THE ardens G OF tone S Reserve Proposal

Towards National Heritage Ian Brown for The Colong Foundation for Wilderness Ltd and Blue Mountains Conservation Society Inc.

Final Report, July 2016 Gardens of Stone Stage 2 Proposal

Published by The Colong Foundation for Wilderness Ltd, Suite 201, Level 2, 332 Pitt Street, Sydney, NSW, 2000 Phone: (02) 9261 2400 | www.colongwilderness.org.au

September, 2016

Text © Blue Mountains Conservation Society Inc. and the Colong Foundation for Wilderness Ltd., 2016 Photography © photographers as credited in each caption, 2016

This publication is copyright. Other than for the purposes of and subject to the conditions prescribed under the Copyright Act 1968 (Commonwealth of ), no part in it in any form or by any means (electronic, microcopying, photocopy, recording or otherwise) may be reproduced, stored in a retrieval system or transmitted without prior written permission of the publisher.

National Library of Australia Cataloguing-in-Publication entry Creator: Brown, Ian, 1954- author. Title: The Gardens of Stone Reserve proposal, towards national heritage / Ian Brown. ISBN: 9780858812512 (loose-leaf) Subjects: National parks and reserves----Blue Mountains. Gardens of Stone National Park (N.S.W.) Dewey Number: 333.783099445

Front cover image: Platy pagodas, Newnes State Forest (Henry Gold)

Above: View from top of pagoda, Newnes State Forest (Richard Green) Natural and Cultural Values

Contents

Summary ...... iii

1 Introduction ...... 1 1.1 What and where are the Gardens of Stone? ...... 1 1.2 Purpose of this report ...... 1 1.3 Geographic scope of the reserve proposal ...... 2 1.4 History of conservation proposals and reservation ...... 4 1.4.2 National parks ...... 4 1.4.3 Gardens of Stone Stage Two reserve proposal ...... 5

2 Geography of the reserve proposal ...... 7

3 Natural values ...... 9 3.1 Geodiversity ...... 9 3.1.1 Geology ...... 10 3.1.2 Geomorphology ...... 10 3.1.3 Catchments ...... 27 3.2 Biodiversity ...... 28 3.2.1 communities ...... 29 3.2.2 Plant species ...... 45 3.2.3 Fauna diversity ...... 52 3.2.4 Threatened fauna ...... 54 3.2.5 Ecosystems ...... 61 3.2.6 Wilderness ...... 61 3.2.7 Ecological resilience and climate change ...... 61

4 Cultural values ...... 63 4.1 Aboriginal heritage ...... 63 4.2 Historic heritage ...... 65 4.3 Scenery and aesthetic values ...... 70 4.4 Recreation ...... 74

i Gardens of Stone Stage 2 Proposal

5 Towards National Heritage ...... 75 5.1 The National Heritage process ...... 75 5.1.1 National Heritage criteria ...... 75 5.1.2 National Heritage thresholds ...... 76 5.1.3 National Heritage guidelines ...... 77 5.2 Potential National Heritage Values ...... 78 5.2.1 Specific values ...... 78 5.2.2 A landscape nomination? ...... 80 5.3 Achieving National Heritage: obstacles & opportunities ...... 81 5.3.1 Nexus with the GBMWHA ...... 81 5.3.2 Distribution of values within Gardens of Stone Stage Two ...... 82 5.3.3 Integrity ...... 82 5.3.4 Evidence ...... 82 5.3.5 Reductive or cumulative? ...... 83 5.4 Advancing the recognition & protection of values ...... 83 5.5 A National Heritage listing: a way forward ...... 84

Recommendations ...... 85

References ...... 86 Online references ...... 90

Acknowledgements Many people have provided valuable input to this report. The author would particularly like to thank Karen McLaughlin for several original maps and Keith Muir for guidance and editing. Alan Page edited species spreadsheets. Other people who provided assistance with specific areas of knowledge include Dr Haydn Washington, Dr Ann Young, Dr Ian Baird and Sharon Riley. However any errors, omissions or failures of emphasis remain the responsibility of the author. Images in this report have been provided by Ian Baird, Nakia Belmer, Yuri Bolotin, Ian Brown, Julie Flavell, Henry Gold, Karen McLaughlin, Robin Murray, David Noble, Jaime Plaza van Roon and Andrew Valja. Their important contributions are gratefully acknowledged.

ii Natural and Cultural Values

Summary

The current Gardens of Stone Stage Two reserve proposal (unreserved as of June 2016) covers some 39,000 hectares of largely natural public land in the western Blue Mountains, on the Newnes Plateau and western escarpment. The proposal adjoins the existing national parks of the Greater Blue Mountains World Heritage Area. Much of the landscape is characterised by pagoda rock formations and diverse vegetation – hence the Gardens of Stone. Large parts of the area are threatened by damaging activities and proposals including roading, open cut coal mining, underground coal mining with associated surface developments, infrastructure development, forestry and unmanaged recreation. No comprehensive survey of the area’s natural and cultural values has been undertaken but considerable information is available. This report compiles and analyses information from all available sources as a basis for assessing the area’s values and considering a potential National Heritage nomination of the as-yet-unprotected Gardens of Stone Stage Two area.

Conservation background Proposals to reserve the Gardens of Stone Stage Two area date back to the 1930s and environmental groups have been actively campaigning for the area since 1985. These proposals are based not only on the area’s capacity to extend the area and values already protected in adjoining, World Heritage listed national parks, but also to protect the special values uniquely embodied by Gardens of Stone Stage Two. These special values relate particularly to geodiversity, biodiversity and landscape, but also to cultural heritage.

Values Natural values considered include geology, geomorphology, plant communities, plant species, endangered ecological communities, fauna diversity, threatened species, landscape, catchments, ecosystems, wilderness and ecological resilience (in relation to climate change). Cultural values are less well documented but include Aboriginal heritage, historic heritage (recognising that Aboriginal and historic heritage are integrated), recreation and scenery/ aesthetic values.

Most significant values Analysis shows that the Gardens of Stone Stage Two reserve proposal encompasses a number of significant values, including some of national significance. Some authorities have also suggested that platy pagodas and slot are potentially of global significance. Some of the nationally significant values are an extension of those values which are protected in the Greater Blue Mountains World Heritage Area (GBMWHA) (although not

iii Gardens of Stone Stage 2 Proposal necessarily specifically listed as World Heritage). Other values are confined, or mostly confined, to the Gardens of Stone Stage Two area. Evidence for these values is strong.

Significant values unique to, or best expressed in, Gardens of Stone Stage Two

■■ Geodiversity – pagoda landscapes (best representation), montane sand dunes (rare), peat swamps (rare/unique).

■■ Biodiversity – rare/threatened (42 species), threatened fauna (42 species), swamps/wetlands/other EECs/other rare communities (15 communities).

■■ Landscape – integration of geodiversity and biodiversity values in a landscape that is probably rare or unique nationally.

■■ Aboriginal heritage - Maiyingu Marragu (specific site of high significance).

■■ Historic heritage – historic roads (specific site of high significance).

Of the above values, Maiyingu Marragu and Mount York are confined to small parts of Gardens of Stone Stage Two and are more suited to nomination by relevant cultural heritage bodies. The other (natural heritage) values listed above are considered suitable for National Heritage nomination. A potentially compelling case could be made for an integrated landscape-based nomination, encompassing pagodas, montane sand dunes, peat swamps, threatened fauna and rare/threatened plants and communities. The Gardens of Stone Stage Two pagoda landscape with its associated flora and fauna could be nominated under National Heritage criterion 2 if considered sufficiently rare. A closer examination of the distribution and characteristics of pagoda-associated flora and fauna would be required to support such an argument. Pagoda landscapes, sand dunes and peat swamps do not occur throughout Gardens of Stone Stage Two, but it can be argued that adequate protection of these features, their integrity and their ongoing evolution would require the inclusion of surrounding natural areas. Thus a case can be made for recognition of the whole area. One part of the area has been identified as a possible extension to the declared Wollemi Wilderness. Further, reservation of the area would significantly extend the existing protected areas of the Greater Blue Mountains World Heritage Area. This is a nationally rare opportunity to complete the protection of an environmental gradient across the mountains,

iv Natural and Cultural Values from the coastal lowlands, over the crest of the and onto the . The high altitude Newnes Plateau is a large area of the highest elevation sandstone terrain available in the Blue Mountains and the bioregion (c. 9,000 ha above 1100m). It is a potentially vital refugium for the future, which will help species cope with a changing climate.

Significant values shared by Gardens of Stone Stage Two and GBMWHA

■■ Geodiversity – slot canyons, waterfalls

■■ Biodiversity – flora/fauna diversity

■■ Natural heritage – wilderness, scenery

■■ Aboriginal heritage

■■ Historic heritage – bushwalking conservation movement, tourism/recreation, mining

The values shared by Gardens of Stone Stage Two and the GBMWHA are not considered to provide a strong basis for National Heritage nomination of Gardens of Stone Stage Two. These values are more strongly expressed in the GBMWHA and most are not yet listed as National Heritage for that place. These values include a rich biodiversity of 33 different plant communities, at least 1000 species of plants and at least 319 vertebrate animal species. Extension of the existing National Heritage recognition for biodiversity values of the GBMWHA across the Gardens of Stone Stage Two area is a worthwhile objective, but probably not achievable without prior reservation for conservation.

Other values The Gardens of Stone Stage Two area encompasses significant Aboriginal, historic, recreational and aesthetic values. The area is becoming increasingly well known as an especially beautiful and inspiring landscape which is also very accessible. The most well known Aboriginal place of Maiyingu Marragu is just one of many rock art and other sites dating back thousands of years. The most significant historic feature is ‘Blue Mountains crossing’ precinct of Mount York, where the 1813 colonial explorers discovered they had crossed the ‘sandstone barrier’ and where a number of early roads survive.

v Gardens of Stone Stage 2 Proposal

Recreationally, the area is already well used for sight-seeing, bushwalking, rock climbing and car touring. The very accessible western escarpment features numerous historic and popular lookouts and walking tracks while the rest of the area offers more remote and informal opportunities. With stronger protection and management the recreational values can be greatly enhanced. Aesthetically, the terrain is both dramatic and intricate, often changing rapidly and surprisingly over quite short distances, especially in the pagoda and escarpment areas where the vegetation can be of low stature but of remarkable variety in colour, form and texture. One walks and weaves between the outcrops as new scenes come into view, more strange ironstone sculptures emerge and another wildflower display or gnarled gum is discovered. Narrow defiles lead round corners into overhangs, caves, ferny glades, groves of huge trees and trickling streams.

Rocky spur and pagodas (Jaime Plaza van Roon)

vi Natural and Cultural Values

Towards National Heritage Consideration of National Heritage criteria, guidelines and thresholds suggests that a National Heritage nomination of the Gardens of Stone Stage Two will face a number of challenges. These challenges include:

■■ boundary definition and the spatial distribution of values, some of which occur only in, or mainly in, certain parts of the Gardens of Stone Stage Two;

■■ the nexus with the GBMWHA, which is already National Heritage listed (but for its World Heritage listed biodiversity values only), and values which the GBMWHA expresses to a greater extent than does the Gardens of Stone Stage Two;

■■ integrity issues associated with a fragmented proposal area, ongoing impacts and current management which is not directed towards conservation;

■■ lack of opportunity for values to be considered cumulatively across a nominated area, such that any single value must (apparently) achieve a (rather vague) threshold level of significance to be listed.

It is considered that the Gardens of Stone Stage Two reserve proposal possesses several values which have the potential to achieve a successful National Heritage nomination. These values are pagoda landscapes, montane sand dunes, peat swamps and biodiversity (rare/threatened plants, animals and ecological communities). The most cogent nomination could be based on the three state forests (Ben Bullen, Wolgan, Newnes). This area encompasses most of the geodiversity and biodiversity values considered to be of national/ global significance within a unified landscape and offers a contiguous area with a coherent boundary. A staged approach to move towards a National Heritage nomination is suggested, which includes progressive ‘reality checks’. It is also suggested that some other options could be pursued for advancing the recognition and protection of the special values of Gardens of Stone Stage Two.

vii Gardens of Stone Stage 2 Proposal

Brittle Gums (Eucalyptus mannifera) and pagoda in Ben Bullen State Forest (Ian Brown)

viii Natural and Cultural Values

1Introduction

1.1 What and where are the Gardens of Stone?

The name ‘Gardens of Stone’ was first applied to parts of the western Blue Mountains landscape in 19851 (see below). At that time the title was applied to the unprotected sandstone plateau bushland between Lithgow and the , a landscape often characterised by ‘pagoda’ rock formations. Landscapes with pagoda formations extend further to the north and south along the western edge of the Blue Mountains sandstone plateau, in the upper catchments of the Cudgegong, Capertee, Wolgan, Wollangambe, Turon and Coxs . The Gardens of Stone Stage Two reserve proposal near Lithgow is the core part of this region, encompassing the best expression of pagoda landscapes. It encompasses about 39,000 hectares of public land. Much of the area is threatened by damaging activities and proposals including roading, coal mining, infrastructure development, forestry and unmanaged recreation.

1.2 Purpose of this report

The values of Gardens of Stone Two reserve proposal were described briefly in a 2005 park proposal (see below). No comprehensive heritage assessment has been undertaken since a national estate listing nomination made many years ago. A substantial amount of new research and documentation has occurred, through environmental assessment processes and independent research. The conservation groups who commissioned this report are interested in nominating the area for National Heritage listing. Scoping National Heritage potential is one impetus for this report, which first reviews all the main values of the area. The report is based on available knowledge to date and no specific new research has been undertaken. A range of information has previously been compiled in a series of books on the wider Gardens of Stone region2. It is noted that a number of gaps exist in the available documentation of the values of the study area.

1 Muir (2005) 2 Keats & Fox (2011-2016)

1 Gardens of Stone Stage 2 Proposal

1.3 Geographic scope of the reserve proposal

The 2005 Gardens of Stone Stage Two reserve proposal extended over about 43,000 hectares and included the following:

■■ a proposed state conservation area of about 24,600 hectares taking in Maiyangu Marrugu Aboriginal Place, Dargans Creek Reserve, Zig Zag reserve and Newnes State Forest on Newnes Plateau (including 3,251 hectares of NPWS identified wilderness in the far north east and south east corners of Newnes State Forest);

■■ a further 8,866 hectares were proposed as a state conservation area on the Great Dividing Range north of over the Ben Bullen and Wolgan State Forests;

■■ the other reserve extensions of 653 hectares lie in the , and 5,077 hectares straddle the western escarpment of the main Blue Mountains ridge from Dargan to Medlow Bath, above the Kanimbla and Megalong Valleys.

This report covers all the lands of the 2005 Gardens of Stone Park Proposal Stage Two reserve proposal3 that have not to date been protected by May 2016 under the National Parks and Wildlife Act 1974 (thus excluding the Airly/Genowlan mesas of the 2005 proposal which were reserved in 2011 as Mugii Murum-ban State Conservation Area, c.3650 ha). Included in the study area are Newnes Plateau/Newnes State Forest, Wolgan State Forest, most of Ben Bullen State Forest, Maiyingu Marragu Aboriginal Place (a Crown reserve, formerly Blackfellows Hand Reserve) and Crown reserves of the Blue Mountains western escarpment from Hassans Walls to Medlow Bath. The area covered in this report is about 39,000 hectares. The area subject to this report is shown in Map 1. The proposal lies to the east and south of the existing and adjoining Gardens of Stone National Park, and Blue Mountains National Park, all constituent reserves of the Greater Blue Mountains World Heritage Area.

3 Muir (2005)

2 Natural and Cultural Values

Map 1. The Gardens of Stone Stage Two Reserve Proposal

3 Gardens of Stone Stage 2 Proposal

1.4 history of conservation proposals and reservation

1.4.1 eArly reserves The earliest moves for protecting parts of Gardens of Stone Two came in the nineteenth century, with some areas ‘reserved from sale’ under the Crown Lands Alienation Act 1861. The creation of ‘reserves’ along the main Blue Mountains ridge and western escarpment was partly prompted by the construction of the western rail line (completed to Lithgow in 1869) and the recognition that important scenic areas should be protected from development. Early reserves came and went at the whim of government, and the historical tenure record is complex. Crown reserves on the Blue Mountains western escarpment which survived to form part of Gardens of Stone Two include Blackheath Glen, Hargraves Lookout-Mount Blackheath, Reserve at Mount Victoria and Hassans Walls Reserve south of Lithgow. The place known locally as Blackfellows Hand Cave, near Wolgan Gap, was first protected within ‘Reserve 42350 for Public Recreation’ in 19084. In 2008, the 491 hectare reserve was declared an Aboriginal Place under the National Parks and Wildlife Act 19745. This designation is an overlay on existing tenure and provides a level of special protection. The place was renamed Maiyingu Marragu by the local community. State Forests were created in the Gardens of Stone Two area during the early 1900s. The Gardens of Stone Two proposal takes in most of Ben Bullen State Forest (20 May 1938, 7,812 ha in 2014), all of Wolgan State Forest (25 May 1917, 1,054 ha in 2014) and all of Newnes State Forest (21 May 1920, 23,338 ha in 2014)6,7. The purpose of state forests was to protect Crown forest lands for future timber supply but they indirectly had broader nature conservation benefits, at least until recent decades when some areas became subject to open-cut mining.

1.4.2 National parks The first significant moves to protect large areas of natural landscape in the Blue Mountains came with Myles Dunphy’s historic and seminal plan for a Greater Blue Mountains National Park in 19328. Dunphy’s proposal took in the Newnes Plateau sector of the current Gardens of Stone Stage Two reserve proposal. Much of the Dunphy plan was progressively implemented from 1959 when Blue Mountains National Park was created. Further additions and other adjoining national parks followed, and in the year 2000 the million-hectare Greater Blue Mountains reserve system was granted World Heritage status.

