Abel Ecology

Biodiversity Development Assessment Report (BDAR)

For Health Infrastructure NSW, CBRE

Address 35-65 Derby St, Kingswood Lot 1, DP 1114090

Nepean Hospital and Integrated Ambulatory Services Redevelopment – SSDA

Prepared for: Health Infrastructure NSW Report No: AE18-REP-1865-ISS 3 Prepared by: Abel Ecology Date: 30 August 2018

PO Box 495 Unit 2, 10-11 Ferguson Road Springwood NSW 2777

T (02) 4751 9487 Abel Ecology Pty Ltd E [email protected] 2 Samuel 20:18 ACN 079 079 762 – ABN 72 516 253 751 www.abelecology.com.au

Disclaimer This report has been prepared in accordance with the scope of services described in agreement between Abel Ecology and the Client.

In preparing this report, Abel Ecology has relied upon data, surveys and site inspection results taken at or under the particular time and or conditions specified herein. Abel Ecology has also relied on certain verbal information and documentation provided by the Client and/or third parties but did not attempt to independently verify the accuracy or completeness of that information. To the extent that the conclusions and recommendations in this report are based in whole or in part on such information, they are contingent on its validity. Abel Ecology assumes no responsibility for any consequences arising from any information or condition that was concealed, withheld, misrepresented, or otherwise not fully disclosed or available to Abel Ecology.

The findings contained in this report are the result of discrete/specific methods used in accordance with normal practices and standards. To the best of our knowledge, they represent a reasonable interpretation of the general condition of the site in question. Under no circumstances, however, can it be considered that these findings represent the actual state of the site/sites at all points.

Any representation, statement, opinion or advice, expressed or implied in this publication is made in good faith but on the basis that Abel Ecology, its agents and employees are not liable (whether by reason of negligence, lack of care or otherwise) to any person for any damage or loss whatsoever, which has occurred or may occur in relation to that person taking or not taking (as the case may be) action in respect of any representation, statement, or advice referred to above. Any findings, conclusions or recommendations only apply to the aforementioned circumstances and no greater reliance should be assumed or drawn by the Client.

Furthermore, this report has been prepared solely for use by the Client. Abel Ecology accepts no responsibility for its use by other parties.

The NSW BC Act 2016 and NSW BC Regulation 2017 are new pieces of legislation. The Biodiversity Assessment Method is also a new method for assessing Biodiversity. This report has been prepared with is Abel Ecology’s knowledge, experience and training. OEH are still refining the Biodiversity Offsets Scheme. Some details provided in this report may require amendment.

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Document History Report Version Prepared by Checked by Submission Method Date Report Draft A Dr Alison Hewitt Steven Smith Dropbox 23 Feb 18 Mark Sherring Dr Daniel McDonald Report Issue 1 Dr Alison Hewitt Steven Smith Dropbox 13 Apr 18 Mark Sherring Dr Daniel McDonald Report Draft B Dr Daniel McDonald Steven Smith Dropbox 25 July 18 Report Issue 3 Dr Daniel McDonald Steven Smith Dropbox 30 Aug 18

Biodiversity Assessment Method Accreditation (BAM) Approval

Reviewed by BAM Assessor Accreditation Date Number Dr Daniel McDonald BAAS17056 30 August 18

This report and associated files must and will also be uploaded to the NSW government BAAS website.

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Table of Contents Executive summary ...... 8 1. Introduction ...... 24 1.1 The proposal ...... 25 1.2 General description of Nepean Hospital ...... 26 1.3 Geology and soils ...... 26 1.4 History of the site ...... 26 1.5 Sources of information used in this assessment ...... 27 2. Landscape features ...... 28 2.1 Landscape features ...... 28 2.2 Site context components ...... 29 2.2.1 Description of the field assessment (identification of the method applied)...... 29 2.2.2 Native vegetation cover (percentage) and patch size ...... 29 3. Field survey methods ...... 31 3.1 Field work effort ...... 31 3.2 Flora survey method, vegetation community and habitat classification ...... 32 3.3 Threatened species generated by the Biodiversity Assessment Method calculator ...... 33 3.3.1 The Biodiversity Assessment Method calculator displayed the following Predicted threatened species (Ecosystem credits): ...... 34 3.3.2 The Biodiversity Assessment Method calculator displayed the following Candidate threatened species (Species credits): ...... 36 3.4 Fauna survey method ...... 38 3.4.1 Diurnal fauna searches ...... 38 3.5 Limitations of the survey ...... 39 4. Survey Results: Vegetation and habitat description ...... 40 4.1 Site vegetation identification and habitat zone descriptions ...... 40 4.1.1 Remnant vegetation ...... 40 4.2 Areas of landscape and gardens ...... 41 4.2.1 Patch size ...... 44 4.3 Vegetation integrity ...... 45 4.4 Commonwealth listed species and communities of conservation concern ...... 46 4.5 Weeds ...... 47 5. Threatened species ...... 48 5.1 Threatened species and details of flora and fauna surveys ...... 48 5.1.1 Species polygons ...... 48 5.1.2 Biodiversity risk weighting ...... 48 5.1.3 Threatened species survey ...... 49

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5.1.4 Wind farm developments ...... 50 6. Survey Results: Fauna ...... 50 6.1 Species of conservation concern ...... 50 6.2 Fauna results ...... 50 7. Avoid and minimising impacts ...... 51 7.1 Avoiding and minimising impacts...... 51 8. Impact summary ...... 53 8.1 Maps & data ...... 53 8.2 Impact summary ...... 53 8.2.1 Measuring the impact of the proposal through ecosystem credits and species credits ...... 54 9. Positive actions ...... 55 9.1 Site management positive actions to enhance biodiversity ...... 55 10. Biodiversity credit report ...... 56 10.1 Credit classes for ecosystem credits and species credits at the development site...... 56 10.2 Table of credit class and matching credit profile ...... 56 11. References ...... 57 Appendix 1. Flora and fauna species list ...... 60 Appendix 2. BAM field data ...... 64 Appendix 3. Moore Trees data for Trees 42 - 65 ...... 73 Appendix 4. Demonstration of use of the principle “Avoid and minimise ecological impacts”...... 74 Appendix 5. Advice from the NSW Office of Environment and Heritage regarding SAII ...... 77 Appendix 6...... 79 Appendix 7. Company Profile ...... 82

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Table of Figures

Figure 1. Nepean Hospital map...... 12 Figure 2. Location map (Aerial photo) of Nepean Hospital and local area...... 13 Figure 3. Proposal Diagram with Nepean Hospital boundaries in red and operational and construction footprint (proposal area) outlined in green...... 14 Figure 4. Tree Protection Plan...... 15 Figure 5. Biodiversity Values map displaying the proposed works area...... 16 Figure 6. Aerial photo indicating the site and the 1500 m buffer area...... 17 Figure 7. Vegetation map for the site and surrounding area...... 18 Figure 8. Site vegetation and survey map...... 19 Figure 9. Site analysis indicating the approximate extent of Cumberland Plain Woodland within Nepean Hospital...... 20 Figure 10. Proposal indicating tower location and existing vegetation...... 21 Figure 11. Amended Plan 2 from the Moore Trees Arboricultural Report (August 2018)...... 22 Figure 12. Extract from page 20 of Moore Trees Arboricultural Development Assessment Report – December 2017...... 75

Table of Tables

Table 1. Critically endangered ecological communities found within the proposal area...... 8 Table 2. Survey dates and weather conditions...... 31 Table 3. Significant features and observations for this zone...... 45 Table 4. Current vegetation integrity score and components for each zone...... 46 Table 5. List of habitat/s on site and their sensitivity class/es...... 49 Table 6. Listing of threatened species that potentially use the site and sensitivity to gain weighting...... 49 Table 7. PCTs requiring offset and the number of ecosystem credits required...... 54 Table 8. Threatened species requiring offset and number of species credits required...... 54

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List of Abbreviations

BAM Biodiversity Assessment Method BC Act Biodiversity Conservation Act 2016 BCR Biodiversity Conservation Regulation 2017 BDAR Biodiversity Development Assessment Report CPW Cumberland Plain Woodland d.b.h. Diameter at breast height (~1.4 metres) EEC Endangered Ecological Community EPZ Environmental Protection Zone ESD Ecologically Sustainable Development LEP Local Environmental Plan LGA Local Government Area PDA Principal Development Area

Note regarding maps in this report The diagrams/site maps used in this report have been supplied by and are used with the permission of Health Infrastructure

Note: In this report the site refers to the proposal area (operational and construction footprint) indicated in Figure 3. The site does not refer to the whole area of Nepean Hospital.

With regard to maps provided by the Land Information Centre, Topographic maps used with the permission of © Land and Property Information, NSW.

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Executive summary

The proposal is to construct a new 6 storey split level car park with rooftop helipad in the northwest corner of the hospital site, and a 14-storey public hospital tower in the north east of the site, which will be connected by covered pedestrian links to existing theatre buildings.

The NSW Government has required that this State Significant Development include an assessment of the impact of the proposal using the Biodiversity Assessment Method (BAM). The type of report prepared for this assessment using the BAM is a Biodiversity Development Assessment Report (BDAR).

An assessment of the proposal under Commonwealth legislation is also included.

Remnant vegetation, a form of Cumberland Plain Woodland within the proposal area consists of scattered single trees and clumps of trees with scattered indigenous groundcovers under the canopy or nearby. The remnant trees within the proposal area are Grey Box Eucalyptus moluccana and Red Forest Gum Eucalyptus tereticornis. The site provides habitat for various indigenous fauna species including threatened fauna species that are able to forage within urban environments.

Table 1. Critically endangered ecological communities found within the proposal area.

C’wealth listing State listing Species/communities EPBC Act ‘99 BC Act ‘16 Cumberland Plain Woodland Schedule 1a, (Plant Community Type (PCT) 849-Grey Box – Critically Critically Forest Red Gum grassy woodland on flats of Endangered* Endangered the Cumberland Plain, Sydney Basin Bioregion)

*Cumberland Plain Woodland is listed by the Commonwealth as Critically Endangered. However, the Commonwealth specifically requires that the patch of Cumberland Plain Woodland must be equal or greater than 0.5 ha. The individual and clumps of Grey Box do not form a continuous patch either within the proposal area or within Nepean Hospital.

