they can be managed. Management Authority and Gippsland Water

6. 3. 5 Initiate a Waterwatch program, involving local landholders, West Gippsland to identify sources of nutrients and pesticides in the top Catchment half of the Jacobs Creek catchment so they can be Management managed. Discussion with landholders through the Authority and Landcare Group would also be a useful way of assessing Gippsland Water pesticide usage rates and application of best practice.

83 Such a project has been carried out before, see Go Mark Foods Pty Ltd, Labertouche and West Jindivick Catchment Sustainability Report, 14 July 2000. Environmental Audit 78 TYERS RIVER CATCHMENT

6.4 Other Land Uses and Activities

207. Recommendations to address opportunities for improvement at the O'Sheas Mill Site Camping Area (section 5.1), the Moondarra State Park (section 5.8), and at Erica (section 5.6) are listed below.

208. For small towns such as Erica, the utilisation of a common effluent drainage system, feeding an artificial wetland to provide treatment of stormwater run off, is a way of reducing the risk to water quality posed by old septic tanks and small blocks that are unable to retain wastewater on site. This is a partial risk reduction measure that is cheaper than connection to sewer.

Recommendations - Other land uses and activities Agency Responsible

6. 4. 1 That bank stabilisation works are performed at the O’Sheas Parks Victoria Mill Site Camping Area to minimise the risk of sediment run off.

6. 4. 2 That a prog ram of turbidity monitoring is undertaken Parks Victoria upstream and downstream of the O’Sheas Mill Site Camping Area.

6. 4. 3 Assess risk to determine if flood protection works, such as Parks Victoria walls, are required for the pit toilet at the Senini’s Track campsite (see section 5.8).

6. 4. 4 Perform a short term program of E coli testing of stormwater Baw Baw Shire in the vicinity of Erica to evaluate the risk of contamination Council of the reservoir from septic tank run off around Erica.

6. 4. 5 Develop a wastewater management plan for the township of Baw Baw Shire Erica which identifies options, costs, priorities and Council (as well timelines for improved wastewater management for areas as Gippsland which can not contain wastewater on site. This could Water, EPA and involve connection of Erica to the Rawson sewage treatment landholders) system, and/or the provision of an artificial wetland for Erica.

Environmental Audit 79 TYERS RIVER CATCHMENT

6.5 Overall Catchment Management

West Gippsland Catchment Management Authority

209. The Tyers River Catchment falls within the area managed by the West Gippsland Catchment Management Authority (WGCMA). Strengths of the WGCMA’s water quality management program include its strong interaction with the regional community through five geographically based management groups and its appointment of a water quality co-ordinator.

210. The following opportunities to further strengthen the WGCMA’s co- ordination of water quality management activities were identified:

- make further use of quantifiable performance indicators and targets with respect to water quality;

- finalise and implement the draft Central Gippsland Water Quality Management Plan;

- provide further formal links between the strategies and programs of other stakeholders with catchment wide management responsibility (NRE, Baw Baw Shire Council, Gippsland Water).

211. The Catchment and Land Protection Act 1994 requires the development of regional catchment strategies which, among other information, must specify procedures for monitoring the implementation of the strategy and assessing its performance. The Regional Catchment Strategy, June 199784, contains performance measures which involve aspects such as the provision of progress reports.

212. Further opportunities exist for the development and reporting against quantifiable performance measures in the Regional Catchment Strategy. As well as water quality measures such as decreased turbidity, these could include measures such as the adoption of improved management practices, index of stream condition assessments, or increased amounts of riparian vegetation.

213. The draft Central Gippsland Water Quality Management Plan 85 was released for public comment in 1996, and remains in draft form86. The Policy

84 Developed by the WGCMA’s predecessor – the West Gippsland Regional Catchment and Land Protection Board. This strategy is under review.

85 This plan is a detailed water quality management plan that specifically targets improved water quality and sits beneath the overall Regional Catchment Strategy.

86 The document is still a working draft and has been updated a number of times since 1996. It is also noted that a number of other Catchment Management Authorities are also in this situation. Environmental Audit 80 TYERS RIVER CATCHMENT

refers to the WGCMA’s Water quality management strategy as the major instrument for the achievement of the Policy’s objectives. Finalisation of the plan would allow for improved tracking of progress towards implementation of the Policy

214. Finalisation of the draft Central Gippsland Water Quality Management Plan would also provide further direction and certainty for landholders and other stakeholders regarding actions to improve water quality, and would assist these stakeholders in the development of their own strategic plans and allocation of resources.