4 Gazetted 15 Jan 1908: historical map of Parish Cox viewed on http://images.maps.nsw.gov.au 5 http://www.environment.nsw.gov.au/AboriginalPlaces/BlackfellowsHand.htm 6 Gazettal dates from historical Parish maps viewed on http://images.maps.nsw.gov.au 7 Forest areas from NSW Forestry Corporation (2014) 8 Mosley (1989)

4 Natural and Cultural Values

The Gardens of Stone area was one of the last parts of Dunphy’s proposal to receive recognition. From 1932 it was not pursued again until 1977, when the National Trust recognised the significance of this landscape by proposing a ‘Pinnacles National Park’9. In 1985 the Colo Committee followed up with a proposal for a 38,000 hectare addition to Wollemi National Park (1979), taking in Newnes Plateau and westwards across public lands on the headwater escarpments of the Wolgan and Capertee rivers10. The report dubbed this region the ‘Gardens of Stone’, in recognition of both its rocky features and the diverse native vegetation. An area of 53,000 hectares titled ‘The Pagoda Country’11 was subsequently placed on the Register of the National Estate. The Register is now defunct, and this listing was not transferred to the new National Heritage regime. In 1993 the Colong Foundation for Wilderness updated the 1985 proposal with a plan to protect the area in two stages. A Gardens of Stone National Park of 11,780 hectares was subsequently created in 1994. The new park included Donkey Mountain and areas east of the Great Dividing Range in the Capertee-Wolgan headwaters. In 1995 the existing Pantoneys Crown Nature Reserve (1977, 3,230 hectares) in the Capertee Valley was added to Gardens of Stone National Park and a further area of 3,600 hectares of the 1985 proposal was added to Wollemi National Park in the northern Newnes Plateau area.

1.4.3 gArdens of Stone Stage Two reserve proposal In 2005, after little further action by government, conservation groups launched Stage Two of the Gardens of Stone reserve proposal12. It took in “all of the remaining parts of the Newnes Plateau and surrounding sandstone uplands” and extended the original proposal southwards to include Crown reserves on the western Blue Mountains escarpment from Lithgow to Medlow Bath. Most of the latter area on the western escarpment was identified in 2002 by the NPWS, Department of Land and Water Conservation and Blue Mountains City Council as additions to the national park estate in ‘the Blue Mountains Public Lands Rationalisation Project’13. The revised Gardens of Stone Two plan recognised extensive existing coal mining tenures by proposing State Conservation Area (SCA) status for much of the area. SCA is a legal designation under the National Parks and Wildlife Act 1974 which would allow approved underground mining to continue whilst protecting surface features.

9 Washington (2001) 10 Falconer & Blackwell (1985) 11 http://www.environment.gov.au/cgi-bin/ahdb/search.pl?mode=place_ detail;search=place_name%3Dgardens%2520of%2520Stone%3Blist_ code%3DRNE%3Bkeyword_PD%3Don%3Bkeyword_SS%3Don%3Bkeyword_ PH%3Don%3Blatitude_1dir%3DS%3Blongitude_1dir%3DE%3Blongitude_2dir%3DE%3Blatitude_2dir%3DS%3Bin_ region%3Dpart;place_id=18258 12 Muir (2005) 13 Public Lands Rationalisation Task Force & Egis Consulting (2002)

5 Gardens of Stone Stage 2 Proposal

In 2011 and after extensive negotiation, a Mugii Murum-ban State Conservation Area SCA (c.3,650 hectares) was created over the Airly-Genowlan mesas in the northern part of the original proposal. Concurrently an underground coal mine approved in 1993 for the area recommenced development and initial production. This is the only significant area reserved in the Gardens of Stone area since 1995 (noting that the adjoining 2,804 hectare Capertee National Park was established in 2010, immediately to the north of Mugii Murum- ban SCA and not within the Gardens of Stone Stage Two reserve proposal). As of early 2016, the remaining parts of Gardens of Stone Stage Two reserve proposal remain unprotected by high-level reservation (i.e. under the National Parks and Wildlife Act 1974). All of these areas are publicly owned, as either State Forest or Crown reserve. However State Forest status has provided no effective management of recreation activities or protection from open-cut coal mining which has taken place in western parts of Ben Bullen State Forest.

Ironstone formation and pagoda landscape on the eastern edge of Newnes Plateau (Ian Brown)

6 Natural and Cultural Values

2Geography of the reserve proposal The Gardens of Stone Park Proposal Stage Two reserve proposal lies on the western margins of the sandstone Blue Mountains plateau. It straddles the Great Dividing Range in the north then follows the Blue Mountains Range (an easterly spur of the Great Dividing Range) east across Newnes Plateau and south along the western escarpment of the Blue Mountains. This area is within the headwater catchments of the east-flowing Wolgan, Wollangambe, Grose and Coxs Rivers, and the west-flowing Turon . The main landform is the dissected Blue Mountains plateau, capped by cliff-forming and sub-horizontal Triassic sandstones with underlying Permian sediments exposed on the slopes. These rocks are within the larger Sydney Basin structure. The surface expression of the sandstone includes extensive pagoda rock formations, gorges, broad rock outcrops, cliffs and slot canyons. The western Blue Mountains sandstone escarpment overlooking the Coxs, Turon and Capertee valleys, and beyond, has been termed the ‘Cliff Wall’ by Cunningham14. The convoluted length of this remarkable landscape feature extends for about 280 km, from the Hunter Valley to the Nattai. On the undulating Newnes Plateau on the western end of Blue Mountains Range, at elevations of between 1000 and almost 1200 metres, there are broad, rounded ridges. Much of the land in the rest of the proposal is a complex of narrow ridges, steep gorges and escarpments. In parts, the proposal extends off the plateau edge and down to the lower escarpment slopes of Permian sediments, into tributary valleys of the Turon, Wolgan and Coxs rivers. Elevation ranges from c.1189 metres on the Newnes Plateau15 (the highest expression of the Sydney Basin sediments) down to c.700 metres in the headwaters of Pulpit Hill Creek (, southern end of the proposal). The current proposal is bounded by Gardens of Stone National Park to the north, with Wollemi National Park and the Darling Causeway//western railway transport corridor to the east. To the west lie semi-rural and industrial lands of the upper Turon and Coxs Rivers. The nearest towns include Ben Bullen, Cullen Bullen, Wallerawang, Lithgow, Mount Victoria, Blackheath and Medlow Bath. The proposal can be divided into four broad divisions: Ben Bullen and Wolgan State Forests (on the Great Dividing Range), small areas in the Wolgan Valley, Newnes State Forest

14 Cunningham (1996) 15 Macqueen (2012)

7 Gardens of Stone Stage 2 Proposal

(Newnes Plateau) and discontinuous western escarpment reserves from Hassans Walls to Medlow Bath. These divisions will be used in this report to assist the description of values. Overall, the climate is temperate and moist, but both precipitation and temperatures vary across Gardens of Stone Stage Two reserve proposal according to elevation, topography and distance inland. The coolest and wettest areas are at high elevations on the Newnes Plateau and western escarpment (where snow may fall several times a year), grading into warmer and drier areas at lower elevations west of the Great Dividing Range and in the rainshadowed Wolgan Valley. Table 1 shows climatic data for stations within and close to Gardens of Stone Stage Two.

Table 1. Climatic data from stations within and close to Gardens of Stone Stage Two reserve proposal

Station Elevation Mean daily temps Variations in Mean annual (°C) monthly rainfall rainfall (mm) means (mm) Newnes Forest 1050m 9.9 - 23.5 (Jan) Highest – 121.0 (Jan) 1073 -1.1 – 9.4 (Jul) Lowest – 67.9 (Sep) 1080m 13.2 – 23.9 (Jan) H – 127.9 (Feb) 951 2.5 – 9.4 (Jul) L – 40.6 (Jul) Lithgow 950m 11.9 – 25.5 (Jan) H – 94.3 (Jan) 859 0.7 – 10.4 (Jul) L – 58.9 (Sep) Glen Davis 290m 16.5 – 30.3 (Jan) H – 72.7 (Feb) 634 2.0 – 15.4 (Jun) L – 36.8 (Sept) Source: Bureau of Meteorology online data

Headwaters of Bungleboori Creek in Newnes State Forest, flowing to the Wollemi Wilderness and (Ian Brown)

8 Natural and Cultural Values

3Natural values The natural values of the Gardens of Stone Two include geodiversity, hydrology, flora, fauna, ecology and landscape. The area has not been comprehensively studied for any aspect of natural heritage; however the geology, in broad terms, is well understood. A substantial body of information also exists on flora, from regional vegetation mapping projects and from environmental impact assessments for mining proposals. The extent and quality of floristic information varies across the area, and there has been no definitive mapping of pagoda distribution. Fauna and hydrology are the least studied components, with most information coming from environmental impact studies for coal mining projects.

3.1 Geodiversity

It has been argued that the Greater Blue Mountains area warrants World Heritage listing for its geological values16,17. This was one of the criteria which was initially proposed to be included in the nomination18, but was not ultimately included19. In reviewing the geodiversity values of the Greater Blue Mountains, Washington and Wray20 concluded that a number of aspects are of national and international significance. They also proposed a ‘statement of significance’ for these values:

The Greater Blue Mountains are the best example in the World of a sedimentary upland, deeply dissected by rivers over tens of millions of years, and of the ongoing processes involved in sculpting these magnificent landforms. The outcropping geology provides an outstanding illustration of the complex and long geological history of the east Australian coastal margin and highlights marine, terrestrial, volcanic and tectonic environments and processes through time. The geology also hosts exemplary erosional landforms/elements including karst, caves, cliff lines, slot canyons, bottleneck valleys, pagodas and other sandstone landforms of national and international significance.

16 Mosley (1989) 17 Washington & Wray (2015) 18 Mosley (1989) 19 NSW National Parks and Wildlife Service & Environment Australia (1998) 20 Washington & Wray, R. (2015)

9 Gardens of Stone Stage 2 Proposal

Gardens of Stone Stage Two reserve proposal is an inherent part of the Greater Blue Mountains natural landscape and its geological history. It offers additional areas that embody some of these identified national and international values. In particular, Gardens of Stone Stage Two encompasses some of the finest examples of cliff lines, slot canyons and pagodas.

3.1.1 Geology The landscape of the Gardens of Stone Stage Two reserve proposal is an uplifted plateau of sub-horizontal sedimentary rocks that has been deeply incised by stream erosion. Permian and Triassic era sediments of the Sydney Basin comprise the entire surface geology. Although underlying metasediments of the Lachlan Fold Belt basement (Devonian-Ordovician age) are exposed in several adjacent valleys, they do not outcrop within Gardens of Stone Stage Two. Similarly, Tertiary basalts occur on the tops of some nearby high points and ranges, but not within Gardens of Stone Stage Two. The sequence of exposed rocks begins at the lowest levels (valley floors and lower slopes) with Permian sediments of the Illawarra Coal Measures (claystone, shale, coal, siltstone, tuff sandstone, mudstone and oil shale), capped by Triassic sediments of the Narrabeen Group (sandstones, shale and claystone) at higher levels (upper slopes, plateau edges and plateau surface)21. The Narrabeen Group is 150m thick at Mount Victoria. This sequence is similar to much of the western Sydney Basin. From a conservation perspective, the most notable geological aspect is that the gently-sloping Permian footslopes of the shallow western valleys of Gardens of Stone Stage Two reserve proposal, together with their characteristic vegetation communities, are not well represented in the existing national parks of the Greater Blue Mountains World Heritage Area (GBMWHA). OEH drew the attention of the Department of Environment and Planning to this issue by stating that the proposed mining “is on the Permian sediments and [these] are highly cleared and poorly reserved”22. Also noteworthy is the extensive area of the Burralow Formation (sandstone) of the Narrabeen Group that forms the surface geology across Newnes Plateau.

3.1.2 Geomorphology Weathering and erosion acting on the geology have produced some remarkable landscape features in Gardens of Stone Stage Two reserve proposal. The most notable and prevalent, but rare at a national and global level, are the pagodas: sandstone pinnacles and domes of the plateau edge and tops, often temple-shaped and in extensive assemblages. But other noteworthy sandstone landforms include peat swamps, relict sand dunes, cliffs, large domed overhangs, natural arches, slot canyons and waterfalls. Many of these features occur

21 Yoo (1992) 22 NSW Office of Environment and Heritage (2014)

10 Natural and Cultural Values in close proximity to each other along the convoluted escarpments, creating a complex and intriguing landscape.

Sandstone pagodas The sandstone pagodas of the western Blue Mountains occur to some degree (mostly scattered and poorly developed) over a north-south band, about 160 kilometres long, from the vicinity of the Darling Causeway and Lithgow to the upper Capertee Valley, and beyond to the Bylong Valley and Goulburn River National Park. The ‘pagoda zone’ is bounded to the west by the edge of the sandstone, and to the east extends into the headwaters of many tributaries of the Hunter, Capertee, Wolgan and Wollangambe Rivers. However the most impressive, well-developed and accessible pagoda landscapes are generally regarded as extending from Newnes Plateau to the Capertee Valley, where the ‘platy’ form of pagoda with its distinctive ironstone banding is particularly prevalent. It has been estimated that about half of the 60,000 hectare platy pagoda ‘heartland’ is protected within the GBMWHA (Wollemi NP, Blue Mountains NP, Gardens of Stone NP) with the remaining half in Mugii Murum-ban SCA and the unprotected Gardens of Stone Stage Two reserve proposal 23.

Platy pagodas, Newnes State Forest (Henry Gold)

23 Washington & Wray (2015)

11 Gardens of Stone Stage 2 Proposal

Pagodas in the region occur on plateau edges, headwater valleys and spur lines descending towards gorges formed in the Banks Wall (mostly) and Burra Moko Head sandstones, at around 1000 metres elevation, where deep weathering along sub-rectilinear vertical joints has exposed sandstone ‘corestones’. Pagodas occur throughout most of Gardens of Stone Stage Two reserve proposal, which is predominantly escarpment country, along the edges of the higher, flatter parts of Newnes Plateau. Map 2 shows one interpretation of pagoda occurrence in this area. This map was produced for a coal mining proposal and has been critiqued as under-representing the occurrence of pagodas and associated landforms in some unprotected areas.

Platy pagodas exhibit complex and fragile forms resulting from differential weathering of resistant bands of ironstone (Ian Brown)

Washington and Wray24 have described the physiography, genesis, rarity and significance of Blue Mountains pagodas. The ‘smooth’ variety are similar to formations found in many other parts of the world and reasonably well understood, while the ‘platy’ form is globally rare with considerable uncertainty about how the characteristic ironstone bands which control the eroded shape are formed. Washington and Wray consider the smooth form to

24 Washington & Wray (2011)

12 Natural and Cultural Values be of national significance, and the platy pagodas to be of international significance. These authors have summarised the significance of pagodas:

Platy pagodas are influenced by numerous layers of ironstone (the sandstone re- cemented and hardened by iron-based minerals), and are distinct and significant features, with no other rock formations in Australia or elsewhere mimicking their geomorphology...While there are many other rock pinnacles and beehives around the world, and whilst ironstone formations are found in other places, the regular stepped-cone shape of platy pagodas is a distinct geomorphic feature. The ironstone banding of the platy pagodas is thus significant in degree, not in nature, as ironstone layers are found throughout many of the Sydney Basin sandstones. However, the development of banding in platy pagodas forms a geomorphic landscape type that can be recognized as distinct and significant even by world standards…No other areas in Australia (or indeed the world) contain platy pagodas, making them unique internationally…Smooth pagodas do have equivalents elsewhere in Australia, though they are still of national significance.

Pagoda terrain is also significant for local ecology. One rare plant species is essentially found only in this habitat (Pagoda Daisy, Leucochrysum graminifolium). The intricate, rocky topography of ledges, overhangs, caves, cracks, chasms and multiple aspects provides a complex variety of habitat, moisture availability and microclimate within small areas. Lichens, mosses, vascular plants and wildlife all exploit this diversity, evidenced by the prevalence of Rock Warblers (endemic to the Sydney Basin), Lyre-bird nests, and the plant ‘community’ mapped as “Pagoda Rock Complex” (see below). A 2012 Planning Assessment Commission (PAC) review25 found that:

■■ the pagodas cannot be considered in isolation. … ‘are part of a landform consisting of multiple pagoda structures and intervening sections of cliffs, with steep slopes and dissecting gullies below’.

■■ The pagodas are “a unique landform on a world scale…” have limited distribution, “provide critical habitat for some flora species and key habitat features for threatened fauna”; and

■■ “the pagoda landform should be afforded special significance status and the highest possible level of protection”.

25 NSW Planning Assessment Commission (2012)

13 Gardens of Stone Stage 2 Proposal

Map 2. Pagoda distribution in Newnes Plateau-Ben Bullen State Forest area Source: Cumberland Ecology (2012), using Washington & Wray (2011) overall boundary of pagoda distribution. (Note: This map was produced for a coal mining proposal and has not been peer reviewed. It may not accurately represent the distribution of pagoda landscapes.)

14 Natural and Cultural Values

The 2012 PAC review recommended that “the pagodas and associated escarpments be considered natural features of special significance and that they be fully protected from any mine-induced impacts.” The Department of Planning and Infrastructure agreed in 2013 with the PAC review, stating “… the Department believes that the PAC’s classification of the pagoda landform as a natural feature of special significance is appropriate and agrees that these features warrant the highest level of protection.”26 The subsequent PAC determination agreed with all these findings and recommendations in a 2014 report27 in refusing development consent for a proposed open-cut mine in the Gardens of Stone region. Pagoda formations can be damaged by subsidence resulting from underground coal- mining. This can cause vertical cracking unrelated to joint systems and in some situations, collapse of pagodas and clifflines. These impacts have occurred in parts of Gardens of Stone Stage Two Reserve Proposal.