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The condition of Cumberland Plain Woodland within the proposal area is in a degraded state and does not meet the criteria for protection by the Commonwealth. The provisions of the EPBC Act 1999 do not apply to this proposal.

The scattered individuals and clumps of Grey Box and Red Forest Gum are present in a highly modified landscape. The ground layer within the proposal area primarily consists of hard surfacing, asphalt or concrete and in some locations, mulch is present within garden beds. Weed invasion is generally low as Nepean Hospital is routinely managed.

Recommendations for this proposal include: Incorporate locally indigenous Cumberland Plain Woodland plant species in the landscape plan for the Hospital.

Use appropriate fencing and arboricultural practice consistent with the Australian Standard Protection of trees on development sites (AS 4970-2009) to minimise the likelihood of damage to any of the retained trees within the proposal area. Liaison between the arborist and the engineer will be required to ensure that on-ground methods of tree protection will be suitably installed. This will include documenting the accurate location of the trees on a plan and their tree protection fencing.

Credit requirements The current credit requirement for the project is: 1. Two (2) credits will be required for the removal of PCT849. Either PCT849 or PCT850 can be purchased to meet the like-for-like option.

Special considerations a) Site vegetation conditions detailed in this report are subject to change over time due to various factors, e.g. germination from seed bank, fire, etc. It is recommended that this report be submitted within 6 months, after which further fieldwork may be required. b) This report does not authorise any clearing of native vegetation on the property, c) It is the responsibility of the landowner to obtain all required permissions from statutory authorities for the proposal.

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This report has been prepared to address the Secretary’s Environmental Assessment requirements (SEARs) for the proposed Nepean Hospital and Integrated Ambulatory Services Redevelopment (Stage 1).

SEARs Requirements Response – reference section / Appendix

General Requirements This report provides biodiversity The Environmental Impact Statement information relevant to the following key (EIS) must be prepared in accordance issues: with, and meet the minimum

requirements of clauses 6 and 7 of • adequate baseline data Schedule 2 the Environmental Planning Figure 6 in this report provides and Assessment Regulation 2000 (the background information about Regulation). vegetation in the locality.

Notwithstanding the key issues • consideration of cumulative impacts specified below, the EIS must include Figure 9 in this report shows other an environmental risk assessment to development that has recently identify the potential environmental occurred on the site.

impacts associated with the • Measures to avoid, minimise and if development. necessary, offset the predicted Where relevant, the assessment of the impacts. key issues below, and any other Section 7.1 of this report provides details significant issues identified in the risk of a consideration avoiding and assessment, must include: minimising biodiversity impacts.

• adequate baseline data; The BAM method described in this report • consideration of potential cumulative requires offsets when appropriate. impacts due to other development in Biodiversity offsets credits will be the vicinity (completed, underway or purchased for the proposal consistent proposed); and with the requirements of the BAM/BDAR.

• measures to avoid, minimise and if necessary, offset the predicted impacts, including detailed contingency plans for managing any significant risks to the environment.

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6. Ecologically Sustainable This report has been prepared using the Development (ESD) NSW Biodiversity Assessment Method BAM). The NSW government describes Demonstrate that the development the BAM as a “repeatable and has been assessed against a suitably transparent assessment of terrestrial accredited rating scheme to meet biodiversity values on land”. industry best practice.

14. Biodiversity The NSW Biodiversity Conservation Act Biodiversity impacts related to the 2016 requires the use of the BAM for proposal and the preparation of a certain projects including some State biodiversity assessment are to be Significant Development / Infrastructure. addressed in accordance with the A Biodiversity Development Assessment requirements of the Biodiversity Report (BDAR) uses the BAM as the Conservation Act 2016. method of assessment. The NSW government has advised that a BDAR is required for this project.

The BAM has been used to assess the proposal. The BAM was released on 25 August 2017, and consequently it is a relatively new method. The NSW government from time to time provides updates and clarifications about the use of the BAM. This report will be amended to be consistent with these updates and clarifications prior to final lodgement of this report.

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Figure 1. Nepean Hospital map.

Site location

Land and property Information NSW. Spatial Information eXchange (SIX) website 2018.

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Figure 2. Location map (Aerial photo) of Nepean Hospital and local area.

Key Nepean Hospital location

5km radius around Nepean Hospital

Land and property Information NSW. Spatial Information eXchange (SIX) website 2018. N

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N Figure 3. Proposal Diagram with Nepean Hospital boundaries in red and operational and construction footprint (proposal area) outlined in green.

Land and property Information NSW. Spatial Information eXchange (SIX) website 2018.

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Figure 4. Tree Protection Plan.

The Tree Protection Plan is an extract from the Arboricultural Development Assessment Report (August 2018) prepared by Paul Vezgoff of Moore Trees. Appendix 4 provides further comments about tree retention and indicates that additional trees within the proposal area will be retained.

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Figure 5. Biodiversity Values map displaying the proposed works area.

The proposed works area is located approximately in the centre of the map. The orange coloured areas approximate the areas of remnant vegetation (4%) within 1500m (1.5 km) of the proposal area.

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Figure 6. Aerial photo indicating the site and the 1500 m buffer area.

Remnant vegetation within the 1500 m buffer area is approximately 4%.

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Figure 7. Vegetation map for the site and surrounding area.

Key * Approximate site location Cumberland Shale Plains Woodland Modified or disturbed land Built land

M.G. Tozer et. al (2010) Native vegetation of southeast NSW: a revised classification and map for the coast and eastern tablelands, Cunninghamia 11(3) 359-406.

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Figure 8. Site vegetation and survey map.

Note: The 400 sqm (m2) plots are nested within the 1000 sqm (m2) plots. There are some differences between the locations of trees displayed on this figure (Figure 8) and Figure 11. This figure was created through the use of a GIS and hand-held GPS unit. In contrast, Figure 11 has been prepared using a survey plan. Land and property Information NSW. Spatial Information eXchange (SIX) website 2018.

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Cumberland Plain Woodland Trees proposed for retention

Figure 9. Site analysis indicating the approximate extent of Cumberland Plain Woodland within Nepean Hospital.

Note: Green circles indicate remnant Cumberland Plain woodland trees to be retained. Orange circles indicate Cumberland Plain Woodland trees proposed for removal. The area within the red rectangular shape shows a development that has been recently assessed and approved. Tree data but not location data is available for the area within the orange rectangle, tree locations within the orange rectangle are only indicative. This diagram was prepared from data from Moore Trees and work undertaken by Abel Ecology.

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Figure 10. Proposal indicating tower location and existing vegetation.

The A indicates where the proposed entrance car park is located. There are some differences between the locations of trees displayed on this figure (Figure 10) and Figure 11. This figure was created through the use of a GIS and hand-held GPS unit. In contrast Figure 11 has been prepared using a survey plan. Source of base map: NSW Health Infrastructure.

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Figure 11. Amended Plan 2 from the Moore Trees Arboricultural Report (August 2018).

The identity of plant species was based upon the Arborist Report.

Many of the numbered trees and shrubs displayed above are species indigenous to Western Sydney. The indigenous Western Sydney species have been classified in the diagram above according to the following information. Eucalyptus sideroxylon is indigenous to Western Sydney. However, it is not considered to be a part of Cumberland Plain Woodland at this site for the following reasons. In western Sydney, it is naturally only found north of the site around Richmond and nearby areas on soils that tend to contain gravel. Additionally, planted cultivated forms of E. sideroxylon usually have red- pink flowers while indigenous Western Sydney forms typically have white flowers.

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Allocasuarina torulosa, Corymbia maculata and Melaleuca lineariifolia are indigenous to Cumberland Plain Woodland or nearby areas but are planted at this location. Melaleuca decora and Melia azedarach at this site are likely to be planted or introduced, however, a precautionary approach has been taken and they are included in the remnant vegetation.

The planted species Acmena smithii, Callistemon salignus and Syzygium paniculatum are included in the above diagram and are indigenous to the Sydney region but are not listed as Cumberland Plain Woodland species. Syzygium paniculatum (282 and 283) is a threatened species, however it is outside the development footprint.

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1. Introduction

A biodiversity survey of the proposed development site at Nepean Hospital campus 35 Derby St, Kingswood (‘the site’ – Figure 1. Nepean Hospital) was undertaken on 24th, 25th and 29th January 2018. The proposal for the site is a construction of a tower and related infrastructure. The proposal is considered to be State significant development or infrastructure.

The following is an extract from the Biodiversity Conservation Act 2016

7.9 Biodiversity assessment for State significant development or infrastructure (1) This section applies to: (a) an application for development consent under Part 4 of the Environmental Planning and Assessment Act 1979 for State significant development, and (b) an application for approval under Part 5.1 of the Environmental Planning and Assessment Act 1979 to carry out State significant infrastructure.

(2) Any such application is to be accompanied by a biodiversity development assessment report unless the Planning Agency Head and the Environment Agency Head determine that the proposed development is not likely to have any significant impact on biodiversity values.

(3) The environmental impact statement that accompanies any such application is to include the biodiversity assessment required by the environmental assessment requirements of the Planning Agency Head under the Environmental Planning and Assessment Act 1979.

Health Infrastructure contacted the NSW Department of Planning and Environment and requested that a waiver be provided. The NSW Department of Planning and Environment advised that a Biodiversity Development Assessment Report (BDAR) is the suitable approach for the proposal.

The preparation of a BDAR requires adherence to the NSW Biodiversity Assessment Method (BAM) 2017.

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This BDAR report has been prepared using the BAM and the assessment addresses both ‘endangered’ and ‘vulnerable’, as required by the Biodiversity Conservation Act 2016 (BCA 2016). Throughout this report ‘threatened’ refers to those species and communities listed as ‘endangered’ or ‘vulnerable’ in Schedules 1 & 2 of the BC Act 2016.

A site map is included in this report as Figure 1.

