Vic Ecology FF Long Report Template

Inverlochy Farming Property, 175 Northern Highway, Wallan, Victoria: Preliminary Documentation EPBC Referral number: 2018/8148

Prepared for Crystal Creek Properties Pty Ltd

1 May 2019 Biosis offices Document information

NEW SOUTH WALES

Newcastle Report to: Crystal Creek Properties Pty Ltd Phone: (02) 4911 4040 Prepared by: Shana Nerenberg, Stephen Mueck Email: [email protected] Biosis project no.: 26184 Sydney Phone: (02) 9101 8700 File name: 26184.Inverlochy.Prelim.Docum.FIN.201900501 Email: [email protected] Citation: Biosis 2018.Inverlochy Farming Property, 175 Northern Highway, Wollongong Wallan, Victoria: Preliminary Documentation. EPBC Referral number: Phone: (02) 4201 1090 2018/8148. Authors: Nerenberg S and Mueck S, Biosis Pty Ltd, Melbourne. Email: [email protected] Project no. 26184

VICTORIA Document control Ballarat Phone: (03) 5304 4250 Email: [email protected] Version Internal reviewer Date issued Melbourne (Head Office) Draft version 01 MV 08/08/2018 Phone: (03) 8686 4800 Fax: (03) 9646 9242 Draft version 02 SN 29/08/2018 Email: [email protected] Draft version 03 SGM 31/01/2019 Wangaratta Phone: (03) 5718 6900 Draft version 04 SN 13/03/2019 Email: [email protected] Final version 01 SN 01/05/2019

Acknowledgements

Biosis acknowledges the contribution of the following people and organisations in undertaking this study:

• Crystal Creek Properties Pty Ltd: Celina Mott, Wally Mott and Alister Oldham

• Department of Environment, Land, Water and Planning for access to the Victorian Biodiversity Atlas and Native Vegetation Information Tools

• Department of the Environment and Energy for access to the Protected Matters Search Tool of the Australian Government

Biosis staff involved in this project were:

• Aaron Harvey (Consulting Services)

• Sonika Kumar (mapping)

 Biosis Pty Ltd This document is and shall remain the property of Biosis Pty Ltd. The document may only be used for the purposes for which it was commissioned and in accordance with the Terms of the Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited. Disclaimer:

Biosis Pty Ltd has completed this assessment in accordance with the relevant federal, state and local legislation and current industry best practice. The company accepts no liability for any damages or loss incurred as a result of reliance placed upon the report content or for any purpose other than that for which it was intended.

Contents

Introduction ...... 1

1.1 Project background ...... 1 1.2 Description of Inverlochy farming property ...... 1 1.3 EPBC referral 2018/8148 ...... 1 1.4 Definitions ...... 2

1. Description of the Action ...... 3

1.1 Response to a) ...... 4 1.1.1 Location, boundaries and size (in hectares) of the disturbance footprint ...... 4 1.1.2 Indirect impacts to adjoining areas ...... 4 1.1.3 Where will rock and other excavated materials be stored ...... 4 1.2 Response to b) ...... 4 1.2.1 The proposed activities associated with the action, timing and duration ...... 4 1.3 Response to c) ...... 5 1.3.1 Feasible alternatives ...... 5 1.3.2 Taking no action ...... 5 1.3.3 Short, medium and long-term advantages ...... 5

2. Description of the Environment and Matters of National Environmental Significance (MNES) ...... 6

2.1 General description of the environment ...... 7 2.1.1 General description of the area of the disturbance footprint ...... 7 2.1.2 General description of the property ...... 7 2.1.3 Long term development proposals ...... 7 2.2 MNES present in disturbance footprint ...... 8 2.2.1 Golden Sun Moth ...... 8 2.3 MNES determined as absent or low likelihood in disturbance footprint ...... 9 2.3.1 Natural Temperate Grassland of the Victorian Volcanic Plains ...... 9 2.3.2 Seasonal Herbaceous Wetlands (Freshwater) of the Temperate Lowland Plains ...... 9 2.3.3 Growling Grass Frog ...... 12 2.3.4 Striped Legless Lizard Delma impar ...... 13 2.3.5 Other listed flora species ...... 13 2.3.6 Other listed fauna species ...... 13 2.4 Listed Migratory species ...... 2 2.5 Resources used ...... 2 2.6 Consultation/advice from local community groups or experts ...... 2 2.6.1 Expert technical investigations ...... 2

3. Relevant impacts ...... 3

3.1 Golden Sun Moth ...... 4 3.1.1 Direct impacts ...... 4

3.1.2 Indirect impacts ...... 4 3.1.3 Distance of works to known habitat ...... 4 3.1.4 Assessment of scale (local/regional/national impact) ...... 4 3.1.5 Quality scoring ...... 5 3.2 Impacts likely to be unknown, unpredictable or irreversible ...... 6 3.3 Data and information used to assess the impacts ...... 6

4. Proposed Avoidance and Mitigation Measures ...... 7

4.1 Proposed avoidance and mitigation measures ...... 8 4.1.1 Avoidance measures ...... 8 4.1.2 Minimisation measures ...... 8 4.1.3 Mitigation Measures ...... 8 4.2 Target outcomes ...... 8 4.3 Buffer and exclusion zones ...... 9 4.4 Expected effectiveness of avoidance and mitigation measures ...... 9 4.5 Statutory or policy basis ...... 9 4.6 Achievability of and responsibility for proposed measures ...... 10 4.7 Rehabilitation ...... 10

5. Proposed offsets ...... 11

5.1 Residual impacts ...... 12 5.2 Offset Strategy ...... 12 5.3 Description of proposed offset ...... 12 5.3.1 Records of GSM for proposed Offset Area ...... 12 5.3.2 Offset area quality ...... 13 5.3.3 Offsets assessment guide ...... 13 5.3.4 EPBC Act offset principles ...... 19 5.4 Progress towards securing offsets ...... 20 5.5 Other offset requirements ...... 21 5.5.1 State offsets ...... 21

6. Social and Economic ...... 22

6.1 Response to a) ...... 23 6.2 Response to b) ...... 23 6.3 Response to c) ...... 23 6.4 Response to d) ...... 23

7. Ecologically sustainable development ...... 24

7.1 Ecologically sustainable development ...... 25

8. Environmental record of the proponent ...... 26

8.1 Proceedings under a Commonwealth or state law ...... 27

9. Other Approvals and Conditions ...... 28

9.1 Commonwealth approvals ...... 29 9.2 State approvals and policy ...... 29 9.2.1 Flora and Fauna Guarantee Act 1988 ...... 29 9.2.2 Planning and Environment Act 1987 (incl. Planning Schemes) ...... 29 9.2.3 Catchment and Land Protection Act 1994 (Victoria) ...... 29 9.3 Monitoring, enforcement and procedure reviews ...... 29

10. Conclusion ...... 30

10.1 Summary of residual impacts...... 31 10.2 Proposed approval ...... 31

11. Information sources ...... 32

11.1 References ...... 33

Appendices ...... 35

Appendix 1 Likelihood table for all MNES ...... 36

Appendix 2 Figures ...... 40

Appendix 3 Native Vegetation Removal Report ...... 49

Appendix 4 Information Supporting Proposed Offset ...... 58

Tables

Table 1 GPS Points of locations along the boundary of the proposed action, Wallan, Victoria...... 4 Table 2 Golden Sun-moth survey details ...... 8 Table 3 Golden Sun Moth survey results...... 8 Table 4 NTGVVP assessment criteria (DSEWPaC 2011b) ...... 9 Table 5 SHWFTLP assessment criteria (TSSC 2012) ...... 10 Table 6 Weather conditions during noctural Growling Grass Frog surveys ...... 12 Table 7 Migratory birds predicted to likely occur within the local area and the assessed impact ...... 2 Table 8 Assessment of GSM habitat against DEWHA (2009b) characteristics ...... 4 Table 9 GSM habitat quality scoring system ...... 5 Table 10 Impact area - Assessment of GSM habitat quality ...... 6 Table 11 Summary of risks and risk management measures ...... 9 Table 12 Offset area - Assessment of GSM habitat quality ...... 13 Table 13 Offsets assessment guide calculations ...... 14 Table 14 EPBC Act offset principles ...... 19 Table 15 Summary of offsets generated in the NVR report...... 21 Table 16 Assessment of the project against the guiding principles of ESD...... 25

Figures

Figure 1 Location of Inverlochy farming property and Disturbance footprint, Wallan, Victoria ...... 41 Figure 2 Location of the impact area for MNES within the disturbance footprint, Wallan, Victoria ...... 42 Figure 3 Aerial photography showing landform modification of DELWP modelled wetland area within the disturbance footprint, Wallan, Victoria ...... 43 Figure 4 Location of native vegetation within the disturbance footprint, Wallan, Victoria ...... 44 Figure 5 Location of MNES within Inverlochy farming property, Wallan, Victoria...... 45 Figure 6 GSM survey effort, Wallan, Victoria ...... 46 Figure 7 Hydrological features of the property showing dams surveyed for Growling Grass Frog Jan-Feb 2017, Wallan, Victoria ...... 47 Figure 8 Proposed Offset Area, Chepstowe, Victoria ...... 48

Introduction

1.1 Project background

The proposed action is located within the farming property ‘Inverlochy’, 175 Northern Highway, Wallan, Victoria, owned by the proponent, Crystal Creek Properties Pty Ltd (Crystal Group).

In December 2016, Biosis Pty Ltd (Biosis) was commissioned by Crystal Group to undertake a flora and fauna assessment of Inverlochy to assist with planning for future agricultural development. The flora and fauna assessment concluded that the property supported potential habitat for Golden Sun Moth Synemon plana (GSM) in some locations. As a consequence, targeted surveys for GSM were undertaken between December 2016 and January 2017.

The targeted surveys detected GSM in a small patch (2.23 ha) of unploughed paddock within the arable flats of the property. Crystal Group identified that this patch would be impacted by proposed agricultural development and appropriate planning permission and environmental approvals were sought.

1.2 Description of Inverlochy farming property

Inverlochy is a large (524 hectares) mixed-farming enterprise supporting broad-acre cropping and cattle production. The property is located approximately 50 kilometres north of the centre of Melbourne. The property is zoned for agriculture (Farming Zone, FZ) (Figure 1). The property is bounded on the east and west by the Northern Highway and Old Sydney Road respectively, and adjoins private property to the north and south.

The proponent has owned the property for 14 years and has improved productivity while managing major weed and erosion problems that were unmanaged at the time of purchase.

The property has a mix of topography. Cropping currently occurs on cleared plains with volcanic surface geology located on the boundary of Victorian Volcanic Plain bioregion. The west side of the property is located on the boundary of the Central Victorian Uplands bioregion and supports gently to moderately undulating hills that remain vegetated and are managed with intermittent grazing.

The property adjoins significant roadside vegetation on Old Sydney Road, protected by a Vegetation Protection Overlay under the Mitchell Planning Scheme. In addition, the Northern Highway is included in a VicRoads proposal to expand this road into a major traffic corridor.

1.3 EPBC referral 2018/8148

In 2018, Crystal Group made a referral under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) for Inverlochy Farming Property (referral number EPBC 2018/8148) for significant impacts to one Matter of National Environmental Significance (MNES).

On 24 April 2018, the proposed action was declared a controlled action under the EPBC Act to be assessed by preliminary documentation.

Biosis was commissioned by Crystal Group to prepare the preliminary documentation.

1.4 Definitions

Disturbance footprint (55.5 ha): The land subject to this referral being one existing paddock supporting improved pasture for cattle production (Figure 1).

Impact area (2.23 ha): A small proportion of the disturbance footprint (2.23 ha out of 55.5 ha) supports MNES, such that the impact area for MNES is smaller than the disturbance footprint (Figure 2).

Native vegetation: Aside from impacts to MNES within the impact area, there are several patches of native vegetation mapped within the disturbance footprint under Victoria’s definitions of native vegetation. These are included for context but are not the subject of this referral (Figure 4).

Offset Area (8.1 ha): the proposed GSM offset to compensate for the residual impacts of the proposed action.

Offset site: generic term used to refer to any offsets that are not the proposed Offset Area.

1. Description of the Action

This should include the precise location of all works to be undertaken (including plans and maps) and elements of the action that may have impacts on relevant MNES.

Please ensure the information includes the following: a) The location, boundaries and size (in hectares) of the disturbance footprint and of any adjoining areas which may be indirectly impacted by the proposal, including nearby habitat, areas where removed rock will be piled and associated activities. b) The proposed activities associated with the action and the anticipated timing and duration (including start and completion dates). c) Any feasible alternatives to the action to the extent reasonably practicable, including, the alternative of taking no action, a comparative description of the impacts of each alternative on MNES and sufficient detail to make clear why any alternative is preferred to another. Short, medium and long-term advantages and disadvantages of the options should be discussed.

Where relevant information was provided at the referral stage, incorporate or refer to this information as necessary in the consolidated preliminary documentation.

1.1 Response to a)

1.1.1 Location, boundaries and size (in hectares) of the disturbance footprint The proposed action is located on flat volcanic plains adjacent to the southern boundary of the property. This area is already used for cropping. The proposed action is to increase the area available for cropping by converting a perennial pasture paddock (currently used for cattle production) to wheat and canola production. Conversion to cropping will required ploughing of the paddock. Where surface basalt rock remains within the paddock, this will be excavated and removed to enable these areas to be ploughed.

Disturbance footprint: The disturbance footprint is the total area to be ploughed and corresponds to fenced boundaries of the current pasture paddock. The current paddock covers 55.5 hectares resulting in a disturbance footprint of 55.5 hectares (Figure 1, Figure 2).

Impact area: The impact area corresponds to the total area of GSM habitat present within the paddock and which will be destroyed by the de-rocking and ploughing (Figure 2). The total area of GSM habitat present within the disturbance footprint is 2.23 hectares. The impact area is therefore 2.23 hectares of GSM habitat.

No other impacts to any MNES are proposed.

1.1.2 Indirect impacts to adjoining areas The adjoining areas are also currently used for cropping and do not support MNES (Biosis 2017). Cropping landscapes are subject to regular disturbance in the form of ploughing, pesticide application and harvesting. Given the cropping landscape context, the proposed action will not constitute a noticeable increase in the disturbance already experienced in the local environment.

1.1.3 Where will rock and other excavated materials be stored Excavated rock and soil will be retained on the property in existing stockpile areas. No rock will be dumped into areas of native vegetation. Excavated rock may in future be used for works within the property or sold for use in gardens or other construction.

Table 1 GPS Points of locations along the boundary of the proposed action, Wallan, Victoria.

Point Latitude Longitude

NW corner -37.43378 144.95575

NE corner -37.43502 144.96604

SE corner -37.43843 144.96545

SW corner -37.43722 144.95514

1.2 Response to b)

1.2.1 The proposed activities associated with the action, timing and duration The proposed activities associated with the action are as follows:

– Spray paddock with herbicide to remove weeds and native grassland vegetation

– Remove embedded rock with an excavator

– Distribute removed rock to the edges of the paddock or stockpile elsewhere on the property

– Plough the entire paddock and sow with next crop rotation. Ideally, the works would be completed prior to the 2019 winter sowing season, with sowing timed to commence after the autumn break. Given the current seasonal conditions, it is anticipated that sowing will occur in May. To meet this timing, the works would need to start several weeks prior to sowing, preferably commencing by the end of March.

1.3 Response to c)

1.3.1 Feasible alternatives In the context of the existing farming practices, the only other alternative to ploughing this paddock would be to continue farming the paddock using current practices. Current practices include use of herbicide and sowing of introduced pasture species. It is likely that under these management practices, the area of suitable habitat would decrease over time as a result of decreased cover of native grass and increased cover of non- food plants for GSM. In addition, if noxious weeds become prevalent, then the landholder is obliged to control them under state legislation. Noxious weed control would be done with use of herbicides, which may be additional to current usage patterns. From the perspective of preventing impacts to GSM habitat, it would appear that there would be little advantage in undertaking the feasible alternative.

1.3.2 Taking no action Taking no action would result in the continuance of existing farming practices as explained above.

1.3.3 Short, medium and long-term advantages From a social and economic perspective, the proponent seeks the advantage of further developing their agricultural business in an efficient manner by utilising all of the land resources available. Doing so improves productivity and allows greater investment into future land management. From an ecological perspective, provision of GSM offsets by placing covenants on private land increases the area of GSM habitat that is under formal protection and contributes to the long term viability of the species.

2. Description of the Environment and Matters of National Environmental Significance (MNES)

The preliminary documentation must provide a general description of the environment affected by and surrounding the proposed action area, in both the short and long term. This section must specifically address: a) A description of the MNES that may be affected by the proposal. b) Information about the resources used to identify and assess the environmental values on site, including survey data and historical records. c) Information detailing known/recorded populations and known or potential habitat in the area surrounding the proposed action area. Information must include maps indicating the distribution of MNES and associated habitat.

2.1 General description of the environment

2.1.1 General description of the area of the disturbance footprint The proposed action is wholly located within an existing fenced paddock that supports improved pasture and cattle production (55.5 hectares, Figure 2). The fenced paddock is located within a matrix of other paddocks used for cropping and cattle production both within the same property and the adjoining property (Figure 6). The south-east corner of the paddock supports a confirmed GSM population that has persisted due to the presence of basalt surface rock that has prevented ploughing (2.23 hectares, Figure 2). This is the only area of the paddock to support MNES (Figure 2, Figure 6).

The impact area supports two patches of low quality native vegetation, Plains Grassland (EVC 132) (Figure 4). The ‘Lack of Weeds’ score for the native vegetation patches is 0/15, the lowest possible score (Biosis 2017). This indicates that the cover of weeds, in general, as well as high threat weeds in particular, is greater than 50% (Habitat Hectare method, DSE 2004). The grassland patches are of low diversity consisting of a low cover of native grasses and scattered occurrence of common herbs including Grassland Wood-sorrel Oxalis perennans, Blushing Bindweed Convolvulus angustissimus subsp. angustissimus, and Grassland Crane's-bill Geranium retrorsum (Biosis 2017).

Between the two patches of native vegetation, weedy grassland vegetation provides further GSM food plants but the cover of native perennial species is too low to meet definitions of native vegetation at either state or federal levels (Figures 4).

The GSM food plants present are Wallaby-grasses (largely Rytidosperma caespitosum and Rytidosperma duttonianum) and Spear grasses (largely Austrostipa bigeniculata and Austrostipa rudis) (Biosis 2017). These species are found at low covers, with the cover of native tussock grasses estimated to be 10% (Biosis 2017).

2.1.2 General description of the property The surrounding environment on the flats of the property includes other cropping paddocks supporting scattered paddock trees but little to no other wooded or grassland native vegetation (Biosis 2017). Remnants of wetland vegetation persist in drains and low-lying areas that have otherwise been drained for agriculture (Figure 3). Planted tree belts are either Blue Gum Eucalyptus globulus subsp. bicostata, or other non-Victorian Australian native trees (Biosis 2017). The west side of the property rises into undulating hills as the property transitions from the Victorian Volcanic Plains to the Central Victorian Uplands bioregion. The hills support native eucalypt woodland and dry forest in moderate to good condition and are currently managed with annual strategic grazing (Biosis 2017). This area has also been impacted by several wildfires in the past decade (Wally Mott, pers. comm.).

2.1.3 Long term development proposals For the western and north-western boundaries of the property, the land use is likely to remain unchanged due to the presence of significant roadside vegetation protected by a Vegetation Protection Overlay. The larger areas of native vegetation within the property are also protected by an Erosion Management Overlay. Residential development is limited in the areas covered by a Bushfire Management Overlay, but rural lifestyle blocks is an allowed use under current planning controls for individual lots within the property.

Opposite to the northern boundary of the property, residential subdivisions are currently under construction (northern side of Taylors Lane). The eastern boundary may also be impacted by the expansion of the Northern Highway although timing for this projected upgrade is not known. The property was included, along with the rest of Wallan, within the Urban Growth Boundary for Melbourne (GAA 2011). The district is therefore likely to experience future residential subdivision. Properties to the south of Inverlochy are within the Melbourne Strategic Assessment (MSA) area (Figure 1) and are proposed for future residential subdivision (see planning information at www.vpa.vic.gov.au).

2.2 MNES present in disturbance footprint

2.2.1 Golden Sun Moth GSM is the only MNES present in the disturbance footprint. The presence of GSM was confirmed using targeted surveys as described below.

A flora and fauna assessment, completed in 2016, identified potential GSM habitat in three locations on the Inverlochy farming property. Subsequently, targeted surveys were undertaken in all three areas of potential habitat.

Targeted surveys were undertaken during the 2016-17 GSM flight season. Pre-season checks were undertaken by Biosis and other ecological consultants at various known sites (reference sites) around Melbourne from late November to collaboratively determine the commencement of the 2016 GSM flight season. GSM were reliably detected in Epping on 7 December 2016. GSM were also detected incidentally at Inverlochy during flora surveys on 7 December 2016, confirming the flight season had started on the property.

Four targeted GSM surveys were completed between 12 December 2016 and 12 January 2017 in accordance with the Significant Impact Guidelines for the Critically Endangered Golden Sun Moth (DEWHA 2009b). Survey effort was recorded using hand-held GPS units to track the progress of each observer. Table 2 details the conditions from each of the four surveys. Survey effort is mapped in Figure 6.

Confirmed GSM habitat Figure 2 shows the areas of confirmed GSM habitat within the proposed disturbance footprint. The targeted surveys recorded three male GSM within the proposed impact area (Table 3). To show the landscape context of the proposed action, Figure 5 shows confirmed GSM habitat for the entirety of Inverlochy.

Table 2 Golden Sun-moth survey details

Date Start/ Temperature Cloud Wind Average wind Ground Humidity Reference End time on site (°C) cover (%) direction speed (km/hr) conditions (%) site

12/12/2016 10:00 AM/ 23/29 5/70 NW/NW 4/4 dry/dry 25/24 Wallan on- 2:30 PM site reference

26/12/2016 12:50 PM/ 29/23.2 90/100 NE/SSW 6/6.5 dry/dry 42/54 Wallan on- 3:50 PM site reference

4/01/2017 10:50 AM/ 23.7/24.7 15/15 N/N 33/30 dry/dry 91/87 Wallan on- 12:20 PM site reference

12/01/2017 11:00 AM/ 20.5/26.5 0/0 SW/SSE 13/13 dry/dry 57/31 Craigieburn 3:30 PM (flight diary)

Table 3 Golden Sun Moth survey results

Survey data GSM observed Number of GSM observed

12/12/2016 No -

26/12/2016 Yes 3

4/01/2017 No -

12/01/2017 No -

Total: 3

2.3 MNES determined as absent or low likelihood in disturbance footprint

The Protected Matters Search Tool (PMST) provides an indication of MNES potentially present within a 5 km radius of the impact area. An assessment of the likelihood of their presence is provided in Appendix 1. Further explanation is provided below for those MNES with potential to occur within the actual impact area.

2.3.1 Natural Temperate Grassland of the Victorian Volcanic Plains NTGVVP is an ecological community restricted to the basalt volcanic plains of western Victoria. It is typically free of large trees and shrubs and has a diverse ground-layer of native grasses and herbs (TSSC 2008). The structural components of the community are provided by the dominant ground cover of large tussock- forming perennial native grasses, with open spaces between the tussocks (TSSC 2008).