Peat swamps The upland peat swamps are a significant geomorphic and ecological feature of the Gardens of Stone Stage Two reserve proposal. These peat swamps (mires) are classified as an Endangered Ecological Community (EEC) under both state and national legislation (see below). The swamps are key habitat for a number of obligate peat swamp dwellers, including the Blue Mountains Water Skink and Giant Dragonfly, both also Endangered (see below), and several threatened plant species. (See also section 3.2.1 below on the biodiversity values of swamps). The peat swamps classified as Newnes Plateau Shrub Swamps28 29 and Newnes Plateau Hanging Swamps30 cover less than 650 hectares on Newnes Plateau, of which only 160 hectares are protected in Blue Mountains and Wollemi National Parks31. The remaining 490 hectares (or 75%) are unprotected and lie in Gardens of Stone Stage Two reserve proposal. A 2010 aerial assessment by the ‘Save Our Swamps’ program, led by Blue Mountains City Council, found that many of the best quality peat swamps were in the headwaters of Carne Creek area (Newnes Plateau) in Gardens of Stone Two32. Peat swamps in part of Newnes Plateau are shown on Map 3.

26 NSW Department of Planning and Infrastructure (2013), page 36 27 NSW Planning Assessment Commission (2014) 28 Hughes (2005) 29 Department of Environment and Conservation (2006) 30 Department of Environment and Conservation (2006) 31 Benson & Keith (1990) 32 Hensen (2010)

15 Gardens of Stone Stage 2 Proposal

Newnes Plateau Shrub Swamp occurs in narrow, elongated swamps formed in low-slope headwaters of the Newnes Plateau, in predominantly sandstone catchments of Triassic Narrabeen Group geology, at approximately 900-1200m elevation on deep sandy organic sediments that are permanently to periodically waterlogged33.

(However note that some of these swamps are not well characterised as “narrow”, being broader and more complex swamps, which in some cases may include contiguous areas of valley side swamps34.)

Newnes Plateau Shrub Swamp EEC in spring, with a variety of shrubs flowering, Newnes State Forest (Ian Baird)

The swamps may have developed since the end of the last glacial period, with evidence of some swamp development by 10,000 years ago35 in response to specific geological, geomorphic and climatic factors. The drainage lines followed by the elongate swamps often follow deep vertical joints in the underlying rocks.

33 Hughes (2005) 34 Baird (2016) 35 Black & Mooney (2006)

16 Natural and Cultural Values

Intact Newnes Plateau Shrub Swamp EEC in winter, Newnes State Forest (Ian Baird)

Washington and Wray have concluded: “The Newnes Plateau Shrub Swamps are also an uncommon geodiversity feature and are highly significant for geodiversity and geoheritage at the national level” 36. The NSW Scientific Committee37 considered Newnes Plateau Shrub Swamps to be transitional between the Coastal Heath Swamps and the Montane Bogs and Fens vegetation classes of Keith38. Keith himself considered them a high elevation expression of the Coastal Heath Swamps vegetation class. On the valley sides above the valley floor shrub swamps, where groundwater seepage emerges, Newnes Plateau Hanging Swamps may also be found39. These hanging swamps may occur as discrete swamp patches or be contiguous with the lower gradient, valley floor shrub swamps. Another swamp type is located on open depressions on the highest ridgelines of the Newnes Plateau above 1150 metres, associated with Snow Gums, shrubby heathland and sedges (Newnes Plateau Rush-Sedge-Snow Gum Hollow Wooded Heath)40.

36 Washington & Wray (2011) 37 Hughes (2005) 38 Keith (2004) 39 Department of Environment and Conservation (2006) 40 Department of Environment and Conservation (2006)

17 Gardens of Stone Stage 2 Proposal

The Newnes Plateau Shrub Swamps and Newnes Plateau Hanging Swamps and their associated biota are primarily groundwater-dependent. Peat development over millennia is a key characteristic41. Newnes Plateau Rush-Sedge-Snow Gum Hollow Wooded Heath, however, appears to be primarily rainfall dependent, with little development of peaty soil. The three swamp landforms described above are categorised under the Environment Protection and Biodiversity Conservation Act 1999 as the Temperate Highland Peat Swamps on Sandstone EEC42 and as “matters of national significance” and are also listed as EECs under the NSW Threatened Species Conservation Act 1995. West of the Newnes Plateau, in Ben Bullen State Forest and along the western edge of Newnes State Forest, another low gradient, valley floor, peat-swamp type occurs. Primarily associated with the Long Swamp complex in the headwater tributaries of the , it also includes some swamp patches in the headwaters of Baal Bone Creek to the north, within Ben Bullen State Forest and adjoining Gardens of Stone National Park. These swamps were described as Coxs River Swamps by Benson and Keith43, and Long Swamp was classified as Mountain Hollow Grassy Fen by DEC44. These swamps form part of the Montane Bogs and Fens vegetation class of Keith45 and are included within the Montane Peatlands and Swamps of the New England Tableland, NSW North Coast, Sydney Basin, South East Corner, South Eastern Highlands and Bioregions EEC in NSW46. Underground coalmining can impact on swamps through cracking and disturbance of groundwater and surface drainage, leading in severe cases to swamp dessication and vegetation death. This has occurred to some swamps in the Gardens of Stone Stage Two Reserve Proposal.

41 Benson & Baird (2012) 42 http://www.environment.gov.au/node/14561 43 Benson & Keith (1990) 44 Department of Environment and Conservation (2006) 45 Keith (2004) 46 Hughes (2005)

18 Natural and Cultural Values

Map 3. Shrub swamps on Newnes Plateau (Source: Baird and Benson, 2012) (Note: The Newnes State Forest boundary includes public road exclusions and the boundaries of small parcels of other tenures.)

19 Gardens of Stone Stage 2 Proposal

Montane sand dunes A relatively recent discovery is a number of ancient, aeolian sand dunes on Newnes Plateau47, mostly within Gardens of Stone Stage Two reserve proposal (see Map 4), in an area that now has dense vegetation and annual rainfall exceeding 1000 mm. The dunes have been dated as being active during the Last Glacial Maximum (c.20,000 years ago), a more arid, colder and possibly windier period. The bulk of the dune building probably occurred over just one or two millennia, and stabilised shortly after 15,000 years ago. Dune types include parabolic dunes, transverse lee dunes and sand sheets or patches. The dunes are up to a hundred metres long and three to six metres in height.

Map 4. Pleistocene dunes on Newnes Plateau. (Source: Hesse et. al. 2003) (NB: Sunnyside and Pine Dune Field are within Gardens of Stone Stage Two reserve proposal, Carne Dune is within Gardens of Stone National Park)

The researchers consider the conditions at the time were marginal for dune formation, requiring a ready sand supply from the weathered sandstone of the plateau and sparse vegetation above the then treeline. They suggest that additional impediments to plant growth, such as lower temperature and lower atmospheric carbon dioxide levels, would have been necessary. These dunes provide an important window into changing Quaternary climates and landscape processes in Australia. Washington and Wray48 consider them to be of national geodiversity significance:

These dunes are in fact the only known high altitude example in Australia of aeolian deposits formed in the last Ice Age. They therefore constitute an important indicator of the last Ice Age periglacial climate in the region…Their

47 Hesse et.al. (2003) 48 Washington & Wray (2011)

20 Natural and Cultural Values

uniqueness and climatic implications require that the dunes be assigned national geodiversity significance.

(However note that other sand dunes are known from lower altitude sandstone plateaus in the Sydney Basin.)

Figure 1. Cross-section and dating results of Pleistocene dune, Sunnyside, Newnes Plateau (Source: Hesse, et. al. 2003)

21 Gardens of Stone Stage 2 Proposal

Canyons Sandstone slot canyons in the Greater Blue Mountains number in the hundreds, and are generally restricted to the strongly-jointed Burra Moko (mostly) and Banks Wall sandstones (both sub-units of Grose Sandstone of the Narrabeen Formation) of the western Blue Mountains. The ‘ zone’ broadly corresponds to the pagoda distribution, including Gardens of Stone Stage Two reserve proposal where a number of canyons exist. One short but very accessible canyon can be reached on a walking track in Centennial Glen near Blackheath. Slot canyons in the Blue Mountains usually result from waterfalls on small streams cutting back along vertical joints at nick points into the otherwise resistant sandstone. This erosion is partly controlled by claystone bands49 and characterised by rotary abrasion in ‘pothole’ features (often abandoned and preserved in canyon walls as the stream cuts down). The depth of the canyons is limited by the occurrence of weaker layers within the sandstone which promote undercutting and lateral widening by collapse of the rock above. Typical canyon depths are 15 to 30 metres, rarely up to 60 metres, with widths of several metres to half a metre. Slot canyons vary in length from 100 metres or less to several kilometres. The longer formations tend to occur where the stream follows the gentle dip of the relevant stratum and are usually intermittent, broken by more open sections of gorge and tributary gullies. These canyons are stunningly beautiful features, popular with recreationists. They also provide limited, unusual and fire-protected habitats for a range of moisture-loving plants and animals. A notable canyon/gorge species is the Wollemi Pine (Wollemia nobilis) which occurs naturally in only a few canyons/gorges in Wollemi National Park. Washington and Wray50 consider that the Greater Blue Mountains canyon system may be of international geodiversity significance:

The Greater Blue Mountains has by far the most extensive and well developed sandstone canyon systems in eastern Australia; it is most probable that these systems are amongst the foremost in the world, but bedrock canyons in general are not well studied worldwide…

49 Holland (1977) 50 Washington & Wray (2011)

22 Natural and Cultural Values

Slot canyon, Bungleboori Creek headwaters, Newnes State Forest (David Noble)

Smooth pagodas on the Great Dividing Range (boundary of Ben Bullen State Forest and Gardens of Stone National Park) (Ian Brown)

23 Gardens of Stone Stage 2 Proposal

Waterfalls Waterfalls are common in the Blue Mountains, as the region is a dissected plateau with numerous cliffs and good rainfall. They often occur at ‘nick points’ (sudden drops in stream beds), where streams are cutting back relatively rapidly into the plateau edges. Most are on small to medium sized streams near the top of catchments and so the high-volume falls of other continents are absent. On the plus side, most flow year-round. Numerous small-volume waterfalls occur in the many small grottoes and canyons of Gardens of Stone Stage Two reserve proposal, such as Centennial Glen falls near Blackheath and many streams draining Newnes Plateau. Outside the canyon environment, streams falling over the western edge of the Newnes Plateau produce higher-volume examples such as East Creek falls and Wolgan Falls (the highest volume waterfall in Gardens of Stone Stage Two, and c.50 metres high).

Wolgan Falls, Newnes State Forest (Andrew Valja)

24 Natural and Cultural Values

Bottleneck valleys ‘Bottleneck’ is a term used to describe a valley where a broad headwater basin narrows downstream into a gorge – a reversal of the more usual physiography where valleys widen downstream, and a globally rare phenomenon51. The Greater Blue Mountains contains a number of such valleys, a specific response to both the geology and the history of uplift of the plateau52. Two fine examples - the Wolgan and Capertee valleys - lie immediately downstream of the Gardens of Stone Stage Two reserve proposal. These streams drain most of the Gardens of Stone Two area, which is therefore the only place in the Greater Blue Mountains that captures, in the same catchments, all three internationally significant sandstone geodiversity features: slot canyons, platy pagodas and bottleneck valleys.

Large domed caverns The Gardens of Stone Stage Two reserve proposal contains some fine examples of large domed caverns, which are widely known from sandstone landscapes. These caverns develop from the more usual and much more common overhangs, where seepage-induced weathering processes have excavated both into the cliff and vertically up into the sandstone behind the case-hardened external cliff face. One cavern, known as Cathedral Cave, has an estimated volume of at least 20,000 cubic metres.

A view into a two-staged domed cavern in Gardens of Stone Stage Two (David Roma)

51 Washington & Wray (2011) 52 Washington & Wray (2011)

25 Gardens of Stone Stage 2 Proposal

Natural arches Small arches up to a few metres across are relatively common in the pagoda landscape, and other sandstone areas, where cavernous weathering breaches a previously continuous surface. They also form where the downward potholing action of a canyon stream tunnels through the rock immediately upstream of a waterfall, leaving a solid connection behind. At least four larger natural arches are known from the Gardens of Stone Stage Two reserve proposal, one of which has a span of some 15 metres with a thickness of about five metres. Arches of this scale are rare in the Greater Blue Mountains sandstone.

Large natural arch in Gardens of Stone Stage Two, off the eastern edge of Newnes Plateau (Yuri Bolotin)

Landscape The association of rare landform features (pagodas, montane sand dunes, peat swamps) in a contiguous and intact landscape creates an important integrated value for the Gardens of Stone Stage Two reserve proposal. Associated biodiversity values (rare/threatened species and communities – see section 3.2 below) add another dimension to this value. Biodiversity values are more widely distributed across the whole proposal and potentially at least partially dependent on this landscape (this requires further study).

26 Natural and Cultural Values

Complex pagoda landscape with diverse vegetation communities and fauna habitats, Newnes State Forest (Henry Gold)

3.1.3 Catchments The Gardens of Stone Stage Two reserve proposal straddles two major divides, the Great Dividing Range and its easterly offshoot the Blue Mountains Range, and hence occupies the headwater catchments of several major river systems. The Newnes Plateau occupies high country astride the top of the Blue Mountains Range immediately east of the Great Divide and drains in three directions. The Wolgan and Wollangambe Rivers drain the northern and eastern Newnes Plateau area and the eastern side of the Great Dividing Range in Ben Bullen and Wolgan State Forests. Both rivers are tributaries of the Colo River which then flows to the . The west-flowing drains the western side of the Great Dividing Range in Ben Bullen State Forest and flows to the . The Coxs River drains the eastern side of Ben Bullen State Forest, the western side of Newnes Plateau and Western Escarpment and is a key input to the Lake Burragorang storage. The drains small areas of Gardens of Stone Two reserve proposal on the northern side of Blue Mountains Range near Blackheath. It flows into the Hawkesbury-. These headwater catchments are vital to the quality and quantity of water delivered downstream for a variety of purposes. These headwaters are in a high rainfall area (mostly

27 Gardens of Stone Stage 2 Proposal more than 1000 mm pa) and in a generally natural condition, and hence offer high quality catchment conditions. Key downstream purposes for these rivers include water supply and conservation. Reservoirs on the upper Coxs River in the Lithgow area supply water for Lithgow’s town supply and for power stations. Several of these reservoirs (e.g. Lake Lyell, Lake Wallace) are key recreational venues for the district. The Coxs River then flows to Lake Burragorang, Sydney’s major water supply and storage. Water from the Wolgan and Colo Rivers is used for dispersed supply to rural properties in the upper Wolgan Valley and lower Colo Valley. All the Gardens of Stone Stage Two reserve proposal catchments feed water into important conservation reserves. The Turon River traverses Turon National Park and ultimately arrives at Macquarie Marshes Nature Reserve (a wetland of international importance). The other rivers all enter national parks of the GBMWHA at various distances from the Gardens of Stone Stage Two. In the Wollangambe catchment, Grose catchment and eastern parts of the Wolgan catchment, the Gardens of Stone Stage Two joins immediately with Wollemi and Blue Mountains National Parks of the GBMWHA. The catchments of Gardens of Stone Stage Two reserve proposal, whilst largely natural, are not pristine. Impacts causing accelerated erosion, sediment movement and degraded water output include roads, tracks, recreation, coal mining, infrastructure and other developments.

3.2 Biodiversity

Gardens of Stone Stage Two reserve proposal does not have a wide variety of rock/soil types, but it straddles the Sydney Basin and South Eastern Highlands bioregions53, taking in a significant precipitation gradient54 and elevation range. The topography is complex, creating a diversity of exposure from sheltered canyons to exposed plateaus and hill tops. These edaphic factors promote a diversity of ecosystems, plants and animals. A large number of species are found at their western and eastern limits in Gardens of Stone Stage Two. Biodiversity is addressed in this report in terms of plant communities, plant species, animal species and threatened species. Information on non-vascular plants and invertebrate animals is limited and with a few exceptions these biota are not considered here. Note that no biodiversity data or records, including all sources consulted for this report, can be guaranteed to be free from errors or omissions.

53 NPWS (2003) 54 Department of Environment and Conservation (2006)

28 Natural and Cultural Values

3.2.1 Plant communities

Available vegetation mapping and flora surveys The vegetation of major protected areas adjacent to Gardens of Stone Stage Two reserve proposal has been mapped in detail: Wollemi National Park in 199855 and Gardens of Stone National Park in 200256. The vegetation of most of Gardens of Stone Stage Two has also been mapped using relatively up-to-date methodology. Three main studies are relevant:

■■ DEC (2006)57, Vegetation of the Western Blue Mountains, covering Newnes State Forest, Wolgan State Forest, Ben Bullen State Forest east of the Great Dividing Range and small areas on the western escarpment between Clarence and Lithgow;

■■ Blue Mountains City Council (2002)58, covering most of the western escarpment Gardens of Stone Stage Two reserve proposal from Medlow Bath to Bell;

■■ Coalpac (2012) 59, covering the south-western part of Ben Bullen State Forest west of the Great Dividing Range.