A location map is included in this report as Figure 2.

Digital shape files are not included in the printed version of this report. These digital files must and will be uploaded to the OEH website when the final report is delivered to the NSW Department of Planning.

1.1 The proposal

The proposal area is displayed in Figure 3. The proposal is to construct a fourteen- storey hospital tower, ancillary buildings, pedestrian links and roads with a

constructional operational footprint on site of approximately 3.08 ha. The work will consist of: a) buildings b) roads and driveways c) parking spaces d) link up to sewage system e) clearing onsite vegetation f) utilities within the lot

Figure 4, Figure 8, Figure 9 and Figure 11 indicates the trees to be retained and removed within the proposal area. This diagram has been used along with discussions with the planning team to determine which trees are proposed to be removed. During negotiations with the project team, there have been some alterations to the trees proposed for removal (see Appendix 4).

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1.2 General description of Nepean Hospital

For the purposes of this report, Nepean Hospital (Figure 1) is defined by the property boundaries of lot 1 DP 1114090. Nepean Hospital campus is 13.92 ha. in size and the elevation is approximately 50 m above sea level. The hospital is bounded to the north by the Great Western Highway with Nepean Private Hospital immediately adjacent north west and adjoined by a pedestrian flyway over Barber Street. The southern boundary of the Nepean Hospital campus is to Derby Street, east is Somerset Road and the western boundary fronts Parker Street.

The site is flat with a slight slope to the east and south. There are no water bodies or creeks. Stormwater management is by engineered structures with concrete culverts and pits to street level.

The adjacent properties (Figure 2) are mixed medical facilities and residential. Kingswood railway station is located 600 m north east.

1.3 Geology and soils

The geology on the site consists of erosional deposits of the Wianamatta Group shales. The soil landscape is Luddenham comprising undulating to rolling low hills and wide valleys, often associated with Minchinbury Sandstone, local relief of 50 – 80 m and gentle slopes of 5 – 20%. Soils are typically shallow (<150 cm) podzolic with an A horizon of loam and or clay/loam and a B horizon of light to medium clay (Bannerman and Hazelton 1990).

1.4 History of the site

The site was cleared and presumably used for livestock grazing in 1943. Since that time urban development of the area including the construction of a hospital has taken place.

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1.5 Sources of information used in this assessment

Literature reviewed in order to assess possible issues relating to this site include: City Plan Survey and Development (2018) Environmental Impact Statement SSDA 8766 Nepean Hospital and Integrated Ambulatory Services Air photo (SIX maps) Tozer (2010) Native vegetation of southeast NSW: a revised classification and map for the coast and eastern tablelands. Cunninghamia, 11(3): 359- Schedules to the BC Act 2016 Schedules to the EPBC Act 1999 OEH Bionet Atlas of NSW Wildlife NSW Government Biodiversity Values Map NSW Government Planning and Environment online Planning Portal Biodiversity Assessment Method (2017)

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2. Landscape features

2.1 Landscape features

Nepean Hospital campus is located in the Sydney Basin IBRA bioregion, in the Cumberland IBRA subregion, and in the Cumberland Plain Mitchell Landscape in New South Wales.

There is approximately 27 ha of native vegetation within the 1500 m buffer area (native vegetation extent), thus approximately 4% (Figure 5, Figure 6) of the buffer area still contains remnant vegetation. The 1500 m buffer area is approximately 707 ha in size.

Remnant native vegetation of varying quality occurs in small pockets within a 1.5 km buffer zone of the hospital campus. These sites include Spence Park, Peppermint Park and the grounds of Kingswood Public School. They have no proximate connectivity to the hospital site and exist in an otherwise urban matrix.

The remaining area is cleared or modified. The Penrith locality has a history of land modification and it is now largely an urbanised area. There is no obvious difference between the mapped vegetation extent and the extent of native vegetation indicated by aerial imagery in the 1500 m radius buffer area.

Only a portion of the vegetation with the proposal area is remnant vegetation. Vegetation within the proposal area is a mix of remnant vegetation and planted vegetation (landscape and gardens) and this is discussed in Section 4.1. Connectivity for most fauna is poor apart from highly mobile species present in urban areas.

No rivers or streams are present within the Nepean Hospital. The closest watercourse which is a first order stream, is approximately 350 m east of the site. There are no wetlands on the site or on adjacent properties. The closest wetland, probably an old dam, is approximately 1.65 km east of the site on Werrington Creek within the Kingswood Campus of the Western Sydney University. The Hawkesbury-Nepean River is approximately 3 km to the west.

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Nepean Hospital is in a highly disturbed landscape. No obvious features of geological significance or soil hazard features were observed during the site assessment. It is assumed that the construction works will be managed so the likelihood of erosion is minimised.

2.2 Site context components

2.2.1 Description of the field assessment (identification of the method applied)

A site-based assessment was undertaken. However, the site is highly disturbed and remnant native vegetation consists of scattered trees or clumps of trees separated by buildings, hard surfaces (concrete and asphalt) and gardens and landscape plantings. Figure 8 displays the character of the proposal area and shows the extent of remnant canopy vegetation as well as landscape plantings. During the training course for the BAM method provided by Muddy Boots (August 2017), it was stated that the plot assessment ideally should be located away from highly disturbed site characteristics such as paths, roads and other constructed features. At this site it was not possible to locate a plot in an undisturbed area, see Section 3.2 for additional details.

2.2.2 Native vegetation cover (percentage) and patch size

The area of remnant vegetation canopy cover within the proposal (works) area was approximately 1300 m2 - this is equal to 0.8% of the proposal area. The 1300 m2 area was calculated as the extent of the remnant tree canopy. While local native species were present as ground covers in other areas, their abundance was approximately 1%. The scattered native species were not used to calculate the area of remnant vegetation within the proposal area.

An assessment of the patch size is also required as an input for the Biodiversity Assessment Method calculator. Patch size is defined as:

an area of intact vegetation that: a) occurs on the development site or biodiversity stewardship site, and b) includes native vegetation that has a gap of less than 100 m from the next area of moderate to good condition native vegetation (or ≤30 m for non- woody ecosystems).

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The vegetation within 100 m of the proposal is not “intact”, it consists of scattered remnant trees. However, trees in the landscape provide connectivity for various flying species. As a precautionary approach, two different values of patch size were used as inputs. The first value was 1(ha), this is the lowest positive whole number value. The other value for patch size used as an input was 501 (ha). Five hundred and one hectares was the largest class of patch size in the Biobanking calculator. The Biodiversity Assessment Method is partially based upon the Biobanking method and Biobanking calculator.

Using either 1 ha or 501 ha made no difference to number of credits required as an offset for this proposal. The patch size selected as an input into the BAM calculator was 1 hectare.

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3. Field survey methods

3.1 Field work effort

Over the five days of fieldwork a total of 52.8 hours was spent undertaking survey work on the site and surrounding habitat areas.

Table 2. Survey dates and weather conditions.

Hours Staff* Temperature Date Time Task (hrs x no. (OC) people) Vegetation survey and DW, AH recordings of incidental fauna 4 Nov 17 10:30-12:50 20.1 -21.4 (2.4 x 2) = 4.8 records. Undertaken as part of a previous survey. Vegetation survey and MS, AH recordings of 24 Jan 2018 08:30 – 15:30 24 - 33 (7 x 2) = 14 incidental fauna records. Vegetation survey and MS, AH recordings of 25 Jan 2018 08:30 – 15:30 23 - 35 (7 x 2) = 14 incidental fauna records. Vegetation survey and MS, AH recordings of 29 Jan 2018 9:00 – 17:00 26 - 37 (8 x 2) = 16 incidental fauna records. 01 Feb 2018 08:30 -10:30 22 - 24 Vegetation survey. (2 x 2) = 4 DM, MS

*Staff associated with field work and analysis of field work: DW = Dr Danny Wotherspoon, AH = Dr Alison Hewitt, MS = Mark Sherring, DM = Dr Daniel McDonald.

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3.2 Flora survey method, vegetation community and habitat classification

A flora survey was conducted to collect the data required for the NSW Biodiversity Assessment Methodology calculator. This included species present, foliage cover, the number of large trees, tree stem size diversity, tree regeneration, presence of hollows, length of fallen logs and litter cover. Vegetation descriptions and species lists were also compiled for the proposal area.

It was not feasible to locate a 20 x 50 m (1000 m2) rectangular plot and a nested 20 m x 20 m (400 m2) square plot including remnant trees without the plots overlapping large areas of built features such as hard surfacing (paths and roads) and buildings. The plots were modified so that the overall required areas were achieved, being 1000 m2 and 400 m2 but the plots were not regular rectangles or squares. The irregular shapes allowed the site vegetation assessment to be undertaken on areas where soil was present and capable of growing plants, including some local indigenous groundcover species. Figure 8 indicates the location of the irregularly shaped plots.

All species within each 1000 m2 plot were recorded and GPS waypoints taken of all trees. The diameter at breast height over bark (dbh in centimetres) was measured from each tree with an arborist tape. For multi-stemmed trees, only the largest living stem was included in the dbh measurement. The presence of hollows and lengths of any fallen logs were recorded.

Litter (and other matter) cover was recorded from five 1 m x 1 m plots placed evenly along a central transect of the 1000 m2 plot.

Within the 400 m2 nested plot, the percentage of foliage cover for each species (live plants only) was estimated including canopy overhanging the plot, even if the plant’s stem was rooted outside the plot.

Growth form codes, such as ‘Tree’, ‘Shrub’, ‘Forb’, ‘Grass’ or ‘Other’, were applied to each species using the ‘Native Species by Growth Form Reference’ provided to course participants of the Biodiversity Assessment Method (BAM) training course. All species were additionally coded as Native (a species indigenous to NSW), Exotic (including Australian native species that are not indigenous to NSW) or High Threat Exotic.

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The following were derived from the data:

1. Composition (native plant species richness for each growth form); 2. Structure (native and non-native plant % foliage cover within each growth form); and 3. Vegetation function scores. A ‘litter cover’ score was calculated as the average percentage of ground cover of litter recorded from the five 1 m x 1 m plots. Tree stem size diversity scores were tallied after allocating the dbh data to stem size classes in centimetres: < 5, 5 – 9, 10 – 19, 20 – 29, 30 – 49, 50 – 79 and 80+.