Within the proposed disturbance footprint, two patches (1.39 hectares) of the ecological vegetation class (EVC) Plains Grassland (EVC 132) were mapped according to the definitions provided in DEPI (2013). The mapped Plains Grassland was also assessed using the Commonwealth guide to identifying the listed community ‘Natural Temperate Grassland of the Victorian Volcanic Plain’ (NTGVVP).

The results of the assessment determined that while the proposed impact area is on the Victorian Volcanic Plain, the cover of weeds within areas identified as Plains Grassland is too high to meet the definition of NTGVVP. Accordingly, the grassland is of insufficient quality for the NTGVVP community to be present (Table 4, Biosis 2017).

The FFG Act listed Western (Basalt) Plains Grasslands Community is synonymous with Plains Grassland and therefore present across the same extent.

The assessment against listing criteria is provided below: Table 4 NTGVVP assessment criteria (DSEWPaC 2011b)

Condition Assessment

Does the patch occur within YES. (criteria met) the Victorian Volcanic Plain?

Is the site dominated by NO. (criteria not met) native vegetation? There is less than 50% cover of native vegetation and the patch is dominated by introduced species.

Result: Not the national ecological community – modified significantly by exotic pasture, plantings or weeds.

2.3.2 Seasonal Herbaceous Wetlands (Freshwater) of the Temperate Lowland Plains Seasonal Herbaceous Wetlands (Freshwater) of the Temperate Lowland Plains (SHWFTLP) are freshwater wetlands that are usually inundated on a seasonal basis, then dry out, so surface water is not permanently present (TSSC 2012). They occur on the lowland plains of temperate south-eastern Australia and have a vegetation structure that is open, i.e. woody cover is absent to sparse, and the ground layer is dominated by herbs (grasses, sedges and forbs) adapted to seasonally wet or waterlogged conditions (TSSC 2012). The soils on which Seasonal Herbaceous Wetlands occur are generally fertile but poorly draining clays of various geologies (TSSC 2012). In the Victorian Volcanic Plain, clays are derived from basalt. In some areas, particularly on the Victorian Volcanic Plain, larger stones and rocks may be present in the soils within or around the wetland (TSSC 2012).

Within the proposed disturbance footprint, four patches (2.32 hectares) of Plains Grassy Wetland (EVC 125) were mapped according to the definitions provided in DEPI (2013). These areas were assessed against the listing advice for the EPBC listed ecological community SHWFTLP. The assessment determined that while the

community is present, it is of insufficient quality to meet the standard required for Commonwealth protection.

The assessment is documented below.

Section 5 of the listing advice (TSSC 2012) states that:

The Seasonal Herbaceous Wetlands ecological community no longer exists at many sites where it was formerly present. In many cases, the loss is practically irreversible because sites have been permanently converted to cropland, pasture, plantation forests, artificial dams or have undergone some other substantial modification that has removed their natural hydrological and biological characteristics (e.g. drainage). In other cases, the ecological community now exists in a disturbed or degraded state.

National listing focuses legal protection on the remaining occurrences of the ecological community that are functional, relatively natural and in relatively good condition. Key diagnostic characters and condition thresholds are used to identify the threatened ecological community and decide when the EPBC Act is likely to apply. Condition thresholds provide guidance for when the occurrence of a threatened ecological community retains sufficient conservation values to be considered a ‘Matter of National Environmental Significance’, as defined under the EPBC Act. This means that the referral, assessment and compliance provisions of the EPBC Act are focussed on the more valuable elements of Australia’s natural environment. Very degraded occurrences that do not meet the condition thresholds are largely excluded from protection under the EPBC Act.

The national ecological community is limited to wetlands that meet the description, key diagnostic characteristics PLUS the condition thresholds.

Table 5 assesses the wetland area against the key diagnostic characteristics and condition thresholds.

Table 5 SHWFTLP assessment criteria (TSSC 2012)

Condition Assessment of Habitat Zone 13 and 15

Landscape • Located in the temperate zone (Victoria). • Limited to the temperate zone of mainland south- • Located on the Victorian Volcanic Plain, 308 metres asl (Google eastern Australia. The ecological community occurs in Earth, accessed 5/7/2018) south-east SA, Victoria and southern NSW. • Basalt-derived clay soil • On flat plains grading into slopes, below 500 m asl. • Associated soils are generally fertile but poorly draining • Winter dominated rainfall, annual average is 688 mm (bom.gov.au, clays derived from a range of geologies. Site number: 088162, accessed 5/7/2018) • Typically in rainfall zones with a Winter seasonal rainfall pattern, extending into a uniform seasonal rainfall pattern at the edge of its range. The mean annual rainfall is usually 400 to 800 mm/year but can be lower at the northern edge of its range.

Hydrology • Wetland is located offline from main drainage lines, indicating the • On isolated drainage lines or depressions which are wetland is largely rain-fed by surface drainage from surrounding seasonally inundated (typically during winter-spring) and hills. subsequently dry (typically by late summer). • When surveyed in December 2016, Habitat Zone 15 appeared to • Rainfall is the main water source. These wetlands are have recently dried indicating winter-spring inundation. The DELWP not dependent on overbank flooding from riverine modelled wetland layer states that the wetland is episodically systems. inundated. • Salinity of the water is fresh to slightly brackish. Salinity • The DELWP modelled wetland layer depicts the wetland as mostly lies within the range, 0 to 1000 mg/L but can be “Freshwater Meadow” indicating a salinity concentration <3,000 up to 3000 mg/L, typically exhibiting a progressive mg/L (DEPI 2013c). increase in salinity as wetlands dry.

Biota • No trees or shrubs present. • Trees and shrubs are sparse to absent. When present, • Habitat Zone 13 is a low lying area within a paddock and is they mostly occur as fringing or scattered individuals. dominated by native graminoid Common Tussock Poa labillardieri with occasional occurrences of other species associated with wetter

Condition Assessment of Habitat Zone 13 and 15

The cover of woody species accounts for no more than environments including the graminoid Brown-back Wallaby-grass 10% projective foliage cover across the wetland. Rytidosperma duttonianum and forb species Common • The vegetative cover of the ecological community is Loosestrife Lythrum hyssopifolia. This patch of vegetation is dominated by a ground layer of native wetland isolated from adjacent patches by areas dominated by graminoids and/or native wetland forbs. introduced pasture species including Cocksfoot Dactylis • A range of graminoids is often present and typically glomerata and Tall Fescue Festuca arundinacea. includes one or more of the following taxa: • Habitat Zone 15 is an excavated drain dominated by Amphibromus spp., Carex tereticaulis, Deyeuxia spp., bareground having recently dried out. The nature of the site Glyceria spp., Lachnagrostis spp., Poa labillardieri, and indicates the vegetation present has recolonised disturbed Rytidosperma duttonianum. Note that other graminoid ground. The vegetation comprises wetland species consistent taxa may also occur, though are not necessarily with the presence of seasonal inundation including the common – refer to Appendix A for a plant species list. graminoid Common Spike-sedge Eleocharis acuta, and forbs • At least one native wetland forb species must be present species Water Milfoil Myriophyllum spp. with fringing vegetation (preferably more) after the ecological community is dominated by graminoids Common Swamp Wallaby-grass inundated. The suite of forbs that may occur within the Amphibromus nervosus and Common Blown-grass Lachnagrostis ecological community’s range is variable and potentially filiformis with occasional occurrences of forb Common large. Refer to Appendix A for a plant species list. Loosestrife. Outside of the excavated channel and fringing • Freshwater algae often are present when the wetland is, vegetation, the surrounding paddock is dominated by or recently has been, wet. The most evident introduced pasture species including Cocksfoot and Tall Fescue. representatives are green algae from the groups • Fauna (other than potential of the site to support MNES) and Charales (stoneworts) and Zygnematales (pond scums). algae species were not assessed. • Characteristic fauna that may be associated with the ecological community include invertebrate groups that are temporary water specialists. The types of fauna present can be highly variable, depending on the inundation history, current conditions and other factors.

Modified wetlands Habitat zone 13 and 15 are likely to be remnants of a once more • Modifications to other types of wetland may result in the extensive wetland. DELWP modelled wetlands layer shows the outline of ecological community being present where it was a wetland at this location suggesting a previously larger area of formerly absent. These modified wetland sites are inundation. Aerial imagery shows that the landform has been altered by included as part of the national ecological community, if excavation of an array of linear drains throughout the modelled wetland they remain a functional natural wetland and conform extent. These drains channel surface water away from the location of to the description of the ecological community. the modelled wetland and into the natural drainage system. A tree belt has also been planted within the extent of the modelled wetland altering water requirements of the vegetation. These modifications are likely to have altered the natural hydrology resulting in reduced residence times and reduced frequency and duration of inundation. The area of inundation is likely to have been reduced although further study would be needed to determine the exact degree of change. These changes to hydrology would be present in both wet and dry conditions. Nutrient enrichment has occurred through the application of fertiliser to improve pasture and nutrient inputs from livestock grazing, Surrounding land use of medium density grazing considered to be High intensity (DEPI 2013c). Soil disturbance has resulted from cattle grazing but this is relatively low compared to disturbances related to excavation. These changes have resulted in a simplification of the vegetation communities present with most vegetation dominated by introduced pasture species with small patches of highly modified native vegetation persisting.

Part A) Condition during ‘typical’ wet cycles: At the time of the assessment, Habitat Zone 15 supported the aquatic The intent here is to determine if a wetland is consistent with herb Water Milfoil and showed evidence of recent drying suggesting the the description and key diagnostic features for the national wetland was experiencing a wet cycle. ecological community, as noted above, and retains sufficient native vegetation cover. There are two key steps. Step 1A: Yes. The assessment above suggests that the wetland is • Step A1) Is the wetland consistent with the key consistent with the key diagnostic characteristics but is highly modified. diagnostic characteristics, noted above? – If yes, go to Step A2. Step 2A: No. The modelled wetland has for the most part been – If no, the wetland is of a different type to converted to agricultural used through draining and native vegetation is the Seasonal Herbaceous Wetlands. only retained in relatively small patches. The modelled wetland is 60.2 ha • Step A2) Is 50% or more of the total cover of plants in in size whereas the area mapped as native vegetation (Plains Grassy the ground layer of the wetland dominated by native Wetland) is 2.32 ha or 3.85% of the wetland. Therefore the wetland does

Condition Assessment of Habitat Zone 13 and 15

species characteristic of the Seasonal Herbaceous not meet the criteria: Is 50% or more of the total cover of plants in the Wetlands ecological community? ground layer of the wetland dominated by native species characteristic – If the answer is yes, the wetland retains of the Seasonal Herbaceous Wetlands ecological community? On a patch sufficient native cover. Go to Part C scale, all patches of Plains Grassy Wetland were recorded as having a Minimum wetland size. weed cover of greater than 50%, with a maximum cover of native vegetation of 43%, which also does not meet the definition. –

Result: If the answer [to Step 2A] is no, the wetland no longer retains sufficient natural values to be considered part of the national ecological community and is not a matter of national environmental significance in relation to this national ecological community.

2.3.3 Growling Grass Frog Growling Grass Frog Litoria raniformis (GGF) habitat includes waterbodies and slow-flowing streams within the known range of the species with suitable aquatic or semi-aquatic vegetation (Commonwealth of Australia 2009c). Probability of occurrence is higher where the species has been recorded within the same catchment, with GGF known to be present downstream in the wider Merri Creek catchment.

The likelihood of GGF presence in the disturbance area or impact area was assessed to be Negligible because any remaining wetland areas are highly modified and do not support permanent water or GGF habitat.

The likelihood of GGF presence in the broader Inverlochy property was also assessed to be Low based on targeted surveys undertaken in accordance with the Significant impact guidelines for the vulnerable growling grass frog (Litoria raniformis) (DEWHA 2009c). All waterbodies (dams, drains and wetlands) within Inverlochy were inspected for the presence of potential GGF habitat and targeted GGF surveys were undertaken in a subset of seven waterbodies with the most suitable potential GGF habitat (Figure 7).

Surveys took place on 24/25 January and 09/10 February 2017 when conditions were suitable for male calling activity (overnight low >12oC, absence of wind other than a light breeze) and between sunset (20:30 hrs) and 3:00 hrs. Weather conditions, including temperature, humidity and wind speed were measured on site using a Kestrel Weather Meter (Model 4000) (Table 6).

The male advertisement call was played through a loud speaker to elicit a response from any male frogs that may be present. Each waterbody was then surveyed systematically by two qualified and experienced observers using head torches to search for tadpoles and searching possible refuge sites for non-calling individuals (logs, vegetation). The presence of any other frog species and other fauna was also noted.

No male Growling Grass Frogs were detected on either survey although seven other (non-listed) frog species were recorded indicating conditions were suitable for frog activity. Based on the results of the targeted surveys and the observation of predatory introduced fish in the waterbodies, the likelihood of this MNES being present on the property is Low.

Table 6 Weather conditions during noctural Growling Grass Frog surveys

Date 24/25 January 2017 9/10 February 2017

Temperature (°C) 13-18 18-22

Humidity (%) 55-75 75-88

Wind Light breeze Light breeze

Precipitation None None

2.3.4 Striped Legless Lizard Delma impar Potential habitat for Striped Legless Lizard (SLL) was identified within the proposed impact area but the likelihood of occurrence was considered low and targeted surveys were not recommended. The reasons for this decision are as follows.

The patch of suitable habitat is isolated and surrounded by agricultural disturbance. • There is a long history of disturbance including grazing, de-rocking and cropping. • There is only one incidental record within 5 km and this record is now more than 25 years old, dating from 1991. Subsequent targeted surveys over the last 10 years in Melbourne’s north and using the recommended tile-checking survey method and targeted excavations, have failed to detect the species in this region, throwing doubt over the presence of the species in Melbourne’s northern fringes. • The disturbance footprint is isolated from the 1991 record by the Hume Freeway and is also isolated from any other potential habitat or source populations by the Northern Highway and the Hume Freeway. As a result, we considered the likelihood of presence too low to recommend targeted surveys.

Should further information come to light that suggests that targeted surveys are warranted the seasonal constraints of these surveys should be noted. Targeted surveys need to start by August to install tile grids which are subsequently checked over the following season.

2.3.5 Other listed flora species Due to the modified nature of the vegetation in the majority of the impact area and the low quality of remaining patches of native vegetation, no potential habitat for threatened grassland flora species was identified (Biosis 2017). Targeted surveys were therefore not undertaken within the impact area. Based on our site assessment and the condition of the habitat present, the following species are considered highly unlikely to occur within the disturbance footprint:

• Spiny Rice-flower Pimelea spinescens subsp. spinescens • Button Wrinklewort Rutidosis leptorhynchoides • Clover Glycine Glycine latrobeana • Large-headed Fireweed Senecio macrocarpus • Matted Flax-lily Dianella amoena

2.3.6 Other listed fauna species Nine other species are identified by the PMST as potentially occurring within the disturbance footprint. However, due to the type and condition of the habitat present the following species were considered to have a low or negligible likelihood of occurring within the disturbance footprint or using the habitat available. These were: • Plains Wanderer • Grey-headed Flying-Fox • Regent Honeyeater • Smoky Mouse • Painted Honeyeater • Australian Grayling • Swift Parrot • Dwarf Galaxias • Greater Glider

The table in Appendix 1 provides the rationale for the likelihood of presence for these species.

2.4 Listed Migratory species

No listed migratory species are predicted to be dependent on the disturbance footprint. While some of these species would be expected to use the disturbance footprint on occasions, it does not provide important habitat for an ecologically significant proportion of any of these species. The proposed action is therefore not considered to result in a significant impact to any migratory species (Table 7).

Table 7 Migratory birds predicted to likely occur within the local area and the assessed impact

Scientific name Common name Most Impact recent record Migratory Shorebirds Numenius madagascariensis Eastern Curlew 2011 Actitis hypoleucos Common Sandpiper 2012 Site does not include habitat suitable for the species. Calidris ferruginea Curlew Sandpiper 2015 Any impact on the species or its habitat is likely to be negligible. Calidris acuminata Sharp-tailed Sandpiper 2015 Calidris melanotos Pectoral Sandpiper 2013 Wetland birds Ardea modesta Eastern Great Egret 2015 Species may occasionally use flooded paddocks or Plains Ardea ibis Cattle Egret 2013 Grassy Wetland in an opportunistic manner. No impact on the species or its habitat will occur. Gallinago hardwickii Latham's Snipe 2014 Site does not include habitat suitable for the species. Any impact on the species or its habitat is likely to be negligible. Raptors Pandion cristatus Eastern Osprey 2000 Site does not include habitat suitable for the species. No impact on the species or its habitat is likely to occur Terrestrial species Hirundapus caudacutus White-throated Needletail 1990 Species does not use any resources that will be impacted. Apus pacificus Fork-tailed Swift 1990 No impact on the species or its habitat will occur. Rhipidura rufifrons Rufous Fantail 2007 Myiagra cyanoleuca Satin Flycatcher PMST Monarcha melanopsis Black-faced Monarch PMST Site does not include habitat suitable for the species. Acrocephalus stentoreus Clamorous Reed Warbler 2011 No impact on the species or its habitat is likely to occur Merops ornatus Rainbow Bee-eater PMST Motacilla flava Yellow Wagtail 2005

2.5 Resources used

See Section 11.

2.6 Consultation/advice from local community groups or experts

2.6.1 Expert technical investigations Biosis Pty Ltd was commissioned to undertake a Flora and Fauna Assessment in 2016. A copy of this report has been provided to the Department of Environment and Energy in previous versions of the preliminary documentation.

3. Relevant impacts

The preliminary documentation must include an assessment of potential impacts (including direct, indirect, consequential and cumulative impacts) that may occur as a result of all elements of the proposed action on the MNES.

Consideration of impacts must not be confined to the immediate area of the proposed action but must also consider the potential of the proposed action to impact on adjacent areas that are likely to contain habitat for MNES. For relevant MNES this must include, but not be limited to: a) An assessment of the direct and indirect loss and/or disturbance of habitat as a result of the proposed action. This should include the potential for overspray to impact other areas once cropping cycles are underway. b) Details on whether any impacts are likely to be unknown, unpredictable or irreversible. c) Any technical data and other information used or needed to make a detailed assessment of the relevant impacts. d) A discussion of potential cumulative impacts on relevant MNES within the broader region where potential impacts from this proposed action are in addition to existing impacts of other activities (including known potential future expansions or developments by the proponent and other developers in the region and vicinity). This should address the potential cumulative impact of the proposal on ecosystem resilience.

All discussions and conclusions should include a full justification based on the best available information including relevant conservation advices, recovery plans, threat abatement plans and guidance documents, if applicable.

3.1 Golden Sun Moth

3.1.1 Direct impacts The de-rocking and ploughing of the proposed action will result in the permanent removal of 2.23 hectares of confirmed GSM habitat (Figure 2).

The quality of the habitat was assessed against the habitat characteristics provided in DEWHA (2009b). The disturbance footprint supports a known population of GSM but the patch is of small size (less than 10 ha, DEWHA 2009b) and has a high weed load, with greater than 50% of the perennial grass cover being introduced (non-food plant) pasture species (Table 8). The long-term security of the patch is considered to be low as explained in Section 2.

Table 8 Assessment of GSM habitat against DEWHA (2009b) characteristics

Habitat characteristic Assessment

Size of patch Patch size is small (less than 10 hectares)

Cover of food plants Cover of food plants is minimal (10 % cover) (Rytidosperma spp., Austrostipa spp., Nassella neessiana)

Distance to nearest source The nearest population is 1.75 kilometres away, separated by crop paddocks population

Amount of shading Nil

Aspect Flat

Amount of bare ground Cover of bare ground is minimal (less than 20%) and biomass was high at time of survey

Presence of rocky areas Rocks still present although removal of surface rock may have occurred

Soil characteristics Basalt derived

Land use history Located within an improved pasture paddock, subject to weed invasion, fertiliser use, and grazing

3.1.2 Indirect impacts There are no anticipated indirect impacts. The areas of GSM habitat proposed for removal are isolated by at least 1 km from all other known GSM populations and the nominated impacts are not expected to directly or indirectly impact any other habitat or populations.

3.1.3 Distance of works to known habitat The habitat is isolated from other GSM populations by cropping and pasture creating a distance of 1.75 kilometres between the impact area and other known GSM populations or potential habitat.

3.1.4 Assessment of scale (local/regional/national impact) The removal of 2.23 hectares of GSM habitat is a significant impact as defined by the impact guidelines for this species. However, the proposed works are only expected to have a localised impact on this species. Given that the impact area is isolated from all other GSM populations by at least 1 kilometre, the removal of this patch is unlikely to affect other local populations. The isolated nature of the impact area and the fact that it is surrounded by agricultural uses also suggests that the species could be lost from this area over time through decreases in food plant cover.

The GSM habitat proposed for removal does not provide habitat or display characteristics that are unique and cannot be found elsewhere within the species range. Similar habitat can be found elsewhere within the

local area and habitat of better quality is found elsewhere within Inverlochy and on properties to the north of Inverlochy (Biosis 2017).

At a regional scale, this proposed removal is insignificant when compared with the amount of clearing that is expected over the next 30 years as part of the Melbourne Strategic Assessment (DSE 2009) (MSA). The MSA has put in place a strategic program for the conservation of GSM in the Melbourne Region as described in the Biodiversity Conservation Strategy (DEPI 2013). It is expected that the security of GSM as a species within Melbourne has already been addressed in the BCS.

3.1.5 Quality scoring The EPBC Act Offsets Assessment Guide requires GSM habitat to be given a score out of 10. In consultation with DoEE, the GSM habitat was assigned a quality score according to the scoring system provided below (Table 9).

Table 9 GSM habitat quality scoring system

Parameter Scoring system

Site context • 0/3 = Habitat patch1 size <0.25 ha.2 (max. 3 points) • 1/3 = Habitat patch size more than 0.25 ha and up to 10 ha.2 • 2/3 = Habitat patch size more than 10 ha, shaped appropriately3 to reduce edge effects.2 • 3/3 = Habitat patch size more than 10 ha, shaped appropriately to reduce edge effects, slightly sloped (3° or less) and north-facing, minimal shading.

Site condition • 0/3 = dominated by introduced vegetation that is not a known food source. (max. 3 points) • 1/3 = dominated by poor quality native vegetation (VQA site condition score up to 30/75) including <20% cover known food source. • 2/3 = dominated by moderate quality native vegetation (VQA site condition score 31-45/75) including between 20% and 40% cover known food source with limited inter-tussock space (<5%), or dominated by introduced vegetation that is a known food source (i.e. Chilean needle grass) where the species stocking rate4 is greater than 20 moths per hectare. • 3/3 = dominated by high quality native vegetation (VQA site condition score 46+/75) including >40% cover known food source and appropriate inter-tussock space.

Species stocking • 0/4 = species not present rate4,5 • 1/4 = 0-5 males per hectare (max. 4 points) • 2/4 = >5-20 males per hectare • 3/4 = >20-50 males per hectare • 4/4 = >50 males per hectare

Notes to table: 1A patch is considered to be an area of GSM habitat separated from other areas of suitable habitat by >200m of unsuitable habitat, or barriers to flight (e.g. buildings, solid fences). A habitat patch should not be defined by administrative boundaries such as farm fencing, title or lot boundaries if habitat is continuous on either side of the boundary. According to the guidelines, if the amount of GSM habitat adjoining the site of the action cannot be determined, the area of habitat will be considered to be the same as that identified within the site. 2Add 1 point (up to a maximum of 3) where a patch is an occupied linkage between 2 populations. 3Assessed on a case by case basis.