Tyers River Catchment Project

215. The Tyers River Catchment Project provides a high level of information on which to base decisions as to where funding for Landcare works or WGCMA stream restoration works is best spent. There is an opportunity to more strongly link the project with the WGCMA’s ongoing overall catchment strategies and business plans.

Baw Baw Shire Council

216. The Baw Baw Shire Council does not have an overall environment strategy or equivalent objectives contained within a management plan or system. Environmental objectives and strategies are contained within the Baw Baw Planning Scheme and the Victorian Planning Provisions, however detailed plans are only provided in relation to the council’s statutory planning decisions.

The Baw Baw Planning Scheme contains a five year plan of action (from December 1998) which includes a proposal to prepare a Shire Wide Environment Strategy. This action is supported and should be high priority.

Land Capability Information

217. The Tyers River Water Supply Catchment Notice of Determination of Land Use 1975 was made under the Soil Conservation and Land Utilization Act 1958, and was kept in force as a Special Area Plan by the Catchment and Land Protection Act 1994. This document is still a legal requirement, and its requirements have been incorporated into the Baw Baw Planning Scheme.

218. The Notice of Determination of Land Use identifies areas of land from which certain land uses or activities should be excluded or performed on a restricted basis for the protection of water quality. These areas are based on land capability ratings which include considerations such as soil type and slope. Although the Notice of Determination of Land Use is approaching 30 years old, its recommendations regarding land management have not been replaced by any more up to date assessments and its requirements still apply.

219. There is an opportunity for NRE to clarify and better publicise and the role of its land capability assessment resources. This is based upon the following: Environmental Audit 81 TYERS RIVER CATCHMENT

- Staff from various areas of NRE were interviewed to determine the current status of the Notice of Determination of Land Use. No information was available.

- The Notice of Determination of Land Use formed the basis of the Erosion Management Overlay (EMO) in the Baw Baw Planning Scheme. Council Officers interviewed were unaware of the Notice of Determination of Land Use and hence some of the detail behind the EMO87. It is noted that an amendment to the Baw Baw Planning Scheme dated 2 November 2000, requires that applications “proposing or involving earthworks or native vegetation removal” within an EMO must be referred to NRE.

- NRE’s Regional Prescriptions identify areas in the Tyers River Catchment to be excluded from forestry activities for the purpose of water supply catchment protection and does so by referring to the Notice of Determination of Land Use. The Notice of Determination of Land Use is not included as an Appendix to the Prescriptions, nor is the document readily available from NRE offices.

- Relevant staff at the West Gippsland Catchment Management Authority were not aware of the Notice of Determination of Land Use, or if there was other land capability information provided by NRE.

Recommendations – Overall Catchment Management Agency Responsible

6. 5. 1 Finalise and implement the Central Gippsland Water West Gippsland Catchment Quality Management Plan. Management Authority and EPA

6. 5. 2 Develop specific water quality performance measures West Gippsland Catchment to include in the Regional Catchment Strategy and the Management Authority and Central Gippsland Water Quality Management Plan. EPA This could include indirect measures such as the rate of adoption of best practice land management techniques, index of stream condition assessments, and the extent of riparian vegetation.

6. 5. 3 That formal links are established between the West Gippsland Catchment WGCMA’s business plan and catchment strategies and Management Authority the Tyers River Project.

87 As no recent permit applications for land clearing in the catchment had been lodged with the council, this process was not able to be assessed. It was noted that the Council Officers interviewed were not aware of the Land Use Determination and hence some of the detail behind the Erosion Management Overlay. Environmental Audit 82 TYERS RIVER CATCHMENT

6. 5. 4 The Baw Baw Shire Council develop and implement a Baw Baw Shire Council Shire Wide Environmental Strategy.

6. 5. 5 That NRE clarify and further publicise its role with NRE regard to the assessment of land capability.