Field data sheets are provided in Appendix 2.

Recorded flora species and other characteristics such as vegetation structure and soils were used to classify the vegetation community on site. The plant community on site was classified according to the NSW VIS.

Plot 2 was used to record data within the landscape plantings are gardens.

3.3 Threatened species generated by the Biodiversity Assessment Method calculator

The online Biodiversity Assessment Method Calculator (BAM Calculator) was used to generate a list of threated species that potentially used the site as habitat. Tab 4 Habitat suitability in the BAM Calculator generated the lists displayed in tables in Sections 3.3.1 and 3.3.2 below. A consideration of whether the habitat on site and the features of the locality are suitable for each threatened species is provided in the second column in each table. The third column in the tables indicates if the species was included in the assessment.

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3.3.1 The Biodiversity Assessment Method calculator displayed the following Predicted threatened species (Ecosystem credits):

Species Presence onsite or Habitat Included in Assessment on site Brown Treecreeper Vagrant only, not No (eastern subspecies) generally present in the Climacteris picumnus locality. victoriae Spotted-tailed Quoll Not generally present in No Dasyurus maculatus the locality. Little Lorikeet Marginal foraging habitat Yes Glossopsitta pusilla in the proposal area, prefers intact vegetation. Flame Robin Vagrant only, not No Petroica phoenicea generally present in the locality. Scarlet Robin Vagrant only, not No Petroica boodang generally present in the locality. Dusky Woodswallow Vagrant only, not No Artamus cyanopterus generally present in the cyanopterus locality. White-bellied Sea-Eagle No suitable habitat on site. No Haliaeetus leucogaster May fly over the proposal (Foraging) area on occasions. Swift Parrot Potential occasional Yes Lathamus discolor foraging habitat. (Foraging) Hooded Robin (south- Vagrant only, not No eastern form) generally present in the Melanodryas cucullata locality. cucullate Little Bentwing-bat Potential occasional Yes Miniopterus australis foraging habitat. (Foraging)

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Species Presence onsite or Habitat Included in Assessment on site Eastern Bentwing-bat Potential occasional Yes Miniopterus schreibersii foraging habitat. oceanensis (Foraging) Eastern Freetail-bat Potential occasional Yes Mormopterus norfolkensis foraging habitat. Koala Not generally present in No Phascolarctos cinereus the locality. (Foraging) Grey-headed Flying-fox Potential foraging habitat. Yes Pteropus poliocephalus (Foraging) Speckled Warbler Vagrant only, not No Chthonicola sagittata generally present in the locality. Diamond Firetail Vagrant only, not No Stagonopleura guttata generally present in the locality. Regent Honeyeater Vagrant only, not No Anthochaera phrygia generally present in the (Foraging) locality.

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3.3.2 The Biodiversity Assessment Method calculator displayed the following Candidate threatened species (Species credits):

Species Presence onsite or Habitat Included in Assessment on site Bynoe's Wattle Not observed during the No Acacia bynoeana proposal area survey. Downy Wattle Not observed during the No Acacia pubescens proposal survey. Regent Honeyeater Vagrant only, not No Anthochaera phrygia generally present in the (Breeding) locality. Not reported to breed in the locality in recent times. Thick Lip Spider Orchid Not observed during the No Caladenia tessellata proposal area survey. White-flowered Wax Plant Not observed during the No Cynanchum elegans proposal area survey. Dillwynia tenuifolia Not observed during the No proposal area survey. Dillwynia tenuifolia - Not observed during the No endangered population proposal area survey. Camden White Gum Not observed during the No Eucalyptus benthamii proposal area survey. Juniper-leaved Grevillea Not observed during the No Grevillea juniperina subsp. proposal area survey. juniperina White-bellied Sea-Eagle No nests of the White- No Haliaeetus leucogaster bellied Sea-Eagle were (Breeding) observed during the proposal area survey. Swift Parrot Does not breed in NSW. No Lathamus discolor The Swift Parrot breeds in (Breeding) Tasmania. Green and Golden Bell No suitable breeding No Frog habitat within the proposal Litoria aurea area.

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Species Presence onsite or Habitat Included in Assessment on site Marsdenia viridiflora R. Br. Not observed during the No subsp. viridiflora proposal area survey. endangered population in the Bankstown, Blacktown, Camden, Campbelltown, Fairfield, Holroyd, Liverpool and Penrith local government areas Cumberland Plain Land Site highly disturbed. Not No Snail observed during the Meridolum corneovirens proposal area survey. Little Bentwing-bat No breeding habitat No Miniopterus australis observed during the (Breeding) proposal area survey. Eastern Bentwing-bat No breeding habitat No Miniopterus schreibersii observed during the oceanensis proposal area survey. (Breeding) Southern Myotis No breeding habitat No Myotis macropus observed during the proposal area survey. Bargo Geebung Not observed during the No Persoonia bargoensis proposal area survey. Squirrel Glider Not generally present in No Petaurus norfolcensis the locality. Koala Not generally present in No Phascolarctos cinereus the locality. (Breeding) Pimelea curviflora var. Not observed during the No curviflora proposal area survey. Spiked Rice-flower Not observed during the No Pimelea spicata proposal area survey.

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Species Presence onsite or Habitat Included in Assessment on site Dural Woodland Snail Site highly disturbed. Not No Pommerhelix duralensis observed during the proposal area survey.

Grey-headed Flying-fox No roosting sites were No Pteropus poliocephalus observed during the (Breeding) proposal area survey. Sydney Plains Greenhood Not observed during the No Pterostylis saxicola proposal area survey. Matted Bush-pea Not observed during the No Pultenaea pedunculata proposal area survey. Austral Toadflax Not observed during the No Thesium australe proposal area survey.

3.4 Fauna survey method

The methods of survey undertaken to detect the various faunal groups or their habitat are outlined below.

Roads and road verges were searched for road-kill fauna. Surveys for mammals, reptiles and frogs are generally run concurrently.

Dates, weather and temperatures of all fieldwork were recorded and are tabulated in Table 2 above.

3.4.1 Diurnal fauna searches

Searching, opportunistic observations and call recording provides an indication of types of species using a site. These methods are used to identify and record live animals or record indirect evidence of animal presence on the site. On occasions, specific surveys may be conducted for a targeted group or species, such as searching the margins of a dam for frogs.

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Generally though, birds, reptiles, frogs and mammals, or evidence of them, may all be present in the same habitat at the time of survey, therefore searching for these faunal groups is generally run concurrently. This involved:

a) Searching shelter sites, basking sites, opportunistic observation, and assessment of shelter site diversity suitability for reptiles. b) Searching shelter sites, calling sites, egg deposition sites, spotlighting and triangulation on calling males for frogs. c) Opportunistic observations and identification of calls of species, and search for indirect evidence such as nests, feathers, scratchings and feeding signs for birds. d) Searching for indirect evidence, such as diggings, droppings, runways and burrows, and opportunistic observations for mammals.

While rigorous surveys are likely to find more species, high species richness for birds can be recorded in a relatively short amount of time. Bird surveys are used as a simple indicator of other parameters, such as biodiversity and the functioning of the ecosystem.

3.5 Limitations of the survey

This survey was conducted in the spring and summer seasons. This was not suitable for winter migrants or species of winter-flowering orchids that lose their aerial stems after fruiting.

The weather conditions were warm and the conditions were suitable for the survey of most diurnally active species.

Species that may use the site were not detected during the survey for the following reasons: a) The species was present during the survey but was not detected due to dormancy, inactivity or cryptic habits. b) The species use the site at other times of the year but was not present during the survey due to being nomadic or migratory.

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4. Survey Results: Vegetation and habitat description

4.1 Site vegetation identification and habitat zone descriptions

4.1.1 Remnant vegetation

The site is highly modified and contains little remnant local native vegetation. However, there are scattered remnant trees, mostly Grey Box Eucalyptus moluccana and Forest Red Gum Eucalyptus tereticornis. The remnant trees and nearby scattered locally indigenous groundcovers represents remnant vegetation.

The scattered remnant vegetation is a remnant of Grassy Woodland (Formation) in the Class Coastal Valley Grassy Woodlands and the Plant Community Type (PCT) is: 849 – Grey Box – Forest Red Gum grassy woodland on flats of the Cumberland Plain, Sydney Basin Bioregion. The Threatened Ecological Community (TEC) associated with PCT 849 is Cumberland Plain Woodland in the Sydney Basin Bioregion and it is listed as a Critically Endangered Ecological Community.

The calculated area of remnant trees (PCT 849) within the proposal area is 0.13 ha. The area of the PCT 849 that is proposed to be removed is approximately 0.1 ha. The BAM calculator appears to require increments of at least 0.1 ha for the size of any vegetation zone.

The species relied upon for identification of the vegetation type was the following species from the canopy layer: Grey Box Eucalyptus moluccana, Red Forest Gum Eucalyptus tereticornis and Kurrajong Brachychiton populneus.

Two individuals of Melaleuca decora, a locally indigenous shrub, appear to be present as a remnant plants within the proposal area.

The following species are present in some parts of the Cumberland Plain but are not remnant at this within the proposal area: • Spotted Gum Corymbia maculata is naturally found in the Cumberland Plain but is typically found around Cecil Park, Liverpool and further south. Spotted Gum Corymbia maculata has been planted at this location.

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• Similarly, Mugga Ironbark Eucalyptus sideroxylon is naturally present in the Cumberland Plain but it is typically associated with gravelly soils and is naturally present north of Penrith around Richmond and the Castlereagh Nature Reserve. Mugga Ironbark is commonly planted in the Sydney region and is planted at this site. • Both the She-oaks Allocasuarina littoralis and Allocasuarina torulosa are indigenous in the Sydney Region but have been planted within the proposal area. • Melaleuca styphelioides and Narrow-leaved Ironbark Eucalyptus crebra are also present and planted within the proposal area. Narrow-leaved Ironbark is a naturally occurring local species and is present in many natural remnants of Cumberland Plain Woodland. However, the individuals of Narrow-leaved Ironbark Eucalyptus crebra present within the proposal area appear planted as they occur in landscaped garden beds and are approximately the same age as the other planted non-local vegetation.