4Stocking rate (measured as males per hectare) calculated as: total number of males recorded across four surveys in one flight season divided by area of habitat surveyed (with survey area confirmed with GPS tracks). It is not expected that results can be extrapolated across unsurveyed areas unless justification is given (e.g. the surveyed area is a sub-sample of the total area). Stocking rate calculations to be rounded up if required.

5It is expected that impact and offset sites to be surveyed on four occasions during the flying season and the survey results to be summed (consistent with survey guidelines). Justification will need to be provided to the Department to support proceeding in the absence of suitable survey effort. For clarity, if lower survey effort than four complete surveys is accepted, the Department will consider: – For impact sites: the highest recorded density is assumed to be the remaining score (e.g. if three surveys detect 5, 10, 15 males/ha, the assumed score for the last survey is 15 males/ha).. – For offset sites: the lowest record is assumed to be the remaining score (e.g. if three surveys detect 5, 10, 15 males/ha, the assumed score for the last survey is 5 males/ha). – For either type of site, if one survey records 5 males/ha, then assumed total of four surveys is 20 males/ha.

Using the scoring system above, the impact area quality scores have been calculated in Table 10. The result is a quality score of 3/10 reflecting the small size of the site, the isolation of the site from other populations and the low number of moths recorded (Table 10).

Table 10 Impact area - Assessment of GSM habitat quality

Parameter Score Justification

Site context The impact area is 2.23 hectares in total size and isolated from all other (max. 3 points) 1/3 nearby GSM populations by more than 1 kilometre. This places the site in the 1/3 category.

Site condition The site is dominated by dominated by poor quality vegetation (VQA site (max. 3 points) condition score of 23.12 / 75) and had a cover of 10% Wallaby Grass 1/3 Rytidosperma spp. and Spear Grass Austrostipa spp. at the time of the assessment. The cover of weeds was high including both annual and perennial weeds. Chilean Needle Grass Nassella neessiana was not identified within the patch. This places the survey area within the 1/3 category.

Species A total of 3 GSM were recorded from the impact site. The total area of habitat 1/4 stocking rate is 2.23 hectares. This gives a stocking rate of 1.35 moths per hectare. This

(max. 4 points) places the survey area within the 1/4 category.

Quality score A score of 3 out of 10 indicates that the impact area is of poor quality and 3/10 unlikely to be an important population of this species.

3.2 Impacts likely to be unknown, unpredictable or irreversible

The impacts are limited in extent and well understood. The impacts to GSM will be limited to the population located in the impact area. Since the impact area is surrounded by crops and pasture, overspray of herbicide or insecticide resulting from the proposed action will not create any additional threat to GSM populations in the local area. It is therefore unlikely that there will be additional or unforeseen impacts. The impacts will be irreversible because the habitat will be replaced with crops or sown introduced pasture species. There are no known records of GSM populations inhabiting crops or sown introduced pasture.

3.3 Data and information used to assess the impacts

The extent of GSM habitat and results of targeted surveys was first documented in Biosis (2017). The impact area is clearly defined and limited to the extent of the existing paddock fencing. The extent of the proposed action was used to determine that the proposed action will result in the complete removal of the 2.23 hectares of GSM habitat.

4. Proposed Avoidance and Mitigation Measures

a) A statement addressing the environmental objectives/outcomes the measures are expected to achieve. This must include details of any baseline data, performance criteria, monitoring, reporting and corrective action proposed to demonstrate progress towards achieving these objectives.

For further information on outcomes-based conditions please see relevant Departmental policy documents at: http://www.environment.gov.au/epbc/publications/outcomes-based-conditions-policyguidance. b) A description (including maps) of the location, boundaries and size (in metres) of any buffer areas for proposed exclusion zones or conservation purposes and details on how these areas will be excluded or protected. c) An assessment of the expected or predicted effectiveness of the measures proposed. d) Any statutory or policy basis for the measures proposed. e) The achievability of the measures proposed, including affordability. f) A description of any proposed rehabilitation to disturbed habitat areas, including its management, methodology and timing.

4.1 Proposed avoidance and mitigation measures

The following sections outline the proposed avoidance and mitigation measures that will be in place during the proposed action. The environmental objectives to be achieved are provided in Table 11.

4.1.1 Avoidance measures Avoidance measures are not possible as within the disturbance footprint due to the nature of the proposed action.

4.1.2 Minimisation measures The proponent has demonstrated their understanding of the need to minimise impacts to GSM habitat. The impacts will be restricted to the proposed impact area and disturbance area. There are no proposed impacts to MNES in the surrounding landscape. The disturbance area is already delineated with farm fencing such at no further marking of the works area is deemed necessary.

Crystal Group have demonstrated their commitment to responsible land management since purchasing Inverlochy 14 years ago and will continue to manage the land in this manner including the use of strategic grazing in wooded areas and regular woody weed control activities.

4.1.3 Mitigation Measures The following measures will be undertaken to ensure the proposed action does not impact on areas outside of the proposed paddock:

• All rock and other excavated will be retained within the paddock OR if excavated material needs to be removed, no excavated material will be stored or disposed of in areas of native vegetation.

• Any soil contaminated with noxious weeds will not be removed from the property without appropriate approvals under the Catchment and Land Protection Act 1994.

• Spraying of herbicide will only be undertaken in appropriate conditions (low wind, following manufacturer’s directions for timing with regard to rainfall) to avoid off-target impacts and ensure effective uptake of the chemical.

• Contractors undertaking the works will be informed of the Limit of Works, noting that the risk of unintended impacts to MNES is low due to the distance between the proposed works and the nearest other habitat for MNES (Section 3.1.3).

4.2 Target outcomes

A summary of potential risks, associated mitigation measures and proposed target outcomes are outlined in Table 11. The environmental outcomes that are expected to be achieved are the minimisation of impacts on MNES to the GSM population in the impact area. An additional target outcome is that there is to be no spread of pathogens or noxious weeds as a result of the proposed works.

Table 11 Summary of risks and risk management measures

Relevant impact Management measures Target outcome

Planning phase

Direct loss of GSM habitat Minimise GSM habitat removal to one paddock. Residual impact on 2.23 ha of GSM habitat Provide offsets in accordance with the EPBC Act only. Offset calculated and provided in Environmental Offsets Policy (DSEWPaC 2012). accordance with DSEWPaC (2012).

Works phase

Direct loss of GSM habitat Pre-works induction and training. No removal of native vegetation or GSM beyond the approved limits of Limit of works constrained to proposed paddock. habitat beyond that authorised for works through inappropriate Contractors to be made aware of limit of works. removal within the project Limit of works. dumping of excavated material Contractors to be made aware of environmental values if working within GSM habitat. Compliance with works area perimeter and mitigation measures.

Direct loss of GSM habitat Compliance with works area perimeter and No spraying of native vegetation or GSM beyond the approved limits of mitigation measures. habitat beyond that authorised for works through inappropriate removal within the project Limit of works. use of herbicide

Disturbance to GSM habitat by Compliance with CaLP Act to prevent weed spread No disturbance to native vegetation or pests, weeds and pathogens including no movement of topsoil to areas of native GSM habitat beyond that authorised for vegetation. removal within the project Limit of Works. No establishment of new high threat weeds or soil pathogens within the works area.

On-going farm operation phase

Disturbance to GSM habitat No native vegetation or GSM habitat will be removed No removal of native vegetation or GSM beyond the approved limits of (sprayed or cultivated) beyond the approved limit of habitat beyond that authorised for works from cultivation or over- works. removal within the project Limits of Works. grazing.

4.3 Buffer and exclusion zones

GSM habitat is present elsewhere on the Inverlochy farming property. These areas are at least 1.75 kilometres away from the impact area so no buffer area is required. The landowner is aware of the environmental values of the retained GSM habitat and has determined that these lots will not form part of the long-term agricultural development of the property. These areas are already delineated from cultivated areas by farm fencing so no further exclusion zone marking is required.

4.4 Expected effectiveness of avoidance and mitigation measures

The proposed management and mitigation measures are considered effective as they will constrain impacts on GSM to the impact area. This will ensure that no other GSM populations or MNES are affected by the proposed action.

4.5 Statutory or policy basis

The statutory or policy basis for the proposed avoidance, management and mitigation measures includes:

• Environment Protection Biodiversity Conservation Act 1999 (Commonwealth);

• Catchment & Land Protection Act 1994 (Victoria);

• Environment Protection Act 1970 (Victoria);

• Flora & Fauna Guarantee Act 1988 (Victoria);

• Planning & Environment Act 1987 (Vic); and

• Victorian Country Fire Act 1958 and Regulations (Victoria).

4.6 Achievability of and responsibility for proposed measures

All mitigation, monitoring and management measures proposed in this document are considered achievable within the current farming context.

All management measures are consistent with current management and farming practices to ensure they are achievable. While the de-rocking and ploughing will be undertaken by contractors, Crystal Group representatives will be regularly on the property to supervise contractors and to ensure these measures are complied with.

Crystal Group will be responsible for supervising contractors and ensuring works are undertaken in compliance with all approvals.

Crystal Group will be responsible for ensuring there are no impacts on GSM habitat outside the impact area.

4.7 Rehabilitation

There is no proposed rehabilitation of disturbed habitat as this is incompatible with the proposed action.

5. Proposed offsets

The Preliminary Documentation must include an assessment of the likelihood of residual impacts occurring, after mitigation and management measures relating to the project have been applied. If residual significant impacts to listed threatened species and communities are determined likely, please provide: a) details of an offset package proposed to be implemented to compensate for the residual significant impacts of the project, b) details of how the offset(s) will compensate for the significant residual impact(s) upon listed threatened species and communities c) a description of how the offset(s) will ensure the protection, conservation and management of the relevant species, for the duration of the impact, d) a description of how the offset(s) are consistent with relevant Commonwealth policies and guidance documents on offsets under the EPBC Act. These documents can be found at the following link: www.environment.gov.au/epbc/publications/environmentaloffsets-policy.htmI e) The offset package can comprise a combination of direct offsets and other compensatory measures, so long as it meets the requirements of the EPBC Act Offset Policy. Offsets should align with conservation priorities for the impacted protected matter and be tailored specifically to the attribute-of the protected matter that is impacted in order to deliver a conservation gain. f) Offsets should compensate for an impact for the full duration of the impact. g) Offsets must directly contribute to the ongoing viability of the MNES impacted by the project and deliver an overall conservation outcome that improves or maintains the viability of the MNES as compared to what is likely to have occurred under the status quo that is if neither the action nor the offset had taken place.

Note offsets do not make an unacceptable impact acceptable and do not reduce the likely impacts of a proposed action. Instead, offsets compensate for any residual significant impact. h) Offsets required by the State can be applied if the offsets meet the Department's EPBC Act Offset Policy.

5.1 Residual impacts

The location of the GSM habitat within the disturbance footprint will result in the removal of confirmed habitat for GSM to the total extent of 2.23 hectares. The total residual impact is therefore 2.23 hectares of GSM habitat. There are no other impacts on MNES.

5.2 Offset Strategy

The residual impacts will be offset in accordance with the EPBC Act Environmental Offsets Policy (DSEWPaC 2012). This will be done by purchasing offsets via a registered offsets broker to the amount required according to the Offsets Assessment Guide.

The inputs into the Offsets Assessment Guide have been prepared in accordance with the document How to use the Offsets Assessment Guide and in consultation with the DoEE. Detailed explanations of the inputs are provided in Table 13.

The result of the Offsets Assessment Guide requires an offset of 8.1 hectares secured in perpetuity and managed to create an improvement in habitat quality for 10 years. This will provide an increase in the area of GSM habitat that is under formal protection.

5.3 Description of proposed offset

Chepstowe is a large sheep station in the west of Victoria (500 hectares, Appendix 4). It is located within the Victorian Volcanic Plain and supports a range of uses including sheep grazing on native pasture. The property has several existing offset sites for GSM as well as voluntary conservation covenants that have protected high quality native grassland areas. The landholder plans to increase the protections in place with further offset agreements if compatible with farm operations while also reserving some areas of the property to maintain farm operations including sheep grazing, pine plantations and areas of cropping.

The proposed Offset Area within the property is located within a paddock that already supports a GSM offset site. The existing GSM offset site has been fenced off and the proposed Offset Area will adjoin this fence (Figure 8). The Offset Area will be approximately square shape with a buffer between the Offset Area and the infrastructure in the paddock. There are numerous GSM records from the existing offset site and proposed Offset Area. A detailed assessment of the Offset Area can be found in Appendix 4.

5.3.1 Records of GSM for proposed Offset Area In December 2018, targeted surveys were undertaken within the proposed Offset Area. These surveys recorded GSM throughout the proposed Offset Area (Figure 8). The details of the surveys can be found in the condition report attached (Appendix 4). In December 2018, a total of 241 GSM were recorded in the proposed Offset Area and a total of 619 GSM were recorded from the broader paddock in which the Offset Area is located. The 2018 surveys were done on foot, using the same team of three field workers walking pre-defined 50 metre transects.

Prior to 2018, GSM have been recorded from the Offset Area during transect surveys undertaken in 2016-17 survey season. A total of 26 males were recorded in 2016-17. However, the much lower number of records compared to 2018 can be explained by differences in survey effort. Even though both years did 3 visits, the 2016-17 surveys used fewer staff (3 staff on the first survey and 1 thereafter) and two of the surveys were done from a quad bike rather than on foot making it harder to observe and record every moth.

There are also presence/absence checks of the site in previous years. E.g. A total of 22 males were recorded in 2015-15 from two surveys using one staff member on quad bike. The details of GSM records prior to 2018 can be found in the condition report (Appendix 4).

5.3.2 Offset area quality The quality of the Offset Area for GSM habitat was assessed using the same scoring method as the impact area (Section 2.3.1). Table 12 below provides the quality assessment for the Offset Area.

Table 12 Offset area - Assessment of GSM habitat quality

Parameter Score Justification

The proposed Offset Area is part of a paddock that already supports GSM offsets. The total area of the paddock is 60 hectares, noting that a fence has been installed at the edge of the other offset sites making it look like these are separate paddocks. The Site context 2/3 paddock is approximately square, which is appropriate for reducing edge effects. However, the paddock is essentially flat with a very slight (less than 1 degree) south- west slope.

The site is dominated by dominated by poor quality vegetation (VQA site condition score 16.32 / 75) but does contain some Wallaby-grass Rytidosperma spp. with cover less 1/3 than 20% at the time of the vegetation assessment. The cover of weeds was high Site condition including both annual and perennial weeds. Note that the Offset Area and the property as a whole does not have Chilean Needle Grass Nassella neessiana such that none of the weeds present are known food plants for GSM.

A total of 619 GSM were recorded for the paddock in which the Offset Area will be located. The total area surveyed was 50.39 hectare. This gives a stocking rate of 15.5 moths per hectare. This places the survey area within the 6-20 moths per hectare category giving a score of 2/4. Species stocking 2/4

rate The Offset Area within the paddock recorded 241 GSM from 8.1 hectares giving a stocking rate of 29.6 moths per hectare. This places the Offset Area in the 20-50 moths per hectare category giving a score of 3/4, however a conservation approach was taken and the lower score was used.

A score out 5 out of 10 indicates that the Offset Area is of moderate quality with Quality score 5/10 potential for improvement.

The following section provides justification for the remaining inputs into the Offsets Assessment Guide.

5.3.3 Offsets assessment guide Table 13 describes the justification for the inputs into the Offsets Assessment Guide for GSM habitat. Some of this information has already been provided above, in which case, this is referenced within the table.

Table 13 Offsets assessment guide calculations

Parameter Input Justification for input

Impact calculator

Area of 2.23 ha Total area of direct loss of GSM habitat as mapped on Inverlochy farming property. habitat

Quality 3/10 The quality score that is input into the impact calculator should be the quality at the time of assessment (DoEE undated). The impact site was assessed in late November 2016, in a year with adequate rainfall, which is an optimal time for survey. The quality assessment is therefore considered to accurately reflect the overall quality of the habitat within the impact area. The quality scoring of the impact area is provided above in Section 3.2.1.

Offset calculator

Time over 20 Years The number (of years) entered into this cell should be the duration of the risk mitigation actions to be taken, or 20 years, whichever is shorter (DoEE undated). which loss The Offset Management Plan (OMP) requires active conservation management for 10 years of the OMP, after which the Offset Area is to be managed as a conservation is averted area in perpetuity. A conservation covenant will prevent detrimental land use changes in perpetuity. (max. 20 years)

Start area 8.1 The start area is the area of GSM habitat required to provide 100% of the residual impact in concert with the other inputs described below. The amount of GSM habitat is (hectares) easily provided by the Chepstowe property, which has 50 hectares of habitat available in the paddock where the Offset Area is located.

Risk of loss 10% The risk of loss is a percentage figure that describes the chance that the habitat on the proposed offset site will be completely lost (i.e. no longer hold any value for the protected (%) matter) over the foreseeable future (either the life of the offset or 20 years, whichever is shorter) (DoEE undated). without Risk of loss: Risk describes the probability with which an adverse event will occur, in this case, extinction of GSM from the Offset Area. The risk of loss without offset is low offset but not 0% because there is a possibility that, without protection as an offset, the GSM habitat could be lost without needing to be offset under Victorian or Commonwealth legislation. As a starting point, the estimated annual probability of extinction for a critically endangered species is 6.8% (Offsets Assessment Guide). Since the annual probability of extinction for the entire species is 6.8%, it is assumed that the annual probability of extinction of GSM on any one site for this species will be at least 6.8%. Following from this, we have agreed with DoEE that a risk of loss of 10% reflects the numerous threats to GSM habitat that are a result of the current land use. A risk of loss of 10% over 20 years equates to a risk of loss of 0.5% in any one year, which while close to zero reflects that the risk is not zero. The following sections detail the threats to GSM habitat that exist in the proposed Offset Area that mean that risk of loss is not zero and other sources of information used to inform the risk of loss:

Native vegetation legislation: The Offset Area was dominated by introduced vegetation at the time of survey due to seasonal conditions and recent grazing management. The vegetation at this time did not meet the definition of a patch as defined under Victorian legislation and removal of this vegetation would not attract biodiversity offsets under the Pyrenees Planning Scheme Clause 52.17 – Native Vegetation.

Farm development plans: The existing landholder is the original landholder and has instigated many improvements the last several decades. These have included cropping in some paddocks, planting of pine plantations in the late 1990s and leasing a small area for three wind turbines in 2012. The farmer has also informed us that some of the paddocks supporting GSM will not be available as offsets because these are near the shearing sheds and are needed for housing sheep during shearing. This demonstrates that farm management is not static and changes with season, market demand and technology. The future use and condition of each paddock likewise is

Parameter Input Justification for input

not static and cannot be predicted with certainty over the next two decades. Current conditions in western Victoria, namely high wool prices, provide incentive for land use intensification such as investing in pasture improvement (ABC news 2018). Anecdotal evidence from western Victoria contends that many former rocky paddocks have been re-rocked and ploughed in the previous 2 to 3 years.

Continuing use rights: The proposed Offset Area is currently used for sheep grazing as part of a larger sheep production system. The landholder is able to continue this use without a permit. Agricultural practices is one of the main threats identified for the persistence of GSM (TSSC 2013). Agricultural production varies on a yearly basis to respond to the prevailing seasonal conditions (e.g. in dry conditions without much grass growth or water, farmers will de-stock so that they have less sheep to feed). Continuing use may involve any of the following activities, which would remove any value for GSM at the Offset Area without necessarily triggering a requirement for a permit or offsets:

• Intensive weed management: use of boom spraying and non-selective herbicide may result in the removal of food plants for GSM. • Cessation of weed management (e.g. in response to resourcing constraints): weed management is an on-going activity in farm management and recommended to protect GSM habitat (TSSC 2013). Cessation of weed control allows weeds to dominate or results in loss of inter-tussock spaces. • Over-sowing: pasture improvement activities including broadcasting or direct drilling of legumes or pasture grasses into existing pasture (e.g. Clover, Rye-grass or Cocksfoot) and which are not food plants for GSM. • De-stocking (removal of stock in response to economic or seasonal conditions): Reduction in grazing pressure for extended periods of time will allow the sward to become rank and thatch to build up to levels too dense for GSM to breed. • Set stocking: when sheep are grazed continuously over the entire year, native grasses and herbs do not have an opportunity to flower and set seed (Dorrough et al. 2006). This means that native vegetation cover declines over time due to lack of reproduction. Set-stocking has resulted in decline of much of Victoria’s native vegetation. • Over-grazing: paddocks that are grazed to the point where much of the grass has disappeared are instead dominated by bare soil. The presence of bare soil allows annual weeds to proliferate reducing inter-tussock spaces. • Fertiliser application: fertiliser favours introduced species and is associated with a decline in native plant species (Dorrough et al. 2012). A list of references on the effects of grazing and native grassland are provided in Section 11.

Estimated risk of loss for Pyrenees Shire: The National Endangered Species Program (NESP) provides indicative risk of loss estimates for each municipality in Australia based on remote-sensed loss of treed vegetation over time (Maseyk et al. 2017). For Pyrenees Shire, the risk of loss of treed vegetation is 4.07% (Maseyk et al. 2017). Due to a lack of available data on loss of native grassland, this estimate is only available for treed vegetation (woodland and forest). For the reasons given below, the risk of loss of treeless vegetation would be found to be higher if a large-scale spatial data set could be collated:

• Treeless vegetation is at greater risk of clearing than treed vegetation because it is part of farm production systems so is subject to agricultural practices that threaten persistence of native plants. • The loss of treeless native vegetation is less noticeable when it’s cleared compared to clearing trees so is more prone to illegal clearing. • There is limited understanding among farmers that native grassland is protected when compared to treed vegetation and so is more prone to illegal clearing. • There are circumstance that allow farmers to apply continuing use rights that result in destruction of native vegetation (e.g. a farmer can in theory spray a whole paddock with herbicide to control noxious weeds and at the same time spray all native species as well).

Parameter Input Justification for input

Risk of loss 1% The risk of loss is a percentage figure that describes the chance that the habitat on the proposed offset site will be completely lost (i.e. no longer hold any value for the protected (%) with matter) over the foreseeable future (either the life of the offset or 20 years, whichever is shorter). offset Risk of loss: Risk describes the probability with which an adverse event will occur, in this case, extinction of GSM from the Offset Area. We have determined in consultation with DoEE that the Risk of Loss with the offset in place is reduced from 10% to 1%. Risk of Loss is not reduced to 0% because this would imply absolute certainty, which is not possible to achieve. Possible sources of risk of loss to the Offset Area include change of ownership, anthropogenic climate change, new human- mediated disease or weed invasion or other unanticipated threat cannot be completely eliminated by the OMP or other management actions. We note that DoEE (undated) stipulates that natural events such as bushfire are not considered in the risk of loss. A risk of loss of 1% over 20 years, equates to a risk of loss of 0.05% for each year of the 20 year time horizon, demonstrating risk of loss is negligible in any one year, although not zero.