Environmental Audit 83 TYERS RIVER CATCHMENT

6.6 Catchment-wide Water Quality Monitoring

Gippsland Water’s Program

220. Gippsland Water performs the majority of the water quality monitoring in the catchment. This monitoring is performed to detect impacts upon water quality that may affect supply of water to domestic and industrial customers.

As with monitoring performed elsewhere in the State as part of the Victorian Water Quality Monitoring Network, the monitoring is conducted at representative points to determine overall water quality. It is not intended to detect impacts from, or measure the performance of particular land uses or activities.

221. Gippsland Water’s catchment monitoring program is (through involvement in the Tyers River Catchment Project) more extensive and proactive than may otherwise be expected of a water supply organisation.

222. Maintenance of Gippsland Water’s continuous turbidity meters throughout the catchment is not systematic or documented. Gradual build up of growth on the probes has the potential to result in false, unreliable turbidity readings.

223. Gippsland Water have an environmental management system for part of their sewage treatment operations which could be used as a framework to incorporate provisions for the management of general water quality monitoring around the catchment. Assessment of the adequacy of this existing environmental management system was beyond the scope of this audit.

Gaps in existing programs

224. There is a lack of detailed water quality data in the middle and upper catchment. In particular, monitoring within the Jacobs Creek Sub-catchment is not currently sufficient to accurately establish the causes of high sediment loads in Jacobs Creek. In particular, storm event sampling is needed to identify sources of run off.

Co-ordination of monitoring

225. Although Gippsland Water has sites at three locations upstream of the Moondarra Reservoir (see map in Appendix 1). The Victorian Water Quality Monitoring Network (being implemented locally through the Gippsland Water Quality Network) does not have any sites to monitor the general condition of water within this catchment. It is noted that there is a lack of consistency with sampling programs and protocols used in the Tyers River Catchment compared with elsewhere in the State.

226. Findings and recommendations that individual stakeholders monitor the impacts of their own land uses and activities have been included throughout Environmental Audit 84 TYERS RIVER CATCHMENT

this report. There is an opportunity for these stakeholders to share information and responsibility for monitoring through becoming involved in the Gippsland Water Quality Network as partners.

Recommendations – Water Quality Monitoring Agency Responsible

6. 6. 1 That the three upstream water quality monitoring Gippsland Water, points88 used by Gippsland Water be formally West Gippsland included in the Gippsland Water Quality Catchment Agreement. In doing so the list of parameters Management sampled should be expanded to include pH, Authority, NRE nutrients, dissolved oxygen, electrical conductivity, and suspended solids89. An additional monitoring point at the downstream end of Tyers Junction should also be included in the program.

6. 6. 2 Formalise and document requirements for Gippsland Water maintenance, calibration and documentation of results of Gippsland Water’s turbidity monitoring devices.

6. 6. 3 Ongoing water quality monitoring be performed in West Gippsland the agricultural sub-catchments (particularly Catchment around Jacobs Creek) with landholder involvement Management through a Waterwatch program. This should be Authority aimed at identifying sources of contamination and at tracking improvements in water quality.

6. 6. 4 That the West Gippsland Catchment Management West Gippsland Authority co-ordinate a water quality monitoring Catchment program within the catchment through a Management partnership agreement under the Gippsland Water Authority Quality network.

88 These monitoring points consist of (1) Tyers River at the entrance to the Moondarra Reservoir “Browns”, (2) Jacobs Creek at the entrance to the Moondarra Reservoir, and (3) Tyers River West Branch upstream of Tyers Junction at “Morgans”.

89 Suspended solids are recommended to provide data to establish a relationship between turbidity loads and suspended solids concentrations in the catchment. Environmental Audit 85 TYERS RIVER CATCHMENT

7 CONCLUSIONS

Audit Findings

The following land uses and activities (in no order of priority) were identified as having a high risk of localised or more general impact on water quality due to sediment run off:

· agricultural land around Jacobs Creek;

· existing unsealed roads throughout the catchment;

· construction and, to a lesser extent, use of the South Face Road; and

· pine plantations and a network of poorly maintained unsealed roads located on Gippsland Water land around the Moondarra Reservoir.