Groundcover species that are known to be locally indigenous and were observed within the proposal area were: Cyperus gracilis, Brunoniella pumilio, Einadia hastata and Dichondra repens. These species are considered to represent local indigenous remnant groundcovers and part of PCT - 849.

The species Lomandra longifolia and Dianella caerulea both occur naturally on the Cumberland Plain, however, at this site appear to be planted. These two species were only recorded in highly modified planted landscapes and did not occur near any of the remnant trees.

The BioNet Vegetation Classification website states that the current extent of PCT849 is 6800 ha and the 93% of PCT849 has been cleared (OEH BioNet Vegetation Classification website checked on 5 February 2018.

4.2 Areas of landscape and gardens

Another vegetation zone is present within the proposal area. This vegetation zone is described as Landscape and gardens in Figure 8.

This vegetation zone contains planted species including species native to NSW eg: Gymea Lily Doranthes excelsa, Flooded Gum Eucalyptus grandis, Tallowwood Eucalyptus microcorys and Broad-leaved Paperbark Melaleuca quinquenervia.

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Other planted native Australian species not naturally present in NSW include Red Flowering Gum Corymbia ficifolia and Marri Corymbia colophylla. These species are both indigenous to Western Australia.

Exotic species such as Bird of Paradise Flower Strelitzia reginae, Traveller’s Tree Ravenala madagascariensis, Black Locust Robinia pseudoacacia, Chinese Elm Ulmus parvifolia and Firecracker Plant Russelia equisetiformis, are also present in the landscape and gardens.

This area of landscape and gardens provides some potential foraging habitat for locally indigenous threatened fauna, such as the Grey-headed Flying-fox (nectar- producing species – planted Grevilleas and planted Callistemons) and threatened microbats (prey such as insects will be present around both exotic vegetation and around street lights).

However, the mixed landscaping area does not represent any natural indigenous vegetation community within the Western Suburbs of Sydney.

It does not match any Plant Community Type (PCT). Dr Daniel McDonald contacted Clare Kerr (OEH) via email the requirement of nominating a PCT to the area of landscape and gardens. This correspondence is provided in Appendix 6. As the BAM requires the selection of a Plant Community Type to represent the area of landscape and gardens, the following possibilities were considered.

1. The most likely PCT based upon common Eucalyptus canopy species within the gardens and landscape area. Tallowood Eucalyptus microcorys, Sydney Blue Gum Eucalyptus saligna and Flooded Gum Eucalyptus grandis are not indigenous to the site. The NSW government website Bionet Vegetation Classification was used to search for a PCT where all three of these species are named as canopy species - see https://www.environment.nsw.gov.au/NSWVCA20PRapp/search/pctsearch.aspx

The PCT 812 Dunn’s White Gum tall open forest of the ranges of the northern NSW North Coast Bioregion lists all three of these canopy species. However, this PCT cannot be used as an input in the BAM calculator as the PCT is not present within the Sydney Basin.

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2. The area of landscape and gardens are unlikely to be considered a “Threatened Ecological Community” as the landscape and gardens do not represent a natural ecological community as the plants have been primarily planted. Some plants found within the landscape and gardens may have grown from seed, but even the regenerating plants are unlikely to generally represent the original indigenous ecological community.

Based upon the premise that the area of gardens and landscape do not represent a threatened PCT, a representative of a non-threatened PCT was selected as an input to the BAM calculator to represent the landscape and gardens area. The representative is PCT 1083 Red Bloodwood – scribbly gum heathy woodland on sandstone plateaux of the Sydney Basin Bioregion. The characteristics that the area of landscape and gardens has in common with PCT 1083 are: They are both found in the Sydney Region and the estimated extent of PCT 1083 is 17%. Hence it is a non- threatened PCT.

3. A third alternative was considered. Namely, the area of landscape and gardens as a form of PCT 849 Grey Box – Forest Red Gum grassy woodland on flats of the Cumberland Plain, Sydney Basin Bioregion. This PCT was considered as it is highly likely that this was the original pre-clearing vegetation community that was found in the area of landscape and gardens. However, a comparison of the landscape and gardens with the NSW Scientific Committee – final determination for Cumberland Plain Woodland in the Sydney Basin Bioregion – critically endangered ecological community listing was also reviewed. It was concluded that the area of landscape and gardens would highly unlikely to be considered a form of Cumberland Plain Woodland.

Consequently, the PCT 1083 Red Bloodwood – scribbly gum heathy woodland on sandstone plateaux of the Sydney Basin Bioregion was selected as the PCT to be used to represent the area of landscape and gardens. The choice of PCT to represent the area of landscape and gardens seems rather arbitrary as the similarity between any PCT and the area of landscape and gardens is low.

Health Infrastructure may choose to negotiate with OEH about the appropriate PCT for the area of landscape and gardens.

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4.2.1 Patch size

Patch size is described as: an area of intact native vegetation that: a) occurs on the development site or biodiversity stewardship site, and b) includes native vegetation that has a gap of less than 100m from the next area of moderate to good condition native vegetation (or ≤30m for non-woody ecosystems). Patch size may extend onto adjoining land that is not part of the development site or biodiversity stewardship site.

Intact vegetation is described as: vegetation where all tree, shrub, grass and/or forb structural growth form groups expected for a plant community type are present.

Remnant vegetation adjoining the site exists in a highly urbanised environment. It is highly unlikely that a contiguous area of an intact shrubby Cumberland Plain vegetation exists in this urban environment. A common, and perhaps the most common shrub species found in Cumberland Plain Woodland is Blackthorn Bursaria spinosa. This species is slightly thorny and while individual shrubs may survive, this species is commonly removed in urban areas. Thus, it is considered for this report that no contiguous intact vegetation exists adjacent to the site. Consequently, the patch size is considered to only consist of the remnant vegetation within the proposal area and the lowest whole number value of patch size (1 ha), has been used as an input in the Biodiversity Assessment Method calculator for this assessment.

The location of the vegetation zones is displayed in Figure 8.

The vegetation integrity was assessed by the use of plots. The raw data is provided in Appendix 2. The survey effort is described in Table 2. The vegetation integrity score calculated by the Biodiversity Assessment Method calculator is displayed in Table 4. Appendix 1 shows the list of flora found on the site.

Other site habitat characteristics are described below.

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Table 3. Significant features and observations for this zone.

Significant features Observations Frequency of large trees Rare (approx. > 50 cm DBH) Tree regeneration and While stem size diversity might indicate a range of Tree stem-size diversity age classes of trees on site, this actually reflects trees planted into garden beds at different times in the past. Natural tree regeneration appears rare and is absent for Grey Box and Red Forest Gum. One Brachychiton populneus was noted that appears to have grown from seed dispersal. Likewise, a few Olea europea subsp. cuspidata, a High Threat Weed was observed as a seedling. Logs, woody debris and Logs and coarse woody debris are absent. litter cover The levels of leaf litter and other forms of introduced organic mulch level within the garden beds is high. Some areas are mown. Food resources Eucalyptus, Corymbia and Callistemon are present and would provide food resources of blossoms and seeds. A low to negligible cover of fallen and rotting material is present near the base of remnant trees.

4.3 Vegetation integrity

The vegetation integrity for the remnant vegetation on-site was assessed and the data is provided in Appendix 2. The vegetation integrity (remnant vegetation condition) was calculated by the BAM calculator using the composition, structure and function attributes of the remnant vegetation.

It is assumed when recording the function characteristics that the number of large trees, tree stem size diversity and tree regeneration refers to species that are native to NSW. Exotic species characteristics were recorded in the field but have not been included in the data used by the BAM calculator.

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The benchmark data used for the calculations was the data available in the BioNet Vegetation Classification for Plant Community Type 849.

The BAM calculator provided the following values (Table 4):

Table 4. Current vegetation integrity score and components for each zone.

Vegetation Composition Structure Function Current zone condition score condition score condition score vegetation integrity score Remnant 14.4 36.8 65 32.5 vegetation Zone 1

Landscape 6.1 9.2 39.7 13.1 and gardens Zone 2

4.4 Commonwealth listed species and communities of conservation concern

Cumberland Plain Woodland is listed as a Critically Endangered Community by the Commonwealth Government. However, the quality of the Cumberland Plain Woodland at Nepean Hospital does not meet one of the condition thresholds.

One condition threshold required by the Commonwealth is that the patch of the ecological community must be 0.5 ha or greater in size. A patch is defined by the Commonwealth as a discrete and continuous area that comprises the ecological community.

The Cumberland Plain Woodland on the Nepean Hospital site cannot be defined as a continuous area totalling 0.5 ha or greater in size. The Cumberland Plain Woodland on the Nepean Hospital site consists of single trees or clumps of trees more common in some areas but scattered over the site. Additional details can be found in Department of the Environment, Water, Heritage and the Arts (Australian Government) 2010.

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Cumberland Plain Shale Woodlands and Shale-Gravel Transition Forest – A guide to identifying and protecting the nationally threatened ecological community. Policy Statement 3.31.

No Commonwealth listed species were observed on site during the field work.

4.5 Weeds

One High Threat Weed, a seedling of African Olive Olea europaea subsp. cuspidata was recorded in the Plot 1 1000 m2 plot area (Figure 8).

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5. Threatened species

5.1 Threatened species and details of flora and fauna surveys

Details of ecosystem credit species associated with the PCT are displayed in Section 3.3.1. The authors of this BDAR stated that the proposal area did not provide habitat for some species sometimes associated with the PCT. The reasons for exclusion are provided in Sections 3.3.1 and 3.3.2. The justification for exclusion of the bird species is supported by Roberts (2009) and Patrick (2016).