A fourth survey (Benson & Keith, 199060) is at a broader scale but is the only available mapping for most of western Ben Bullen State Forest. No detailed vegetation mapping is known for some parts of the western escarpment between Blackheath and Hassans Walls (Lithgow). The Benson & Keith and DEC (Department of Environment and Conservation) surveys each use different methodologies and community definitions. Benson & Keith use broad classes only, with just six communities mapped in the Gardens of Stone Stage Two reserve proposal. DEC used the more recently adopted Statewide Vegetation Classes61, and sub- divided each of them into a number of fine-scale communities. DEC consequently mapped 29 native communities in the Gardens of Stone Stage Two area, within 17 Statewide Classes. The DEC study also provides data on the distribution of plant species, particularly rare and threatened species. The Coalpac survey applied the DEC communities with the addition of one variant community and a number of “derived native grasslands”. The Blue Mountains City Council

55 Bell (1998) 56 EcoGIS (2002) 57 Department of Environment and Conservation (2006) 58 Blue Mountains City Council (2002) 59 Cumberland Ecology (2012) 60 Benson & Keith (1990) 61 Keith (2004)

29 Gardens of Stone Stage 2 Proposal mapping adapted the broad classes of Benson & Keith, refining multiple communities from some of them. Additional studies have been undertaken for various environmental impact assessments, such as for the Springvale Colliery extension62. Together, the mapping has recognised a rich diversity of vegetation types in Gardens of Stone Stage Two reserve proposal, including rainforest, wet sclerophyll forests, dry sclerophyll forests, woodlands, grassy woodlands, swamps, heaths and riverine forests. These communities occupy a range of environments including high plateau tops, swamps, exposed rocks, watercourses, sheltered slopes and canyons.

Mixed montane woodland and heath communities, Newnes State Forest (Karen McLaughlin)

Diversity of plant communities The best available mapping for each part of Gardens of Stone Stage Two reserve proposal has been compiled and shown on Maps 5 and 6, with the legend for Map 5 in Table 4. All mapped communities are listed in Table 3. The difference in community definitions between sources creates difficulties for summarising the diversity of the Gardens of Stone Stage Two vegetation. The communities used for broader scale mapping often encompass two or more communities from finer scale mapping, and even apparently similar communities do not

62 Centennial Coal (2014)

30 Natural and Cultural Values always correspond due to definitional issues. Table 2 shows how many communities have been mapped in each sector of Gardens of Stone Stage Two. By avoiding double-counting a minimum total of 33 different communities in Gardens of Stone Stage Two is suggested.

Table 2. Number of plant communities in sectors of Gardens of Stone Stage Two reserve proposal

Sector of GoS2 No. communities Source & comments mapped Ben Bullen State Forest 14 DEC WBM. Exc. Coalpac variant & derived grasslands, and NW BBSF* Wolgan Valley slopes 9 DEC WBM Newnes Plateau 23 DEC WBM Western BM escarpment 13 BMCC. Some parts not mapped. ALL COMBINED 33 DEC WBM plus BMCC (minimum total number, excluding possible community overlaps between surveys) Excluding Coalpac variant and derived grasslands, and NW BBSF. * NW sector covered only by Benson & Keith at broad scale. Few if any communities likely to occur which are additional to those mapped by DEC and Coalpac in remainder of BBSF.

Tall open forest of the Western Escarpment, near Mount Victoria (Ian Brown)

31 Gardens of Stone Stage 2 Proposal Comments Also mapped in Coalpac BBSF study area Also mapped in Coalpac BBSF study area Also mapped in Coalpac BBSF study area Also mapped in Coalpac BBSF study area Mapped in Coalpac BBSF study area only (not by DEC) Also mapped in Coalpac BBSF study area EEC TSC ActTSC Act EPBC BBSF WVS NP WE Table 3. PlantTable communities mapped four by studies and their distribution within Gardens of Stone Stage reserve Two proposal Plant communityPlant DEC (2005): Vegetation of the Western Blue Mountains Rainforest (1) Temperate GullySandstone Warm Hillslope Mountain Talus Gum-Brown Stringybark-Grey Gum-Broad-leaved Hickory Moist Forest (3) Sheltered Gully Brown Barrel Ferny Forest (4) Newnes Plateau Narrow-leaved Peppermint-Mountain Gum-Brown Stringybark (7) Forest Layered (8) Forest Shrubby Barrel Peppermint-Brown Sheltered Newnes Tableland Gully Snow Gum-Ribbon Gum Montane Grassy Forest (11) Gully Ribbon Gum-Blackwood-AppleTableland (13) Forest Box Tableland Mountain Gum-Snow Gum-Daviesia Montane Open Forest (14) Hollows Black Gum-BlackTableland (15) Open Sally Forest Capertee Rough-barked Box-Grassy (20) Woodlands Apple-Redgum-Yellow (21) Forest Gum-Stringybark Open Grassy Box-Grey Red Slopes Capertee-Wolgan Ash-Layered (26) Open Forest Narrow-leaved Peppemint-Silver-top Plateau Newnes Newnes Plateau Gum Hollows variant: Brittle Gum-Mountain Gum-Scribbly Gum- (26a) Forest Open Shrubby Gum Snow Sandstone Plateau and Ridge Scribbly Gum-Silver-top Ash Shrubby Woodland (28) (29) Forest Shrubby Peppermint Sydney Slopes Sandstone Exposed Blue Mountains Sydney Peppermint-Silver-top Ash Shrubby Woodland (30) Tableland Hills Scribbly Gum-Narrow-leaved Stringybark Shrubby Open Forest (32) Peppermint-Brittle Broad-leaved Gum-Red Open Stringybark Grassy Tableland (33) Forest (34) Forest Grassy Brittle Gum-Broad-leaved Slopes Peppermint Tableland Gully Mountain Gum-Broad-leavedTableland (35) Peppermint Grassy Forest

32 Natural and Cultural Values Comments Matches DEC WBM (1) May include DEC WBM matches (43), BMCC May match several DEC WBM units May match several DEC WBM units Also mapped in Coalpac BBSF study area Also mapped in Coalpac BBSF study area May include DEC WBM (51) EEC TSC ActTSC ActTSC ActTSC ActTSC YES YES YES BBSF WVS NP WE Rainforest E. Open-forest piperita Tall Doryphora sassafras - – Eucalyptus cypellocarpa Eucalyptus Scribbly Gum-Stringybark Woodland Slope Woodland Talus mapping Vegetation (2002): BMCC Blue Mountains Escarpment Complex Blue Mountains Heath and Scrub Blue Mountains Swamps Newnes Plateau Hanging Swamp (51) Swamp Hanging Plateau Newnes Newnes Plateau Rush-Sedge-Snow Gum Hollow Wooded Heath (52) Mountain Hollow Grassy Fen (53) Benson & Keith Wallerawang (1990): 1:100,000 Forest Blue Mountains Plateau Sandstone Coxs River Swamps Newnes Plateau Shrub Swamp Montane Gully Forest Pagoda Rock Complex Plant communityPlant Coxs Permian Red Stringybark-Brittle Gum Woodland (37) Pagoda Rock Sparse Shrubland (43) Tree-Dwarf Rocky Sheoak- (44) Heath Tea Plateau Sandstone Tree-Banksia-Mallee (45) Heath Tea Plateau Newnes Dwarf (46) Heath Sheoak-Banksia Plateau Newnes Newnes Plateau Shrub Swamp (50) apetalum Ceratopetalum

33 Gardens of Stone Stage 2 Proposal Comments May relate to DEC WBM (28) May relate to DEC WBM (26) B&K Matches May include DEC WBM matches (43), B&K Variant on DEC (20) After DEC (20) After DEC (20) After DEC (13) After DEC (33) After DEC (11) After DEC (35) After DEC (35) EEC EPBC Act EPBC ActTSC BBSF WVS NP WE E. piperita Forest Open - radiata Open-forest/Tall Open-forest Open-forest/Tall E. piperita Forest/Woodland Open Alluvial Woodland ssp. - Eucalyptus sieberi Eucalyptus Eucalyptus sclerophylla Bench Woodland Eucalyptus Megalong Footslopes Forest Footslopes Megalong Montane Gully Forest Pagoda Rock Complex Coalpac Environmental (2012): Assessment (communities not already listed under DEC WBM above) grassy non Woodland: Box Apple-Redgum-Yellow Capertee Rough-barked Grasslands Native Derived Grassland Native Derived Box Capertee Rough-barked Apple-Redgum-Yellow (EPBC Act CEEC) Capertee Rough-barked Apple-Redgum-Yellow Box Derived Native Grassland (TSC Grassland Native Derived Box Capertee Rough-barked Apple-Redgum-Yellow Act EEC) Gum-Blackwood-Apple Ribbon Gully Native Derived Forest Tableland Box Grassland Broad-leaved Peppermint-BrittleTableland Gum-Red Stringybark Grassy Woodland Grassland Native Diversity Derived Low Tableland Gully Snow Gum-Ribbon Gum Grassy Forest Low Diversity Derived GrasslandNative Derived Forest Grassy Peppermint Broad-leaved Gum Mountain Gully Tableland GrasslandNative Tableland Gully Mountain Gum Broad-leaved Peppermint Grassy Forest Low Grassland Native Diversity Derived Plant communityPlant Eucalyptus gullickiiEucalyptus oreades Eucalyptus radiata Eucalyptus

34 Natural and Cultural Values

Map 5. Plant communities of Newnes Plateau, Ben Bullen State Forest and areas north Map by Karen McLaughlin. Sources: BMCC (2002), Coalpac (2012), DEC (2006), Benson & Keith (1990)

35 Gardens of Stone Stage 2 Proposal

Table 4. Vegetation reference for Map 5 Sources: BMCC (2002), Coalpac (2012), DEC (2006), Benson & Keith (1990)

36 Natural and Cultural Values

Map 6. Plant communities of the Western Escarpment Map by Karen McLaughlin. Source: BMCC (2002)

37 Gardens of Stone Stage 2 Proposal

Endangered Ecological Communities Endangered Ecological Communities (EECs) and Vulnerable Ecological Communities (VECs) are legally recognised at state level under the Threatened Species Conservation Act 1995, and EECs at national level under the Environmental Protection and Biodiversity Conservation Act 1999. The Benson and Keith mapping is not at a fine enough scale to identify EECs (although the B &K 1990 mapping has some swamp omissions/errors and is obviously at a smaller scale, the DEC swamp mapping also has various errors/omissions due to the limited amount of sampling that was done, as well as some misinterpretation). Only the DEC and Coalpac surveys identified EECs within the Gardens of Stone Stage Two reserve proposal, and these are noted in Table 5 (“Blue Mountains Swamps” equivalents were not listed as an EEC until after BMCC’s 2002 report). Excluding “double-ups” (slight variations or communities mapped under different names by different studies), Gardens of Stone Stage Two reserve proposal can be considered to include six EECs: one grassy woodland and five swamp/wetland communities. Map 7 (from the DEC 2006 report) shows EECs mapped by that project, relevant areas included being Newnes Plateau, part Ben Bullen State Forest and small areas on the Western Escarpment.

Snowfall in Newnes Plateau Rush-Sedge-Snow Gum Hollow Wooded Heath EEC (Ian Brown)

38 Natural and Cultural Values

Table 5. Threatened Ecological Communities (EEC or VEC) recorded within Gardens of Stone Stage Two reserve proposal, with approximate distribution

Mapped community EEC or VEC EEC Distribution within (and source) TSC Act EPBC Act Gardens of Stone Stage Two Capertee Rough-barked White Box-Yellow Box- Grassy White Box Woodlands Wolgan Valley slopes Apple-Redgum-Yellow Box- Blakely’s Red Gum Woodland Grassy Woodlands (DEC 20) EEC Capertee Rough-barked White Box-Yellow Box- BBSF (Coalpac area) Apple-Redgum-Yellow Box Blakely’s Red Gum Woodland Derived Native Grassland EEC (Coalpac after DEC)** Capertee Rough-barked Grassy White Box Woodlands BBSF (Coalpac area) Apple-Redgum-Yellow Box Derived Native Grassland (Coalpac after DEC)* Newnes Plateau Shrub Newnes Plateau Shrub Temperate Highland Peat Newnes Plateau Swamp (DEC 50) Swamps EEC Swamps on Sandstone

Newnes Plateau Hanging Newnes Plateau Shrub Temperate Highland Peat Newnes Plateau Swamp (DEC 51) Swamps EEC Swamps on Sandstone

Newnes Plateau Rush- Montane Peatlands and Temperate Highland Peat Newnes Plateau Sedge-Snow Gum Hollow Swamps etc. EEC Swamps on Sandstone Wooded Heath (DEC 52)

Mountain Hollow Grassy Fen Montane Peatlands and BBSF (DEC 53) Swamps etc. EEC Blue Mountains Swamps Blue Mountains Swamps VEC Temperate Highland Peat Western BM escarpment (BMCC)** Swamps on Sandstone Source: DEC (2006), Coalpac (2012) * Coalpac mapped two variations of this community (derived from DEC 20), distinguished according to the differing TSC Act and EPBC Act definitions. They cannot be counted as additional EECs to the DEC 20 community. ** Some areas of this BMCC community are equivalent to the TSC Act EEC, but cannot be counted as an additional EEC to the Newnes Plateau swamp communities.

In relation to the shrub swamp EECs, the OEH Capertee Subregional Assessment63 states the following:

The Newnes Plateau is important for the conservation of upland swamps and their dependent flora and fauna in NSW…The entire extent of the Newnes Plateau Shrub Swamp EEC is 650 ha of which only 160 ha is protected in Blue Mountains and Wollemi National Parks…These swamps are characteristically groundwater dependent ecosystems and support species of groundwater dependent flora and fauna, including several threatened species.

Newnes Plateau Hanging Swamps and their dependent biota are similarly groundwater dependent.

63 Office of Environment and Heritage (2014)

39 Gardens of Stone Stage 2 Proposal

The OEH Capertee Subregional Assessment64 states that Mountain Hollow Grassy Fen EEC:

…occurs on alluviums on the central and southern tablelands in frost hollows and depressions at elevations ranging between 865-950 m and rainfall range between 800-930 mm where it forms open tussock grassy swamps. Soils are alluvial peats and clay loams…which are often waterlogged…This community is poorly represented in conservation reserves in the region…

Mountain Hollow Grassy Fen EEC, Ben Bullen State Forest (Julie Favell)

64 Office of Environment and Heritage (2014)

40 Natural and Cultural Values

Map 7. Endangered Ecological Communities mapped in Western Blue Mountains study area by DEC 2006 (Map 12 from The Vegetation of the Western Blue Mountains, Vol. 1 Technical Report)

41 Gardens of Stone Stage 2 Proposal

Conservation status of vegetation communities For each mapped community, the DEC 2006 survey calculated the following data as at May 2004:

■■ total mapped area;

■■ estimated total area extant within the Hawkesbury-Nepean Catchment (HNC);

■■ estimated total area cleared within HNC;

■■ estimated area of pre-clearing extent protected within conservation reserves (NPW Act).

These data enable the conservation status of each mapped community to be assessed (for that part of Gardens of Stone Stage Two reserve proposal covered by the DEC mapping, and on the assumption that significant changes since 2004 to the data and approximated percentages are unlikely.) This assessment is shown in Table 5, with communities listed in approximate order of conservation potential within Gardens of Stone Stage Two. Table 6 includes some further analysis from that done by DEC, in relation to Gardens of Stone Stage Two specifically. This analysis shows that protection of the Newnes Plateau-Ben Bullen State Forest-Wolgan Valley slopes landscape could make a major contribution to ecosystem conservation by protecting a number of very restricted plant communities that are also poorly represented in existing conservation reserves, or not protected at all. Further analysis is required to determine what proportion of particular communities are covered by Gardens of Stone Stage Two reserve proposal, but Table 7 lists ten poorly conserved communities (five of them EECs) that have substantial representation within Gardens of Stone Stage Two and a further five communities (one an EEC) for which Gardens of Stone Stage Two offers lesser but significant conservation potential. It should be noted that the total mapped extent of communities 52 and 53 within the Western Blue Mountains study area is extremely limited, to only 46 hectares and 98 hectares respectively (see Table 5). All of this extent would appear to be within Gardens of Stone Stage Two. Only 3% of community 52 and 7.5% of community 53 are reported to be represented in existing conservation reserves (Table 5).