Risk levels were determined by assessing the risk of the Policy’s objectives being breached or of the beneficial uses identified in the Policy being compromised. The assessment was carried out for all waterways within the catchment, consistent with the areas protected by the Policy, and did not focus on the downstream point of the catchment where the Moondarra Reservoir is located. Potential impacts of sediment run off varied across the catchment. At the top of the catchment, the primary potential impacts were on aquatic invertebrate life due to coarse sediment deposits and/or short term elevated turbidity levels. At the bottom of the catchment, the main potential impact of sediment run off was treatment costs associated with potable water supply.

Turbidity levels in some areas of the catchment met the Policy’s long term objectives, however some areas of non compliance were observed. Turbidity levels at “Morgans” in the upper catchment met the Policy’s annual 50th and 90th percentile objectives. At “Browns”, on the Tyers River where it enters the Moondarra Reservoir, turbidity levels complied with the annual 50th percentile objective in the Policy, but not the 90th percentile objective. At the downstream end of Jacob’s Creek, where it enters the Moondarra Reservoir, turbidity levels exceeded both annual percentile objectives of the Policy. These impacts on Jacobs Creek were most likely due to run off from agricultural land and to a lesser Environmental Audit 86 TYERS RIVER CATCHMENT extent, unsealed roads. Turbidity levels at the outlet of the Moondarra Reservoir met both of the Policy’s annual percentile objectives.

Some land uses and activities, for example timber harvesting in State Forest, have extensive management systems in place to minimise risks to water quality. In the case of timber harvesting, the existence of this comprehensive management framework allowed the auditor to complete a detailed assessment of these systems and their implementation. This management framework contrasts with a lack of management systems in place for some other land uses, such as agriculture, where although management systems are under development they are not yet implemented and therefore could not be audited. This difference is reflected in the environmental audit report which presents detailed findings and recommendations in relation to timber harvesting in State Forest, consistent with the principle of continuous improvement. In the case of agricultural land the environmental audit report simply states that systems are required.

Observations and Recommendations

Environmental Audit 87 TYERS RIVER CATCHMENT

To ensure ongoing compliance with the Policy and sustainable use of the catchment, the following key actions are recommended:

· further development of the strategic management framework so that significant risks to water quality are effectively managed;

· application of an improved water quality monitoring program that will detect problems, and that will provide reliable data on which action can be based;

· provision of adequate guidance for the management of unsealed roads, and the development of a prioritised program to address areas which pose a high risk to water quality;

· continued development and implementation of the South Face Road Environmental Management System;

· inclusion of assessment of environmental outcomes in NRE’s supervision and auditing of forestry activities;

· finalisation and implementation of the draft Central Gippsland Water Quality Management Plan;

· continued development of the Landcare group; and

· inclusion of objectives and procedures for the management of land around the Moondarra Reservoir in Gippsland Water’s Environmental Management System.

SCOTT EDWARD MALONEY

ENVIRONMENTAL AUDITOR

Environmental Audit 88 TYERS RIVER CATCHMENT

8 REFERENCES

Australian and New Zealand Environment and Conservation Council, Australian Water Quality Guidelines for Fresh and Marine Waters, November 1992

Bannon M., Tyers River Catchment Annual Report – Year One May 2000

Bren L., Controlling Sediment and Nutrient Movement within Catchments, October 1997

British Colombia Ministry of Forests, Forest Road Engineering Guidebook, August 1995

Commonwealth and Victorian Regional Forest Agreement (RFA) Steering Committee, Victorian Statewide Assessment of Ecologically Sustainable Forest Management, 1997

Croke J., Managing Sediment Sources and Movement in Forests: The Forest Industry and Water Quality, November 1999

CSIRO Division of Forestry, Review of the Code of Forest Practices for Timber Production – Interim Report, September 1995

Department of Conservation Forests and Lands, A Permanent Road Network for the Ash and Associated Mixed Species Forests of the Central Highlands and Eastern Strzeleckis. Internal Technical Report, May 1988

Department of Conservation Forests and Lands, Discussion Paper Processes for Development of Timber Harvesting Plans Central Highlands Roads, October 1989

EPA, Impacts of Urban Wastewater on the Upper Yarra River and its Tributaries, SRS 92/001, January 1992

Friends of Baw Baw National Park, Issues Concerning the Upper Tyers River Catchment and the South Face of the Baw Baw National Park, July 2000

National Health and Medical Research Council & Agriculture and Resource Management Council of Australia and New Zealand, Australian Drinking Water Quality Guidelines, 1996