5.1.1 Species polygons

Appendix 1 Provides a list of flora and fauna recorded during the proposal area survey. The area of remnant vegetation and the area of landscape and gardens was considered to represent the species polygon for each species. As discussed above in Section 4.1 the areas of planted vegetation (landscape and gardens) potentially providing foraging habitat for threatened species such as the Grey-headed Flying- fox was assigned to Plant Community Type (PCT) 1083.

5.1.2 Biodiversity risk weighting

Appendix 7 of the BAM method 2017 provides a background to Biodiversity risk weighting.

Biodiversity risk weightings apply to both ecosystems (vegetation types/PCTs) and threatened species. Two Plant Community Types are assessed in this BDAR. One is a form of Cumberland Plain Woodland and it is listed as a Critically Endangered Ecological Community. It has a very high sensitivity to loss as displayed in Table 5. The area of landscape and gardens has been assigned to PCT 1083,

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Table 5. List of habitat/s on site and their sensitivity class/es.

PCT/Habitat/Ecosystem Sensitivity to loss class 849 - Grey Box - Forest Red Gum grassy Very high sensitivity woodland on flats of the Cumberland Plain, Sydney Basin Bioregion. Area of landscape and gardens – Low sensitivity assigned to PCT 1083 – Red Bloodwood – scribbly gum heathy woodland on sandstone plateau of the Sydney Basin Bioregion

The threatened fauna species that could potentially use the site as well as their corresponding sensitivity are listed below in Table 6. Only Ecosystem credit species were considered to potentially use the site.

Table 6. Listing of threatened species that potentially use the site and sensitivity to gain weighting.

Species Sensitivity to gain class Little Lorikeet High sensitivity to potential gain Swift Parrot (foraging) Moderate sensitivity to potential gain Little Bentwing-bat High sensitivity to potential gain Eastern Bentwing-bat High sensitivity to potential gain Eastern Freetail-bat High sensitivity to potential gain Grey-headed Flying-fox High sensitivity to potential gain

5.1.3 Threatened species survey

The inputs for webpage 4 Habitat suitability of the BAM Calculator are provided in Sections 3.3.1 and 3.3.2. These inputs were used in the BAM Calculator. The output from the BAM calculator indicated that no specialised fauna survey was required. It is assumed this output was generated as the area of remnant vegetation proposed for removal is small (approximately 0.1 ha) and the habitat quality was not high.

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Based upon the information in Section 3.3.2:

• No species credit species polygons were required as part of this assessment. • No table detailing species credit species and their abundance and the associated habitat features is provided.

5.1.4 Wind farm developments

A wind farm is not included in the proposal. A map of habitual flight paths for nomadic and migratory species likely to fly over the site or a map of threatened aerial species resident on the site is not required.

6. Survey Results: Fauna

6.1 Species of conservation concern

No threatened species of fauna were recorded during the proposal area survey. The site potentially provides habitat for the following threatened species: (derived from Section 3.3.1): Little Lorikeet, Swift Parrot, Little Bentwing-bat, Eastern Bentwing-bat, Eastern Freetail-bat and the Grey-headed Flying-fox. All these species are described as Ecosystem Species. No Species Credit species were recorded during the proposal area visits and similarly no breeding habitat of Species Credit Species was noted during the proposal survey.

The Biodiversity Assessment Method calculator did not require any surveys for a particular species.

6.2 Fauna results

Fauna species recorded during the proposal area surveys is displayed in Appendix 1. All species recorded occur in highly modified environments and include: a reptile Dark-flecked Garden Sunskink Lampropholis delicata, various birds including Rainbow Lorikeet Trichoglossus haematodus and Noisy Miner Manorina melanocephala; and mammals including the Common Brush-tailed Possum Trichosurus vulpecula.

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7. Avoid and minimising impacts

7.1 Avoiding and minimising impacts

The BAM provides the following guidance on Avoid and minimise impacts.

Demonstration of efforts to avoid and minimise impact on biodiversity values in accordance with Chapter 8. Assessment of direct and indirect impacts unable to be avoided at the development site in accordance with Sections 9.1 and 9.2. The assessment would include but not be limited to: type, frequency, intensity, duration and consequence of impact. For major projects: details of the adaptive management strategy proposed to monitor and respond to impacts on biodiversity values that are uncertain (Section 9.4).

An analysis of the remnant trees representing Cumberland Plain Woodland within the majority of Nepean Hospital is displayed in Figure 9. The tree species considered to represent remnant Cumberland Plain Woodland within the Nepean Hospital are Grey Box Eucalyptus moluccana, Forest Red Gum Eucalyptus tereticornis, Coast Grey Box Eucalyptus bosistoana, Narrow-leaved Ironbark Eucalyptus crebra and Kurrajong Brachychiton populneus.

Other trees naturally present in some parts of the Cumberland Plain are not considered to represent remnant Cumberland Plain Woodland on this site, see Section 4.1 for additional information.

The species identity of the trees and their locations on site were derived from the Moore Trees reports and the fieldwork undertaken by Abel Ecology. Moore trees provided additional information regarding the trees numbered 42 through to 65 that was not available in any of their reports, see Appendix 3. These additional trees consist of nine Red Forest Gums Eucalyptus tereticornis and two Grey Box Eucalyptus moluccana, an indicative location for these trees is displayed in Figure 9; no precise location information was available.

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Figure 9 shows that the approximate central portion of the proposal area contains no remnant trees as the area is currently a large car park. Two remnant trees proposed for removal are present on the eastern side of the development footprint and two other clumps of remnant trees are present on the western side of the proposal. Locating the proposal over the existing car park enables part of the proposal to be located in an area with little or no biodiversity values. Some remnant Cumberland Plain Woodland will be removed for the proposal, however, no areas of native vegetation within Nepean Hospital have an excellent vegetation condition. Cumberland Plain Woodland existing primarily as scattered trees or clumps of trees will be retained both north and south of the central portion of the development footprint.

Connectivity of Cumberland Plain Woodland within Nepean Hospital and in the locality will not be significantly altered by the proposal. Connectivity between areas of habitat is currently provided for highly mobile flying species that are present in urban areas and terrestrial species that are able to survive and move through urban areas. The proposal is unlikely to significantly change connectivity for species in this urban locality.

During the preparation of the BDAR a reduction in other impacts on the remnant vegetation near the proposed tower have been achieved. Appendix 4 provides additional information.

The primary method for minimising impacts on the retained Cumberland Plain Woodland is to provide tree protection fencing to exclude any personnel, vehicles or building supplies from within the Tree Protection Zones. This will help to minimise the likelihood of damage to the retained Cumberland Plain Woodland.

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8. Impact summary

8.1 Maps & data

• Submitted proposal in the Credit Calculator – The data must be directly submitted to OEH when the final report has been approved by HI.

8.2 Impact summary

The proposal will require the removal of approximately 0.1 ha of PCT849 comprising primarily Grey Box Eucalyptus moluccana and Red Forest Gum Eucalyptus tereticornis trees, a part of Cumberland Plain Woodland.

The threshold for potential Serious And Irreversible Impacts (SAII) for Cumberland Plain Woodland (PCT849) is not yet available. However, the area of Cumberland Plain Woodland proposed for removal is equal to approximately 0.1 ha. This area is less than half of the lowest clearing threshold for entry into the BAM offset scheme, so it is unlikely that the clearing of 0.01ha will be considered a SAII.

If any SAIIs will be incurred because of the proposal, the SAIIs will be the removal of the PCT849 (Cumberland Plain Woodland). The area of PCT849 that is proposed for removal is indicated in Figure 8. Figure 8 also displays both: a) The impacts requiring offset (0.1 ha of CPW – all CPW within the proposal area except the area marked by the green stars) (Figure 8); and b) and the impacts not requiring offset, displayed as remaining site vegetation.

The impacts that will require offset are the impacts on the Cumberland Plain Woodland (PCT849). The site also contains mixed plantings that provide habitat for both common and threatened species, some of these mixed plantings will be removed for the proposal and will not require offset.

No offsets for Species Credit Species are required as part of the proposal.

The areas not directly assessed for this project include areas within Nepean Hospital but outside of the green polygon as displayed in Figure 9.

Additional information about assessing a SAII when no threshold value is available can be found in guidance provided in correspondence from OEH (Appendix 5).

8.2.1 Measuring the impact of the proposal through ecosystem credits and species credits

The future vegetation integrity score for the single remnant vegetation zone (ha of PCT849) within the proposal area is: 0. Note the remnant vegetation zone is defined as the remnant Cumberland Plain Woodland trees that are proposed for removal within the proposal footprint. All remnant Cumberland Plain Woodland trees within the remnant vegetation zone (zone 1) will be removed.

Other remnant Cumberland Plain Woodland trees that are present within the proposal area or within Nepean Hospital proposed for retention are not included in the remnant vegetation zone.

The change in the vegetation integrity score will be: -32.5 for zone 1, the remnant vegetation zone (Cumberland Plain Woodland).

The number of ecosystem credits required for the impact of the proposal on vegetation zone 1 is: 2.

No species credits are required for any threatened species that may potentially be impacted by the proposal.

The area of landscape and gardens was assigned to PCT 1083. This area is identified as zone 2. The change in the vegetation integrity score for zone 2 will be – 13.1.

Table 7. PCTs requiring offset and the number of ecosystem credits required.

PCTs requiring offset Number of ecosystem credits required PCT849 2

Table 8. Threatened species requiring offset and number of species credits required.

Threatened species requiring offset Number of species credits required No threatened species require offset Not applicable

9. Positive actions

9.1 Site management positive actions to enhance biodiversity

ARCADIA Landscape Architecture have prepared a Landscape Concept and Stage SSDA set of plans (December 2017). These plans describe Cumberland Plain Woodland as the historic vegetation on the site and include locally indigenous Cumberland Plain Woodland species in the Planting Palette for the site.

10. Biodiversity credit report

10.1 Credit classes for ecosystem credits and species credits at the development site.

No species credits are generated by the proposal.

10.2 Table of credit class and matching credit profile

The credit classes for PCT 1083 are displayed above. However, no credit requirements are generated by removal of the area of landscape and gardens (assigned to PCT 1083) for this proposal.