Averting loss: Because the threats listed in the previous section related primarily to land management, to achieve a conservation gain, the Offset Area must be secured against adverse management practices. The Offset Area will be secured by a conservation covenant administered by the statutory authority Trust for Nature. The conservation covenant ensures that the Offset Area is managed primary for conservation rather than business-as-usual, which manages the area for production. The implementation of the covenant means that the Offset Area moves from unprotected to protected tenure status. This creates an averted loss on the property compared to a ‘business as usual’ scenario. Based on experience with previous conservation covenants, once the Offset Area is protected by an on-title conservation covenant, the risk of the current land manager undertaking the management actions listed above are reduced and considered to be low to negligible. In this case, the risk of loss of 1% describes any unforeseen event that may pose a threat to the species. In addition, yearly monitoring and compliance reporting will detect any changes to biomass or species composition that may threaten the GSM habitat. This is further supported by the proposed Offset Area being contiguous with existing offset sites. The existing offset sites have been in place for several years and over that time have recorded consistent numbers of GSM (Abzeco 2018). The number of GSM recorded in the adjacent offset site in 2015 was 46 and the same number were recorded in 2016, noting that only two or three surveys were done on each occasion (Compartments G, H and I in Abzeco 2018) The greatest risk to conservation covenants comes with a change of ownership. If due diligence is not undertaken prior to sale, it is common for properties to be purchased without knowledge of or full understanding of encumbrances on a property. If the new owner is less dedicated to, not as skilled or less experienced at conservation management, then there is a risk that management will be less successful under new ownership.

Confidence 90% For the averted loss component, confidence in result captures the level of certainty about the strength and effectiveness of the proposed risk-mitigation measures and the capacity of in result – these measures to mitigate the risk of loss of the site (DoEE undated). Risk of loss A 90% confidence in the result is used to reflect that there is a high degree of certainty that implementing the conservation covenant will occur and will decrease the risk of loss to 1% over the 20 year time horizon. DoEE has agreed that this it is reasonable to have a high degree of certainty because there is a high degree of certainty that the Trust for Nature process will implement the conservation covenant and provide support and advice to the landholder on complying with the covenant. Biosis has a high degree of confidence in the conservation covenant process because the main threats to GSM habitat at the proposed Offset Area are related to land management practices directly within the control of the land manager. As stated in the section above, by implementing the OMP and conservation covenant, the risk that inappropriate management actions are undertaken is effectively eliminated both through change in on-title protections and monitoring of the OMP. A high degree of confidence is also based on the MNES in question. GSM is one of the most common MNES requiring offsets within Melbourne (due to its persistence in native and introduced grasslands) so that the habitat management requirements are better understood than species less commonly offset.

Parameter Input Justification for input

The confidence cannot be 100% as some risk still exists. The largest remaining risk is associated with a change of land ownership with a lessening of commitment to conservation land manage by subsequent landowners. While the on-title covenant prevents a change in land use, once the ten year monitoring period ends, there will be less external oversight to ensure any subsequent landholder is equally competent at managing the Offset Area.

Time until 10 Years This timeframe is set at 10 years to allow time for all the management actions to be implemented under the OMP. An immediate benefit will be attained when the ecological conservation covenant is put on title preventing adverse land management. Ecological benefit in the form of a measureable improvement in habitat quality will be achieve benefit after 10 years of management as stipulated in the OMP. See below.

Start 5 The quality score that is input into the impact calculator should be the quality at the time of assessment (DoEE undated). quality The Offset Area was assessed in March 2018 in a low rainfall year. While not ideal conditions for survey of plant species diversity, the conditions were adequate for (scale of 0- determining the presence of food plants and habitat characteristics for GSM. Although not ideal, the quality assessment is considered adequate to reflect the habitat 10) quality for GSM within the Offset Area. Further information on the Offset Area condition can be found in Biosis (2018) and Abzeco (2018). The quality scoring of the impact area is provided above in Section 5.3.2.

Future 4 Future quality without offset is the estimate of the habitat quality at this future time based on a business as usual scenario – that is, considering current management practices, use quality of the site and historic trends for the quality of habitat on the site (DoEE undated). without The future quality without offset is based on the impacts of continuing use rights if they are to be applied without regard for the GSM population. These are detailed offset above in the Risk of Loss section. (scale of 0- 10) Note that this future quality score does not include continuing use rights that could result in the complete loss of all GSM habitat. These potential impacts have been included in the Risk of Loss assessment above.

Table 13.1 Projected loss of quality (set at loss of 1 point only in consultation with DoEE) Parameter Score Justification

Site context Unchanged. It is not anticipated that the site context will change substantially over the 20 year time horizon. That is, farming will 2/3 continue in accordance with the current Farming Zone (FZ) so that isolation by development of the site from the broader GSM population that occupies the surrounding landscape is unlikely.

Site condition 0/3 Decrease of 1 point. As stated in the sections above, continuing use rights and associated farming practices remain a threat to the persistence of native plant species and can encourage dominance of introduced species.

Species stocking Unchanged. It is almost certain that an increase in weed cover and decrease in native cover (captured in the site condition score) rate would lead to a decrease in habitat quality and result in GSM favouring other areas of the landscape. However, the species stocking 2/4 rate categories have been developed to assist in comparing sites based on field data and have no predictive capacity.

Note that a score of 0/4 would indicate GSM no longer present, which would equate to a loss of the site, which is captured in the risk of loss parameters and not considered here.

Quality score 4/10 A score of 4/10 reflects a decrease in quality of 1 point due to increased weed cover and decreased cover of native plant species.

Parameter Input Justification for input

Future 6 Future quality with offset should be the estimated habitat quality at the future time incorporating the proposed offset activities (DoEE undated). quality The future quality with offset is based on the result of the activities stipulated in the OMP, which aim to decrease weed cover and increase the cover of native grasses. with offset These activities include localised herbicide application, strategic grazing or ecological burns and are designed to favour native grasses (particularly GSM food plants) and (scale of 0- reduce the cover of introduced grasses and noxious weeds. Site context will be improved because the new conservation covenant will increase the amount of secured 10) GSM habitat in the landscape, although this cannot be captured by the scoring system.

Table 13.2 Projected increase in quality (set at gain of 1 point only in consultation with DoEE) Parameter Score Justification

Site context Unchanged. It is not anticipated that the site context will change substantially over the 20 year time horizon. That is, farming will 2/3 continue in accordance with the current Farming Zone (FZ) and a large GSM population already occupies the surrounding landscape.

Site condition Increase of 1 point. As stated above, activities stipulated in the OMP aim to decrease weed cover and increase the cover of native grasses. Under this management, it is anticipated that site condition will measurably improve. To increase from the 1/3 category 2/3 to the 2/3 category, weed cover will need to be reduced to below 50%, high threat weeds will need to be less than 50% of total weed cover, organic litter will need to be between 5 and 15% and bare ground will need to be between 20 to 40%. Understory score is unlikely to improve where life forms have become extinct or remain highly modified in their diversity and cover abundance.

Species stocking Unchanged. The species stocking rate categories have been developed to assist in comparing sites based on field data and have 2/4 rate no predictive capacity.

Quality score 6/10 A score of 6/10 reflects an increase in quality of 1 point due to improved weed and biomass management.

Confidence 75% For the change in habitat quality component, the confidence in result captures the level of certainty about the successful achievement of the proposed change in quality (DoEE in result – undated). Future A 75% confidence in the result is used to reflect that there is some uncertainty about the successful achievement of an increase in 1 point of quality. An increase in 1 point quality of quality will require the site condition (Habitat hectares method) to increase from 16.32 to 31. Such an increase will require substantial management inputs as well as with offset favourable seasonal conditions. This level of uncertainty therefore reflects the nature of vegetation, which responds to seasonal conditions as well as management actions. However, the adaptive management framework set out in the OMP allows for adjustments to management to be made in response to seasonal conditions so that land managers can compensate for fluctuations in seasonal conditions. Despite this uncertainty, there is a reasonable degree of confidence that an improvement can be achieved. This is because the OMP does not stipulate any activities that require specialist skills or have specialist inputs (e.g. re-seeding of native grass or re-introduction of threatened species). Instead, management improvements are achieved through standard land management activities that can be undertaken by a farmer (herbicide application, strategic grazing and ecological burns). It is also noted that the only food plants present on the site are native grass species, so GSM food plants will not be targeted by weed control (i.e. Chilean Needle-grass Nassella neessiana, is absent from the property, with strict weed hygiene protocols in place to prevent its invasion).

5.3.4 EPBC Act offset principles A summary of how the proposed offset package meets the EPBC Act Environmental Offsets Policy is provided in Table 14.

Table 14 EPBC Act offset principles

Offset Principle Response

Suitable offset must:

1. Deliver an overall The conservation outcome that will be delivered by the proposed offsets will be to secure an conservation outcome that Offset Area of larger size, superior landscape context and higher starting quality compared to improves or maintains the the area that is being removed. The GSM habitat that is to be removed by the proposed action viability of the aspect of the is a small, isolated patch of habitat embedded in a cropping landscape that is under threat from environment that is protected current agricultural activities. The impact area is too small and of too low quality to be given by national environment law formal protection and there is reason to believe that the GSM at the impact site would not and affected by the proposed persist in the long term due to the adjacent herbicide application and introduced pasture action. management (Section 1.3).

The impact area scored a quality of 3/10 and will be offset with GSM habitat conservatively scored 5/10 for quality. While the impact area is small and isolated, the Offset Area is embedded in a landscape that supports a large population of GSM and will be adjacent to existing offset sites. By securing this offset, which adjoins existing GSM offsets, the area of GSM habitat protected by conservation covenants will be expanded, creating greater protection for the species. The protection and ongoing improvements proposed will secure the offset in perpetuity and places controls the current threatening processes, which are active as part of business-as-usual farm management.

2. Be built around direct offsets The offset package includes direct offsets only. but may include other compensatory measures.

3. Be in proportion to the level The offset proposal is informed by the EPBC offsets calculator, which takes the level of statutory of statutory protection that protection into account. While GSM is listed as critically endangered, the low probability of long applies to the protected term persistence of GSM at the impact area means that the impact area would not have matter. contributed to the long term persistence of the species. Given this context, an Offset Area more than 3 times the size of the impact area and located within a large, landscape scale GSM population, which does have the ability to support the long term persistence of the species, would appear proportionate to the level of statutory protection.

4. Be of a size and scale The offset proposal is informed by the EPBC offsets calculator, which calculates offset size in proportionate to the residual relation to impact areas. Proportionate to on-going approved impacts to GSM, the residual impacts on the protected impacts of the proposed action are inconsequential. Firstly, the proposed action affects a matter. population that is assessed as unlikely to contribute to the long-term persistence of the species within the Melbourne region where the persistence of GSM has been secured under the MSA (DEPI 2013b). Secondly, the impacts could almost be considered trivial compared to the thousands of hectares of habitat that have been approved for removal for Melbourne’s growth corridors under the MSA. E.g. there were 250 hectares cleared for just one of 28 Precinct Structure Plans (Truganina South PSP, DEPI 2013d). Given these two points, the offsets would appear to be proportionate to the residual impacts.

5. Effectively account for and Risk of Loss and risk of not achieving an increase in quality are both components of the offset manage the risks of the offset assessment guide and so have been incorporated into the calculation of the area of habitat not succeeding. required for the offset. The risk of the offset not succeeding has been minimised by securing an offset on a property that has existing GSM offsets in place. While it is impossible to eliminate all risk from a situation, the areas of risk within the control of the landholder have been addressed in the OMP. Risk management has also been incorporated into the OMP for the Offset Area through the use of adaptive management.

There are many GSM offsets now in operation so the risks associated with managing this habitat are known and are directly related to the level of management effort. That is, GSM habitat declines in quality with neglect of management but can be readily maintained with a regular management routine. An offset such as the one proposed, that is being actively

Offset Principle Response

managed by a farmer who lives on the property and has a direct and long standing interest in the land under management, is more likely to succeed than many public reserves, which have very low levels of management due to resourcing constraints.

6. Be additional to what is Under current legislation, there is no requirement for offsets should GSM become extinct at the already required, determined impact area as a result of continuing agricultural uses. As such, the offsets provided here are by law or planning regulations additional to what would be provided under a business-as-usual scenario. or agreed to under other schemes or programs. Under current legislation, there is no requirement for offsets should GSM become extinct at the proposed Offset Area as a result of continuing agricultural uses. As a result, all management actions implemented as part of the OMP and aimed at conservation of GSM habitat will be additional to those required under business-as-usual farming practices.

7. Be efficient, effective, timely, The EPBC Act offsets policy states that Efficient and effective offsets are those that maintain or transparent, scientifically improve the viability of a protected matter through the sound allocation of resources. In this case, robust and reasonable. the proposed offset will add onto an existing GSM offset site. This strategy not only expands the area of GSM habitat under protection but also minimises risk by providing an offset managed by a landholder who has demonstrated that they can maintain GSM habitat on their property for the purpose of offsets. The EPBC Act offsets policy state that an offset should be implemented either before, or at the same point in time as, the impact arising from the action. The offset will be as timely as possible within the constraints of administrative requirements. The proponent will enter into an agreement with the offset provider to secure the offset prior to approval. This will ensure an offset will be available at the time of the proposed action. The EPBC Act offsets policy state that Offsets must be based on both scientifically robust and transparent information that sufficiently analyses and documents the benefit to a protected matter’s ecological function or values. A condition report for the Offset Area was prepared to detail the investigations that informed the evaluation of the Offset Area. All information used to evaluate the Offset Area was collected by qualified ecologists specifically for the purpose of evaluating the values for the protected matter. The offset is providing habitat for one MNES only so the Offset Area was evaluated for its value for GSM only. All GSM records collected in 2018 were collected in accordance with the specified guidelines. The GSM records and mapping collected for the Offset Area have been provided in the offset condition report or in the attachment to the condition report.

8. Have transparent governance The OMP for the Offset Area sets out a monitoring protocol to quantitatively evaluate the GSM arrangements including being population over the 10 year management period. This will include periodic GSM surveys and able to be readily measured, regular measuring of weed and native grass cover. Reporting will be done annually and auditing monitored, audited and will be done in compliance with any approval conditions The OMP will follow the format enforced. previously approved by DoEE for managing similar GSM offset sites. The OMP will be enforced through the Trust for Nature process and any conditions applied through the EPBC approval process.

5.4 Progress towards securing offsets

Abzeco Pty Ltd have been engaged as the offset broker for the landholder and will also register the offsets. The landholder has given in-principal support of the proposed offset and reached an agreement on pricing with the project proponent.

Biosis undertook targeted surveys of the proposed Offset Area in December 2018 allowing calculation of the presence, distribution and stocking rate of the species. Biosis is providing on-going technical inputs for the EPBC referral process.

5.5 Other offset requirements

5.5.1 State offsets Offsets for the project are also prescribed under Victoria’s Guidelines for the removal, destruction or lopping of native vegetation. (DELWP 2017) to compensate for the clearing of native vegetation. The offset requirements are measured General Habitat Units (GHUs) as detailed below in Table 15. The NVR report is provided in Appendix 3. These offsets can be purchased through the Native Vegetation Credit Register and a quote from a registered offsets broker has been provided to the proponent.

Table 15 Summary of offsets generated in the NVR report.

Attribute Outcome

Native vegetation removal extent 3.708 ha

Location category of vegetation to be removed Location 3

General offset amount (General Habitat Units - 1.605 GHUs GBEU)

Minimum strategic biodiversity value score 0.468

Offset vicinity Port Phillip and Westernport CMA or Mitchell Shire Council

6. Social and Economic

The economic and social impacts of the action, both positive and negative, must be analysed. Matters of interest may include:

a) details of any public consultation activities undertaken, and their outcomes,

b) details of any consultation with Indigenous stakeholders,

c) projected economic costs and benefits of the project, including the basis for their estimation through cost/benefit analysis or similar studies, and

d) employment opportunities expected to be generated by the project (including construction and operational phases).

6.1 Response to a)

This action is being undertaken by a private farming business on private farmland with no external stakeholders having been identified.

6.2 Response to b)

The proponent is seeking advice on compliance with the Victorian Aboriginal Heritage Act 2006.

6.3 Response to c)

All costs will be borne by the proponent. The proposed action is being undertaken to increase the area available for cropping with the economic benefits of this change in land use expected to be attained within several seasons.

6.4 Response to d)

Inverlochy farming property employs several staff to manage and undertake farm work on the property.

7. Ecologically sustainable development

Provide a description of the proposed action in relation the principles of ecologically sustainable development, as defined in the EPBC Act:

• the long-term and short-term economic, environmental, social and equitable considerations,

• the precautionary principle which states that a lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation where there are threats of serious or irreversible environmental damage,

• the principle of inter-generational equity which states that the present generation should ensure that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations,

• the conservation of biological diversity and ecological integrity should be a fundamental consideration in decision- making, and

• improved valuation, pricing and incentive mechanisms should be promoted.

To assist you, the National Strategy for Ecologically Sustainable Development (1992) is available on the following web site: http://www.environment.gov.au/resource/nationalstrategy-ecologically-sustainable-development.

7.1 Ecologically sustainable development

The National Strategy for Ecologically Sustainable Development (1992) sets out the policy framework for the Australian Government to make decisions and take actions to pursue ecologically sustainable development (ESD). It defines ecologically sustainable development as: 'using, conserving and enhancing the community's resources so that ecological processes, on which life depends, are maintained, and the total quality of life, now and in the future, can be increased'.

The National Strategy requires government departments to ensure that the principles and objectives of ESD are delivered and sets out the following core objectives for achieving ESD:

• to enhance individual and community well-being by following a path of economic development that safeguards the welfare of future generations; • to provide for equity within and between generations; and • to protect biological diversity and maintain essential ecological processes and life-support systems.

These objectives have also been incorporated into the EPBC Act, which defines five ESD principles. Table 16 summarises the assessment of the Project against EPBC Act principles of ESD.

Table 16 Assessment of the project against the guiding principles of ESD.

EPBC Act Guiding Principle Project Response

The long-term and short-term economic, Social and Economic: The project seeks to increase farm viability for the next 10 to 15 environmental, social and equitable years (medium term). The proposed action will result in an increase of area available for considerations cropping of 35 hectares. This will increase the area available for cereal crop and canola production. After this time, it is likely that the area will be subject to residential subdivision so truly long term management is not possible. Environmental: Long term environmental implications have been addressed by the documentation above (Sections: 1.1.3 , 2.1.3 and 5.3.4).

The precautionary principle which states Robust environmental assessments have been completed to assess the potential impacts that a lack of full scientific certainty of the project. The assessments undertaken for this project provide a sound basis for should not be used as a reason for understanding the likely project impacts and in developing effective management and postponing measures to prevent mitigation measures for the proposed works. By providing offsets, this project will avert environmental degradation the predicted business-as-usual scenario of GSM habitat being lost at the impact site through degradation of habitat quality, which would not have been offset.

The principle of inter-generational equity The proposed offset will ensure residual impacts on MNES are accounted for at the time which states that the present generation of the action and will contribute to increasing the habitat for this species under protection should ensure that the health, diversity whereas the impact area is too small and of too low quality to be given formal protection. and productivity of the environment is maintained or enhanced for the benefit The project seeks to increase farm viability for the next 10 to 15 years by increasing the of future generations. area that can be cultivated. After this time, the area will most likely be subject to residential sub-division making inter-generational considerations of the proposed action difficult to evaluate.

The conservation of biological diversity Decision-making is undertaken by the regulator, in this case, DoEE. This document aims to and ecological integrity should be a provide all information required for the decision maker to evaluate the project against fundamental consideration in decision- their own criteria. The proponent has demonstrated their compliance with environmental making regulations by referring the proposed action to the Minister for the Environment and undertaking to provide a compliant offset.

Improved valuation, pricing and incentive This does not apply to the project. mechanisms should be promoted.

8. Environmental record of the proponent

The information provided must include details of any proceedings under a Commonwealth, State or Territory law for the protection of the environment or the conservation and sustainable use of natural resources against: a) The person proposing to take the action. b) For an action for which a person has applied for a permit, the person making the application.

If the person proposing to take the action is a corporation, details of the corporation’s environmental policy and planning framework should be described.

8.1 Proceedings under a Commonwealth or state law

None

9. Other Approvals and Conditions

The preliminary documentation must include information on any other requirements for approval or conditions that apply, or that the proponent reasonably believes are likely to apply, to the proposed action. This must include: a) a description of any approval that has been obtained or is required to be obtained from a State, Territory or Commonwealth agency or authority (other than an approval under the EPBC Act), including any conditions that apply (or are reasonably expected to apply) to the action, and b) a description of the monitoring, enforcement and review procedures that apply, or are proposed to apply, to the action.

9.1 Commonwealth approvals

No other Commonwealth approvals are required.

9.2 State approvals and policy

9.2.1 Flora and Fauna Guarantee Act 1988 Under the FFG Act a permit is required from DELWP to 'take' protected flora species from public land. The site is on private land so a permit is not required.

9.2.2 Planning and Environment Act 1987 (incl. Planning Schemes) A planning permit application to remove native vegetation under Clause 52.17 of the Mitchell Planning Scheme has been submitted to Mitchell Shire and is under review.

Removal of native vegetation and offset requirements are provided above in section 5.5.

9.2.3 Catchment and Land Protection Act 1994 (Victoria) The CaLP Act identifies and classifies certain species as noxious weeds or pest animals, and provides a system of controls on noxious species.

Four declared noxious weeds were identified from within the disturbance footprint: Spear Thistle Cirsium vulgare, Artichoke Thistle Cynara cardunculus, Variegated Thistle Silybum marianum and Gorse. The proponent must take all reasonable steps to prevent the growth and spread of regionally controlled weeds, and prevent the spread of and as far as possible eradicate established pest animals. Mitigation measures to prevent the spread of these weeds including correct disposal of contaminated soil within Inverlochy should be implemented.

9.3 Monitoring, enforcement and procedure reviews

The proposed excavation works to remove the surface rock are short term and will be undertaken by farm employees or contractors. The works will be overseen by Crystal Group to ensure compliance with the planning permit conditions once the permit is issued.

10. Conclusion

The preliminary documentation must provide an overall conclusion as to the environmental acceptability of the proposal, including discussion on compliance with the principles of Ecologically Sustainable Development and the objects and requirements of the EPBC Act.

To assist you, the National Strategy for Ecologically Sustainable Development (1992) is available on the following web site: https://www.environment.gov.au/about-us/esd/publications/national-esd-strategy.

You may wish to include a statement as to whether or not the controlled action should be approved and may recommend conditions pertaining to an approval. This should include justification for undertaking the proposed action in the manner proposed. The measures proposed or required by way of offset for any unavoidable impacts on MNES and the relative degree of compensation, should be restated here.

10.1 Summary of residual impacts

The proposed impact to MNES is expected to have only a local impact on the MNES and will not affect the broader persistence of the species in the long term. This is because the habitat proposed for removal has a low likelihood of long-term viability given the small isolated nature of the habitat and the ongoing effects of surrounding agriculture. In addition, the impact area would not be of sufficient size of quality to be granted formal protection due to high weed cover and low numbers of GSM present. The proposed removal of 2.23 hectares of low quality GSM habitat is inconsequential when compared to the amount of GSM habitat approved for removal in Melbourne’s growth corridor and the Melbourne Strategic Assessment has already been undertaken to secure the MNES within the Melbourne area. The proposed action will provide compensatory offsets therefore placing more GSM habitat under formal protection. This outcome provides for greater security and management of GSM within their Victorian distribution in a manner consistent the EPBC Act Environmental Offsets Policy (DSEWPaC 2012).

10.2 Proposed approval

Crystal Group accepts that the proposed action and associated GSM habitat removal has been determined as a controlled action under the EPBC Act due to the impact upon the critically endangered MNES. Crystal Group is committed to managing the risk to this MNES and providing offsets to compensate for the loss of this MNES.