42 Natural and Cultural Values EEC status EEC EEC EEC EEC EEC Occurrence in Gardens of Stone Stage Two (DEC WBM study area) Ben Bullen SF slopes Valley Wolgan Newnes Plateau slopes Valley Wolgan Ben Bullen SF Newnes Plateau Ben Bullen SF Newnes Plateau Newnes Plateau Ben Bullen SF escarpmentWestern Ben Bullen SF Newnes Plateau Newnes Plateau Ben Bullen SF escarpmentWestern Newnes Plateau Ben Bullen SF slopes Valley Wolgan Newnes Plateau Ben Bullen SF slopes Valley Wolgan Wolgan Valley slopes Valley Wolgan Newnes Plateau Newnes Plateau 15% 16% 16% 73% HNC 7.5% 5.5% 100% 100% 100% 100% 100% 100% 100% 100% c.78% c.54% within extent % of total study area study 0% 0% 0% 0% 0% 0% 0% 0% (ha) <5% <2% <2% <2% <10% 0-10% extent 10-20% 10-30% Est. area protected protected of original original of 95% >70% >70% >70% <10% <10% 30-70% 30-70% 10-30% 10-30% 10-30% 75-85% 65-80% 60-80% 60-80% 60-80% Est. total in HNC (ha) area cleared cleared area 797 861 384 1739 2477 >501 2695 9369 5457 3000 >500 18800 10500 18800 18800 1300 * Est. total area extant in HNC (ha) 98 274 797 861 394 384 1041 1739 2477 1586 3077 2695 9369 5457 2200 3048 area (ha) area Total mapped Total Table 6. PlantTable communities, clearing loss, reservation status and occurrence within Gardens of Stone Stage reserve Two proposal DEC WBM Community WBM DEC Tableland Slopes Brittle Slopes Gum-Broad-leaved Grassy Peppermint Tableland (34) Forest Hillslope Mountain Talus Gum-Brown Stringybark-Grey Gum- Broad-leaved Hickory Moist Forest (3) Coxs Permian Red Stringybark-Brittle Gum Woodland (37) Gum-Ribbon Gully Snow Tableland Gum Montane Grassy (11) Forest Tableland Gully Mountain Gum-Broad-leavedTableland Peppermint (35) Forest Grassy Newnes Plateau Narrow-leaved Peppermint-Mountain Gum- Brown Stringybark Layered Forest (7) Tableland Mountain Gum-Snow Gum-Daviesia Montane Open (14) Forest Gully Ribbon Gum-Blackwood-AppleTableland (13) Forest Box Tableland Broad-leaved Peppermint-Brittle Broad-leaved Gum-Red Tableland Stringybark Grassy Open Forest (33) Newnes Sheltered Peppermint-Brown Barrel Shrubby Forest (8) Forest Shrubby Barrel Peppermint-Brown Sheltered Newnes Gum-Stringybark Box-Grey Red Slopes Capertee-Wolgan (21) Forest Open Grassy Mountain Hollow Grassy Fen (53) Capertee Rough-barked Apple-Redgum-Yellow Box-Grassy Box-Grassy Apple-Redgum-Yellow Capertee Rough-barked (20) Woodlands Tableland Hollows Black Gum-BlackTableland (15) Open Sally Forest Newnes Plateau Hanging Swamp (51) Swamp Hanging Plateau Newnes Newnes Plateau Shrub Swamp (50)

43 Gardens of Stone Stage 2 Proposal EEC status EEC EEC Occurrence in Gardens of Stone Stage Two (DEC WBM study area) Newnes Plateau Ben Bullen SF slopes Valley Wolgan Newnes Plateau Newnes Plateau Newnes Plateau Ben Bullen SF slopes Valley Wolgan escarpmentWestern Newnes Plateau Newnes Plateau escarpmentWestern Newnes Plateau escarpmentWestern Newnes Plateau Newnes Plateau Ben Bullen SF escarpmentWestern Newnes Plateau Ben Bullen SF escarpmentWestern Newnes Plateau Ben Bullen SF slopes Valley Wolgan escarpmentWestern Newnes Plateau Newnes Plateau Ben Bullen SF slopes Valley Wolgan escarpmentWestern 1% 4% 3% 11% 24% <1% 18% 24% 25% 20% 38% HNC 1.5% within extent % of total study area study (ha) 95% <15% >80% >80% >80% >80% >99% extent 50-70% 60-70% 70-85% 70-85% 70-85% Not listed Est. area protected protected of original original of <1% <5% <5% <5% 5-20% 10-20% 10-20% 10-20% 10-20% 10-30% 35-55% 50-80% Not listed Est. total in HNC (ha) area cleared cleared area 6000 8000 8000 8000 5000 >7200 15300 28640 1700 * 28640 28640 111800 Not listed Est. total area extant in HNC (ha) (2006) DEC Source: 4 71 46 144 296 1925 1697 7601 3240 1898 6864 3000 area (ha) area Not listed communities are not as well conserved as indicated. conserved as not are well communities Total mapped Total Swamps of the New England Tableland, NSW North Coast, Sydney Basin, South East Corner, South Eastern Highlands and Australian Alps Bioregions”. Therefore these sub- Therefore Bioregions”. Alps Australian and Highlands South Eastern South East Corner, Basin, North NSW Coast, Sydney Tableland, of the England New Swamps * in relation to these two communities, this and subsequent columns seem to refer to the status of the broader community class to which they belong: “Montane Peatlands and and Peatlands “Montane belong: they which to class the of to the community status refer seem broader to columns subsequent and this these two communities, to relation * in DEC WBM Community WBM DEC Tableland Hills Scribbly Gum-Narrow-leavedTableland Stringybark (32) Forest Open Shrubby Newnes Plateau Rush-Sedge-Snow Gum Hollow Wooded Rush-Sedge-Snow Wooded Hollow Gum Plateau Newnes Heath (52) Sheltered Gully Brown Barrel Ferny Forest (4) Sandstone Plateau Tea Tree-Dwarf Rocky Sheoak-Banksia Tea Plateau Sandstone Heath (44) Newnes Plateau Tea Tree-Banksia-Mallee (45) Heath Tea Plateau Newnes Dwarf (46) Heath Sheoak-Banksia Plateau Newnes Newnes Plateau Narrow-leaved Peppermint-Silver-top Ash- Narrow-leaved Peppermint-Silver-top Plateau Newnes (26) Forest Open Layered Newnes Plateau Gum Hollows variant: Brittle Gum-Mountain (26a) Forest Gum-Scribbly Open Gum-Snow Shrubby Gum Sandstone Plateau and Ridge Scribbly Gum-Silver-top Ash Shrubby Woodland (28) Sandstone Slopes Sydney Peppermint Shrubby Forest (29) Forest Shrubby Peppermint Sydney Slopes Sandstone Exposed Blue Mountains Sydney Peppermint-Silver-top Ash (30) Woodland Shrubby Sandstone Gully Warm Temperate Rainforest (1) Temperate GullySandstone Warm Pagoda Rock Sparse Shrubland (43)

44 Natural and Cultural Values

Table 7: Poorly conserved plant communities with significant representation within Gardens of Stone Stage Two reserve proposal

COMMUNITY (WBM DEC 2006) MAJOR conservation potential within GoS2 Newnes Plateau Shrub Swamp (50) Newnes Plateau Hanging Swamp (51) Newnes Plateau Rush-Sedge-Snow Gum Hollow Wooded Heath (52) * Mountain Hollow Grassy Fen (53) * Tableland Mountain Gum-Snow Gum-Daviesia Montane Open Forest (14) Tableland Gully Ribbon Gum-Blackwood-Apple Box Forest (13) Tableland Hollows Black Gum-Black Sally Open Forest (15) Capertee Rough-barked Apple-Redgum-Yellow Box-Grassy Woodlands (20) Tableland Gully Mountain Gum-Broad-leaved Peppermint Grassy Forest (35) Newnes Plateau Narrow-leaved Peppermint-Mountain Gum-Brown Stringybark Layered Forest (7) SIGNIFICANT conservation potential within GoS2 Capertee-Wolgan Slopes Red Box-Grey Gum-Stringybark Grassy Open Forest (21) Hillslope Talus Mountain Gum-Brown Stringybark-Grey Gum-Broad-leaved Hickory Moist Forest (3) Tableland Slopes Brittle Gum-Broad-leaved Peppermint Grassy Forest (34) Coxs Permian Red Stringybark-Brittle Gum Woodland (37) Tableland Gully Snow Gum-Ribbon Gum Montane Grassy Forest (11) Source: DEC (2006) * These two communities are included in the TSC Act listing of “Montane Peatlands and Swamps of the New England Tableland, NSW North Coast, Sydney Basin, South East Corner, South Eastern Highlands and Australian Alps Bioregions”65

3.2.2 Plant species Floristic information for Gardens of Stone Stage Two reserve proposal comes mainly from vegetation mapping (above) and environmental assessments (mainly for coal mining proposals). Environmental groups and local volunteers, especially Lithgow Environment Group members, have gathered some information on plant species in areas subject to coal mining and mining proposals. Local enthusiasts have published two guidebooks on the plants of Hassans Wall Reserve. These informal studies have added to the body of available information.

Plant species diversity No comprehensive survey has been undertaken for plant species occurring in Gardens of Stone Stage Two reserve proposal. Table 8 lists species diversity data for sub-areas and adjoining areas. Hassans Walls and Mount York Reserves are part of Gardens of Stone Stage Two, most of the Coalpac Consolidation area is part of Gardens of Stone Stage Two, Western Blue Mountains mapping encompasses much of Gardens of Stone Stage Two but extends much further and Gardens of Stone National Park adjoins Gardens of Stone Stage Two.

65 DEC (2006)

45 Gardens of Stone Stage 2 Proposal

These surveys vary in their intensity and accuracy, and it is not always clear if totals include introduced species, or exclude non-vascular species. The survey of Hassans Walls Reserve, by community volunteers, is perhaps the most comprehensive of any sub-area within Gardens of Stone Stage Two reserve proposal. The total of 487 species includes mosses and bryophytes, with a further 40 fungi and lichens also recorded. Of 637 plant species recorded for Ben Bullen State Forest, a notable 46 or nearly 14% are orchids, against an estimated Australian average of 5-6%66. Combining plant species lists from the Atlas of NSW Wildlife67 for Ben Bullen, Newnes and Wolgan state forests gives a total native plant biodiversity of at least 967 species. Plant diversity for the whole Gardens of Stone Stage Two reserve proposal (39,000 ha), including the somewhat different environments of the western escarpment, would exceed 1000 native species. This compares with about 1500 species recorded for the million-hectare Greater Blue Mountains World Heritage Area when it was nominated in 199768.

Table 8. Total numbers of native plant species in areas related to Gardens of Stone Stage Two reserve proposal

Region Area No. native Source plant species Western Blue Mtns 157,000 ha 1551 Department of Environment and Conservation (2006) Newnes State Forest 23,338 ha 814 Atlas of NSW Wildlife (http://www.environment.nsw.gov.au/ atlaspublicapp/UI_Modules/ATLAS_/ AtlasSearch.aspx) Hassans Walls Reserve 770 ha 487# Lithgow & District Community Nursery (Lollback et. al., 2014) Gardens of Stone NP 15,000 ha 576 Atlas of NSW Wildlife Mount York Reserve* 653 ha* 220* Gondwana Consulting Pty Ltd (2008) Ben Bullen SF 7812 ha 637 Atlas of NSW Wildlife Coalpac Consolidation project area c.800 ha 590 Coalpac (Cumberland Ecology, 2012), Lithgow Environment Group Ltd (2012) * but not all of reserve included in survey; # includes mosses and bryophytes

Rare and threatened plants Threatened plant species are legally recognised at state level under the Threatened Species Act 1995, and at national level under the Environmental Protection and Biodiversity Conservation Act 1999. A much larger number of plants are recognised under the Register of Threatened Australian Plants (or ROTAP)69, which was first compiled in 1979 but is still maintained by CSIRO. The ROTAP list is authoritative but has no legal basis. One advantage of the ROTAP list over the statutory lists is that it includes many species which are significant

66 Jones (2008) 67 http://www.environment.nsw.gov.au/atlaspublicapp/UI_Modules/ATLAS_/AtlasSearch.aspx 68 New South Wales National Parks and Wildlife Service & Environment Australia (1998) 69 Briggs & Leigh (1996)

46 Natural and Cultural Values due to a restricted range but which may not be under specific threat. ROTAP codes are shown in Table 9. Information on rare and threatened plants in Gardens of Stone Stage Two reserve proposal is available from a range of sources including the vegetation mapping by DEC and BMCC (see above), and the Atlas of NSW Wildlife70 for State Forests. PlantNET71 and Australia’s Virtual Herbarium72 provide location data. Other information sources include recent environmental assessments for mining projects, including Coalpac73, Angus Place74, Pine Dale75 and Springvale76, submissions to those assessments, and a guidebook to plants of Hassans Wall Reserve77.

Rock Sprengelia (Sprengelia monticola) rare plant, Western Escarpment. This species inhabits shaded cliff faces (Ian Brown)

Table 10 lists the 42 rare and threatened plants that have been recorded in Gardens of Stone Stage Two reserve proposal, together with their status under the three risk lists and their general distribution within Gardens of Stone Stage Two. This number can be

70 http://www.environment.nsw.gov.au/atlaspublicapp/UI_Modules/ATLAS_/AtlasSearch.aspx 71 http://plantnet.rbgsyd.nsw.gov.au 72 http://avh.ala.org.au/occurrences/search#tab_mapView 73 Cumberland Ecology (2012) 74 RPS Australia East Pty Ltd (2014) 75 R.W Corkery & Co. (2010) 76 Centennial Coal (2014) 77 Lollback et. al. (2014)

47 Gardens of Stone Stage 2 Proposal considered a minimum. Table 11 shows a further seven species that have been described in various references as being either likely to occur or as having potential to occur within parts of Gardens of Stone Stage Two. Seven of the species in Table 10 are of particular note, being either limited to or partially limited to Gardens of Stone Stage Two reserve proposal. Only one plant species is known to be entirely restricted to Gardens of Stone Stage Two, hindii. Leptospermum blakelyi is very close to being restricted to the area. Leucochrysum graminifolium is restricted to the greater Gardens of Stone pagoda landscape, south of the . Gardens of Stone Stage Two takes in a substantial proportion of the known occurrence of four other species, three of which are known from only one other, disjunct, area. The OEH Capertee Subregional Assessment78 outlines the most important threatened plant species of Newnes Plateau:

The Newnes Plateau is another area with a high level of plant endemism. Derwentia blakelyi favours moist sites, often along streams and among sedges and tea tree although it can occur on rocky slopes. It is not represented in any conservation reserve…Boronia deanei is a species of upland swamps…it is not well represented in conservation reserves, especially within the Greater Blue Mountains region….Persoonia hindii is restricted to the Newnes Plateau and is not protected in any conservation reserve…this species was only discovered in 1989 and all known locations are within Newnes State Forest where it occurs in dry sclerophyll forests and woodlands on sandy soils…

Table 9. ROTAP Codes79

Code Meaning 1 Known from one collection only. 2 Geographic range in Australia less than 100 km. 3 Geographic range in Australia greater than 100 km. X Presumed extinct. E Endangered. V Vulnerable. R Rare. K Poorly known. C Reserved. At least one population in National Park or other proclaimed reserve(s). a 1000 plants or more are known to occur within a conservation reserve(s). i Less than 1000 plants are know to occur within a conservation reserve(s). - Reserved population size is not adequately known. t Total known population is reserved. + Taxon has a natural occurrence overseas.

78 Office of Environment and Heritage (2014) 79 Briggs & Leigh (1996)

48 Natural and Cultural Values

Hind’s Mintbush (Prostanthera hindii), a rare plant restricted to sandstone of the north-western Sydney Basin (Ian Brown)

Rare plant Deane’s Boronia (Boronia deanei) flowering in Newnes Plateau Shrub Swamp EEC, Newnes Plateau (Ian Baird)

49 Gardens of Stone Stage 2 Proposal

Table 10. Rare and threatened plants recorded in Gardens of Stone Stage Two reserve proposal and specific sectors

Status Status Status

Species Common name TSC EPBC NP WE

ROTAP WVS Act Act BBSF

Acacia asparagoides - - 2R ✓ ✓ ✓ Acacia bynoeana Bynoe’s Wattle E E 3VCi ✓ Acacia flocktoniae Flockton Wattle V V 2VC- ✓ Acacia meiantha A - - 2RCi ✓ ✓ Acrophyllum austral V V 2VCi ✓ Alamaleea incurvata - - 2RC-t ✓ Atkinsonia ligustrina - - 2RCa ✓ ✓ Boronia deanei subsp. deanei B Deane’s Boronia V V 3VCa ✓ Caesia parviflora var. minor Small Pale Grass-lily E - - ✓ Deyeuxia microseta - - 3KC- ✓ Dillwynia stipulifera C - - 3RCa ✓ Dillwynia tenuifolia V - 2RCa ✓ Epacris muelleri - - 3RCi ✓ Eucalyptus aggregata Black Gum V V - ✓ Eucalyptus cannonii Capertee Stringybark V - 2VCi ✓ ✓ Eucalyptus cunninghamii Cliff Mallee Ash - - 2RCa ✓ Eucalyptus gregsoniana Wolgan Snow gum - - 3RCa ✓ ✓ Euphrasia bowdeniae V V 2VCit ✓ Genoplesium superbum Superb Midge Orchid E - 2RC-t ✓ Gonocarpus longifolius - 3RC- ✓ ✓ evansiana Evans Grevillea V V 2VC- ✓ constablei - - 2RCa ✓ Haloragodendron lucasii E - 2RCat ✓ Lastreopsis hispida Bristly Shield Fern E - - ✓ Leptospermum blakelyi D - - 2R ✓ Leptospermum rupicola - - 3RC- ✓ Leucochrysum graminifoliumE Pagoda Daisy - - 2R ✓ ✓ ✓ Leucopogon fletcheri subsp. fletcheri E - 2RC- ✓ Notochloe microdon - - 2RC- ✓ ✓ Olearia quercifolia F Oak-leaved Olearia - - 3RC- ✓ Needle Geebung V V 2VC- ✓ ✓ Persoonia hindii G Hind’s Geebung E 2V ✓ Persoonia marginata Clandulla Geebung V V 2V ✓ Persoonia recedens - - 2R ✓ ✓ Philotheca obovalis - - 3RCa ✓ ✓ Prostanthera cryptandroides ssp. Wollemi Mint-bush V V - ✓ ✓ cryptandropides Prostanthera hindii Hind’s Mint-bush - - 2KC- ✓ ✓ Pseudanthus divaricatissimus - - 3RCa ✓ ✓ Pultenaea glabra Smooth Bush-pea V V 3VCa ✓ ✓ Rupicola apiculata - - 2RCa ✓ Sprengelia monticola Rock Sprengelia - - 2RC-t ✓ Derwentia blakelyi V - 2K ✓ ✓ TOTALS 42 20 11 38 9 2 28 21 A Newnes Plateau and Mullion Range (Orange) only B Newnes Plateau and Kanangra-Boyd swamps only C Newnes Plateau and Budawangs only D Newnes Plateau-Hassans Walls endemic E Blue Mountains endemic, sandstone pagoda landscapes south of Capertee River only F Blue Mountains endemic G Newnes Plateau endemic BBSF = Ben Bullen State Forest WVS = Wolgan Valley slopes NSF = Newnes Plateau WE = Western escarpment

50 Natural and Cultural Values

Woodland of rare plant Eucalyptus agglomerata (Julie Flavell)

Table 11. Other rare and threatened plants likely to occur, or with potential to occur, in Gardens of Stone Stage Two reserve proposal

Status Status Status Species Common name TSC Act EPBC Act ROTAP Caesia parviflora var. minor E - - Darwinia peduncularis V - 3RCi Diuris aequlis Buttercup Doubletail V V 3VC- Euphrasia arguta CE CE 3X Prasophyllum fuscum Tawny Leek Orchid CE - - Prostanthera stricta Mt Vincent Mintbush V V 2V Rulingia prostrata - - 2ECi Thesium australe Austral Toadflax V V 3VCi+

51 Gardens of Stone Stage 2 Proposal

Pagoda Daisies (Leucochrysum graminifolium) are restricted to pagoda landscapes of the western Blue Mountains (Jaime Plaza van Roon)

3.2.3 fAuna diversity No comprehensive fauna survey has been undertaken for Gardens of Stone Stage Two reserve proposal. This report primarily addresses vertebrate fauna. Numbers of native vertebrate species recorded in the Atlas of NSW Wildlife80 for Ben Bullen State Forest, Wolgan State Forest, Newnes State Forest and Gardens of Stone National Park are shown in Table 12. The minimum proven diversity for Gardens of Stone Stage Two is represented by combining data from Newnes, Ben Bullen and Wolgan state forests which gives 317 terrestrial vertebrate species, plus two recorded fish species. The western escarpment sector might add a few more species. Of note is the diversity of bats, by far the most diverse of all mammalian groups in Gardens of Stone Stage Two reserve proposal, with a total of 20 species.