11. References

Abel Ecology (November 2017) Prescribed Ecology Actions Report (PEAR) for Nepean Hospital, Penrith (Lot 1, DP 1114090) – Proposed demolition, new building and additions to existing buildings and car park (AE17-REP-1821-ISS-1). Barrett, G., Silcocks, A., Barry, S., Cunningham, R. and Poulter, R. (2003). The New Atlas of Australian Birds. Royal Australasian Ornithologists Union, Victoria. Benson, D. & McDougall, L. (1991). Rare Bushland Plants of Western Sydney. Royal Botanical Gardens, Sydney. Benson, D.H. and Howell, J. (1990). Taken for granted: the bushland of Sydney and its suburbs. Kangaroo Press, Kenthurst. Briggs, J. D., and Leigh, J. H. (1995). Rare or Threatened Australian Plants. CSIRO, Canberra. Brooker, M. I. H. and Kleinig, D. A. (1990). Field Guide to Eucalypts, Volume 1. South- eastern Australia. Inkata, North Ryde. Carolin, R. C. and Tindale, M. D. (1994). Flora of the Sydney Region Fourth Edition. Reed, Chatswood. Cogger, H. G. (1983). Reptiles and Amphibians of Australia. Reed, Frenchs Forest. Cropper, S. (1993). Management of Endangered Plants. CSIRO, Melbourne Department of Environment, Climate Change and Water (NSW) (2010). Cumberland Plain Recovery Plan, OEH (NSW), Sydney. Department of the Environment, Water, Heritage and the Arts (Australian Government) (2010). Cumberland Plain Shale Woodlands and Shale-Gravel Transition Forest – A guide to identifying and protecting the nationally threatened ecological community. Policy Statement 3.31 Duffy et al. (2000). The efficacy of Anabat ultrasonic detectors and harp traps for surveying microchiropterans in south-eastern Australia. Acta Chiropterologica. 2(2): 127-144, 2000. Ehmann, H. (1992). Encyclopaedia of Australian Animals Reptiles. Angus and Robertson, Pymble.

Ehmann, H. (Ed.) (1997). Overview Chapter, pages 13 - 42 In Threatened Frogs of New South Wales: Habitats, Status and Conservation. Frog and Tadpole Study Group of NSW Inc. Fairley, A. and Moore, P. (1989). Native Plants of the Sydney District, An Identification Guide. Kangaroo Press, Kenthurst. Hazelton, P. A., Bannerman, S. M. & Tillie, P.J. (1989). Soil Landscapes of the Penrith 1:100 000 Sheet. Soil Conservation Service of NSW, Sydney. Leary, T. (2005). Fauna Survey of Parks and Wildlife Division estate on the Cumberland Plain with some observations on the remnant mammal fauna. Department of Environment and Conservation Oral presentation at the Symposium on Cumberland Plain Woodland. University of Western Sydney. McDonald R. C., Isbell, R. F., Speight, J. G., Walker, J., & Hopkins, M. S., (1990). Australian soil and land survey field handbook Second edition. Inkata Press, Melbourne. McKenzie, N. J., Grundy, M. J., Webster, R. and Ringrose, A. J. (2008). Guidelines for Surveying Soil and Land Resources (Second Edition). CSIRO Publishing, Collingwood, VIC. Moore Trees (June 2017) Arboricultural Development Assessment Report – Nepean Hospital Redevelopment – Final Moore Trees (September 2017) Arboricultural Development Assessment Report – Nepean Hospital Redevelopment – Main Works Project – Version 1 5.10.2017. Moore Trees (July 2018) Arboricultural Development Assessment Report – Nepean Hospital and Integrated Ambulatory Services Redevelopment – Concept and Stage 1 SSDA – Final. NSW NPWS (1997). Native Flora of Western Sydney, Urban Bushland Biodiversity Survey, National Parks & Wildlife Service, Hurstville, NSW. NSW Office of Environment and Heritage (2017) Biodiversity Assessment Method (BAM). NSW Scientific Committee, (2001). Final Determination for Clearing of Native Vegetation, Key Threatening Process. Patrick, A. (2016) Birds of Sydney – Two and a half centuries of birdwatching. Self- published, Sydney.

Richards, G. C., (2001). Towards defining adequate bat survey methodology: why electronic call detection is essential throughout the night. The Australian Bat Society Newsletter Number 16 March 2001: 24-28. Roberts, P. (2009) Sydney Birds and where to find them. Jacana Books, an imprint of Allen & Unwin, Crows Nest NSW. Robinson, L. (1994). Field Guide to the Native Plants of Sydney. Kangaroo Press, Kenthurst. Robinson, M. (1993). A Field Guide to Frogs of Australia. Reed/Australian Museum, Chatswood. Simpson, K., Day, N. & Trusler, P. (1996). Field Guide to the Birds of Australia. Penguin, Ringwood, Vic. Specht. R. L. (1970). Vegetation of the Australian Environment. G. W. Leeper (Ed.), 4th Edition, CSIRO, Melbourne. Strahan, R. (Ed.) (1995). The Mammals of Australia. Reed, Sydney. Tozer, M.G. Turner, K., Keith, D.A., Tindall, D., Pennay, C., Simpson, C., MacKenzie, B., Beukers, P. and Cox, S. (2010). Native vegetation of southeast NSW: a revised classification and map for the coast and eastern tablelands. Cunninghamia, 11(3): 359-406.

Appendix 1. Flora and fauna species list

The grid reference for this locality is 288280 East, 6262268 North (GDA 1994) Flora list

The following flora species were observed in the proposal survey area. GYMNOSPERMS CUPRESSACEAE # Callitris (endlicheri) ZAMIACEAE # Lepidozamia peroffskyana

ANGIOSPERMS DICOTYLEDONES ACANTHACEAE # Casuarina glauca “shagpile” Brunoniella pumilio CHENOPODIACEAE ALTINGIACEAE Einadia hastata * Liquidambar styraciflua CONVOLVULACEAE APOCYNACEAE Dichondra repens * Trachelosperma jasminoides EUPHORBIACEAE ASTERACEAE # Triadica sebifera * Conyza sp. FABACEAE BIGNONIACEAE * Robinia pseudoacacia * Jacaranda mimosifolia * Dolichandra unguis-cati FAGACEAE * Quercus robur CARYOPHYLLACEAE * Paronychia brasiliana LYTHRACEAE * Lagerstroemia indica CASUARINACEAE Allocasuarina littoralis (probably MAGNOLIACEAE planted) * Magnolia grandiflora Allocasuarina torulosa (probably planted)

MALVACEAE # Syzygium paniculatum Brachychiton acerifolius (possibly # Tristaniopsis laurina introduced by wildlife) Brachychiton populneus OLEACEAE * Ligustrum lucidum MELASTOMATACEAE * Olea europaea ssp africana HTE * Tibouchina urvilleana * Fraxinus raywood

MELIACEAE OXALIDACEAE Melia azedarach (probably introduced * Oxalis sp. by wildlife or planted) # Toona ciliata PITTOSPORACEAE # Hymenosporum flavum MYRTACEAE Pittosporum undulatum # Acmena ingens # Callistemon “littlejohn” PLANTAGINACEAE # Callistemon salignus * Russelia equisetiformis # Callistemon viminalis # Corymbia calophylla POLYGONACEAE # Corymbia citriodora * Polygonum aviculare # Corymbia ficifolia % Corymbia maculata PROTEACEAE Eucalyptus crebra # Banksia integrifolia # Eucalyptus grandis # Banksia spinulosa # Eucalyptus microcorys # Grevillea juniperinus hybrid Eucalyptus moluccana # Grevillea robusta # Eucalyptus punctata # Grevillea “robyngordon” # Eucalyptus saligna # Grevillea rosmarinifolia cv. % Eucalyptus sideroxylon # Grevillea shiressii cv. Eucalyptus tereticornis # Grevillea “moonlight” # Lophostemon confertus # Melaleuca armillaris ROSACEAE # Melaleuca bracteata * Photinia glabra Melaleuca decora * Prunus persica # Melaleuca linariifolia # Melaleuca quinquenervia RUTACEAE # Melaleuca styphelioides # Murraya paniculata

SALICACEAE ULMACEAE # Xylosma senticosum * Ulmus parvifolia SCROPHULARIACEAE # Eremophila parviflora cv. VERBENACEAE * Duranta repens

MONOCOTS

AMARYLIDACEAE IRIDACEAE * Clivia miniata * Dietes iridoides

ARECACEAE LOMANDRACEAE * Phoenix roebelenii Lomandra longifolia (probably planted) ASPARAGACEAE * Sansevieria trifasciata LOMANDROIDEAE * Liriope muscari # Cordyline australis

ASPHODELACEAE PHORMIACEAE * Aloe vera Dianella caerulea (probably planted)

CYPERACEAE POACEAE Cyperus gracilis * Ehrharta erecta

DORANTHACEAE STELITZIACEAE Doryanthes excelsa (probably planted) * Ravenala madagascariensis * Strelitzia reginae

Key * = Exotic / weed # = Non-Cumberland Plain Woodland native, does not occur naturally onsite % = Planted at this location HTE – High Threat Exotic

Fauna list

Fauna species recorded during the site survey include the following:

Reptiles Dark-flecked Garden Sunskink The single recorded reptile species was identified by visual observation.

Birds Masked Lapwing White Cockatoo Rainbow Lorikeet Welcome Swallow Noisy Miner Magpie-lark Australian Magpie Pied Currawong Australian Raven * Common Mynah All species of birds were identified by visual observation.

Mammals Brush-tailed Possum (scat) Gould’s Wattled Bat (Anabat analysis). A brief Anabat survey was undertaken on the 11 October from dusk until 8:30 pm. Only one species of microbat was recorded.