It is Crystal Group’s position that the project be approved subject to conditions as deemed appropriate by DoEE. Should the action be approved by the Commonwealth, these conditions would form the minimum set of requirements imposed by one of the regulatory authorities involved in the approvals process for this project. The conditions are expected to relate to undertaking the action in a manner that minimises impact on GSM habitat through compliance with a defined limit of works, site inductions, and commitment to manage retained areas of GSM habitat.

Compensatory offsets are proposed for the residual impacts to GSM habitat.

11. Information sources

The preliminary documentation must state for the information provided, the following: a) The source of the information. b) How recent the information is. c) How the reliability of the information was tested. d) The uncertainties (if any) in the information. e) The guidelines, plans and/or policies considered.

11.1 References

ABC 2018. Booming sheep and wool prices see money flow into iconic Victorian town. ABC News Rural. Accessed 29/01/2019, URL: https://www.abc.net.au/news/rural/2018-03-06/prices-weather-combine-in-rare- good-times-victorian-farmers/9508850

Biosis 2017. Wallan South Precinct Structure Plan: Biodiversity Assessment Report. Report for Crystal Creek Properties Pty Ltd. Authors: Nerenberg S, Gilmore D, Hollier C & Stoot L, Biosis Pty Ltd, Melbourne. Project no. 23811

Dorrough et al. 2006. Soil phosphorus and tree cover modify the effects of livestock grazing on plant species richness in Australian grassy woodland. Biological Conservation. 130: 394-405.

Dorrough et al. 2012. Differential responses of plants, reptiles and birds to grazing management, fertilizer and tree clearing. Austral Ecology. 37: 569-582.

DELWP 2017. Guidelines for the removal, destruction or lopping of native vegetation. Victorian Government Department of Land, Water and Planning, Melbourne (December 2017).

DEPI 2013. Permitted clearing of native vegetation - Biodiversity assessment guidelines. Victorian Government Department of Environment and Primary Industries, Melbourne (September 2013).

DEPI 2013b. Biodiversity Conservation Strategy for Melbourne’s Growth Corridors. The State of Victoria, Melbourne.

DEPI 2013c. Index of Wetland Condition Assessment Procedure September 2013. Department of Environment and Primary Industries, East Melbourne, Victoria.

DEPI 2013d. Sub-Regional Species Strategy for the Golden Sun Moth. The Victorian Government Department of Environment and Primary Industries

Melbourne, May 2013

DEPI 2014. Advisory List of Rare or Threatened Plants in Victoria – 2014. Victorian Government Department of Environment & Primary Industries, East Melbourne.

DEWHA 2009a. Significant impact guidelines for the critically endangered spiny rice-flower (Pimelea spinescens subsp. spinescens). Nationally threatened species and ecological communities EPBC policy statement 3.11. The Australian Government, Canberra.

DEWHA 2009b. Significant impact guidelines for the critically endangered golden sun moth (Synemon plana). Nationally threatened species and ecological communities EPBC Act policy statement 3.12, The Australian Government, Canberra.

DEWHA 2009c. Significant impact guidelines for the vulnerable growling grass frog (Litoria raniformis). Nationally threatened species and ecological communities EPBC Act policy statement 3.14. The Australian Government, Canberra.

DoE 2013. Matters of National Environmental Significance Significant impact guidelines 1.1. Environment Protection and Biodiversity Conservation Act 1999. The Australian Government, Canberra.

DoEE 2017. EPBC Act Policy Statement 3.21— Industry guidelines for avoiding, assessing and mitigating impacts on EPBC Act listed migratory shorebird species. The Australian Government, Canberra.

DSE 2004. Native Vegetation: Sustaining a living landscape. Vegetation Quality Assessment Manual – Guidelines for applying the Habitat hectares scoring method. Version 1.3. Victorian Government Department of Sustainability & Environment, Melbourne.

DSE 2006. Ministerial Guidelines for Assessment of Environmental Effects under the Environment Effects Act 1978. Victorian Government Department of Sustainability and Environment, Melbourne.

DSE 2009. Advisory List of Threatened Invertebrate Fauna in Victoria - 2009. Department of Sustainability and Environment, East Melbourne, Victoria.

DSE 2010. Victorian Biodiversity Atlas ‘VBA_FAUNA25, FAUNA100 & FAUNARestricted, FLORA25, FLORA100 & FLORARestricted’ August 2010 © The State of Victoria. Victorian Government Department of Sustainability & Environment, Melbourne.

DSE 2013. Advisory List of Threatened Vertebrate Fauna in Victoria – 2013. Victorian Government Department of Environment & Primary Industries, Melbourne.

DSEWPaC 2011a. Environment Protection and Biodiversity Conservation Act 1999 referral guidelines for the vulnerable striped legless lizard Delma impar. The Australian Government, Canberra.

DSEWPaC 2011b. Nationally Threatened Ecological Communities of the Victorian Volcanic Plain: Natural Temperate Grassland & Grassy Eucalypt Woodland A guide to the identification, assessment and management of nationally threatened ecological communities. The Australian Government, Canberra.

DSEWPaC 2012 Environment Protection and Biodiversity Conservation Act 1999 Environmental Offsets Policy. The Australian Government, Canberra.

EPA 1991. Construction Techniques for Sediment Pollution Control. Publication 275, Environment Protection Authority Victoria, Melbourne.

EPA 1996. Environmental Guidelines for Major Construction Sites. Publication 480, Environment Protection Authority Victoria, Melbourne.

EPA 2004. Publication 960, Guideline for Environmental Management. Doing it right on subdivisions. Temporary environmental protection measures for subdivision construction sites. Environment Protection Agency, Melbourne.

Growth Areas Authority (GAA) 2011. Growth Areas Process Preliminary Assessment Report North Region: Whittlesea, Mitchell and Hume (Excluding Sunbury / Growth Areas Process 2011 Preliminary Assessment Report Whittlesea, Mitchell and Hume (Excluding Sunbury / Diggers Rest). Growth Areas Authority, Melbourne. https://vpa.vic.gov.au/wp-content/Assets/Files/GROWTH%20AREAS%20LOGICAL%20INCLUSIONS% 20REVIEW%20PROCESS%20North%20Region%20Report%202011%20Main%20Report%20Final_.pdf

Maseyk FJF, Evans MC & Maron M 2017. Guidance for deriving ‘Risk of Loss’ estimates when evaluating biodiversity offset proposals under the EPBC Act. Report to the National Environmental Science Programme. Department of the Environment and Energy. Centre of Biodiversity and Conservation Science, School of Earth and Environmental Science, The University of Queensland, Brisbane, Queensland 4072, Australia.

Sinclair 2010. Vegetation mapping of the Port Phillip Bay (Western Shoreline) and Bellarine Peninsula Ramsar Site

Threatened Species Scientific Committee (TSSC) 2016. Conservation Advice Delma impar striped legless lizard. Canberra: The Australian Government, Canberra.

Threatened Species Scientific Committee (TSSC) 2012. Commonwealth Listing Advice on Seasonal Herbaceous Wetlands (Freshwater) of the Temperate Lowland Plains. Department of Sustainability, Environment, Water, Population and Communities. Canberra, ACT: Department of Sustainability, Environment, Water, Population and Communities.

Threatened Species Scientific Committee (TSSC) 2013. Approved Conservation Advice for Synemon plana (golden sun moth). The Australian Government, Canberra.

Appendices

Appendix 1 Likelihood table for all MNES

Table A1 Likelihood table for all MNES (excluding migratory species) obtained from a PMST (DoEE 31/05/2018)

Common Most Likely Scientific name Conservation status Habitat description name recent Other occurrence in Rationale for likelihood ranking database records disturbance EPBC VIC FFG record footprint Flora species Amphibromus River Swamp VU PMST Swampy areas, mainly along the Murray River Low Little suitable habitat, swamp fluitans Wallaby-grass between Wodonga and Echuca with scattered hydrology has been highly records from southern Victoria. modified to drain water Dianella amoena Matted Flax- EN e L PMST Lowland grassland and grassy woodland, on Low Remaining grassland area is small lily well-drained to seasonally waterlogged fertile and of low quality due to past sandy loam soils to heavy cracking clays. grazing Dodonaea Trailing Hop- VU v PMST Sandy or clay soils in low-lying, winter-wet areas Low Remaining grassland area is small procumbens bush in grasslands, woodlands, and low-open forest. and of low quality due to past grazing. Outside known range. Glycine latrobeana Clover Glycine VU v L PMST Grasslands and grassy woodlands, particularly Low Remaining grassland area is small those dominated by Kangaroo Grass. and of low quality due to past grazing Lachnagrostis Adamson's EN v L PMST Low-lying, seasonally wet or swampy areas of Negligible Little suitable habitat, swamp adamsonii Blown-grass plains communities, often in slightly saline hydrology has been highly conditions. modified to drain water Lepidium Basalt EN e L 2010 Basalt plains grassland and woodland Low Recent record but remaining hyssopifolium Peppercress communities. grassland area is small and of low quality due to past grazing Leucochrysum White Sunray EN e L PMST Grasslands of the Victorian Volcanic Plains, Low Remaining grassland area is small albicans var. primarily on acidic clay soils derived from basalt, and of low quality due to past tricolor with occasional occurrences on adjacent grazing sedimentary, sandy-clay soils. Pimelea Spiny Rice- CR e L PMST Primarily grasslands featuring a moderate Negligible Remaining grassland area is small spinescens subsp. flower diversity of other native species and inter- and of low quality due to past spinescens tussock spaces, although also recorded in grazing. Outside of known range. grassland dominated by introduced perennial grasses. Pomaderris Round-leaf CR e L PMST Endemic in Victoria, and apparently confined to a Negligible No suitable habitat. Outside of vacciniifolia Pomaderris single population at Carboor Upper (near known range Myrtleford), where it is growing in dry woodland on shallow soil derived from sedimentary rock

Prasophyllum Maroon Leek- EN e L PMST Grassland and grassy woodland environments Negligible No suitable habitat. frenchii orchid on sandy or black clay loam soils that are generally damp but well drained. Pterostylis Green-striped VU PMST Grows in moist areas of heathy and shrubby Negligible No suitable habitat. Outside known chlorogamma Greenhood forest, on well-drained soils. range. Rutidosis Button EN e L PMST Higher quality Plains Grassland and Grassy Negligible Remaining grassland area is small leptorhynchoides Wrinklewort Woodland in Western Victoria, particularly those and of low quality due to past with fertile soil and light timber cover. grazing. Senecio Swamp VU v 2002 PMST Seasonally-inundated herb-rich swamps, Negligible No suitable habitat, swamp psilocarpus Fireweed growing on peaty soils or volcanic clays. hydrology has been highly modified to drain water Thelymitra Spiral Sun- VU v L PMST Typically on well-drained soils on slightly Negligible No records, outside known range matthewsii orchid elevated sites, but also on coastal sandy flats. Often in open situations following disturbance. Xerochrysum Swamp VU v L 2005 PMST Sedge-swamps and shallow freshwater marshes Low No suitable habitat, swamp palustre Everlasting and swamps in lowlands, on black cracking clay hydrology has been highly soils. modified to drain water Fauna species Anthochaera Regent CR cr L PMST A range of dry woodlands and forests dominated Negligible In Victoria this species is now phrygia Honeyeater by nectar-producing tree species. largely confined to drier woodlands in the north-east of the State Botaurus Australasian EN en L 1990 Shallow freshwater and brackish wetlands with Negligible No suitable habitat. poiciloptilus Bittern abundant emergent aquatic vegetation. Calidris ferruginea Curlew CR en PMST Large intertidal sandflats, banks, mudflats, Negligible No suitable habitat Sandpiper estuaries, inlets, sewage farms, saltworks, harbours, coastal lagoons and bays. Grantiella picta Painted VU vu L 1988 Dry open woodlands and forests. Typically Low No recent records, little mistletoe Honeyeater forages for fruit and nectar in mistletoes and in tree canopies. Lathamus discolor Swift Parrot CR en L 1991 A range of forests and woodlands, especially Low No suitable habitat those supporting nectar-producing tree species. Also well-treed urban areas. Numenius Eastern CR vu PMST Large intertidal sandflats, banks, mudflats, Negligible No suitable habitat madagascariensis Curlew estuaries, inlets, sewage farms, saltworks, harbours, coastal lagoons and bays. Pedionomus Plains- CR cr L 1905 Native grassland with a sparse, open structure. Negligible No suitable habitat torquatus wanderer Rostratula Australian EN cr L PMST Shallows of well-vegetated freshwater wetlands. Low Limited suitable wetland habitat – australis Painted Snipe unlikely to occur regularly

Petauroides Greater VU vu PMST Wet and damp sclerophyll forest with large Negligible No suitable habitat volans Glider hollow-bearing trees. Pteropus Grey-headed VU vu L PMST Rainforest, wet and dry sclerophyll forest, Medium Far ranging species, may use air poliocephalus Flying-fox woodland and urban areas. space to travel through the area Pseudomys Smoky Mouse EN cr L PMST Coastal heath and heathy woodland, wet forest, Negligible No records, no suitable habitat fumeus sub-alpine heath and dry sclerophyll forest. Delma impar Striped VU en L 1991 Natural temperate grassland, grassy woodland Low Only one record from the local Legless Lizard and exotic grassland. area, much of the disturbance footprint has been cultivated Litoria raniformis Growling VU en L 1991 Still or slow-flowing waterbodies and Low No suitable habitat. None detected Grass Frog surrounding terrestrial vegetation. during targeted surveys on the property. Prototroctes Australian VU vu L PMST Adults inhabit cool, clear, freshwater streams. Negligible No suitable habitat. maraena Grayling Galaxiella pusilla Dwarf VU en L PMST Slow-flowing or still freshwater wetlands such as Negligible No suitable habitat. Galaxias swamps, drains and backwaters of streams. Synemon plana Golden Sun CR cr L 2009 Natural temperate grassland, grassy woodland Recorded Confirmed presence using targeted Moth and pasture supporting spear grasses and surveys wallaby grasses and exotic grassland dominated by Chilean needle grass. Threatened communities Community EPBC Type of presence (PMST) Status Rational status Grassy Eucalypt Woodland of the Victorian Volcanic Plain CR Community known to occur within area Not present Not River Red-gum present Grey Box (Eucalyptus microcarpa) Grassy Woodlands and Derived Native EN Community may occur within area Not present No Grey Box present Grasslands of South-eastern Australia Natural Temperate Grassland of the Victorian Volcanic Plain CR Community likely to occur within area Not present HZ 14 - Does not meet requirements for listing according to DSEWPaC (2011) - native tussock cover <50% of perennial cover Seasonal Herbaceous Wetlands (Freshwater) of the Temperate Lowland CR Community likely to occur within area Not present HZ 13 and 15 – does not meet Plains condition thresholds for this community White Box-Yellow Box-Blakely's Red Gum Grassy Woodland and Derived CR Community likely to occur within area Not present None of these species present Native Grassland

Appendix 2 Figures

o y t y o a g r l

a P a l g C n n a N Millar Cl T i W h d a s e e i K A W l v cac S W

G i ia l m

r D n a Legend e t s oy M a i i a

y Ct C y n R t n e i g h t t t k c g o a u e i l p t

r n

C a o s a a W l P

Study Area H M S il C

u ne u Randall Cr n t o g Darraweit Rd R hton Inverlochy property boundary (530g ha) Cl Potter Ct e Whittlesea Stella Ct ! William St Disturbance footprint boundary (55.5 ha) Banon St William St !Sunbury D n

a a

h e

Jacob St Dakota Av r Land Parcels Stud Ct R MeltonMaestro Dr ank Av ! in B Active parcel vd King St Win t Lantern Ct d C Lilydale Bentinck St s ! o e Pretty Sally Drive Drain r i High St D r ! Proposed parcel r th Ringwood u !Melbourne G r D Dr lCt e n b Windham St m Dudley St

a a o t i s C l l e il I Wetlands (DELWP supplied data) laid e A Ad !Werribee W n g e Queen St

e in

L u H

2 - Freshwater meadow Q K i s Wallan a

a Pamela Ct K d

l i P e MSA (BCS) extent n t l C y We g m dding Dr Willia D r Wellington St

Stanley St Thomas Pl Urban Growth Boundary H o r Wallan l

l y

D D

r Byron Av Watson St Fellow Ct a A Wetland

Caitlyn Av d Zoe Pl e High St Watson St r c

d n L

Stringybark Av u R

a Eden Pl

C y

Raglan St d e c v n Good B t Mcleod Ct

d e nia Nicholson St Duke St

C Osborne Way

S Nash Ct

f f d l Watergum Way e y O v t D y A A C r W Rowes Lane lm a

ond y t e Botanical Av s t

a W

Glade Dr r M Mead Cl C

a D a id y enhai r Alexander Av Lyons Way Narrowleaf St Taylors Lane

MITCHELL SHIRE

Duke Street Drain

Hume Fwy

Northern Hwy S to c k d a Macsfield le R R d d

Old Sydney Rd

F Kalkallo Creek

m u H

Acknowledgement:VicMap Data ©State of Victoria

Figure 1: Location of Inverlochy farming property and subject paddock, Wallan, Victoria 0 220 440 660 880

Matter: 23811, Biosis Pty Ltd Date: 31 January 2019, ± Metres Ballarat, Brisbane, Canberra, Hobart, Melbourne, Checked by: SNP, Drawn by: SKM, Last edited by: snerenberg Newcastle, Sydney, Wangaratta & Wollongong Location:P:\26100s\26184\Mapping\26184_F1_Locality.mxd Scale 1:22,500 @ A4, GDA 1994 MGA Zone 55 GF

Legend Disturbance footprint boundary Impact area: Golden Sun Moth habitat proposed for removal Golden Sun Moth records location GF (3 males observed)

2.23 ha

Figure 2 Location of the GF impact area for MNES within the Action area, Wallan, Victoria

0 170

Metres Scale: 1:3,157 @ A3 Coordinate System: GDA 1994 MGA Zone 55 ± Biosis Pty Ltd Ballarat, Brisbane, Canberra, Hobart, Melbourne, Newcastle, Sydney, Wangaratta & Wollongong

Matter: 23811, Date: 31 January 2019, Acknowledgements: State Government of Victoria - VicMap - Nearmap Checked by: SN, Drawn by: LDM, Last edited by: snerenberg Location:P:\26100s\26184\Mapping\26184_F2_MNES.mxd Legend Disturbance footprint boundary Golden Sun Moth habitat extent (proposed for removal) Golden Sun Moth records location GF (3 males observed) wetland_current Wetlands 2 - Freshwater meadow

2.23 ha

Excavated drains Excavated drain Figure 3 Aerial photography showing landform modification of DELWP modelled wetland

0 160

Metres Scale: 1:2,830 @ A3 Coordinate System: GDA 1994 MGA Zone 55 ± Biosis Pty Ltd Ballarat, Brisbane, Canberra, Hobart, Melbourne, Newcastle, Sydney, Wangaratta & Wollongong

Matter: 23811, Date: 10 August 2018, Acknowledgements: State Government of Victoria - VicMap - Nearmap Checked by: SN, Drawn by: LDM, Last edited by: snerenberg Location:P:\26100s\26184\Mapping\26184_F3_aerial.mxd Legend HZ_15.B Inverlochy property boundary Disturbance footprint boundary Habitat zone Ecological vegetation class Plains Grassland (FFG listed) Plains Grassy Wetland

HZ_15.C

0.11 ha

0.32 ha HZ_15.A

HZ_14.B HZ_13.A 1.7 ha 0.99 ha Figure 4 Location of native vegetation within Action area, Wallan, Victoria

0 160 0.19 ha HZ_13.B Metres Scale: 1:2,939 @ A3 0.18 ha Coordinate System: GDA 1994 MGA Zone 55 HZ_14.A 0.22 ha ± Biosis Pty Ltd Ballarat, Brisbane, Canberra, Hobart, Melbourne, Newcastle, Sydney, Wangaratta & Wollongong

Matter: 23811, Date: 31 January 2019, Acknowledgements: State Government of Victoria - VicMap - Nearmap Checked by: SN, Drawn by: LDM, Last edited by: snerenberg Location:P:\26100s\26184\Mapping\26184_F4_NativeVeg.mxd Legend Inverlochy property boundary Disturbance footprint boundary Golden Sun Moth habitat extent

Figure 5 Location of MNES within Inverlochy farming property, Wallan, Victoria

0 200 400

Metres Scale: 1:8,190 @ A3 Coordinate System: GDA 1994 MGA Zone 55 ± Biosis Pty Ltd Ballarat, Brisbane, Canberra, Hobart, Melbourne, Newcastle, Sydney, Wangaratta & Wollongong

Fellow Ct

Hadley Dr Kilmore ! H Watson St o l B l yron Clonbinane

y A v Lawson Way

High St !

D r Bylands Wandong

Caitlyn Av r ! !

Wellington St ! Heathcote

a oe P l Z l l Darraweit Junction

e !

Dudley St

Stanley St i ! Guim

A ! Yabamac Raglan St Wallan u d !

a ! Stringybark Av ! Upper Plenty r L ! ia Wallan East n ! Everlasting St C Vinelea c f A t Beveridge v Lancefield ! Goodenia Bvd Mcleod Ct Duke St ! Junction ! C Nash Ct Whittlesea o Bulbine St Jamieson Way ! r Laffy St Appleberry Way kwo W Kalkallo Tussock Dr od St Nicholson St C y Evans Ent ! Watergum Way a o t f Woodstock t W f Osborne Way ! Almond Av a e Glade Dr y y Yan Yean Mead Cl ! Teatree Lane D Scott Cr Botanical Av Oaklands

r !

C Mernda Brock Ct a Junction !

! Craigieburn ! Wollert Indigo St s ! ! M Narrowleaf St Treeviolet Lane e a Alexander Av c Weatherglass St y d Lyons Way Minogue Way Maidenhair Dr o C n t a l

d Crystal Cl C l Stevenson St Legend Parsons Pl Taylors Lane

Edwardes St Inverlochy property boundary Disturbance footprint boundary

Date of survey 19/12/2016

Rowes Lane 26/12/2016 04/01/2017

d R 1/12/2016

e GF

n GF

d y Golden Sun Moth observed S

d GF l GF (number of moths seen) O GF

MITCHELL SHIRE GF GF GF GFGF

Figure 6: Golden Sun Moth survey effort, Wallan, Victoria

GF 0 200 400 600 GF Metres Scale: 1:10,602 @ A3 Coordinate System: GDA 1994 MGA Zone 55

r n ± Biosis Pty Ltd H Ballarat, Brisbane, Canberra, w Melbourne, Newcastle, Sydney, y Wangaratta & Wollongong

Matter: 26184, Date: 10 August 2018, Checked by: A JH, Drawn by: DK, Last edited by: snerenberg Acknowledgements: Vicmap (c) State of Victoria Location:P:\26100s\26184\Mapping\ 26184_F6_MothSurveyEffort Legend Inverlochy property boundary

1E Disturbance footprint boundary Waterbodies surveyed for Growling Grass Frog Hydrology Drainage Channel Stream

360

370

320

340 350 1A 330 1B

a Ro L 1D wes 1C

310

360

Northern Hwy

2B 1F

1G Figure 7 Hydrological features of the study area showing dams surveyed Macsfield Rd for Growling Grass Frog, 340 14A Jan-Feb 2017 300

330

0 200 400

310 Metres Scale: 1:8,921 @ A3 Coordinate System: GDA 1994 MGA Zone 55 320 ± Biosis Pty Ltd Ballarat, Brisbane, Canberra, Hobart, Melbourne, Newcastle, Sydney, Wangaratta & Wollongong

Matter: 24110, Date: 10 August 2018, Acknowledgements: State Government of Victoria - VicMap - Nearmap Checked by: SN, Drawn by: SSK, Last edited by: snerenberg Location:P:\26100s\26184\Mapping\24110_FX_EcoFeaturesGGF_Habitat.mxd !( !( !( !( !( !( !( !( !