NRE, Gippsland Region, Management Prescriptions for timber production and other forest uses, October 1998

NRE, Audit of Compliance with the Code of Forest Practices for Timber Production (and Associated Prescriptions) in State Forests of Victoria 1997/98, December 1998

NRE, North East Catchment Management Authority, Implementation of North East Water Quality Strategies on Public Land. Upper Murray Roads; Water Quality Survey Methodology, August 2000

State Forests of New South Wales, Forest Practices Code Part Four. Forest Roads and Fire Trails, February 1999

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APPENDIX 2 – RESULTS OF RAPID BIOLOGICAL ASSESSMENT OF STREAMS IN THE SOUTH FACE ROAD AREA - JULY AND AUGUST 2000 Dr David Robinson – EPA, Freshwater Sciences.

Background

I had previously visited this area on 27 July 1999. At that time the road had just been put through to the Tyers River West Branch and construction of the bridge over Christmas Creek had just started. In the year 2000 I visited the area on two occasions, the first was 13 July 2000 and the second was 16 and 17 August 2000. The bridge over Christmas Creek had been completed but the road had still progressed no further than the Tyers River West Branch.

On my first visit (27 July 1999) I collected biological samples in the Tyers River West Branch upstream and downstream of the roading activities. Because of the nature of the terrain in the Tyers River West Branch downstream of the roading I was not satisfied that the downstream location that I used then could be used for future assessment of roading activities for the following reasons:

- The nature of the terrain just downstream of where the road comes to the Tyers River West Branch is such that it would be unsafe for regular access for sampling;

- The nature of the stream is not comparable to the upstream location and would be extremely difficult to obtain representative samples under any flow conditions; and

- The downstream point was too close to the future road crossing and would probably not pick up much of the runoff from road works.

For these reasons I sought to investigate, on 13 July 2000, a possible sampling site at the end of Grey Gum Track which brings one to within about a 100 metres of the stream at a point that is about 1 kilometre downstream of the future road crossing over the Tyers River West Branch. This I feel is about the right distance for assessment of impact. The Tyers River West Branch at the end of Grey Gum Track is comparable to the upstream sampling location and although difficult to work in, sampling is still quite feasible.

For the purpose of making a preliminary assessment of possible impacts from the roading activities I collected biological samples from the upstream location on the Tyers River West Branch and from the downstream location at the end of Grey Gum Track on 13 July 2000. I also recorded observations on the nature of the substrate at each location using the standard stream habitat assessment sheets. On 16 and 17 August 2000 I also collected biological samples and recorded observations on the nature of the habitat at Christmas Creek and Growlers Creek. At both of these locations I took samples upstream and downstream of the South Face Road crossing. The downstream locations were about 200 metres downstream of the road crossing at both Christmas Creek and Growlers Creek. Aquatic macroinvertebrates were collected using EPA’s rapid bioassessment Environmental Audit 91 TYERS RIVER CATCHMENT

(RBA) technique from the Tyers River West Branch, Christmas Creek and Growlers Creek. One kick sample of the benthic habitat was collected at each location except for Christmas Creek where we collected two kick samples at each location. Littoral habitat was not sampled because the very fast flowing nature of the streams means that there is little of this habitat available for sampling.

Observations of the stream habitat

Tyers River West Branch

Upstream: The stream is a large, (mean stream width 6 metres) steep gradient cascading stream surrounded by dense Nothofagus forest. The bed of the stream is typically large boulders and bedrock. Current velocities are generally very high and could be described as mainly torrent and cascade with small areas of riffles and runs. Upstream of the roading activities there are suitable runs and riffles for sampling. The substrate in these areas is typically small to large cobbles (up to 20 cm diameter). The cobbles are fairly loose and easily dislodged whilst sampling, there was very little fine material amongst the cobbles (some coarse sand and gravel).

Downstream (end of Grey Gum Track): The general character of the stream (mean stream width 5 metres) is very similar to that upstream, although the gradient might be a little steeper. The bed of the stream is largely boulders and bedrock although at this location there was a lot more coarse sand especially around the edges of the stream. The stream habitat assessment recorded a much larger amount of sand at this site with a little less bedrock and cobble. I examined the moss covered boulders at the edges closely and observed that the moss on the rocks and boulders extended about 5 cm below the level of the sand and that below the sand level the moss was shrivelled and dead. This gave me the impression that the sand had been recently deposited. The bed in the run and riffle areas was again large cobbles but at this location they were difficult to dislodge being embedded in much coarse sand. Generally speaking the character of the stream was very similar to upstream except that there was a lot more coarse sand at the downstream location.