80 http://www.environment.nsw.gov.au/atlaspublicapp/UI_Modules/ATLAS_/AtlasSearch.aspx

52 Natural and Cultural Values

Table 12. Number of native fauna species in areas related to Gardens of Stone Stage Two reserve proposal

Area Relevance to Amphibians Reptiles Birds Mammals TOTAL Gardens of Stone Two Gardens of Stone Adjoining GARDENS 13 39 136 46 234 NP OF STONE STAGE TWO Newnes SF Entirely within 17 43 171 50 281 GARDENS OF STONE STAGE TWO Ben Bullen SF Mostly within 9 20 104 37 170 GARDENS OF STONE STAGE TWO Wolgan SF Entirely within 0 1 19 2 22 GARDENS OF STONE STAGE TWO Combined Newnes- Entirely within 18 47 185 67 317 Ben Bullen-Wolgan GARDENS OF STONE state forests STAGE TWO Source: Atlas of NSW Wildlife

Wombats are common throughout Gardens Of Stone Stage Two, and one of at least 67 native mammals found in the area (Yuri Bolotin)

53 Gardens of Stone Stage 2 Proposal

3.2.4 threatened fauna The best available information on threatened fauna in the Gardens of Stone Stage Two reserve proposal is from the Atlas of NSW Wildlife (NB: this data is “only indicative” and “cannot be considered a comprehensive inventory and may contain errors and omissions”) 81. Table 13 lists all 42 threatened species which have been recorded in Ben Bullen, Wolgan and Newnes State Forests. A few of these may no longer be extant (e.g. Brush-tailed Rock- wallaby) while several other species may be expected to occur but have not been recorded to date. The Southern Myotis (Myotis macropus) has been reported for Maiyangu Marrugu Aboriginal Place82. Of particular note are the threatened species associated with the high altitude swamps which are of such limited distribution. The swamps of Gardens of Stone Stage Two reserve proposal comprise a significant proportion of the known habitat for the Blue Mountains Water-skink (Eulamprus leuraensis) and Giant Dragonfly Petalura( gigantea), both Endangered. The endangered Bathurst Copper Butterfly Paralucia( spinifera) is reported from Ben Bullen State Forest, near the eastern edge of its range. Also of interest is the large number of threatened bat species, numbering seven, many of which are dependent on hollows within the Gardens of Stone Stage Two forests.

The Little Eagle (Vulnerable) is one of 42 threatened species of fauna found in Gardens of Stone Stage Two (Julie Flavell)

81 http://www.environment.nsw.gov.au/atlaspublicapp/UI_Modules/ATLAS_/AtlasSearch.aspx 82 Eco Logical Australia (2013)

54 Natural and Cultural Values

Table 13. Threatened fauna species recorded for State Forests within Gardens of Stone Stage Two reserve proposal

Species Common name Status Status BBSF WSF NSF TSC EPBC Act Act Amphibians Mixophyes balbus Stuttering Frog E V ✓

Litoria littlejohni Littlejohn’s Tree Frog V V ✓

Reptiles

Hoplocephalus bungaroides Broad-headed Snake E V ✓

Eulamprus leuraensis Blue Mountains Water skink E E ✓

Varanus rosenbergi Rosenberg’s Goanna V - ✓

Birds

Xanthomyza phrygia Regent Honeyeater E CE ✓

Hieraaetus morphnoides Little Eagle V - ✓ ✓

Callocephalon fimbriatum Gang-gang Cockatoo V - ✓ ✓

Calyptorhynchus lathami Glossy Black-cockatoo V - ✓ ✓

Glossopsitta pusilla Little Lorikeet V - ✓ ✓ Ninox strenua Powerful Owl V ✓ ✓

Climacteris picumnus victoriae Brown Treecreeper (eastern subsp.) V ✓ ✓

Grantiella picta Painted Honeyeater V V ✓

Daphoenositta chrysoptera Varied Sitella V - ✓

Melanodryas cucullata cucullata Hooded Robin (SE form) V - ✓ ✓

Petroica boodang Scarlet Robin V - ✓ ✓ ✓

Petroica phoenicea Flame Robin V - ✓ ✓

Lophoictinia isura Square-tailed Kite V - ✓

Ninox connivens Barking Owl V - ✓

Tyto novaehollandiae Masked Owl V - ✓

Tyto tenebricosa Sooty Owl V - ✓

Chthonicola sagittata Speckled Warbler V - ✓

Melithreptus gularis gularis Black-chinned Honeyeater (eastern V - ✓ subspecies) Pomatostomus temporalis Grey-crowned Babbler (eastern V - ✓ temporalis subspecies) Daphoenositta chrysoptera Varied Sitella V - ✓

Stagonopleura guttata Diamond Firetail V - ✓

Mammals

Petaurus norfolcensis Squirrel Glider V - ✓ ✓

Saccolaimus flaviventris Yellow-bellied Sheathtail-bat V - ✓

Mormopterus norfolkensis Eastern Freetail-bat V - ✓

55 Gardens of Stone Stage 2 Proposal

Species Common name Status Status BBSF WSF NSF TSC EPBC Act Act

Chalinolobus dwyeri Large-eared Pied Bat V V ✓ ✓

Falsistrellus tasmaniensis Eastern False Pipistrelle V - ✓ ✓

Miniopterus schreibersii Eastern Bentwing-bat V - ✓ ✓ oceanensis Scoteanax rueppellii Greater Broad-nosed Bat V - ✓ ✓

Vespadelus troughtoni Eastern Cave Bat V - ✓ ✓ Myotis macropus Southern Myotis V ✓

Dasyurus maculatus Spotted-tail Quoll V E ✓

Phascolarctos cinereus Koala V V ✓

Cercartetus nanus Eastern Pygmy-possum V - ✓

Petrogale penicillata Brush-tailed Rock-wallaby E V ✓

Pseudomys novaehollandiae New Holland Mouse - V ✓

Invertebrates

Paralucia spinifera Bathurst Copper Butterfly E V ✓

Petalura gigantea Giant Dragonfly E - ✓ ✓

TOTALS 42 41 12 22 2 35

The Broad-headed Snake (Endangered) is a rare inhabitant of rocky terrain in Gardens of Stone Stage Two (Ian Brown)

56 Natural and Cultural Values

The Sooty Owl (Vulnerable) is a rare resident of in Gardens of Stone Stage Two, and one of four threatened owls recorded for the area (Akos Lumnitzer)

Blue Mountains Water-skink The OEH Capertee Subregional Assessment83 summarised the significance of Newnes Plateau for the endangered Blue Mountains Water Skink (Eulamprus leuraensis):

The Blue Mountains water-skink…occurs in a limited area of the middle and upper Blue Mountains from Newnes Plateau…to just south of Hazelbrook…between the elevations of 560-1060m. Genetic studies have shown that populations from the Newnes Plateau are distinct from those of other areas of the Blue Mountains and even local populations less than 0.5 kilometres apart can be distinctive. Dispersal between populations is thought to be limited and if it occurs are (sic) mostly males…the Blue Mountains water-skink is restricted to sedge and shrub swamp habitats which form on valley floors and sides or undulating plateau on high dissected Narrabeen Sandstone plateau (sic). Swamps are characterised by sandy-peaty soils that are permanently wet. However not all potentially suitable swamps are inhabited…and the size of swamps may be important…

83 Office of Environment and Heritage (2014)

57 Gardens of Stone Stage 2 Proposal

The high altitude swamps of Gardens of Stone Stage Two are a stronghold of the Blue Mountains Water-skink (Endangered) (Nakia Belmer)

Giant Dragonfly The NSW Scientific Committee Final Determination for endangered species listing for the Giant Dragonfly Petalura( gigantea) states:

The Giant Dragonfly…is an extremely large, and unusual species of dragonfly, which is considered to be largely terrestrial throughout its life cycle. It is one of the few extant members of an ancient family, the Petaluridae…The giant dragonfly has been recorded from permanent wetlands, both coastal and upland, from Moss Vale northwards to southern Queensland, but has not been recorded in most areas for many years. A number of sites from which old records exist are no longer wetlands. Given the spectacular and highly visible nature of the adults the sparsity of recent records is likely to be indicative of a real decline in the species’ distribution…The declining population size and loss or degradation of wetland habitats in which it occurs, are threats to the survival of the species84

84 http://www.environment.nsw.gov.au/determinations/GiantDragonflyEndSpListing.htm

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Baird and Burgin note that the Giant Dragonfly require a specific habitat of groundwater- dependent mires, and they are thus subject to a range of threatening processes, including groundwater impacts caused by underground coal mining85.

A female Giant Dragonfly (Ian Baird)

Purple (Bathurst) Copper Butterfly

The Bathurst Copper Butterfly (Paralucia spinifera)…is one of Australia’s rarest butterfly species…and is only found between Bathurst and Hartley in the Central Tablelands of New South Wales…restricted to elevations above 900 metres where it feeds exclusively on a form of Blackthorn, Bursaria spinosa subsp. lasiophylla. The Bathurst Copper Butterfly has a mutualistic relationship with a species of small black ant, Anonychomyrma itinerans, which protect the caterpillar from predation and host the pupae within their nest. The Bathurst Copper Butterfly is known from a total of twenty-nine sites comprising less than thirty hectares of habitat, which makes it vulnerable to the operation of threatening processes.86

85 Baird & Burgin (2016) 86 NSW National Parks and Wildlife Service (2001)

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Purple Copper Butterfly (Endangered) (Robin Murray)

Glossy Black-cockatoos (Vulnerable) feed almost exclusively on She-oak seeds (Julie Flavell)

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3.2.5 Ecosystems An ecosystem approach provides a more holistic assessment of natural values than the reductive approach of considering specific biological components (as above). Pagoda landscapes and upland swamps are two ecosystems within Gardens of Stone Two that are unique to the region and poorly conserved. The OEH Capertee Subregional Assessment87 concluded as follows:

The upland swamps of the Newnes Plateau and associated flora and fauna are unique in NSW and south-eastern Australia and many are currently being impacted and threatened with permanent loss from longwall underground coal mining. Unique sandstone pagoda landscapes are threatened by underground and open cut coal mining. These ecosystems are poorly protected in the conservation reserve system in NSW and are irreplaceable once mining impacts have occurred.

3.2.6 Wilderness A statutory assessment of the Wollemi Wilderness under the Wilderness Act 1987 was undertaken by NPWS in 1997. Some 2,351 ha of Newnes State Forest on the eastern edge of Newnes Plateau was identified as wilderness88. In 1999, a 361,000 ha wilderness was declared within Blue Mountains and Wollemi National Parks. It is the largest formally protected wilderness in Australia, but did not include the identified wilderness within Newnes State Forest89. This area which is within Gardens of Stone Stage Two reserve proposal would make a significant contribution to enhancing the protection of intact ecosystems contiguous with the GBMWHA.

3.2.7 eCological resilience and climate change Expansion of the area protected by the GBMWHA into adjacent areas is one way to enhance the conservation of World Heritage values. The advantage of increasing the protected area and connectivity is obvious, but it has some more subtle benefits. The mainly montane areas represented by Gardens of Stone Stage Two reserve proposal are amongst the environments most threatened by anthropogenic climate change. With increasing temperatures, cool climate species will need the capacity to spread to higher elevations. The Newnes Plateau, in particular, is a large area of the highest elevation sandstone terrain available in the Blue Mountains and the Sydney Basin bioregion (c. 9,000 ha above 1100m) and is therefore a potentially vital refugium for the future90.

87 Office of Environment and Heritage (2014), Executive Summary 88 New South Wales National Parks and Wildlife Service (1997) 89 https://www.colongwilderness.org.au/campaigns/the-gardens-of-stone/nsw-wilderness-red-index 90 Benson & Smith (2015)

61 Gardens of Stone Stage 2 Proposal

It has been argued that protection of environmental gradients more generally as well as connectivity are important conservation strategies for the Greater Blue Mountains91. Gardens of Stone Stage Two reserve proposal provides an opportunity to extend gradients not only into higher rainfall/lower temperature zones (e.g. Newnes Plateau) but also into lower rainfall/higher temperature zones (e.g. Wolgan Valley and western slopes of Ben Bullen State Forest). In totality, the continentally rare opportunity offered by the protection of Gardens of Stone Stage Two together with the existing GBMWHA would provide a gradient right across the mountains, from the coastal lowlands, over the crest of the Great Dividing Range and onto the Central Tablelands.

Frosty morning in Mountain Gum (Eucalyptus viminalis) forest (Ian Brown)

91 Benson & Smith (2015)

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4Cultural values

4.1 aboriginal heritage

(NB: it is acknowledged that the separation of Aboriginal and historic heritage is both artificial and undesirable. They are discussed separately here to assist presentation.)

Aboriginal occupation of the Gardens of Stone Stage Two reserve proposal is believed to date back at least 12,000 years, and some 22,000 years in the Greater Blue Mountains92. Gardens of Stone Two extends over the traditional Country of at least two and possibly three Aboriginal language groups: Wiradjuri in the west and north, Gundungurra and possibly Darug in the east and south. These communities maintain a strong contemporary interest in their Country and are involved in many land management issues and programs. Mingaan Aboriginal Corporation, Bathurst Local Aboriginal Land Council and Gundungurra Tribal Council are the main organised groups with an interest in Gardens of Stone Two. Relatively few Aboriginal archaeological sites have been recorded for Gardens of Stone Two, compared to some other parts of the Greater Blue Mountains such as the Blue Labyrinth and southern Wollemi National Park where known sites number in the hundreds. Over 1000 sites have been recorded within the entire Greater Blue Mountains World Heritage Area93. However recorded Aboriginal sites in Gardens of Stone Two include several of high significance. The range of sites includes pigment rock art, grinding grooves, occupation deposits in rock shelters and surface scatters. It is likely that places of significance and stories related to the landscape are widespread, but currently unrecorded. The Gardens of Stone Two area has not been systematically surveyed or researched with the Aboriginal community and many more sites are likely to exist. (The OEH Aboriginal Heritage Information Management System (AHIMS) has not been consulted for this report due to the complexity of the Gardens of Stone Stage Two reserve proposal and costs). A bushwalker who knows the area well has advised he has seen “about a dozen” rock art sites in Gardens of Stone Stage Two, some of which have not yet been formally recorded94.

92 Stockton & Merriman (2009) 93 McKay (2015) 94 Bolotin, Y. (2016)

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Maiyingu Marragu Aboriginal Place protects a large sandstone shelter with extensive Aboriginal rock art and other features (Ian Brown)

A representative of the local Wiradjuri community who is also a professional Aboriginal heritage officer has stressed that all sites in Gardens of Stone Stage Two are “special and ancient” and therefore of equal importance with regard to preservation and significance to the Aboriginal and wider communities95. The best known and most visited archaeological site in Gardens of Stone Two is Maiyingu Marragu Aboriginal Place (formerly Blackfellows Hand Reserve). The cultural heritage centres on a large sandstone overhang with extensive stencil and painted art, as well as occupation evidence. The site includes a men’s and a women’s area, and there is a women’s birthing area in a secluded part of the complex96. Maiyingu Marragu holds special meaning to Wiradjuri people because of their continuing cultural connection to the place. The place is also highly valued by the wider Aboriginal community, including Gundungurra, Darug and Darkinjung people. Maiyingu Marragu is a place where traditional culture can be sustained. The area is very accessible and used by the Aboriginal community as a ‘bush school room’ where young people can hear stories from Elders and learn to collect and use bush food and natural medicine97. The site is also popular with non-Aboriginal visitors who wish to see and learn about Aboriginal culture.

95 Riley, S. (2016) 96 http://www.environment.nsw.gov.au/AboriginalPlaces/BlackfellowsHand.htm 97 http://www.environment.nsw.gov.au/AboriginalPlaces/BlackfellowsHand.htm

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Most other Aboriginal heritage sites in Gardens of Stone Two are not publicised. Sites of particular significance include an unusual, dome-shaped shelter with pigment art re- discovered in 2012 in Ben Bullen State Forest, a shelter with pigment art in Kangaroo Creek, grinding grooves on the eastern edge of Newnes Plateau and small shelters with artefact- rich occupation deposits adjacent to high altitude shrub swamps on Newnes Plateau. The argument has been made that the Aboriginal heritage values of the Greater Blue Mountains are of at least national significance, and probably global significance98. This was a value submitted as part of the original World Heritage nomination of the Greater Blue Mountains99, which was not accepted at the time, however a re-nomination for these values is being developed. Much more has been learnt about the Aboriginal heritage of the area over the past 20 years. The potential National Heritage and World Heritage values encompass the rich heritage of rock art and other archaeological sites and the continuing and dynamic Aboriginal culture associated with a protected landscape. Gardens of Stone Stage Two reserve proposal can contribute substantially to those values by both extending the scale and diversity of the protected landscape and adding to the number of significant places that are protected.