!( !( !( !( !( !( !(

!Chepstowe Carngham! Mount Emu ! Poverty Point !

!( Rileys Rd

!Mortchup ! Snake Valley

Chinaman Flat !( ! !( !( Legend !( !( !( !( !( Abzeco data and results Existing offsets !( !( !( GSM record locations (2016 - 17) !( Biosis survey results !( !( !( !( !( 2018 survey area !( !( !( !( Dec 2018 survey results !( !( !( !( !( !( !( !( 1 moth !( !( !( 2 - 4 moths !( !( !( !( !( !( !( 5 - 8 moths !( !( !( !( Proposed offset GSM offset area (8.1 ha)

PYRENEES !( SHIRE

Figure 8 Location of proposed offset site, Chepstowe, Victoria.

Chepstowe - Pittong Rd

0 30 60 90 120 150

Metres Scale: 1:3,446 @ A3 Coordinate System: GDA 1994 MGA Zone 54 ± Biosis Pty Ltd Albury, Ballarat, Melbourne, Newcastle, Sydney, Wangaratta & Wollongong

Matter: [Matter], Date: 31 January 2019, Checked by: [Consultant], Drawn by: [GIS], Last edited by: snerenberg Esri, HERE, Garmin, © OpenStreetMap contributors, and the GIS user community, Source: Esri, DigitalGlobe, GeoEye, Earthstar Location: P:\26100s\26184\Mapping\ Acknowledgements: Vicmap ©State of Victoria, Imagery - NearMap 2017 Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community 26184_F4_CHEP_GSM_Offset.mxd

Appendix 3 Native Vegetation Removal Report

This report provides information to support an application to remove, destroy or lop native vegetation in accordance with the Guidelines for the removal, destruction or lopping of native vegetation. The report is not an assessment by DELWP of the proposed native vegetation removal. Native vegetation information and offset requirements have been determined using spatial data provided by the applicant or their consultant.

Date of issue: 21/12/2017 Report ID: BIO_2017_008 Time of issue: 2:08 pm

Project ID 26546_DELWP_2017_20171219

Assessment pathway

Assessment pathway Detailed Assessment Pathway

Extent including past and proposed 3.708 ha

Extent of past removal 0.000 ha

Extent of proposed removal 3.708 ha

No. Large trees proposed to be removed 0

Location category Location 3 The native vegetation is in an area where the removal of less than 0.5 hectares could have a significant impact on habitat for one or more rare or threatened species.The native vegetation is also in an area mapped as an endangered Ecological Vegetation Class.

1. Location map

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Native vegetation removal report

Offset requirements if a permit is granted

Any approval granted will include a condition to obtain an offset that meets the following requirements:

General offset amount1 1.605 general habitat units

Vicinity Port Phillip and Westernport Catchment Management Authority (CMA) or Mitchell Shire Council Minimum strategic biodiversity value 0.468 score2 Large trees 0 large trees

NB: values within tables in this document may not add to the totals shown above due to rounding Appendix 1 includes information about the native vegetation to be removed Appendix 2 includes information about the rare or threatened species mapped at the site. Appendix 3 includes maps showing native vegetation to be removed and extracts of relevant species habitat importance maps

1 The general offset amount required is the sum of all general habitat units in Appendix 1.

2 Minimum strategic biodiversity score is 80 per cent of the weighted average score across habitat zones where a general offset is required

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Native vegetation removal report

Next steps

Any proposal to remove native vegetation must meet the application requirements of the Detailed Assessment Pathway and it will be assessed under the Detailed Assessment Pathway.

If you wish to remove the mapped native vegetation you are required to apply for a permit from your local council. Council will refer your application to DELWP for assessment, as required. This report is not a referral assessment by DELWP.

This Native vegetation removal report must be submitted with your application for a permit to remove, destroy or lop native vegetation.

Refer to the Guidelines for the removal, destruction or lopping of native vegetation (the Guidelines) for a full list of application requirements This report provides information that meets the following application requirements:  The assessment pathway and reason for the assessment pathway  A description of the native vegetation to be removed (partly met)  Maps showing the native vegetation and property (partly met)  Information about the impacts on rare or threatened species.  The offset requirements determined in accordance with section 5 of the Guidelines that apply if approval is granted to remove native vegetation.

Additional application requirements must be met including:  Topographical and land information  Recent dated photographs  Details of past native vegetation removal  An avoid and minimise statement  A copy of any Property Vegetation Plan that applies  A defendable space statement as applicable  A statement about the Native Vegetation Precinct Plan as applicable  A site assessment report including a habitat hectare assessment of any patches of native vegetation and details of trees  An offset statement that explains that an offset has been identified and how it will be secured.

© The State of Victoria Department of Environment, Land, Water and Planning Disclaimer Melbourne 2017 This publication may be of assistance to you but the State of Victoria and its employees do not guarantee that the publication is without flaw of any kind or is This work is licensed under a Creative Commons Attribution 4.0 International wholly appropriate for your particular purposes and therefore disclaims all liability licence. You are free to re-use the work under that licence, on the condition that for any error, loss or other consequence which may arise from you relying on you credit the State of Victoria as author. The licence does not apply to any any information in this publication. images, photographs or branding, including the Victorian Coat of Arms, the Victorian Government logo and the Department of Environment, Land, Water Obtaining this publication does not guarantee that an application will meet the and Planning logo. To view a copy of this licence, visit requirements of Clauses 52.16 or 52.17 of the Victoria Planning Provisions and http://creativecommons.org/licenses/by/34.0/au/deed.en Victorian planning schemes or that a permit to remove native vegetation will be granted. Authorised by the Victorian Government, 8 Nicholson Street, East Melbourne. Notwithstanding anything else contained in this publication, you must ensure that For more information contact the DELWP Customer Service Centre 136 186 you comply with all relevant laws, legislation, awards or orders and that you obtain and comply with all permits, approvals and the like that affect, are applicable or are necessary to undertake any action to remove, lop or destroy or otherwise deal with any native vegetation or that apply to matters within the scope of Clauses 52.16 or 52.17 of the Victoria Planning Provisions and Victorian planning schemes. www.delwp.vic.gov.au

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Appendix 1: Description of native vegetation to be removed

The species-general offset test was applied to your proposal. This test determines if the proposed removal of native vegetation has a proportional impact on any rare or threatened species habitats above the species offset threshold. The threshold is set at 0.005 per cent of the mapped habitat value for a species. When the proportional impact is above the species offset threshold a species offset is required. This test is done for all species mapped at the site. Multiple species offsets will be required if the species offset threshold is exceeded for multiple species. Where a zone requires species offset(s), the species habitat units for each species in that zone is calculated by the following equation in accordance with the Guidelines: Species habitat units = extent x condition x species landscape factor x 2, where the species landscape factor = 0.5 + (habitat importance score/2) The species offset amount(s) required is the sum of all species habitat units per zone Where a zone does not require a species offset, the general habitat units in that zone is calculated by the following equation in accordance with the Guidelines: General habitat units = extent x condition x general landscape factor x 1.5, where the general landscape factor = 0.5 + (strategic biodiversity value score/2) The general offset amount required is the sum of all general habitat units per zone.

Native vegetation to be removed

Information provided by or on behalf of the applicant in a GIS file Information calculated by EnSym

BioEVC Extent Large Partial Condition Polygon SBV HI Zone Type BioEVC conservation without Habitat Offset type tree(s) removal score Extent score score status overlap units

15-A Patch vvp_0125 Endangered 0 no 0.420 0.316 0.316 0.560 0.155 General

13-A Patch vvp_0125 Endangered 0 no 0.390 1.705 1.705 0.639 0.817 General

13-B Patch vvp_0125 Endangered 0 no 0.390 0.188 0.188 0.686 0.093 General

14-A Patch vvp_0132 Endangered 0 no 0.310 0.404 0.404 0.725 0.162 General

14-B Patch vvp_0132 Endangered 0 no 0.310 0.987 0.987 0.449 0.332 General

15-C Patch vvp_0125 Endangered 0 no 0.420 0.109 0.109 0.330 0.046 General

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Appendix 2: Information about impacts to rare or threatened species’ habitats on site

This table lists all rare or threatened species’ habitats mapped at the site.

Species Conservation Species common name Species scientific name Group Habitat impacted % habitat value affected number status

Critically Golden Sun Moth Synemon plana 15021 Dispersed Top ranking map 0.0011 endangered Critically Grassland Earless Dragon Tympanocryptis pinguicolla 12922 Dispersed Habitat importance map 0.0006 endangered

Large-headed Fireweed Senecio macrocarpus 503116 Endangered Dispersed Habitat importance map 0.0005

Large-flower Crane's-bill Geranium sp. 1 505342 Endangered Dispersed Habitat importance map 0.0005

Yellow Watercrown Grass Paspalidium flavidum 507820 Endangered Dispersed Habitat importance map 0.0005

Plump Swamp Wallaby- Amphibromus pithogastrus 503624 Endangered Dispersed Habitat importance map 0.0004 grass

Brackish Plains Buttercup Ranunculus diminutus 504314 Rare Dispersed Habitat importance map 0.0004

Swamp Everlasting Xerochrysum palustre 503763 Vulnerable Dispersed Habitat importance map 0.0003

Plains Yam-daisy Microseris scapigera s.s. 504657 Vulnerable Dispersed Habitat importance map 0.0002

Matted Flax-lily Dianella amoena 505084 Endangered Dispersed Habitat importance map 0.0002

Pale-flower Crane's-bill Geranium sp. 3 505344 Rare Dispersed Habitat importance map 0.0002

Striped Legless Lizard Delma impar 12159 Endangered Dispersed Habitat importance map 0.0002

Tough Scurf-pea Cullen tenax 502776 Endangered Dispersed Habitat importance map 0.0002

Lachnagrostis punicea subsp. Purple Blown-grass 504206 Rare Dispersed Habitat importance map 0.0002 punicea

Western Golden-tip Goodia medicaginea 501518 Rare Dispersed Habitat importance map 0.0002

Critically Golden Sun Moth Synemon plana 15021 Dispersed Habitat importance map 0.0002 endangered

Swamp Fireweed Senecio psilocarpus 504659 Vulnerable Dispersed Habitat importance map 0.0002

Dianella sp. aff. longifolia Arching Flax-lily 505560 Vulnerable Dispersed Habitat importance map 0.0002 (Benambra)

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Pale Swamp Everlasting Coronidium gunnianum 504655 Vulnerable Dispersed Habitat importance map 0.0002

Grevillea rosmarinifolia subsp. Rosemary Grevillea 504066 Rare Dispersed Habitat importance map 0.0002 rosmarinifolia

Lewin's Rail Lewinia pectoralis pectoralis 10045 Vulnerable Dispersed Habitat importance map 0.0001

Small Milkwort Comesperma polygaloides 500798 Vulnerable Dispersed Habitat importance map 0.0001

Yarra Gum Eucalyptus yarraensis 501326 Rare Dispersed Habitat importance map 0.0001

Clover Glycine Glycine latrobeana 501456 Vulnerable Dispersed Habitat importance map 0.0001

Growling Grass Frog Litoria raniformis 13207 Endangered Dispersed Habitat importance map 0.0001

Small Scurf-pea Cullen parvum 502773 Endangered Dispersed Habitat importance map 0.0001

Black Falcon Falco subniger 10238 Vulnerable Dispersed Habitat importance map 0.0000

Geranium solanderi var. solanderi Austral Crane's-bill 505337 Vulnerable Dispersed Habitat importance map 0.0000 s.s.

Speckled Warbler Chthonicola sagittatus 10504 Vulnerable Dispersed Habitat importance map 0.0000

Australasian Shoveler Anas rhynchotis 10212 Vulnerable Dispersed Habitat importance map 0.0000

Hardhead Aythya australis 10215 Vulnerable Dispersed Habitat importance map 0.0000

Bearded Dragon Pogona barbata 12177 Vulnerable Dispersed Habitat importance map 0.0000

Habitat group  Highly localised habitat means there is 2000 hectares or less mapped habitat for the species  Dispersed habitat means there is more than 2000 hectares of mapped habitat for the species

Habitat impacted  Habitat importance maps are the maps defined in the Guidelines that include all the mapped habitat for a rare or threatened species  Top ranking maps are the maps defined in the Guidelines that depict the important areas of a dispersed species habitat, developed from the highest habitat importance scores in dispersed species habitat maps and selected VBA records  Selected VBA record is an area in Victoria that represents a large population, roosting or breeding site etc.

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Appendix 3 – Images of mapped native vegetation 2. Strategic biodiversity values map

3. Aerial photograph showing mapped native vegetation

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4. Map of the property in context

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Appendix 4 Information Supporting Proposed Offset

Attached:

• Draft Offset Management Plan

Below:

• Offset Assessment Guide

• Chepstowe condition report

© Biosis 2019 – Leaders in Ecology and Heritage Consulting 58 Offsets Assessment Guide For use in determining offsets under the Environment Protection and Biodiversity Conservation Act 1999 2 October 2012 Key to Cell Colours This guide relies on Macros being enabled in your browser. User input required

Matter of National Environmental Significance Drop-down list Name Golden Sun Moth

EPBC Act status Critically Endangered Calculated output Annual probability of extinction 6.8% Based on IUCN category definitions Not applicable to attribute

Impact calculator Offset calculator Minimum Attribute Attribute Total % of (90%) direct Information Time horizon Start area and Future area and Future area and Confidence in Adjusted Net present value Information Protected matter attributes relevant to Description Quantum of impact Units Protected matter attributes relevant quantum of Units Proposed offset Raw gain impact offset Cost ($ total) source (years) quality quality without offset quality with offset result (%) gain (adjusted hectares) source case? to case? impact offset requirement met? Ecological communities Ecological Communities

Risk of loss Risk of loss Area (%) without (%) with Risk-related offset offset Start area time horizon (hectares) Future area Future area (max. 20 years) without offset with offset Quality 0.0 0.0 Area of community No Area of community No (adjusted (adjusted hectares) hectares)

Time until Future quality Future quality Total quantum of Start quality 0.00 ecological without offset with offset impact (scale of 0-10) benefit (scale of 0-10) (scale of 0-10)

Threatened species habitat Threatened species habitat

Risk of loss Risk of loss Small area in Area 2.23 Hectares (%) without 10% (%) with 1% paddock with Time over offset offset which loss is Start area scattered Spear 20 8.1 0.73 90% 0.66 0.18 grass Austrostipa averted (max. (hectares) Future area Future area Biosis (2017) Wallan Third party offset without offset with offset spp. and Wallaby Quality Adjusted 20 years) 7.3 8.0 Area of habitat Yes 3 Scale 0-10 South Biodiversity Area of habitat Yes 0.67 provided by Chepstowe 0.67 100.45% Yes grass Rytidosperma hectares (adjusted (adjusted Assessment Report sheep farm spp. GSM presence hectares) hectares) confirm using standard targeted Time until Future quality Future quality Total quantum of Adjusted Start quality surveys. 0.67 ecological 10 5 without offset 4 with offset 6 2.00 75% 1.50 0.78 impact hectares (scale of 0-10) benefit (scale of 0-10) (scale of 0-10)

Minimum Impactcalculator

Attribute calculator Offset Attribute Total % of (90%) direct Information Time horizon Future value without Future value with Confidence in Adjusted Information Protected matter attributes relevant to Description Quantum of impact Units Protected matter attributes relevant quantum of Units Proposed offset Start value Raw gain Net present value impact offset Cost ($ total) source (years) offset offset result (%) gain source case? to case? impact offset requirement met? Number of features Number of features e.g. Nest hollows, habitat trees e.g. Nest hollows, habitat trees No No

Condition of habitat Condition of habitat Change in habitat condition, but no Change in habitat condition, but no change in extent No change in extent No

Threatened species Threatened species

Birth rate Birth rate e.g. Change in nest success e.g. Change in nest success No No

Mortality rate Mortality rate e.g Change in number of road kills e.g Change in number of road kills per year No per year No

Number of individuals Number of individuals e.g. Individual plants/animals e.g. Individual plants/animals No No

Summary

Cost ($) Net present Protected matter attributes Quantum of impact % of impact offset Direct offset adequate? Other compensatory value of Direct offset ($) Total ($) offset measures ($)

Birth rate 0 $0.00 $0.00

Mortality rate 0 $0.00 $0.00

Number of individuals 0 $0.00 $0.00 Summary

Number of features 0 $0.00 $0.00

Condition of habitat 0 $0.00 $0.00

Area of habitat 0.669 0.67 100.45% Yes $0.00 N/A $0.00

Area of community 0 $0.00 $0.00

$0.00 $0.00 $0.00 31 January 2019

Celina Mott Crystal Group 3/22 Church St Whittlesea VIC 3757

Dear Celina,

Offset Site Report: Chepstowe proposed GSM offset area Project no. 26184

Introduction

As you are aware, Biosis Pty Ltd was engaged by Crystal Creek Properties to determine the offset strategy for the proposed clearing of 2.23 hectares of confirmed Golden Sun Moth Synemon plana (GSM) habitat at your farming property, Inverlochy, 175 Northern Highway, Wallan. This proposed removal is being assessed under referral 2018/8148 under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).

It was proposed that the required offsets be obtained from Abzeco Pty Ltd on the sheep station called Chepstowe, located at 346 Carngham Streatham Road, Chepstow in western Victoria.

We provided the first version of this report (dated 5 August 2018) based on a site visit to the property undertaken in March 2018 and combined with the information provided to us by Abzeco.

During the site visit, a due diligence assessment was undertaken to quantify the location and condition of potential habitat for GSM.

Since that time, targeted surveys for GSM were undertaken on Chepstowe in December 2018.

This condition report has been updated based on the survey data collected in December 2018 and in consultation with the Department for the Environment and Energy (January 2019).

Methods

The property is approximately 32 km west of Ballarat and 130 km west of the Melbourne central business district (Figure 1). It is also within the Victorian Volcanic Plain bioregion. The area surveyed is within a sheep station located at 346 Carngham Streatham Road, Chepstowe, Victoria. The land parcel within the property nominated for the GSM offset is Lot PC375103 (SPI) identified as Chepstowe-Snake Valley Road within the Parish of Chepstowe and Pyrenees Shire.

Due diligence inspection The area was surveyed by Stephen Mueck on 26 March 2018 (accredited DELWP vegetation quality assessor HH173 – current until 19/4/2020).

The habitat characteristics of GSM habitat described in DEWHA (2009b) were used to confirm the presence of GSM habitat. Abzeco (2018) provided at the end of this letter was used to confirm the presence of the species.

© Biosis 2019 - Leaders in Ecology and Heritage Consulting 1 To provide context to the vegetation assessment, the potential for presence of Natural Temperate Grassland of the Victorian Volcanic Plain (NTGVVP) was assessed within the survey area. The assessment was done according to DSEWPaC (2011b) to identify if 1). If the community is present and 2). If the community is of sufficient quality for protection under the EPBC Act (referred to as “national listing”) (DSEWPaC 2011b). The inspection also assessed the presence of native vegetation as defined under Clause 52.17 Native Vegetation of the Pyrenees Shire planning scheme using the methods stipulated in the Guidelines for the Removal, Destruction or Lopping of Native Vegetation (DELWP 2017).

To provide vegetation quality scores, data was collected to complete a Vegetation Quality Assessment (Habitat hectare method, DSE 2004). Notes were also taken as to the presence and extent of pest plants and animals, including the location and extent of target weeds such as woody weeds.

Targeted surveys for GSM Targeted surveys for GSM were undertaken using the field methods stipulated in the Commonwealth EPBC Act Policy Statement 3.12 (DEWHA 2009). The surveys were undertaken during the 2018-19 flight season, beginning 19 November 2018 and concluding after four surveys had been completed (Table 1). The start of the flight season at Chepstowe was confirmed by the landholder who provided results of checks of existing GSM offset sites on the property.

DEWHA (2009) stipulates that surveys are to be undertaken during specific weather conditions suitable for male GSM flight: temperatures above 20oC by 10:00 am, in the warmest part of the day from 10:00 am to approx. 2:00 pm with relatively clear, calm conditions. Weather conditions on site (temperature, humidity and wind speed) were obtained from the nearest Bureau of Meteorology weather station (first survey) and measured using a Kestrel Weather Meter (Model 4000) for subsequent surveys. Weather data recorded for each survey is provided in Table 1.

The suitability of conditions for flight were also confirmed using the existing offset sites on the property as a reference site (Table 1).

The survey methods require an ecologist to traverse the offset area on foot while marking the GPS location of every GSM seen, as far as practicable. The surveys were undertaken by walking in pre-defined straight lines (transects) across the proposed offset area with each line no more than 50 metres apart. Survey tracks of each ecologist were recorded separately with a GPS device to confirm coverage of the proposed offset area (Figure 2).

Permits Biosis undertakes flora and fauna assessments under the following permits and approvals:

• Research Permit/Management Authorisation and Permit to Take Protected Flora & Protected Fish issued by DELWP under the Wildlife Act 1975, Flora and Fauna Guarantee Act 1988 and National Parks Act 1975 (Permit number 10007569). • Approvals 07.15 and 14.12 from the Wildlife and Small Institutions Animal Ethics Committee. All GSM records will be submitted to DELWP for incorporation into the Victorian Biodiversity Atlas, in accordance with permit conditions.

Qualifications The difficulty in determining GSM distribution within a given area is well documented (Gibson and New 2007). It is well understood that emergence patterns in this species can vary markedly within and between seasons (Gibson and New 2007). To account for difficulties associated with GSM emergence patterns, surveys were

© Biosis 2019 - Leaders in Ecology and Heritage Consulting 2 undertaken in accordance with the prescribed methods resulting in four site visits throughout the season. It must be noted therefore that the surveys offer a snapshot of the distribution of the species over the flight season and cannot be considered a complete inventory of every individual that occupied the site during the current season.

On-site mapping and data recording was conducted using GPS-enabled tablet devices and ArcGIS Collector App with aerial photo interpretation and Garmin hand-held GPS devices. The accuracy of this mapping is therefore subject to the accuracy of the GPS receiver of the tablet (generally ± 3 metres) and dependent on the limitations of aerial photo rectification and registration.

Results

Due diligence inspection - GSM The results of the due diligence inspection confirmed the presence of GSM habitat in the proposed offset area, with scattered occurrences of Wallaby Grass Rytidosperma spp. identified throughout. The habitat was observed to have a high cover of weeds especially annual grasses and Brown-top Bent Agrostis capillaris, limiting the accuracy of estimations of the cover of food plants. As such, estimates were conservative, with an estimate of 10% cover provided. Photos of the proposed offset area are at the end of this report (Appendix 2).

The condition of the GSM habitat identified during the due diligence inspection was assessed against the habitat characteristics provided in DEWHA (2009b) (Table 1).