Christmas Creek

This stream (mean stream width 3-4 metres) is a little smaller than the Tyers River West Branch and although not as steep in gradient, it would still be described as a steep gradient cascading stream. Boulder and bedrock were less dominant in Christmas Creek, which was sandier than the Tyers River West Branch. The downstream location on Christmas Creek was a little sandier than the upstream location. The forest type around Christmas Creek was very similar to the Tyers River West Branch being dense Nothofagus dominated forest. The canopy was more closed in over the stream at Christmas Creek as compared to the Tyers River West Branch. This is probably because of the lesser stream width at Christmas Creek. The downstream site at Christmas Creek was about 200 metres downstream of the road crossing. Although this is probably too close to pick up all of the runoff from the roadworks it was considered, on the basis of Environmental Audit 92 TYERS RIVER CATCHMENT observations at the sites, that road runoff would be entering the stream above the downstream site.

Growlers Creek

Growlers Creek is a small stream (mean stream width 1 metre), much smaller than the Tyers River West Branch and Christmas Creek. It is less steep being dominated by riffles and runs, but still has very little or no pool habitat. The surrounding forest is very similar to Christmas Creek and the Tyers River West Branch (Nothofagus dominated) but at Growlers Creek the canopy is completely closed over the stream. The stream, both upstream and downstream of the road, flows under extensive logjams and fallen tree trunks.

Biological sampling

All locations had a fauna typical of a fast flowing coldwater stream with very high water quality. A total of 78 species (taxa) were collected from the Tyers River West Branch, Christmas Creek and Growlers Creek. A listing of all species collected at all sites in 1999 and 2000 is in Table 1.

At Christmas Creek and Growlers Creek the respective upstream and downstream locations had very similar faunas, although the two creeks were distinct from each other. The lists of species from respective upstream and downstream locations were very similar with the same common species occurring upstream and downstream. There were differences between Christmas and Growlers Creek with Growlers Creek having a slightly less species rich fauna and in particular there were fewer species of stonefly and mayfly in Growlers Creek. The differences probably relate to the difference in stream size and character of the habitats in each of the creeks.

In the Tyers River West Branch the two sets of samples collected a year apart from the upstream site were very similar faunistically. The downstream location sampled in July 1999 (which was not far downstream and in very difficult terrain) proved to be very similar faunistically to the upstream location on the Tyers River West Branch. However, the downstream location on the Tyers River West Branch at the end of Grey Gum track was distinct. It had slightly fewer species of invertebrates and in particular the numbers of species of stoneflies were much less at the downstream location. Another clear difference between the two locations was that the size of animals at the downstream location was generally much smaller, and in particular the very large mayfly Ameletoides lacusalbinae which was the most abundant species upstream was absent downstream.

The differences in stream fauna between the upstream and downstream locations are indicative of some change in conditions between the two locations, which are only about 1 km apart and in most respects have very similar physical habitats. The most conspicuous faunal difference was the absence of the large mayfly nymph Ameletoides lacusalbinae. This large active swimming species is known to be very susceptible to trout predation and if the introduced trout is absent at the upstream location but not at the downstream location this could explain this

Environmental Audit 93 TYERS RIVER CATCHMENT difference in the fauna. It is also likely that a large soft bodied animal such as Ameletoides lacusalbinae would be very susceptible to bombardment from coarse sand particles as might happen if large quantities of sandy material had been washed into the stream from eroding road batters. Thus until the presence or absence of trout at the downstream location is established it is not possible to say with certainty why this mayfly is absent at the downstream site, only that it could indicate the effects of inputs of sandy material or the effects of trout predation.

The presence of a lot of coarse sand at the downstream site is indicative of inputs of eroded material. In particular the observation that moss covered boulders at the edge of the stream had moss that was buried by sand and that the buried moss was dead is evidence that the sand was recently deposited into the stream. The downstream site generally seemed much sandier with the cobbles being much more embedded in sand.