4.2 historic heritage

(NB: it is acknowledged that the separation of Aboriginal and historic heritage is both artificial and undesirable. They are discussed separately here to assist presentation.)

European heritage within Gardens of Stone Two relates to a number of historical themes, including exploration, settlement, transport, mining and recreation.

Exploration Blaxland, Wentworth and Lawson were the first Europeans known to set eyes on the Gardens of Stone landscape, when they traversed what is now the Blue Mountains Range from Lapstone to Mount York in 1813. They then descended the pagoda-edged cliffline and crossed the Hartley Valley beneath the Hassans Walls escarpment before turning back from Mount Blaxland. The construction of Coxs Road along the same route in 1815 created the first known and surviving European artefacts in Gardens of Stone Two. Coxs Road and associated features can still be seen where the road descends Mount York. Governor Lachlan Macquarie

98 McKay (2015) 99 NSW NPWS & Environment Australia (1998)

65 Gardens of Stone Stage 2 Proposal journeyed along the new road to Bathurst that same year, naming Mount York itself and Hassans Walls. In later years a number of alternatives to Coxs descent were constructed and parts survive in the Mount York Heritage Reserve: ■■ Lawsons Long Alley (1824) ■■ Lockyers Road (1830) ■■ Victoria Pass (1832) ■■ Berghofers Pass (1912) All four roads have been recognized at local (Council) and national (Register of the National Estate) level. All but Berghofers Pass are also recognized on the NSW State Heritage Inventory100. The Register of the National Estate was replaced in 2007 by the Australian National Heritage List (for state-controlled places), but no sites in the Mount York precinct have been listed to date101.

The monuments at Mount York were renovated for the 2013 bicentenary of the ‘Blue Mountains Crossing’ (Ian Brown)

100 Gondwana Consulting (2008) 101 http://www.environment.gov.au/heritage/places/national-heritage-list

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Victoria Pass (1832) is still used by the Great Western Highway and passes between Crown reserves of Gardens of Stone Two. These historic roads were the conduit by which the fledgling colony of New South Wales expanded into the hinterland. A number of monuments at Mount York were built at various times to commemorate the “first crossing of the Blue Mountains” and associated events, some in conjunction with anniversary celebrations102. The Mount York precinct generally is an important site in the European exploration and settlement history of Australia.

Mining Below Mount York was reportedly the first place that oil shale was discovered in New South Wales, by William Lawson in 1823, and mining began at Kerosene Creek in the 1860s. Remains of mining activities from the nineteenth and early twentieth centuries can be found at several locations in Gardens of Stone Two, including at Blackheath Glen (coal), Fairy Bower at Mount Victoria (chert, 1920s) and the Darling Causeway escarpment and Kerosene Creek (oil shale). The Fairy Bower and Darling Causeway sites include significant remains of inclined railways which descended the escarpment103,104,105. Hassans Walls and some other nearby parts of Gardens of Stone Two were undermined for coal in the early twentieth century, while the latter part of that century up to present has seen underground mining beneath large parts of Newnes State Forest and Ben Bullen State Forest within the proposal. The historic oil shale industry at Newnes was serviced by a railway off the main western line at Newnes Junction, across Newnes Plateau and into the Wolgan Valley. The line opened in 1907 and closed in 1932106. The hardware was salvaged but much of the formation is still visible within Newnes State Forest and on into Wollemi National Park. The Glow Worm Tunnel and the remains of the works at Newnes are major visitor attractions within Wollemi National Park, and community proposals have been advanced to re-open the railway formation as a recreational trail.

Transport Apart from the western road descents in the Mount York precinct described above, another historically significant transport construction within/adjacent to Gardens of Stone Two is the Great Zig Zag, the original descent of the western railway from the plateau into the Lithgow Valley, which is recognized as one the greatest Australian engineering achievements of the colonial era. The Great Zig Zag was in use until 1910, when its inefficiencies were bypassed

102 Gondwana Consulting (2008) 103 Reid (1979) 104 Moodie (2012) 105 Roads & Traffic Authority NSW (2009) 106 Eardley & Stephens (2012)

67 Gardens of Stone Stage 2 Proposal by a new alignment involving many tunnels, which is still in use today, and which passes through Gardens of Stone Two for part of its length. The dam in the headwaters of Dargan Creek (Dargan) was built to supply water for steam engines plying the western railway line.

Recreation From the late nineteenth century into the early part of the twentieth century, a vast network of picnic areas, lookouts and walking tracks were constructed throughout the escarpment tourist precincts of the upper Blue Mountains. These developments took in the Crown reserves of the western Blue Mountains escarpment from Medlow Bath to Lithgow that are included in Gardens of Stone Two, and remain the basis of much of the recreational use of the area today. Historic recreational facilities in Gardens of Stone Two include:

■■ walking tracks in Blackheath Glen; ■■ Hargraves Lookout (Shipley Plateau); ■■ Mount Blackheath Lookout (Shipley Plateau); ■■ Shipley Plateau/Centennial Glen/Porters Pass walking tracks (Blackheath); ■■ Mount Piddington Lookout (Mount Victoria); ■■ Fairy Bower/Mount Piddington walking tracks (Mount Victoria); ■■ Reinits Pass and Little Zig Zag walking tracks (Mount Victoria); ■■ Mitchells Ridge Lookout (Mount Victoria); ■■ several lookouts on Hassans Walls plateau (Lithgow).

Many of these items are listed in local heritage registers. It has been recognised that many Blue Mountains walking tracks and associated facilities are of state significance, with some possibly of national significance. They were extensively assessed in the Blue Mountains Walking Track Heritage Study (1999)107, which found the colonial-era Coxs, Lockyers and Lawsons Long Alley roads at Mount York (now used as walking tracks) to be of state historical significance. Far and above the significant historic places in Gardens of Stone Stage Two reserve proposal and their collective value, the region contributes to the overall historic value of the Blue Mountains. The historical significance of the Greater Blue Mountains has been summarised by Professor Ann McGrath108:

The Greater Blue Mountains region is a unique repository of a rich heritage that spans early convict and pastoral history, economic and technological growth,

107 Musecape & Beaver (1999) 108 McGrath (2015)

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tourism, wilderness and political movements, science, culture and creativity. The region has therefore played an outstanding role in the conceptualisation of Australia’s national history and its national legends, consolidating the status of the Greater Blue Mountains region as a site of national heritage significance.

McGrath argues that a number of the key historic themes embodied by the Greater Blue Mountains are of National Heritage significance. Gardens of Stone Stage Two reserve proposal can contribute to several of these as shown in Table 14.

Table 14. Potential National Heritage historic themes in Gardens of Stone Stage Two reserve proposal

Theme (after McGrath, 2015) Gardens of Stone Stage Two contribution a theatre for a foundational national history Mount York precinct exploration and ‘opening up the land’ Historic roads, Mount York precinct the tourist industry Historic recreational facilities, western escarpment bushwalking and the conservation movement Long campaign for protection of Newnes Plateau

Historic walking track in Sandstone Gully Warm Temperate Rainforest, Western Escarpment (Ian Brown)

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4.3 scenery and aesthetic values

The spectacular, intricate and beautiful scenery of the Gardens of Stone landscape has been recognised by Europeans since the earliest explorations. When surveyor Robert Hoddle crossed Newnes Plateau in 1823 he became perhaps the first to describe in writing the pagoda country so typical of the western escarpments: The appearance of the rock was singular and romantick, and had the appearance of a castle and Town in ruins.109

Large domed sandstone caverns are one of the dramatic scenic features of Gardens of Stone Stage Two (Ian Brown)

Sixteen years later, in 1839, author and artist Louisa Anne Meredith travelled along the Bathurst Road. Passing beneath Hassans Walls she remarked on the escarpment scenery:

These walls or cliffs rise, I should think, to a height of about three hundred feet perpendicularly above the road, and their summits, broken and fissured in

109 Hoddle (1823)

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various fantastic forms, exactly resemble a crowning the brow of the sheer precipice, with here and there a stunted tree or graceful shrub growing from crevices in the dark rock.110

The Blue Mountains more generally have long been famed for their scenery. Although the scenery of the region was not specifically accepted as a global value when the area was listed as World Heritage in 2000, the Greater Blue Mountains have since been recognised as one of Australia’s National Landscapes111. This classification identifies nature tourism destinations in Australia that are recognised and marketed internationally. Blue Mountains National Park was the most popular national park in NSW in 2014, receiving 4.3 million domestic visitors112. The Blue Mountains tourism region received 99,500 international overnight visitors in 2014-15113. Natural scenery is the prime attraction for the Blue Mountains. (Note that there is currently no National Heritage criterion which can be applied to ‘superlative scenery’ as specified in World Heritage criteria). The Blue Mountains region has been widely celebrated over two centuries in various art forms, including painting, literature, film, music and photography114. A key aspect of the scenic appeal of the Blue Mountains is the frequent opportunity to look down from easily-reached, cliff-edge viewpoints into deep valleys and across broad vistas of forested wilderness. As Haydn Washington has noted:

The scenic attractiveness of the Greater Blue Mountains relates strongly to the deeply dissected sandstone plateau landscape. There are few outstanding peaks, and the region’s grandeur mostly becomes apparent when one looks into and across the mighty valleys.115

The most famous Blue Mountains viewpoints are mostly not in Gardens of Stone Two, but at such places as Echo Point, Govetts Leap and Kanangra Walls. However the southern parts of Gardens of Stone Two, along the western escarpment reserves, do offer similar but less celebrated views, from places like Hargraves Lookout, Mount Piddington, Mount York and Hassans Walls. These views are generally across rural valleys and hills to more vegetated escarpments. Then there are the ‘looking-up’ vistas, as described (above) by Louisa Meredith, from the Wolgan Valley and beneath the western escarpment, where the colourful clifflines (especially at sunset) can be enjoyed in all their looming splendour above the tall forests of the footslopes.

110 Meredith (n.d.) 111 http://www.tourism.australia.com/programs/national-landscapes.aspx 112 http://www.environment.nsw.gov.au/research/NSWparkspopularity.htm 113 Destination NSW (2015) 114 Fallding (2015) 115 Washington (2015)

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But much of the Gardens of Stone Two has a different scenic emphasis. The northern parts are less accessible than in the south. Cliff-edge viewpoints abound, but many are in remote locations only accessible on foot, or they look into narrow gorges (e.g. Carne Creek) rather than across wide vistas. More typically, Gardens of Stone Two offers a more intimate aesthetic, of a kind which is available across the Blue Mountains but often subsumed by the ‘grand vista’. As scientist and Gardens of Stone aficionado Haydn Washington has written: “The pagoda landscape is a visual feast for the human eye”.116

Pagodas on the western escarpment of Newnes Plateau (Henry Gold)

Washington was referring to the complex and shifting interplay of rock features, vegetation and background scenery that so delights visitors to this unique landscape. This is an intricate terrain, often changing rapidly and surprisingly over quite short distances, especially in the pagoda and escarpment areas where the vegetation can be of low stature but of remarkable variety in colour, form and texture. One walks and weaves between the outcrops as new scenes come into view, more strange ironstone sculptures emerge and another wildflower

116 Washington (2015)

72 Natural and Cultural Values display or gnarled gum is discovered. Narrow defiles lead round corners into overhangs, caves, ferny glades, groves of huge trees and trickling streams. One of the most popular locations for landscape and aesthetic appreciation has been the relatively accessible pagoda area known as the Lost City, on Newnes Plateau. Apart from pagodas, other important aesthetic features include gorges, cliffs, escarpments, canyons and caverns, the colours and patterns of the rock itself as exposed through weathering, wildflower displays in spring, swamps, heathlands, woodlands and tall forests. Atmospherics and weather effects such as frost, snow, fog and mist can enhance the visual appeal of these features. The rich aesthetic of the northern parts of Gardens of Stone Two has not been explored by artists and writers over long periods to the same extent as the main Blue Mountains area, partly because of overshadowing by the famous places, and partly because of inaccessibility leading to unfamiliarity. Photography has been the main artistic medium for interpreting this landscape to date, with painting and music to a lesser extent. Much of this artistic production has recently been driven by the campaign to protect the area. Perhaps one of the first accomplished nature photographers to train his camera on the northern parts of Gardens of Stone Stage Two reserve proposal was Henry Gold, with well known images including “Lost City, Gardens of Stone” and “Pagodas” (produced as a poster for the World Heritage campaign by the Colong Foundation in 1989)117. Others have followed, particularly in response to the “Gardens of Stone In Focus” photographic competition118. Few well known paintings have been done of Gardens of Stone Stage Two reserve proposal. The Fleurieu Art Prize for Landscape (billed as the ‘richest landscape art prize in the world”) was in 2011119 awarded to the evocative acrylic painting “Pagodas at Newnes” by Julie Harris, who developed a series of works on the Gardens of Stone landscape120. Even music has featured as a Gardens of Stone artform in recent years. The “Gardens of Stone” (2012) is a collection of original, contemporary classical music for piano and didjeridu, composed and performed by Amanda Handel and Michael Jackson and inspired by the landscape121.

117 Washington (2015) 118 https://www.colongwilderness.org.au/campaigns/the-gardens-of-stone/gardens-stone-focus-photographic-competition 119 https://en.wikipedia.org/wiki/Fleurieu_Art_Prize 120 http://julieharris.com.au/index.php/gardens-of-stone/ 121 http://www.gardensofstone.com.au/

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4.4 recreation

Gardens of Stone Stage Two reserve proposal contains a wide range of nature recreation opportunities122, however since recreation is not a criterion for National Heritage only brief details are included here (see above for recreation in relation to historic values). As described above, the western escarpment of the Blue Mountains has been an important area for scenic viewing and walking since the late nineteenth century, when the construction of a range of recreational facilities began. These lookouts, picnic areas and walking tracks are still in popular use today. Many have been refurbished in recent years by Blue Mountains City Council and Lithgow City Council. Other popular recreational activities in the escarpment precinct include nature study, birdwatching and rock climbing, as well as camping, mountain biking and horse riding to a lesser extent. Camping opportunities are available at Mount York and the Quota Picnic Area in Blackheath Glen. The recreational environment of the Newnes Plateau and other Gardens of Stone Stage Two reserve proposal areas is different, with few facilities and more dispersed and informal/ unmanaged activity. No constructed walking tracks exist, although the reserve proposal is a popular destination for off-track bushwalking with club walks scheduled on most months and informal walks more frequently. Canyoning, rock climbing and mountain biking also occur to a limited extent. These activities are strongly based on the unique aesthetic, topographic and scenic qualities of the Gardens of Stone Stage Two landscape, as described above. The only formal campsite in the northern Gardens of Stone Stage Two reserve proposal is at Bungleboori in Newnes State Forest but it is in a degraded state. The multi-use Bicentennial National Trail traverses the proposal along the Great Dividing Range and upper valleys of Baal Bone Creek and Coxs River, following management trails. It includes a low-key campsite adjacent to Baal Bone Creek in Ben Bullen State Forest. Numerous management trails and informal/illegal tracks provide the basis for off-road vehicle recreation (trail bike riding, 4WDing and quad bikes), which is currently the most popular activity in some areas, even though it is often undertaken illegally (unlicensed riders/drivers and/or unlicensed vehicles).

122 Brown (2009)

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5Towards National Heritage

5.1 the National Heritage process

The National Heritage List is a list of places with outstanding natural, Indigenous or historic heritage value to the nation123. It is the prime mechanism for recognising and protecting nationally significant heritage values at Commonwealth level. The list and its processes are established under the Environment Protection and Biodiversity Conservation Act 1999, which provides a level of statutory protection for listed places. Nine specific criteria are applied to guide the nomination of places to the list and subsequent assessment by the Australian Heritage Council (the Council). A place must be assessed to meet one or more criteria for the Council to recommend a listing to the Australian Minister for the Environment. The place must also meet a threshold of ‘significance’ for specific criteria.

5.1.1 National Heritage criteria These (with editorial emphasis) are the National Heritage criteria against which the heritage values of a place are assessed124: 1. the place has outstanding heritage value to the nation because of the place’s importance in the course, or pattern, of Australia’s natural or cultural history;

2. the place has outstanding heritage value to the nation because of the place’s possession of uncommon, rare or endangered aspects of Australia’s natural or cultural history;

3. the place has outstanding heritage value to the nation because of the place’s potential to yield information that will contribute to an understanding of Australia’s natural or cultural history;

4. the place has outstanding heritage value to the nation because of the place’s importance in demonstrating the principal characteristics of:

123 https://www.environment.gov.au/heritage/about/national/national-heritage-list-criteria 124 https://www.environment.gov.au/heritage/about/national/national-heritage-list-criteria

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i. a class of Australia’s natural or cultural places; or

ii. a class of Australia’s natural or cultural environments;

5. the place has outstanding heritage value to the nation because of the place’s importance in exhibiting particular aesthetic characteristics valued by a community or cultural group;

6. the place has outstanding heritage value to the nation because of the place’s importance in demonstrating a high degree of creative or technical achievement at a particular period;

7. the place has outstanding heritage value to the nation because of the place’s strong or special association with a particular community or cultural group for social, cultural or spiritual reasons;

8. the place has outstanding heritage value to the nation because of the place’s special association with the life or works of a person, or group of persons, of importance in Australia’s natural or cultural history;

9. the place has outstanding heritage value to the nation because of the place’s importance as part of Indigenous tradition.