Table 1 GSM habitat condition results, Chepstowe Property

Habitat characteristic Assessment

Size of patch Patch size is large (greater than 10 hectares)

Cover of food plants Cover of food plants appeared minimal at time of assessment (less than 20 % cover) (Rytidosperma spp., Austrostipa spp., Nassella neessiana)

Distance to nearest source Contiguous with confirmed population/existing GSM offset site population

Amount of shading Nil

Aspect Flat

Amount of bare ground Cover of bare ground minimal (less than 20%)

Presence of rocky areas Rocks still present although removal of surface rock may have occurred

Soil characteristics Basalt derived

Land use history Long history of sheep grazing, current grazing pressure high

The report provided by Abzeco (2018) confirms the presence of GSM within the broader patch of vegetation, with records provided from the 2016/17 and 2017/18 survey season (Attachment 1).

© Biosis 2019 - Leaders in Ecology and Heritage Consulting 3 Due diligence inspection - NTGVVP At the time of survey, the proposed offset area had insufficient cover of native perennial tussock grasses and insufficient species richness to meet the definition of NTGVVP. The assessment of the vegetation against the criteria for national listing for NTGVVP is provided in Table 2 for context.

Table 2 NTGVVP assessment results (DSEWPaC 2011b)

Condition Assessment

Does the patch occur within YES. (criteria met) the Victorian Volcanic Plain?

Is the site dominated by NO. (criteria not met) native vegetation? There is less than 50% cover of native vegetation and the patch is dominated by introduced species.

Not the national ecological community – modified significantly by exotic pasture, plantings Result: or weeds.

Due diligence inspection – Native vegetation patches and VQA The time of survey (May) was not an ideal time for vegetation survey as the high cover of weeds limited the accuracy of any cover estimates and sheep grazing had left insufficient plant material to positively identify many species. It was decided that the conditions were unsuitable to make an accurate assessment of the presence of native vegetation as defined under DELWP (2017) such that no patches were mapped.

The Vegetation Quality Assessment for Plains Grassland (EVC 132) resulted in a site condition score of 16.32 out of 75 indicating poor vegetation quality (Table 3). The overall Habitat score of 27.32 is a low score for Plains Grassland reflecting a low site condition score a moderate landscape score (11 out of 25).

Table 3 Vegetation condition results, Chepstowe Property

Site ID 1 Habitat Zone ID A EVC Name - # Plains Grassland (EVC 132-61) Max Score Score Large Old Trees 10 Not Applicable Canopy Cover 5 Not Applicable Lack of Weeds 15 2

Understorey 25 5 Recruitment 10 3 Site

Condition Organic Matter 5 2 Logs 5 Not Applicable Total Site Score (standardised) 16.32 Patch Size 10 8

Neighbourhood 10 2

Value Distance to Core 5 1

Landscape Total Landscape Score 11 HABITAT SCORE 100 27.32 Habitat points = #/100 1 0.27 Habitat Zone area (ha) 8.1 Habitat hectares (Hha) 2.187

© Biosis 2019 - Leaders in Ecology and Heritage Consulting 4 Golden Sun Moth targeted surveys All GSM surveys were undertaken on days where weather conditions were suitable for flight as stipulated in DEWHA (2009), see Table 4 below.

Table 4 Golden Sun Moth survey conditions

Date Time Temp. (°C) Cloud cover Wind Wind speed Humidity (%) Reference site Start (End) Start (End) (%) direction (km/hr) Start (End) Start (End) Start (End) Start (End)

01/11/18 12:13 PM (4:34 PM) 24.6 (27.0) 2 (50) NNE (NNE) 26.0 (28.0) 27.0 (27.0) Existing GSM offset

01/12/18 9:48 AM (4:15 PM) 22.2 (30.0) 15 (75) N (N) 13.7 (19.1) 34.0 (34.3) Existing GSM offset

06/12/18 9:58 AM (4:00 PM) 20.0 (27.0) 35 (5) SE (SE) 11.0 (18.0) 31.0 (26.0) Existing GSM offset

12/12/18 9:49 AM (3:17 PM) 21.6 (33.6) 0 (0) SW (SW) 4.5 (4.5) 32.4 (22.1) Existing GSM offset

A total of 619 male GSM were recorded flying within the proposed offset areas from three surveys (Table 5). Emergence patterns were consistent with expectations surprisingly consistent with GSM numbers quite similar across the three surveys. (Table 5). GSM were observed flying in throughout the paddock at the start of the first survey, this paddock being used as the on-site reference site for survey of other paddocks on the property. However, time limitations prevented transect data from being recorded for this paddock. Given that the numbers were consistent across the other three surveys, as per guidance provided from DoEE, the lowest score is substituted for the first survey to calculate density for the purposes of assessing quality. See quality scoring section below.

Table 5 Golden Sun Moth survey results

Survey data GSM observed Number of GSM observed

19/11/2018 Yes Large numbers, flying males easily observed from fence

1/12/2018 Yes 196

6/12/2018 Yes 262

11/12/2018 Yes 161

Total: 619

Figure 2 shows the proposed offset area and GSM records.

© Biosis 2019 - Leaders in Ecology and Heritage Consulting 5 Quality scoring of GSM habitat The EPBC Act Offsets Assessment Guide requires GSM habitat to be given a score out of 10. After several months of consultation with DoEE, the GSM habitat was assigned a quality score according to the scoring system provided below (Table 6).

Table 6 GSM habitat quality scoring system

Parameter Scoring system

Using the scoring system above, the offset area and impact area quality scores have been recalculated as follows.

Table 7 GSM habitat quality scoring – Chepstowe offset area

Parameter Score Justification

Site context The proposed offset area is part of a paddock that already supports GSM (max. 3 points) offsets. The total area of the paddock is 60 hectares, noting that a fence has been installed at the edge of the other offset sites making it look like these 2/3 are separate paddocks. The paddock is approximately square, which is appropriate for reducing edge effects. However, the paddock is essentially flat with a very slight (less than 1 degree) south west slope.

Site condition The site is dominated by dominated by poor quality vegetation (VQA site (max. 3 points) condition score 16.32 / 75) but does contain some Wallaby Grass Rytidosperma spp. with cover less than 20% at the time of the vegetation 1/3 assessment. The cover of weeds was high including both annual and

perennial weeds. Note that the offset area and the property as a whole does not have Chilean Needle Grass Nassella neessiana such that none of the weeds present are known food plants for GSM.

Species A total of 619 GSM were recorded for the paddock in which the offset area stocking rate will be located from three surveys. The total area surveyed was 50.39 hectare. (max. 4 points) 2/4 The survey with the lowest score was 161 moths, which added to the total records from the three surveys, makes an estimate of 780 moths over four surveys. This estimate gives a stocking rate of 15.5 moths per hectare. This places the survey area within the 6-20 moths per hectare category.

Quality score A score out 5 out of 10 indicates that the offset area is of moderate quality 5/10 with potential for improvement.

Table 8 GSM habitat quality scoring – Inverlochy impact area

Parameter Score Justification

Site context The impact area is 2.23 hectares in total size and isolated from all other (max. 3 points) nearby GSM populations by more than 1 kilometre. This places the site in the 1/3 1/3 category.

Species A total of 3 GSM were recorded from the impact site. The total area of habitat 1/4 stocking rate is 2.23 hectares. This gives a stocking rate of 1.35 moths per hectare. This

(max. 4 points) places the survey area within the 1/4 category.

Quality score A score of 3 out of 10 indicates that the impact area is of poor quality and 3/10 unlikely to be an important population of this species.

Discussion

The quality calculations above have determined that the offset area is of a higher quality than the impact area (Table 7, Table 8). This is due to the offset area being a substantially larger size and supports a higher density of GSM. The quality score for the offset area is considered a conservative assessment because the offset area was assessed in sub-optimal conditions of late in the growing season and heavy grazing. If allowed to recover and is assessed in better conditions, the site condition may in fact be better than it was at the time of the assessment.

The offset area will be able to provide a gain in habitat quality through land management that favours native grasses. For herbaceous weeds and especially annual grasses, stocking rates or duration of grazing are to be amended to avoid over-grazing and reduce annual weed reproduction. To lower the cover of species such as Bromes Bromus spp., Quaking-grass Briza spp. and Rye-grass Lolium spp. significant effort will be required . Other forms of weed control will also be necessary such as spot spraying Spear Thistle Cirsium vulgare as required.

For perennial species, such as Brown-top Bent Agrostis capillaris and Creeping Bent-grass Agrostis stolonifera, these are considered to be high threat weeds and need to be actively controlled. This will most likely need to be done with a mix of planned burns followed by careful follow up weed spraying of germinants. Other perennial weed species such as Toowoomba Canary-grass Phalaris aquatica and Cocksfoot Dactylis glomerata are present at lower levels but will still need to be actively targeted with herbicide control.

For woody weeds, the property supports small scattered populations of woody weeds such as Gorse Ulex europaeus, Sweet Briar Rosa rubiginosa and Hawthorn Crataegus monogyna but otherwise woody weed species do not appear to be prevalent in the surrounding landscape. The local elimination of these species is therefore a plausible management outcome.

GSM have been recorded from the across the property over a number of years, mostly recently being December 2018 and dating back to the 2012/2013 flight season. As a result, the proposed offset area is confirmed GSM habitat.

Conclusion

The offset assessment guide calculations require an offset area of 8.1 hectares based on the quality calculations listed above and other inputs.

The location of the proposed offset can be seen in Figure 2. Flying GSM were also observed in the adjoining existing offset areas by field staff as they undertook the 2018 surveys and recorded throughout the property. This provides evidence that the property supports a large, connected population of GSM. Given this evidence, the proposed offset is considered high quality GSM habitat and suitable as a biodiversity offset. Management of biomass and weed cover at the site will be needed ensure that habitat quality for GSM improves.

Please contact me on 8686 4847 if you would like to discuss further.

Yours sincerely,

Shana Nerenberg. Consultant Botanist

References

Abzeco 2018. Golden Sun Moth Records and Habitat Mapping 346 Carngham-Streatham Road, Chepstowe. Report for Neville Oddie. Authors Scott-Walker, G. and Francis, R. Abzeco, Eltham. Report 12104-02 Version 1.0.

DEPI 2014. Advisory list of rare or threatened plants in Victoria. Department of Sustainability and Environment, Melbourne.

Threatened Species Scientific Committee (TSSC) 2008. Commonwealth Listing Advice on Natural Temperate Grassland of the Victorian Volcanic Plain. Department of the Environment, Water, Heritage and the Arts.

Mena Park ! Mildura

B e a u ! fo Swan Hill r t ! Kerang - ! C ! Echuca ! Wodonga a ! r ! Wangaratta n ! St g ! ! h Arnaud Bendigo a ! m ! Stawell ! Mansfield R ! Ararat d ! Ballarat ! Cann River ! ! Hamilton Melbourne ! ! Lakes ! ! Entrance Geelong ! ! ! Traralgon ! ! Warrnambool

eatham Rd - Str m ha g ! Chepstowe rn a C

PYRENEES M or SHIRE tch up - Mo un t E mu Rd

Mortchup !

Legend

Study area GOLDEN GOLDEN PLAINS Acknowledgement: VicMap Data ©State of Victoria PLAINS SHIRE SHIRE Figure 1 Location of the Carngham Streatham Road offset site, Chepstowe, Victoria 0 500 1,000 1,500 2,000

Matter: 25271, ± Biosis Pty Ltd Metres Albury, Ballarat, Melbourne, Date: 17 April 2018, Newcastle, Sydney, Wangaratta & Wollongong Checked by: SGM, Drawn by: SSK, Last edited by: skumar Scale 1:50,000 @ A4, GDA 1994 MGA Zone 55 Location:P:\25200s\25271\Mapping\25271_F3_Locality_Offset !( !( !( !( !( !( !( !( !

!( !( !( !( !( !( !(

!Chepstowe Carngham! Mount Emu ! Poverty Point !

!( Rileys Rd

!Mortchup ! Snake Valley

Chinaman Flat !( ! !( !( Legend !( !( !( !( !( Abzeco data and results Existing offsets !( !( !( GSM record locations (2016 - 17) !( Biosis survey results !( !( !( !( !( 2018 survey area !( !( !( !( Dec 2018 survey results !( !( !( !( !( !( !( !( !( !( 1 moth !( !( !( !( !( 2 - 4 moths !( !( !( !( !( !( 5 - 8 moths !( Proposed offset GSM offset area (8.1 ha)

PYRENEES !( SHIRE

Figure 8 Location of proposed offset site, Chepstowe, Victoria.

Chepstowe - Pittong Rd

0 30 60 90 120 150

Metres Scale: 1:3,446 @ A3 Coordinate System: GDA 1994 MGA Zone 54 ± Biosis Pty Ltd Albury, Ballarat, Melbourne, Newcastle, Sydney, Wangaratta & Wollongong

Appendix 1

Plant species recorded from 346 Carngham Streatham Road, Chepstowe. Includes areas of native vegetation as well as GSM habitat areas.

Notes to tables:

EPBC Act: DEPI 2014a: CR - Critically Endangered e - endangered EN - Endangered v - vulnerable VU - Vulnerable r - rare k - poorly known PMST – Protected Matters Search Tool

FFG Act: Noxious weed status: L - listed as threatened under FFG Act SP - State prohibited species P - protected under the FFG Act (public land only) RP - Regionally prohibited species RC - Regionally controlled species RR - Regionally restricted species

# - Native species outside natural range

Status Scientific Name Common Name Indigenous species Acacia melanoxylon Blackwood Acacia paradoxa Hedge Wattle Acaena echinata Sheep's Burr Acaena novae-zelandiae Bidgee-widgee Allocasuarina verticillata Drooping Sheoak Anthosachne scabra s.s. Common Wheat-grass Arthropodium minus Small Vanilla-lily Arthropodium spp. Vanilla Lily Asperula conferta Common Woodruff P Asplenium flabellifolium Necklace Fern Austrostipa mollis Supple Spear-grass Austrostipa spp. Spear Grass Bolboschoenus spp. Club Sedge P Brunonia australis Blue Pincushion Burchardia umbellata Milkmaids Bursaria spinosa Sweet Bursaria P Calocephalus citreus Lemon Beauty-heads Carex breviculmis Common Grass-sedge Centella cordifolia Centella P Cheilanthes austrotenuifolia Green Rock-fern P Chrysocephalum semipapposum Clustered Everlasting P Chrysocephalum sp. 1 Plains Everlasting Convolvulus angustissimus subsp. angustissimus Blushing Bindweed Cynoglossum suaveolens Sweet Hound's-tongue Deyeuxia quadriseta Reed Bent-grass Deyeuxia quadriseta Slender Reed Bent-grass Dichondra repens Kidney-weed Drosera aberrans Scented Sundew Eleocharis acuta Common Spike-sedge Eleocharis sphacelata Tall Spike-sedge Epilobium billardierianum Variable Willow-herb Eryngium ovinum Blue Devil

Status Scientific Name Common Name Eucalyptus camaldulensis River Red-gum Eucalyptus ovata Swamp Gum P Euchiton japonicus s.s. Creeping Cudweed Geranium retrorsum s.s. Grassland Crane's-bill Gonocarpus tetragynus Common Raspwort Goodenia pinnatifida Cut-leaf Goodenia P Helichrysum luteoalbum Jersey Cudweed Hemarthria uncinata var. uncinata Mat Grass Hydrocotyle laxiflora Stinking Pennywort Hypericum gramineum spp. agg. Small St John's Wort Juncus spp. Rush Juncus subsecundus Finger Rush Lachnagrostis filiformis s.s. Common Blown-grass P Leptorhynchos squamatus Scaly Buttons Lobelia pratioides Poison Lobelia Lomandra filiformis Wattle Mat-rush Lomandra nana Dwarf Mat-rush Melicytus dentatus s.s. Tree Violet Microlaena stipoides var. stipoides Weeping Grass Montia australasica White Purslane Oxalis perennans Grassland Wood-sorrel Pelargonium spp. Stork's Bill Phragmites australis Common Reed Pimelea curviflora s.s. Curved Rice-flower Pimelea humilis Common Rice-flower Plantago gaudichaudii Narrow Plantain P Pleurosorus rutifolius s.s. Blanket Fern Poa labillardierei Common Tussock-grass Poa morrisii Soft Tussock-grass Poa sieberiana Grey Tussock-grass Rubus parvifolius Small-leaf Bramble Rumex brownii Slender Dock Rumex dumosus Wiry Dock Rytidosperma spp. Wallaby Grass Schoenus apogon Common Bog-sedge P Senecio glomeratus Annual Fireweed P Senecio quadridentatus Cotton Fireweed P Senecio spp. Groundsel P Solenogyne dominii Smooth Solenogyne P Thelymitra spp. Sun Orchid Themeda triandra Kangaroo Grass Tricoryne elatior Yellow Rush-lily Triglochin procera Water Ribbons Velleia paradoxa Spur Velleia Veronica gracilis Slender Speedwell Wahlenbergia communis s.s. Tufted Bluebell Wahlenbergia luteola Bronze Bluebell Wahlenbergia spp. Bluebell Introduced species Acetosella vulgaris Sheep Sorrel Agrostis capillaris Brown-top Bent Aira spp. Hair Grass Anthoxanthum odoratum Sweet Vernal-grass Arctotheca calendula Cape Weed Briza minor Lesser Quaking-grass Bromus hordeaceus subsp. hordeaceus Soft Brome Centaurium erythraea Common Centaury RR Cirsium vulgare Spear Thistle Cotula coronopifolia Water Buttons RR Crataegus monogyna Hawthorn

Status Scientific Name Common Name Cynosurus echinatus Rough Dog's-tail Disa bracteata South African Orchid Erodium botrys Big Heron's-bill Erodium cicutarium Common Heron's-bill Helminthotheca echioides Ox-tongue Holcus lanatus Yorkshire Fog Hypochaeris radicata Flatweed RC Juncus acutus subsp. acutus Spiny Rush Leontodon taraxacoides subsp. taraxacoides Hairy Hawkbit Lolium rigidum Wimmera Rye-grass Malus spp. Apple RC Marrubium vulgare Horehound Phalaris aquatica Toowoomba Canary-grass Plantago coronopus Buck's-horn Plantain Plantago lanceolata Ribwort Quercus spp. Oak Romulea rosea Onion Grass RC Rosa rubiginosa Sweet Briar RR Silybum marianum Variegated Thistle Solanum nigrum s.s. Black Nightshade Sonchus asper s.s. Rough Sow-thistle Sonchus oleraceus Common Sow-thistle Stellaria media Chickweed Trifolium subterraneum Subterranean Clover RC Ulex europaeus Gorse

Appendix 2

Photos recorded from the offset area within the Chepstowe property

Photo 1 Grassland dominated by introduced annual grasses within proposed offset area.

Photo 2 Grassland dominated by introduced annual grasses within proposed offset site.

Photo 3 Overview of the property looking south from the northern boundary.

Attachment: ABZECO 2018 GSM report

Prepared for Neville J. Oddie Report 12104-02, Version 1.0

June 2018

Abzeco Pty Ltd Suite 1/4 Brisbane St, Eltham Vic. 3095 T:(03) 9431-5444 F:(03) 9431-5443 ABN 66 967 834 756 www.abzeco.com.au Abzeco 12104 - Golden Sun Moth Records and Habitat Distribution, 346 Carngham-Streatham Road, Chepstowe – June 2018

Acknowledgements Surveys and incidental records for Golden Sun Moth have been taken by Abzeco Staff each flight season since 2010. Staff that have contributed records include Richard Francis, Bradley Jenner, Geordie Scott-Walker, Daniel Nugent, Kathy Himbeck, Josh McCaig, Graham Jury, David De Angelis, George Collins, Johnathon Sordello and Daniel Young. Records provided by Australian Ecosystems have also been included. Project maps with survey results and incidental GSM records were produced by Kathy Himbeck. Cover photos: Photos taken by Abzeco Staff during vegetation assessments on the subject land. Top - GSM habitat assessment November 2013; Bottom left - Clumping Golden Moths Diuris gregaria; Second from left - Little Whip Snake Suta flagellum; Second from right - Clover Glycine Glycine latrobeana; Right - Golden Sun Moth Synemon plana (GSM flight season 2012-13). Version Control Version Responsibility Name Date Signature

1.0 Primary author Geordie Scott-Walker 22/5/2017

1.0 Secondary author Richard Francis 13/06/2018

1.0 Reviewer Matt Hatton 14/06/2018

Page 2 of 16 Abzeco 12104 - Golden Sun Moth Records and Habitat Distribution, 346 Carngham-Streatham Road, Chepstowe – June 2018

Table of Contents 1 Introduction ...... 4 2 GSM Survey and Habitat Assessment ...... 5 2.1 GSM Survey methods ...... 5 2.2 Habitat Assessment ...... 5 2.3 Survey limitations ...... 6 Figure 1. All records for GSM from the property and extent of suitable habitat, 346 Carngham- Streatham Road, Chepstowe ...... 7 Figure 2. Location of survey compartments across 40 ha GSM offset area, 346 Carngham- Streatham Road, Chepstowe ...... 8 Figure 3. GSM Records Summary, Location of Property Management Units and GSM Habitat Extent, 346 Carngham-Streatham Road, Chepstowe ...... 9 3 Results ...... 10 3.1 Vegetation Description ...... 10 3.2 GSM Survey results ...... 11 3.2.1 Golden Sun Moth Records Flight Season 2010-2011...... 11 3.2.1 Golden Sun Moth Records Flight Season 2011-2012...... 11 3.2.1 Golden Sun Moth Flight Season 2012-2013 ...... 11 Table 1. Results of visual searches undertaken during the 2012-2013 Golden Sun Moth flight season at the study site, 346 Streatham-Carngham Rd, Chepstowe...... 11 3.2.2 Golden Sun Moth Flight Season 2015-2016 ...... 12 Table 2. Results of visual searches undertaken during the 2015-2016 Golden Sun Moth flight season at the study site, 346 Streatham-Carngham Rd, Chepstowe...... 12 3.2.3 Golden Sun Moth Flight Season 2016-2017 ...... 13 Table 3. Results of visual searches undertaken during the 2016-2017 Golden Sun Moth flight season at the study site, 346 Streatham-Carngham Rd, Chepstowe...... 13 3.2.4 Golden Sun Moth Flight Season 2017-2018 ...... 14 Table 4. Results of visual searches undertaken during the 2017-2018 Golden Sun Moth flight season at the study site, 346 Streatham-Carngham Rd, Chepstowe...... 14 4 Discussion ...... 15 5 References ...... 16

Page 3 of 16 Abzeco 12104 - Golden Sun Moth Records and Habitat Distribution, 346 Carngham-Streatham Road, Chepstowe – June 2018

1 Introduction The property is a large privately owned sheep station at 346 Streatham-Carngham Road, Chepstowe, approximately 150km west of Melbourne, Victoria (Figure 1). The municipal authority is Pyrenees Shire and the bioregion is the Victorian Volcanic Plain. Targeted Golden Sun Moth Synemon plana (GSM) surveys have been undertaken annually within the property since the 2012/13 flight season, along with numerous incidental records taken during land management activities such as seed harvesting within the flight season. Other consultancy firms (e.g. Australian Ecosystems) have also recorded GSM during vegetation assessment on parts of the land. Over the last 8 years Abzeco staff have come to consider GSM as common and widespread on the subject land, with frequent observations in both the ungrazed higher quality grassland areas and across the extensive areas of grazed native pastures where we regularly harvest Wallaby Grass seed. In June 2018 Abzeco Pty Ltd was commissioned by Neville J Oddie to document Golden Sun Moth Synemon plana (GSM) records collected both during targeted surveys and as incidental records on land at 346 Carngham-Streatham Road, Chepstowe. Based on the vegetation composition, structure and location of GSM records a Habitat Distribution Map has also been produced. This information is intended to, in part, inform the suitability of the site to be used as an offset. The property is known to support a range of rare plant and animal species including GSM, Stripped Legless Lizard Delma impar, Clover Glycine, Fat Tailed Dunnart Sminthopsis crassicaudata, Hoary Sunray Leucochrysum albicans subsp. tricolor and Golden Moth orchids Diuris spp. along with a diverse assemblage of flora and fauna species characteristic of Plains Grassland. There is an existing 40 ha GSM offset area in the south-east portion of the land, currently managed by Abzeco to the specifications of the endorsed CMP to satisfy offset requirements for GSM under the Commonwealth Environment Protection and Biodiversity Conservation Act 1996 (EPBC Act). The offset was set up to ensure losses incurred at an approved development site in Wollert, Victoria, were appropriately compensated appropriately compensated via the sustainable management of land for the long-term maintenance of GSM and associated native grassland habitat on private land at Chepstowe, Victoria. Furthermore, 0.76 ha of the site is secured in-part, to fulfil obligations in accordance with Condition 14 of the City of Whittlesea Planning Permit No. 712628 as a Net Gain Offset under the requirements of the Victorian Native Vegetation Management Framework (DNRE 2002). The existing GSM offset is secured in perpetuity via a section 173 agreement with Pyrenees Shire Council, until such time as it is replaced by a Trust for Nature Conservation Covenant prior to completion of the offset management period, in accordance with requirements of the CMP. A number of state offsets are also registered on the land and actively managed by the Abzeco team and the landowner. These areas are located in the highest quality grassland remnants on the property and have been managed in the absence of grazing pressure for at least 10 years using fire as the principle management tool for biomass reduction.