The changes in fauna and the observation of sandy deposits at the downstream location are indicative of some sort of impact or changed conditions. It is considered possible that slugs of sand being washed into the river from eroding surfaces, or that differences in trout predation could account for the observed differences in stream fauna. More study of the two locations as well as upstream and downstream locations on other creeks would help to resolve the matter. However, it will not be possible to strictly prove the impact or non-impact of roading activities, in this situation, because of the lack of before impact data.

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Table 1Tyers River West Branch, Rapid Biological Assessment, Benthic samples (Kick)

Taxon Western Western Western Western Christmas Christmas Christmas Christmas Growlers Growlers Tyers River Tyers River Tyers River Tyers River Creek Creek Creek Creek Creek Creek South- face Intermediat South-face downstrea upstream upstream downstrea downstrea upstream downstrea Road – e Road – m (Grey 16/8/00 16/8/00 m 16/8/00 m 16/8/00 17/8/00 m 17/8/00 27/7/99 13/7/00 Gum Track) D/S 13/7/00 Collector 1 Collector 2 Collector 1 Collector 2 27/7/99

Oligochaeta 2 1 11 1 4 2 1 2 1

Hydracarina 1 1 1 1

Plecoptera

Eusthenia venosa 2 2 1 5

Cosmioperla kuna 1 3 2 5 3 6 2 3

Eunotoperla kershawi 1 1 1 1 2 2 6 3 1

Trinotoperla irrorata 9 2 3 1 6 5 7

Riekoperla tuberculata 8

Riekoperla williamsi 2 3 4 2

Riekoperla rugosa group 1 4 12 2 1 1 2 2

Riekoperla sp (juv.) 2 1

Dinotoperla christinae 2

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Dinotoperla sp (juv) 1

Leptoperla kimminsi 2 3 2 2 3

Leptoperla primitiva 1

Leptoperla sp (juv) 1

Neboissoperla alpine 1 1

Austropentura victoriae 1 2 5 5

Austropentura sp (juv.) 3

Austroheptura neboissi 1 1 1 2

Austroheptura sp. (juv.) 1

Austrocercella/ Austrocercoides 1 1 3 1

Ephemeroptera

Ameletoides lacusalbinae 56 63 43 34 7 13 9

Coloburiscioides sp AV1 2 5 3 6 6 17 10

Coloburiscioides sp AV2 2 5 21

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Austrophlebioides marchanti 10

Austrophlebioides sp AV2 7 4 11 3

Nousia sp AV1 2

Nousia sp AV2 10 3 2

Nousia sp AV3 7 13 16 22 15 17 16

Nousia sp AV 11 1 22 10

Baetidae MV sp 1 4 2 7 21 10 7 10

Baetidae MV sp 3 2

Trichoptera

Austropsyche sp AV1 7 1 10 6 16 21 27 8 3

Asmicridea sp AV1 5

Hydrobiosella sp AV2 1 1 5 1 1

Hydrobiosella sp (juv) 1

Smicrophylax sp AV1 2

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Psyllobetina cumberlandica 1 1 2 1

Taschorema rugulum 1 3 1

Taschorema kimminsi 1

Taschorema sp complex (juv.) 3

Tanjilana akvoreia 1 2 2

Austrheithrus sp 1 3

Kosrheithrus sp 1

Allocoella grisea 1 1 2 7 2

Aphilorheithrus sp (juv) 1

Agapetus sp 4 2 1

Tamasia acuta 1 1

Conoesucus sp AV3 1 3 2 1 1

Conoesucus sp (juv) 1

Coenota plicata 3 7 1

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Condocerus paludosus 1

Coleoptera

Austrolimnius sp (Ad) 2 1 1 1 4 1

Notriolus tasmanica (Ad) 1

Kingolus sp. (Ad) 2 3 4 2

Kingolus yarraensis (L) 1 2 3 1

Austrolimnius group A (L) 2 1

Austrolimnius sp (L) 1 1

Simsonia sp L12E (L) 3

Simsonia tonnoiri (L) 1

Simsonia sp (Ad) 1

Sclerocyphon sp (juv) 1

Ptilodactylidae 1 1 4 2

Diptera

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Tipulidae EPA sp 36 2 1

Tipulidae EPA sp 39 1 5 1 1 5

Tipulidae EPA sp 1 1 1 1

Tipulidae EPA sp 44 1 1

Tipulidae UID 1 1

Austrosimulium montanum

Austrosimulium victoriae 2 1

Austrosimulium sp (juv.) 1

Simuliidae sp (juv) 1

Edwardsina sp 5 7

Paracnephia sp 1 1 1 5 1

Pelecorhyachidae 3

Thaumaleidae EPA sp 1 1

Dasyoma sp 1

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Podomonopsis 3 2 5 4 1 3 1 3