Of these criteria, it is considered that only criteria 6 and 8 are unlikely to be relevant to the Gardens of Stone Stage Two reserve proposal. The other seven criteria are potentially relevant, to varying degrees. Note that there is currently no National Heritage criterion which can be applied to ‘superlative scenery’ as specified in World Heritage criteria. Criterion 5 relates only to a much narrower interpretation of aesthetic value.

5.1.2 National Heritage thresholds To quote from the National Heritage website125:

As well as assessing a place against criteria for its heritage value, the Council is also required to apply a ‘significance threshold’. This test helps the Council to judge the level of significance of a place’s heritage value by asking ‘how important are these values?’.

125 https://www.environment.gov.au/heritage/about/national/national-heritage-list-criteria

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To reach the threshold for the National Heritage List, a place must have ‘outstanding’ heritage value to the nation. This means that it must be important to the Australian community as a whole. To determine whether a place has ‘outstanding’ heritage values, it is compared to other, similar types of places. This allows the Council to determine if one place is ‘more’ or ‘less’ significant compared to other similar places, or if it is unique. The degree of significance can also relate to the geographic area, for instance, the extent of a place’s significance locally, regionally, nationally or internationally.

Escarpment with fog and Blue Mountains Ash trees, Western Escarpment (Ian Brown)

5.1.3 National Heritage guidelines The National Heritage Guidelines126 provide detailed information on the listing process, on how nominations are assessed and on how to apply the National Heritage criteria. In particular, examples and information are given on the assessment of the key thresholds of significance, integrity and authenticity. Significant quotes from the guidelines follow (with editorial emphasis):

Determining the level of significance is the major task of the assessment process. The first decision is to determine if a place has heritage value, while the second decision is to determine the level of significance… To determine if a place meets the threshold of outstanding heritage value a comparative analysis is generally conducted…

126 Australian Heritage Council (2009)

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The conclusion whether a place satisfies the threshold or not must in each case be based on evidence and reasoned analysis of the evidence against the relevant criterion… The notion of integrity assists in determining the relative significance of a place compared with places of a similar type. Generally a high degree of integrity would be expected for most National Heritage places. However, exceptions will occur… For the natural environment, integrity is an indicator of the likely long term viability or sustainability, reflecting the degree to which the place has been affected by other activities, the ability of the place to restore itself (or be restored) and the time frame likely for any restorative processes. For the cultural environment, integrity is the ability of the place to retain and convey key heritage values… The notion of authenticity assists in determining if the heritage value for cultural places is genuine or of undisputed origin.

5.2 Potential National Heritage Values

5.2.1 sPecific values The synthesis occupying the preceding bulk of this report provides a basis for considering which values have potential to achieve National Heritage listing under one or more criteria. Some of those values are demonstrably widespread in the adjacent and already-listed (but not necessarily for those values) Greater Blue Mountains World Heritage Area, with Gardens of Stone Stage Two reserve proposal representing only a relatively minor extension of the spatial distribution of the value. These values are not considered to be appropriate candidates for a stand-alone Gardens of Stone Stage Two nomination. Other values offer more cogent National Heritage potential because they are more closely limited to Gardens of Stone Stage Two reserve proposal. These values include aspects of geodiversity, biodiversity, landscape and historic heritage. It is noted that the OEH Capertee Subregional Assessment was a thorough review of the biodiversity conservation potential of the (‘Capertee’) sub-region. The study area covered most of the Gardens of Stone Stage Two reserve proposal (except for the eastern parts of the Western Escarpment), and found that all parts of this area rated either Very High or High as “Priority Areas for Biodiversity” 127. Table 15 summarises potential National Heritage values of Gardens of Stone Stage Two which are not considered suitable for nomination. Table 16 summarises the values which are considered suitable for National Heritage nomination, together with the relevant National Heritage criteria and the spatial distribution of the value within Gardens of Stone Stage Two.

127 Office of Environment and Heritage (2014)

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Table 15. Potential National Heritage values of Gardens of Stone Stage Two reserve proposal which are more widespread in the GBMWHA and not suitable for nomination

Category Specific value Comment Geodiversity Slot canyons Bulk of canyons in GBMWHA Waterfalls Bulk of BM waterfalls outside Gardens of Stone Stage Two Biodiversity Fauna diversity Most fauna spp. more common in GBMWHA Natural heritage Wilderness Bulk of BM wilderness in GBMWHA Scenery Bulk of BM scenery in GBMWHA Aboriginal heritage Aboriginal heritage Bulk of intact BM heritage in GBMWHA Historic heritage Bushwalking conservation movement Bulk of associated landscapes in GBMWHA Tourism/recreation Bulk of early BM walking tracks outside Gardens of Stone Stage Two Mining Bulk of mining heritage outside Gardens of Stone Stage Two

Table 16. Potential National Heritage values of Gardens of Stone Stage Two reserve proposal which are suitable for nomination

National Location/s in Comments Category Specific value Heritage Gardens of Stone criterion Stage Two Geodiversity Pagodas 2 Mainly Newnes, Ben Arguably the best assemblage in GBM. Bullen & Wolgan Platy pagodas may be internationally State Forests significant. Montane sand dunes 2 Newnes Plateau (inc. Rare and important. GOSNP) Peat swamps 2 Newnes Plateau Geomorphically rare Biodiversity Rare/threatened plants 2 Throughout 42 spp, substantial area of habitat. Threatened fauna 2 Throughout 42 spp, substantial area of habitat. Swamps/wetlands + 2 Newnes Plateau 6 EECs, 9 other rare communities, rare/ other EECs + other rare 4 (ii) (?) and Ben Bullen threatened plants, Giant Dragonfly, BM communities State Forest for peat Water Skink. swamps. All 3 State Forests for other communities Landscape Integration of 2 Throughout Pagodas, sand dunes, peat swamps, geodiversity/biodiversity rare/threatened plants, threatened values in a rare fauna, 6 EECs, 10 rare communities. landscape Whole area supports protection of this landscape with its specific values. Aboriginal Maiyingu Marragu 9 Maiyingu Marragu Discrete site important to local heritage 1 (?) Aboriginal community. Not a priority for 2 (?) conservation NGOs to pursue? Historic Mount York historic 1 Mount York precinct Should already be NH. Not a priority for heritage roads 2 (western BM conservation NGOs to pursue? 8 escarpment)

It is apparent from Table 16 that Criterion 2 is the most likely National Heritage criterion under which a successful nomination might be mounted. This would include seven and possibly eight distinct values across both natural and cultural heritage and could possibly be mounted with a ‘cumulative significance’ argument, or as an integrated landscape (see below). This option has the advantage of including values which occur broadly across Gardens of Stone Stage Two reserve proposal: eighty-four (84) rare and threatened species

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(plus 16 rare or endangered communities) is a powerful value, especially if backed with the more localised geodiversity values. Other identified values are localised to particular parts of Gardens of Stone Stage Two reserve proposal. It could be considered to mount these as discrete nominations, but this would not achieve listing of all Gardens of Stone Stage Two. Spatially discrete values include pagodas, montane sand dunes, peat swamps, other rare/endangered plant communities, Maiyingu Marragu and Mount York. The latter two cultural values would be of peripheral benefit in protecting Gardens of Stone Stage Two overall. Maiyingu Marragu and Mount York are confined to small parts of Gardens of Stone Stage Two and are more suited to nomination by relevant cultural heritage bodies: the Aboriginal community for Maiyingu Marragu and local government for Mount York. The three State Forests (Ben Bullen, Wolgan and Newnes) contain the entire area or core areas for all identified geodiversity values, peat swamps and several other rare/endangered communities, as well as 42 threatened animal species (Table 13) and 31 rare/threatened plant species (Table 10). This area could make for a strong and spatially coherent nomination. Newnes Plateau (and State Forest) could potentially stand alone as a smaller but coherent area of rare biodiversity that is unique to Australia.

5.2.2 A landscape nomination? Perhaps the most outstanding feature of Gardens of Stone Stage Two reserve proposal from a National Heritage perspective is the pagoda landscape with its associated flora and fauna that have evolved in a temperate climate. A potentially compelling case could be made for an integrated landscape-based nomination, encompassing pagodas, montane sand dunes, peat swamps, threatened fauna and rare/threatened plants and communities. The pagoda landscape with its associated flora and fauna could be nominated under Criterion 2 if considered sufficiently rare. If the necessary comparative analysis confirms that the temperate pagoda system is distinctive, Gardens of Stone Stage Two along with parts of Wollemi National Park and Mugii Murum-ban State Conservation Area is certain to be one of the best places in Australia to demonstrate the characteristics of this environment and its evolution. To support such an argument, a closer examination of the distribution and characteristics of pagoda-associated flora and fauna would be required. Such an analysis may reveal that this pagoda landscape features a distinctive assemblage of plants and animals. Pagoda landscapes, sand dunes and peat swamps do not occur throughout Gardens of Stone Stage Two, but it can be argued that adequate protection of these features, their integrity and their ongoing evolution would require the inclusion of surrounding natural areas. Thus a case can be made for recognition of the whole area.

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5.3 achieving National Heritage: obstacles & opportunities

A ‘high bar’ exists for achieving National Heritage listing. A prima facie case would seem to exist that a number of aspects of Gardens of Stone Stage Two reserve proposal are capable of demonstrating national significance, either separately or in combination. However there are other factors that could weaken or block a successful nomination for National Heritage. These factors are general as well as specific to particular National Heritage criteria. Some of the barriers to be overcome in achieving National Heritage are described below. These issues would need to be addressed in formulating a nomination.

5.3.1 Nexus with the GBMWHA The GBMWHA is already listed as National Heritage, by automatic virtue of its World Heritage status. It is therefore National Heritage listed only under its listed World Heritage values, which are aspects of biodiversity. If the values for which Gardens of Stone Stage Two reserve proposal was nominated could be regarded as additive (i.e. already covered in part by the GBMWHA) rather than exclusive (to Gardens of Stone Two), then the threshold of significance may be problematic. Certain biodiversity values are in this category, whereas other biodiversity values and geodiversity and cultural values are theoretically unaffected. However, these potentially unaffected values are mostly also embodied within the GBMWHA, in some cases to a greater extent (even though not listed under National Heritage or World Heritage). Values in this category include pagoda landforms (criterion 2), wilderness (criterion 2 or 4, maybe) and Aboriginal heritage (criterion 4). A nomination under such shared values, without a corresponding nomination for the GBMWHA, would be anomalous. Some moves have been made towards nominating the GBMWHA for some of its unlisted but significant values, mainly cultural and geodiversity, firstly for National Heritage but with the long term aim of an expanded World Heritage listing. In 2005 Dr Geoff Mosley renominated the GBMWHA for National Heritage listing under a number of criteria128. In 2015 the Greater Blue Mountains World Heritage Advisory Committee published a collection of papers arguing for world heritage significance of several values for which it is not currently listed129. This could be both an opportunity and a threat for a Gardens of Stone Stage Two National Heritage listing. The potential for ‘piggy-backing’ on a GBMWHA nomination is small, given the unprotected status of Gardens of Stone Stage Two reserve proposal (and therefore no official support) and integrity issues, but a subsequent nomination for Gardens of Stone Stage Two would be additive, creating problems in achieving the threshold of national significance.

128 Mosley (2005) 129 The Greater Blue Mountains World Heritage Area Advisory Committee (2015)

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5.3.2 distribution of values within Gardens of Stone Stage Two National Heritage is a values-based system. It does not provide for an area to be nominated which is then presented as embodying certain values. Rather the values come first, then the place is defined to capture the values. So the spatial definition of any nomination (how the defined area encompasses the values) is an important issue, but the guidelines provide little guidance on how restrictively a geographic line should be drawn around values. In Gardens of Stone Stage Two reserve proposal, most of the key values are limited to parts of the proposal. For example, pagodas, montane sand dunes, peat swamps and significant historic values are all restricted in extent. The legitimacy of including the landscape surrounding a particular value in order to provide context, buffer and protection is unclear and may warrant further investigation/advice. An integrated landscape approach may have the potential to overcome these issues.

5.3.3 Integrity The current Gardens of Stone Stage Two reserve proposal includes a range of impacts, some parts lack continuity and none of the area (almost by definition) has management integrity or legal protection as conservation tenure. It is a moot point whether pursuing National Heritage can help to achieve protection of Gardens of Stone Stage Two and its values, or whether protection needs to come before a cogent case for National Heritage can be mounted. Impacts in Gardens of Stone Stage Two reserve proposal include roads/fire trails, mining infrastructure, mining subsidence, timber-getting, recreational disturbance and pine plantations. These impacts directly affect key values in places. The proposal lacks spatial coherence, as parts of the proposal are discrete and unconnected, e.g. Hassans Walls Reserve, Ben Bullen State Forest south of (noting that some apparently isolated segments are in fact connected to existing reserves, e.g. Wolgan Valley slopes, areas north of Blackheath). All these issues make it more difficult to mount a case for integrity.

5.3.4 Evidence Some apparently strong values of Gardens of Stone Stage Two reserve proposal do not have strong evidence. For instance, the pagoda landscapes are clearly of great aesthetic appeal to many people (criterion 5) but the documentary and artistic demonstration of this is very limited. Another largely unknown aspect is the association of rare/threatened biota with pagoda and associated landscapes.

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5.3.5 reductive or cumulative? The National Heritage system is a reductive one, requiring assessment against specific criteria. It does not encourage a nomination where a number of values attach to a place and can be argued to cumulatively achieve national significance. It would seem that in such a case each criterion would need to achieve the necessary standard to be listed, so it would be possible for a place to fall just short on several criteria and still not get ‘over the bar’. It is not a ‘points system’ where scores from different values can accumulate to achieve a certain minimum. This issue may require further research, but would seem to be problematic for Gardens of Stone Stage Two reserve proposal where several strong values apply to the same landscape but each value may face difficulty in demonstrating, in isolation, ‘outstanding heritage value to the nation’. This difficulty is exacerbated by the disjunct spatial distribution of particular values in Gardens of Stone Stage Two. However, an integrated landscape nomination may be capable of side-stepping this problem.

5.4 advancing the recognition & protection of values

In compiling this report a number of gaps have become apparent in the available documentation of the natural and cultural values of the Gardens of Stone Stage Two reserve proposal. It is also apparent that some of those values are under-recognised. Opportunities exist for both improving documentation and advancing the recognition and protection of the area’s values. These opportunities could be pursued to strengthen a subsequent National Heritage nomination, or independently of any such nomination. Actions that could be considered include:

■■ produce a study of the distribution of smooth and platy pagodas and their associated landscapes;

■■ assess the rare and threatened biota (plants, animals, ecological communities) within Gardens of Stone Stage Two and consider whether additional nominations for listing under the TSC Act could be appropriate (e.g. DEC community 52);

■■ study the association of rare/threatened biota with pagoda and associated landscapes.

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5.5 a National Heritage listing: a way forward

This report has synthesised information on the natural and cultural values of Gardens of Stone Stage Two reserve proposal and identified those values with National Heritage potential. This final section has outlined the National Heritage process and identified issues which would need to be addressed to achieve a successful listing. Obvious conclusions from this analysis are a) that values of national importance almost certainly do exist in Gardens of Stone Stage Two, and also b) that those values would need to be very carefully presented to mount a cogent nomination with a reasonable prospect of success, in order to overcome a range of assessment obstacles. There may be little point in submitting a National Heritage nomination with only a small chance of success. The following recommendations constitute a rational program for developing a nomination with built-in ‘reality checks’.

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Recommendations

1. Seek peer review of this report by a range of experts.

2. Consult with National Heritage experts on the obstacles (as described above, and any others) facing a Gardens of Stone Stage Two nomination.

3. Consider other options for advancing the recognition of the area’s values (as suggested in section 5.4 above).

4. Compile and refine detailed arguments, comparative analysis and spatial analysis for each candidate value or combined values in Gardens of Stone Stage Two reserve proposal.

5. Consider the option of nominating parts of Gardens of Stone Stage Two reserve proposal for specific candidate values or combined values as National Heritage.

6. Consult again with National Heritage experts and decide if a nomination should be prepared and submitted, for which values or combined values and for which area/s.

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Online references http://julieharris.com.au/index.php/gardens-of-stone/ http://plantnet.rbgsyd.nsw.gov.au http://www.environment.gov.au/cgi-bin/ahdb/search.pl?mode=place_detail;search=place_name%3D- gardens%2520of%2520Stone%3Blist_code%3DRNE%3Bkeyword_PD%3Don%3Bkeyword_ SS%3Don%3Bkeyword_PH%3Don%3Blatitude_1dir%3DS%3Blongitude_1dir%3DE%3Blongi- tude_2dir%3DE%3Blatitude_2dir%3DS%3Bin_region%3Dpart;place_id=18258 http://www.environment.gov.au/heritage/places/national-heritage-list http://www.environment.gov.au/node/14561 http://www.environment.nsw.gov.au/AboriginalPlaces/BlackfellowsHand.htm http://www.environment.nsw.gov.au/AboriginalPlaces/BlackfellowsHand.htm http://www.environment.nsw.gov.au/determinations/GiantDragonflyEndSpListing.htm http://www.environment.nsw.gov.au/atlaspublicapp/UI_Modules/ATLAS_/AtlasSearch.aspx http://www.environment.nsw.gov.au/research/NSWparkspopularity.htm http://www.gardensofstone.com.au/ http://www.tourism.australia.com/programs/national-landscapes.aspx https://en.wikipedia.org/wiki/Fleurieu_Art_Prize https://www.colongwilderness.org.au/campaigns/the-gardens-of-stone/nsw-wilderness-red-index https://www.colongwilderness.org.au/campaigns/the-gardens-of-stone/gardens-stone-focus-photograph- ic-competition https://www.environment.gov.au/heritage/about/national/national-heritage-list-criteria

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