Page 4 of 16 Abzeco 12104 - Golden Sun Moth Records and Habitat Distribution, 346 Carngham-Streatham Road, Chepstowe – June 2018

2 GSM Survey and Habitat Assessment

2.1 GSM Survey methods The GSM survey methods applied were in accordance with the guidelines for Golden Sun Moth visual encounter surveys prescribed by DSE (2010) and DEWHA (2009b) guidelines to maximise the chance of detecting individuals. The guidelines followed include:  Surveys were conducted by suitably qualified and experienced Abzeco ecologist.  Surveys were conducted across the entire offset site that supports grassy vegetation irrespective of whether the vegetation was native or exotic.  Surveys commenced when the flight season around the Melbourne region began. Broadly the Golden Sun Moth flight season can vary from between late October to early January (DEWHA 2009b).  Surveys were conducted on suitable days (ideal flying conditions) ensuring they were at least a week apart during the main flight period.  Surveys were undertaken on days when male moths were most likely to be flying and therefore detectable, which were days with the following conditions: o Warm to hot day (generally above 20°C by 10am); o Clear or mostly cloudless sky; o Still or relatively still wind conditions; and, o At least two days since rain.  Given the size of the survey area a transect approach was utilised with one observer on a motorised vehicle or one or more observers on foot.  Temperature, wind speed and humidity data for the study site was obtained using a hand- held weather meter (Kestrel® model k3500) measured at ~50 cm off the ground. In addition to the areas subject to targeted survey as described above, records for GSM have been recorded incidentally over the last 7 years by Abzeco staff while undertaking land management works such as seed harvesting, pest plant and animal control. During the 2017-18 flight season Abzeco staff were instructed to systematically record GSM observations. Seed harvesting was timed to occur on suitable warm sunny days with light winds during the flight season with staff instructed to cease harvesting when moths were observed flying in order to undertake GSM survey over broad areas from vehicles in known habitat to confirm presence. All areas assessed during this period had incidental records from previous flight seasons. For large paddocks assessed in this manner notes were taken on the number of individuals observed and a single point made roughly in the centre of the management unit (fenced paddock).

2.2 Habitat Assessment Across the subject land GSM habitat assessments were undertaken as follows: . Spring survey to record flora species (inclusive of threatened species, notable weed infestations and mapping as appropriate) along with a general site description;

Page 5 of 16 Abzeco 12104 - Golden Sun Moth Records and Habitat Distribution, 346 Carngham-Streatham Road, Chepstowe – June 2018

. Photographic documentation made of vegetation condition and structure; and, . Within existing offset sites, vegetation assessment included 1m2 quadrats at each established monitoring point, documenting the following: - Current vegetation condition; - Presence/absence of weed species and cover; - Presence/absence of host plant species and cover; - Proportion of bare ground; and - Sward height.

2.3 Survey limitations

Short survey duration Field surveys were intended to describe the structure and composition of GSM habitat across the study site. General descriptions of vegetation condition were made for broad areas, cover estimates were made for key floristic attributes, and measures of sward height were taken at each quadrat. These features can provide good representation of the site at the time of survey, to depicting seasonal influences such as the generally dry conditions experienced during spring 2015, and levels of grazing pressure in the weeks leading up to each survey.

Page 6 of 16 Figure 1. GSM Records, Existing Offsert Areas and Potential Golden Sun Moth Offset Areas at 346 Carngham-Streatham Road, Chepstowe.

UNNAMED

STREATHAM-CARNGHAM ROAD UNNAMED

MENA PARK ROAD

UNNAMED

CE CB NORTH AND SOUTH ROAD

CG BA CHEPSTOWE-SNAKE VALLEY ROAD AC CF

CA AA

CHEPSTOWE-PITTONG ROAD

B A

UNNAMED

AB MCINTOSH ROAD

UNNAMED

Date created: 28/02/2018 Abzeco Pty. Ltd Legend Suite 1, 4 Brisbane Street Property Boundary GSM records 2012-13 Existing Offsets (42.73ha) Fenceline Road Created by: Kathryn Himbeck Eltham, Victoria 3095 Ph 03 9431 5444 GSM Habitat/NTGVVP (262.966 ha) GSM records 2015-16 Golden Sun Moth Existing Offset (40.54ha) Water Body Cadastre www.abzeco.com.au 2012 Australian Ecosystems GSM Data GSM records 2016-17 200 100 0 200 400 600 800 File: J:\Jobs\2013_Jobs\12104 2010-2011 Incidental Abzeco GSM records GSM records 2017-18 Scale 1:15,000 (A3) Chepstowe /AbzecoFig1_GSMHabitat Note: location of property boundaries, watercourse and topography indicative only. Meters GDA 1994 MGA Zone 54 Figure 2. Location of fourteen quadrats and survey compartments across 40ha GSM offset at 346 Carngham-Steatham Rd, Chepstowe.

STREATHAM-CARNGHAM ROAD

Compartment A

7 Compartment B 6 5

Compartment C 9 CHEPSTOWE-PITTONG ROAD

Compartment F

12 13 10 11 Compartment E

Compartment D 14

4 3 Compartment G Compartment H 2 1

Compartment I

Legend Golden Sun Moth Survey Area Property Boundary Vegetation Quadrat Fenceline Cadastre Gate Abzeco Pty. Ltd Water Body Date created: 04/01/2017 Suite 1, 4 Brisbane Street Wind Turbine Road Eltham, Victoria 3095 Created by: Kathy Himbeck Ph 03 9431 5444 www.abzeco.com.au 40 20 0 40 80 120 160 Scale 1:5,000 (A4) File: J:\Jobs\2013_Jobs\ 13002GSMOffset\Abzeco Meters GDA 1994 MGA Zone 54 ChepstoweGSM-Fig1 Note: location of property boundaries, watercourse and topography indicative only. Figure 3. GSM Records, Location of Property Management Units and GSM Habitat Extent, 346 Carngham-Streatham Road, Chepstowe

UNNAMED

STREATHAM-CARNGHAM ROAD UNNAMED

MENA PARK ROAD

UNNAMED

CE CB NORTH AND SOUTH ROAD

CG BA CHEPSTOWE-SNAKE VALLEY ROAD AC CF

CA AA

CHEPSTOWE-PITTONG ROAD

B A

UNNAMED

AB MCINTOSH ROAD

UNNAMED

Date created: 28/02/2018 Abzeco Pty. Ltd Legend Suite 1, 4 Brisbane Street Property Boundary Existing Offsets (85.463 ha) Fenceline Road Cadastre Created by: Kathryn Himbeck Eltham, Victoria 3095 Ph 03 9431 5444 GSM Habitat/NTGVVP (262.966 ha) GSM records Water Body www.abzeco.com.au Treed File: J:\Jobs\2012_Jobs\12104 200 100 0 200 400 600 800 Scale 1:15,000 (A3) Note: location of property boundaries, watercourse and topography indicative only. Meters GDA 1994 MGA Zone 54 Abzeco 12104 - Golden Sun Moth Records and Habitat Distribution, 346 Carngham-Streatham Road, Chepstowe – June 2018

3 Results 3.1 Vegetation Description The study site is characterised by gently rolling hills on basalt parent material, generally grading from upslope areas to the south of Carngham-Streatham Road through lower slopes and drainage depressions down to the Baillie Creek flood plain. The southern section of the property supports several prominent rises and occasional rock outcropping. The property is divided into numerous paddocks, with grazing pressure variable and seasonally based. The higher quality stands of plains grassland are not grazed, with fire used for biomass management during early winter and weed control timed to follow during the post burn flush. The native vegetation areas are characteristically grassy, with several Eucalypt plantations and shelter-belts of both Eucalypt and Pine trees. Due to the propensity for sheep to camp on elevated sites many of the upslope areas are weed-dominated. Consistent long-term use as stock camps has led to a reduction in perennial grass cover, with increased nutrient loads from stock defecation coupled with soil disturbance promoting the dominance of winter-active annual broadleaf weeds such as Herons-bills *Erodium spp. and Capeweed *Arctotheca calendula. Several logs are present in these elevated sections and one old Yarra Gum Eucalyptus yarraensis is indicative of former indigenous woody plant cover, much of which is likely to have been Drooping Sheoak Allocasuarina verticillata, among other taxa. In the grazed pasture areas vegetation is dominated by native cool-season grasses (supporting the C3 photosynthetic pathway) including Wheat-grass Anthosachne scabra, Weeping Grass Microlaena stipoides var. stipoides, Wallaby grasses Rytidosperma spp., Spear grasses Austrostipa spp., Tussock grasses Poa spp. and the warm-season Kangaroo Grass Themeda triandra (supporting the C4 photosynthetic pathway). A variety of native forbs are present in the patchy higher quality areas dotted through the property. These patches include Pink Bindweed Convolvulus angustissimus ssp. angustissimus, Scaly Buttons Leptorhynchos squamata, Solenogyne Solenogyne spp., Yellow Rush-lily Tricoryne elatior, Chocolate Lily Arthropodium spp., Common Bog-sedge Schoenus apogon, Spreading Crassula Crassula decumbens var. decumbens, Creeping Cudweed Euciton collinus s.s., Plains Slender Mint Mentha sp. aff. diemenica, Bluebells Wahlenbergia spp., Pussy Tails Ptilotus spathulata, Grass-cushions Isoetopsis graminifolia, Grassland Wood-sorrel Oxalis perennans, Austral Adder’s-tongue Ophioglossum lusitanicum, Blue Devil Eryngium ovinum and Dwarf Aphelia Aphelia pumilio. Several taxa are scattered at low abundance such as those suited to isolated wetter areas including Rushes Juncus spp., Matted Pratia Lobelia pedunculata s.l., and those species afforded protection from stock grazing in rocky areas including Tangled Shrub-violet Melicytus angustifolius ssp. angustifolius. Surface rock is prominent throughout the southern sections of the property, mostly on rises and slopes. A combination of bare ground, loose grass litter, soil crust and mosses are characteristic elements of the ground flora mingled interstitially with perennial grasses and native forbs. Weeds are prevalent throughout the grazed areas but at low cover, mostly consisting of annual herbs and grasses, however, several species of perennial grass are also present. High frequency species include Onion Grass *Romulea rosea, Hair-grass *Aira spp., Fescue *Vulpia spp., Flatweed *Hypochaeris radicata, Smooth Cat’s-eat *H. glabra, Hairy Hawkbit *Leontodon taraxacoides ssp. taraxacoides, Sweet Vernal-grass *Anthoxanthum odoratum, Spear Thistle *Cirsium vulgare, Subterranean Clover *Trifolium subterraneum, Suckling Clover *T. dubium, Hop Clover *T.

Page 10 of 16 Abzeco 12104 - Golden Sun Moth Records and Habitat Distribution, 346 Carngham-Streatham Road, Chepstowe – June 2018 campestre, Creeping Bent-grass *Agrostis stolonifera, Large Quaking-grass *Briza maxima, Lesser Quaking-grass *B. minor, Erect Chickweed *Moenchia erecta, Capeweed *Arctotheca calendula, Bulbous Meadow-grass *Poa bulbosa, Cicendia *Cicendia spp. and Mouse-ear Chickweed *Cerastium glomeratum. 3.2 GSM Survey results

3.2.1 Golden Sun Moth Records Flight Season 2010-2011 No targeted surveys were undertaken for GSM during the 2010-11 flight season, however a number of incidental records were made while undertaking vegetation surveys. The location of records is provided in Figure 1. 3.2.1 Golden Sun Moth Records Flight Season 2011-2012 No targeted surveys were undertaken for GSM during the 2011-12 flight season, however a number of incidental records were made while undertaking vegetation surveys. The location of records is provided in Figure 1. 3.2.1 Golden Sun Moth Flight Season 2012-2013 Two separate sets of records are available for the 2012-13 flight season. One set of records come from Australian Ecosystems which are incidental records obtained during a vegetation assessment and the other data is from an Abzeco targeted survey, which included the area of GSM offset. The location of records is provided in Figure 1. The Abzeco targeted survey was undertaken over four site visits during November and December of 2012. Due to the lack of nearby independent reference sites, the in-situ registered offset areas known to support GSM were used as pseudo reference sites to confirm GSM activity. A total of 155 Golden Sun Moth were detected in the survey area during 2012-2013 targeted surveys, which were undertaken during suitable conditions. The majority of records were during the final day of surveying, which was undertaken by line transect on a Quadbike at low speed.

Table 1. Results of visual searches undertaken during the 2012-2013 Golden Sun Moth flight season at the study site, 346 Streatham-Carngham Rd, Chepstowe.

Survey 1 2 3 4 Date 26/11/2012 28/11/2012 29/11/2012 18/12/2012 Start time 11:00 11:00 11:00 11:00 Distance between 50 25 10 10 transects (m)

Air temp (0C) 24 27 34 25

Wind speed 15 9 27 20 (km/h) Cloud Cover 20 10 0 20

Weather conditions (~%)

D. N Assessors B.H, D.N, D.Y B.H, D.N, D.Y B.H, D.N, D.Y Neville Oddie

GSM detected 1 female 5 males 3 males 146+ males

Page 11 of 16 Abzeco 12104 - Golden Sun Moth Records and Habitat Distribution, 346 Carngham-Streatham Road, Chepstowe – June 2018

3.2.2 Golden Sun Moth Flight Season 2015-2016 Two surveys were conducting during the 2015-2016 flight season with 111 GSM observed across the entire survey site on 17 November 2015. The second survey was undertaken on 24 November 2015 across approximately 60% of the survey site, observing 80 individuals including 9 females. The targeted surveys were undertaken in suitable conditions. Table 1 details the survey dates, results and a summary of relevant weather conditions for each of the two surveys conducted in 2015. The location of records is provided in Figure 1 with a map of compartments in Figure 2. The GSM flight season for 2015-2016 around Melbourne was from late October 2015, until early- January 2016.

Table 2. Results of visual searches undertaken during the 2015-2016 Golden Sun Moth flight season at the study site, 346 Streatham-Carngham Rd, Chepstowe.

Survey 1 2 Date 17/11/2015 24/11/2015 Start time 12:00 13:45

Air temperature (0C) 33.5 16

Wind speed (km/h) 5.8 10 Weather conditions Cloud Cover (~%) 65 6

Assessors NO DDA

A 8 25 B 22 NA C 9 NA D 17 NA E 13 NA GSM detected per compartment F 28 23 G 9 13 H 1 8 I 4 11 Total 111 80

Survey notes:  17/11/2015 – One personnel traversed the entire survey site undertaking the GSM survey using a quadbike.  24/11/2015 – One personnel traversed the sections of the survey site on foot recording the location of all GSM observed. Only compartments A, F, G, H and I were surveyed. A total of 9 females were observed with four in compartment A, three in compartment F, one from compartment G and one female from compartment I. Moths were seen to be flying and resting in grass periodically. The extent of the survey site assessed supported relatively short grass with a cover of 15% bare ground. It was noted that the Wallaby Grass was seeding.

Page 12 of 16 Abzeco 12104 - Golden Sun Moth Records and Habitat Distribution, 346 Carngham-Streatham Road, Chepstowe – June 2018

3.2.3 Golden Sun Moth Flight Season 2016-2017 Three surveys were conducting during the 2016-2017 flight season with 34 GSM observed across the entire survey site on 6 December 2016, 193 recorded on 14 December 2016 and 3 noted on 19 January 2017. The targeted surveys were undertaken in suitable conditions. Table 2 details the survey dates, results and a summary of relevant weather conditions for each of the two surveys conducted in 2016/17. The location of records is provided in Figure 1 with a map of compartments in Figure 2. The GSM flight season for 2016/2017 around Melbourne, was from early-December 2016, until mid-January 2017.

Table 3. Results of visual searches undertaken during the 2016-2017 Golden Sun Moth flight season at the study site, 346 Streatham-Carngham Rd, Chepstowe.

Survey 1 2 3 Date 6/12/2016 14/12/2016 19/01/2017 Start time 11:05 12:00 10:00

Air temperature (0C) 33.5 16 25.2

Wind speed (km/h) 5.8 10 7.0 Weather conditions Cloud Cover (~%) 65 6 0

Assessors GJ, BJ, JM NO GJ

A 9 4 2 B 8 18 0 C 1 20 0 D 5 56 0 E 4 48 1 GSM detected per compartment F 2 6 0 G 2 21 0 H 1 4 0 I 2 16 0 Total 34 193 3

Survey notes:  6/12/2016 – Three personnel walked 25 m apart along a transect traversing the entire survey site. No GSM females were noted but males were observed aggregating around patches of ground that supported approximately 40% bare ground. Most of the single moth observations were recorded in areas of grass cover from 40 – 100%.  14/12/2016 – One personnel traversed the entire survey site undertaking the GSM survey using a quadbike. No females were noted and all males were observed to be flying over the vegetation.  19/01/2017 – One personnel traversed the entire survey site on foot. All three male GSM were observed flying over vegetation with a cover estimate of 60 – 100%.

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3.2.4 Golden Sun Moth Flight Season 2017-2018 Two surveys were conducting during the 2017-2018 flight season with 179 GSM recorded across the survey areas on the 13th and 15th of December 2017 by George Collins and Jonathan Sordello. At least 84 males were recorded on 13th and at least 95 males on the 15th of December. The location of records is provided in Figure 1 and for the location of property management units see figure 3. An extremely large area of known habitat with previous incidental GSM records was traversed by vehicle during the 2017-18 flight season. Abzeco staff were on site seed harvesting with works timed to occur on suitable warm sunny days with light winds during the flight season. Staff were instructed to cease harvesting when moths were observed flying in order to undertake GSM survey over broader areas of the site. For large areas assessed in this manner, notes were taken on the number of individuals observed and a single point made roughly in the centre of the management unit (paddock dominated by native grasses). Mapping of the extent of suitable habitat cover was also undertaken.

Table 4. Results of visual searches undertaken during the 2017-2018 Golden Sun Moth flight season at the study site, 346 Streatham-Carngham Rd, Chepstowe.

Survey 1 2 Date 13/12/2017 15/12/2017 Start time 9:55 12:00

Air temperature (0C) 26 21

Wind speed (km/h) 24 16 Weather conditions Cloud Cover (~%) 5 35

Assessors GC, JS GC, JS

CD 58 64 GSM detected by Management AA 26 31 Unit Total 84 95

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4 Discussion A recent study of Golden Sun Moth distribution demonstrates how the distribution of the species can shift markedly from large connected populations to small patches at a local scale, primarily due to dispersal and survivorship (Kutt et al. 2015). The study demonstrated how long-term weather patterns and landscape configuration interact to affect local distribution and abundance over time, driven by environmental properties such as aspect and relative moisture (i.e. wet and dry landscape positions). For example, during shifts between dry and wet periods GSM occurrence at the property scale will shift from “lower elevation run-on to higher elevation run- off locations in the landscape” (Kutt et al. 2015, p. 103). This is particularly pertinent at the decadal time-scale with which regional and local weather patterns can undergo significant change, for example in response to El Niño and La Niña events (BOM 2012). The subject land supports a variety of land types inclusive of both lower-lying, seasonally damp areas and more elevated, drier topography with varying aspects. The variety of landscape positions across the property provides the local GSM population a reasonable area of ecological space that the species may occupy over decadal timespans, assuming that these areas carry sufficient habitat in terms of species composition and structure. Extensive areas of the property clearly provide suitable GSM habitat, while patches composed primarily of exotic grasses such as Brown-top Bent and Sweet Vernal-grass also occur. For practical management purposes, annual monitoring should be designed to identify local patterns in population ‘movement’, for both male and female GSM. In response to climatic drivers of habitat suitability the land manager can strategically adjust the local grazing regime to promote GSM populations within the offset site by controlling biomass and weeds, and by avoiding inappropriate grazing management. Any alterations to grazing practices will need to be timed to avoid high impacts to the breeding cycle of the species, to target flowering periods of undesirable plant species and to assist maintain an open sward prior to breeding season.

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5 References Abzeco (2013) Abzeco 12104 Targeted GSM Report – 346 Streatham-Carngham Road, Chepstowe, November 2013. Abzeco (Applied Botany, Zoology and Ecological Consulting), Eltham, Victoria. Abzeco (2014) Golden Sun Moth Conservation Management Plan 346 Streatham-Carngham Road, Chepstowe. Unpublished report prepared for Asset 1 Pty Ltd by Abzeco Pty Ltd, Eltham, Victoria. Abzeco (2017) Golden Sun Moth Population and Habitat Assessment at 346 Carngham-Streatham Road, Chepstowe for the Wollert Residential Development Offset, June 2017. Unpublished report prepared for Neville Oddie by Abzeco Pty Ltd, Eltham, Victoria. Biosis Research (2010) Priciples and Practical Management Guidelines for Protected Areas of Golden Sun Moth Synemon plana habitat in urban areas. Biosis Research Pty Ltd, Port Melbourne. Bureau of Meteorology (2012) Record-breaking La Niña events. An analysis of the La Niña life cycle and the impacts and significance of the 2010-11 and 2011-12 La Niña events in Australia. Australian Government Bureau of Meteorology, Melbourne. DEWHA (2009a) Background Paper to EPBC Act Policy Statement 3.12 – Significant Impact Guidelines for the Critically Endangered Golden Sun Moth (Synemon plana). Australian Government Department of the Environment, Water, Heritage and the Arts, Canberra. DEWHA (2009b) EPBC Act Policy Statement 3.12 - Significant Impact Guidelines for the Critically Endangered Golden Sun Moth (Synemon plana). Australian Government Department of the Environment, Water, Heritage and the Arts, Canberra. Kutt, A. S., McKenzie, V. J., Wills, T. J., Retallick, R. W. R., Dalton, K., Kay, N. and Melero-Blanca, E. (2015) Spatial and temporal determinants of golden sun moth Synemon plana distribution. Austral Ecology 40: 100-107.

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