Paraheptagyia 4 1 4

Eukiefferiella 1 3 1 1

Cricotopus 3 4 18

Botryocladius 1 1

Orthocladiinae SO1 1

Orthocladiinae (juv) 1 1 9 1

Riethia 2 1 1

Paratanytarsus 10 32 8 1 1

Parakiefferiella sp 1 1

Polypedilum 1

Tanytarsus 1

Theinnemanniella 2 1

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Crustacea

Pseudomoera sp 4 3 6 1 5 4 5

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APPENDIX 3 – RECOMMENDED WATER SAMPLING PROGRAM, SOUTH FACE ROAD

The following program of assessment and monitoring is recommended to assess the impacts of roading and forestry activities on the major streams in the South Face Road area.

The monitoring program should contain the following elements:

- monitoring points upstream and downstream of crossings over major streams eg. Tyers River West Branch, Tyers River East Branch, Christmas Creek, Growlers Creek;

- a monitoring point at Tyers Junction as this point receives run off from the entire Upper Tyers area;

- baseline monitoring (monthly) for basic physico-chemical parameters (suspended solids, turbidity, electrical conductivity, pH and temperature). Colour could also be considered;

- flow event monitoring for suspended solids and turbidity;

- continuous turbidity monitoring for Tyers junction and upstream and downstream of the Tyers River West Branch; and

- assessment of within stream impacts.

There are two components of the assessment of within stream impacts:

- measurement of sediment deposition; and

- assessment of impact on benthic fauna.

The biological monitoring should be conducted twice per year (Autumn and Spring) and should assess at least the major streams eg Christmas Creek and the Tyers River West Branch.

When choosing upstream and downstream locations on a particular stream, for the purpose of assessment, care will need to be taken to ensure that the two locations are as comparable as possible and that the downstream location is sufficiently far downstream to pick up an impact. The biological monitoring should focus on aquatic macroinvertebrates because of their general usefulness for this purpose. The recommended method is EPA’s Rapid Biological Assessment method (EPA Publication no 604 Rapid Bioassessment of Victorian Streams, June 1998), which would be quite capable of showing any substantial changes in community composition. It is recommended that at least two kick samples are collected at each site or location. The samples should be taken from areas of moderate current velocity, ie. runs and riffles, and should include in the samples a range of substrate types including bedrock/ boulder, cobbles, pebbles and sandy deposits.

In addition to the invertebrate sampling it will be necessary to make an assessment of the fish populations present at each site, particularly the two sites on the Tyers River West Branch. This is because of the possible influence of trout, an introduced predatory species that can have a marked effect on invertebrate populations. Trout are not able to move upstream past significant barriers such as waterfalls and it is likely that they will not be present in the upper sections of these very high gradient streams unless they have been deliberately introduced Environmental Audit 103 TYERS RIVER CATCHMENT there. Trout are definitely known to occur in the Tyers River West Branch at EPA’s long-term monitoring site at the Christmas Creek road, but it is not known how far up the river system they occur.

Measurement of sediment deposition should be once per year (Autumn), and should include quantification of the different sediment types at each site. This quantification needs to provide estimates of the relative amounts of each sediment type at the whole site (possibly using transects at each site) so as changes in the relative amounts of broad sediment classes can be recorded. For example has the amount of coarse sandy material at a site increased or not?

Duration of monitoring

At least two years after the South Face Road construction has ceased for physico-chemical parameters and for the biological and sediment deposition at least one pre (if possible) and two years of post construction (each year of post construction for the biological to include two seasons). The monitoring should continue longer if there is an indication of a continuing impact which would also indicate the need for further remedial works to reduce the impact, and provide an assessment of recovery or non-recovery of the affected streams.

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