Appendix 2. BAM field data

Plot 1 data

Plot 2 data

Appendix 3. Moore Trees data for Trees 42 - 65

42 Willow Bottle brush (Callistemon salignus) 5 2 100

43 Melaleuca (Melaleuca linariifolia) 3 1.5 100 44 Grey gum (Eucalyptus punctata) 13 4.5 350 45 Grey gum (Eucalyptus punctata) 9 3 250 46 Lemon-scented gum tree (Corymbia citriodora) 17 8 450 47 Grey gum (Eucalyptus punctata) 9 3 250 48 Lemon-scented gum tree (Corymbia citriodora) 9 3 200 49 Tallowwood (Eucalyptus microcorys) 6 2 120 50 Tallowwood (Eucalyptus microcorys) 6 2 120 51 Tallowwood (Eucalyptus microcorys) 8 4 250 52 Forest red gum (Eucalyptus tereticornis) 10 4 300 53 Forest red gum (Eucalyptus tereticornis) 10 4 300 54 Forest red gum (Eucalyptus tereticornis) 10 4 300 55 Forest red gum (Eucalyptus tereticornis) 10 4 300 56 Grey box ( Eucalyptus moluccana) 7 2 200 57 Tallowwood (Eucalyptus microcorys) 8 4 250 58 Forest red gum (Eucalyptus tereticornis) 12 4 300 59 Forest red gum (Eucalyptus tereticornis) 12 4 300 60 Forest red gum (Eucalyptus tereticornis) 12 4 300 61 Tallowwood (Eucalyptus microcorys) 12 4 300 62 Forest red gum (Eucalyptus tereticornis) 12 4 300 63 Forest red gum (Eucalyptus tereticornis) 12 4 300 64 Grey box ( Eucalyptus moluccana) 15 6 500 65 Jacaranda (Jacaranda mimosifolia) 7 7 400

Appendix 4. Demonstration of use of the principle “Avoid and minimise ecological impacts”

The impact on remnant vegetation has been avoided by the following:

1. The proposal footprint within the Nepean Hospital site is primarily located on an existing car park. The existing car park has little/no remnant vegetation. Thus, the proposed tower has avoided impacts on the majority of the remnant vegetation on the site.

2. The Arboriculture Report (details) for the site indicated that trees around an access road, a roundabout and a roundabout with a parking area (shown below) were proposed for removal. Negotiations between the project ecologist and others associated with the project allowed the retention of additional remnant Cumberland Plain canopy trees. Figure 11 and Figure 8 illustrate trees that are proposed for retention after negotiation.

3. Use of tree protection measures consistent with the Australian Standard Protection of trees on development sites (AS 4970-2009) will minimise impacts on the remnant Cumberland Plain Woodland trees retained near the proposed works.

Figure 12. Extract from page 20 of Moore Trees Arboricultural Development Assessment Report – December 2017.

Note: trees in red including remnant Cumberland Plain Woodland trees were proposed for removal. Negotiations during the assessment have avoided the yellow circled remnant Cumberland Plain Woodland trees within the works area. During design discussions the remnant Cumberland Plain Woodland trees 209, 220 and 221 were also considered for removal. Impacts on these trees have also been avoided.

Note: trees in orange circles are remnant Cumberland Plain Woodland trees proposed for removal (Figure 11). Negotiations during the assessment have avoided the green circled remnant Cumberland Plain Woodland trees within the works area.

Note: The locations of trees in Figure 8. do not align with the location of trees in Figure 11. It is assumed that Figure 8 in general provides a more accurate location of trees on part of the site. These two figures (Figure 11 and Figure 8) are an attempt to try to reconcile the two different tree plans.

The nominated tree locations are approximate and were obtained on the site by use of a handheld GPS unit. An accurate plan will require a collaborative approach between the surveyor and the ecologist. The nominated locations (coloured circles) have been located to match the surveyed locations as closely as possible, but there is still room for error. Some trees present on the site may not have been included in the survey diagram.

Appendix 5. Advice from the NSW Office of Environment and Heritage regarding SAII

From: OEH ROD LMBC Support Mailbox [email protected] Subject: FW: SAII for Cumberland Plan Woodland LMBC-991 Date: 21 March 2018 at 9:57 AM To: [email protected]

Dear Daniel,

Thanks for your enquiry and I apologise for the delay in response. Thresholds for threatened ecological communi;es that are listed as a poten;al 'serious and irreversible impact' are under development. In the absence of these thresholds consent authori;es will use the informa;on provide in the BDAR, by the accredited assessor, in accordance with 10.2 of the BAM (along with other informa;on in the BDAR) to make a determina;on on whether or not the proposed impact will be serious and irreversible.

To address requirements under s 10.2.2.1 (c) of the BAM I recommend you indicate, in your BDAR, that as of the 20/03/2018 thresholds have not been published in the TBDC for this community.

I hope this addresses your ques;on, please do not hesitate to contact the LMBC Mailbox for further informa;on if required.

Thank you.

Kind Regards,

Maria Avila Land Management and Biodiversity Conservation Contact Service Centre Conservation Program Office of Environment and Heritage T: 1800 931 717 E:[email protected] Please ensure you keep all cc’ed parties included in any replies to this email.

From: Dr. Daniel McDonald [mailto:[email protected]] Sent: Friday, 9 February 2018 11:15 AM To: OEH ROD LMBC Support Mailbox Subject: SAII for Cumberland Plan Woodland

Good Morning,

I am working through the Biodiversity Assessment Method for a site in Western Sydney. I am trying to iden;fy the SAII clearing threshold for Cumberland Plain Woodland.

Sec;on 10.2.2 of the Biodiversity Assessment Method (BAM) states:

"10.2.2 Additional impact assessment provisions for ecological communities 10.2.2.1 The assessor is required to provide the following further information in the BDAR or BCAR about potential ecological communities: 1. (a) the action and measures taken to avoid the direct and indirect impact on the potential entity for an SAII 2. (b) the area (ha) and condition of the TEC to be impacted directly and indirectly by the proposed development. The condition of the TEC is to be represented by the vegetation integrity score for each vegetation zone 3. (c) a description of the extent to which the impact exceeds the threshold for the potential entity that is specified in the Guidance to assist a decision-maker to determine a serious and irreversible impact"

I have highlighted in orange the phrase/s in Sec;on 10.2.2 for which I require more informa;on.

Sec;on 3.2.3 of the document Guidance to assist a decision-maker to determine a serious and irreversible impact states:

3.2.3 Step 3: Determine if the impacts exceed the threshold The decision-maker can compare impact assessment information from Steps 1 and 2 for each potential SAII entity against the corresponding impact threshold. Impact thresholds for potential SAII entities are available in the Threatened Biodiversity Data Collection and must be recorded by the assessor in the BAR. Proposals that to do not exceed the threshold identified for a potential SAII entity are unlikely to result in a serious or irreversible impact. However, a decision-maker may consider impacts on entities that do not necessarily exceed the impact threshold.

I have not been able to locate the impact thresholds within the document or webpage Threatened Biodiversity Data Collec4on. I have not been able to loca;on any document or webpage with that name. The link in the document does not appear to func;on. Please provide guidance on where I might ﬁnd this informa;on.

Thanks and regards, Daniel

Dr Daniel McDonald

The image part with relationship ID rId49 was not found in the file.

Appendix 6.

Appendix 7. Company Profile

Abel Ecology has been in the biodiversity consulting business since 1991, starting in the Sydney Region, and progressively more state wide in New South Wales since 1998, and now also in Victoria. During this time extensive expertise has been gained with regard to Master Planning, Environmental Impact assessments including flora and fauna, bushfire reports, Vegetation Management Plans, Management of threatened species, Review of Environmental Factors, Species Impact Statements, Biodiversity Development Assessment Reports and as Expert Witness in the Land and Environment Court. We have done consultancy work for industrial and commercial developments, golf courses, civil engineering projects, tourist developments as well as residential and rural projects. This process has also generated many connections with relevant government departments and city councils in NSW. Our team consists of four scientists and two administrative staff, plus casual assistants as required.

Licences

NPWS s132C Scientific licence number is SL100780 expires 30 April 2019 NPWS GIS data licence number is CON95034

DG NSW Dept of Primary Industries Animal Care and Ethics Committee Approval expires 8 December 2018

DG NSW Dept of Primary Industries Animal Research Authority expires 8 November 2018

The Consultancy Team

Dr Danny Wotherspoon

Grad Dip Bushfire Protection (University of Western Sydney 2012) PhD (researching Cumberland Plain vegetation and fauna habitat, at Centre for Integrated Catchment Management, University of Western Sydney, 2008) Planning for Bushfire Protection Certificate course (University of Technology, 2006) Consulting Planners Bushfire Training Course (Planning Institute of Australia, 2003) MA (Macquarie University, 1991) Wildlife Photography Certificate (Sydney Technical College, 1987) Herpetological Techniques Certificate (Sydney Technical College, 1986) Applied Herpetology Certificate (Sydney Technical College, 1980) Dip Ed (University of New England, 1978) BSc (Zoology, Ecology) University of New England 1974)

Dr Daniel McDonald

Cert IV – GIS (Riverina TAFE 2016) PhD (The University of Sydney 2006) M. Agr (The University of Sydney 1996) B. Ag Sc. (The University of Sydney 1991) Daniel is an accredited Biobanking Assessor (0075) and is accredited to undertake the Biodiversity Assessment Methodology (BAAS17056). Quantified Tree Risk Assessment (QTRA) and Visual Tree Assessment (VTA)

Mark Sherring

Consulting Planners Bushfire Training Course (Planning Institute of Australia, 2003) Certificate of Horticulture (Richmond T AFE, 1995) Bush Fire Operations modules (Mt. Riverview Fire Brigade, 1993) Certificate of Permaculture (Hazelbrook) Certificate of Bush Regeneration (Nepean TAFE, 1992) Certificate of Rural Operations. (Nepean TAFE, 1992) B.Math (University of Newcastle, 1990)

Dr Alison Hewitt

B. Sc. (Hons), PhD. MESA, MAPS, MASBS, Snr 1st Aid cert, White card. Alison has researched and published on the reproductive biology and ecology of Australian Melaleuca species, native plant responses to fire and the vegetation of western Sydney. Alison's interests include plant ecology and flora survey methodology, bush regeneration, plant identification and gardening. Alison teaches Botany and Ecology sessionally with Western Sydney University.