,
New South Wales
Message
The reporting significantly underplays the value of the critically endangered woodland which is to be removed. It is
understandable for proponent-commissioned ecological assessments to under-report vegetation viability, condition &
extent. However the submitted reporting also contains serious factual errors including comment that Bursaria spinosa
is indicative of disturbed habitats (p26; the opposite is the case) and that Eucalyptus acmenoides is a common tree
species on site (if this species is present at all it is a regional anomaly and of conservation significance). The assessment in general fails to consider that the vegetation at stake is critically endangered - the benchmark for it's protection and restoration must be commesuarately high.
The project will remove vegetation within areas covered by the Growth Centres Biodiversity Certificaton Order and areas outside; it will also impact on Cumberland Plain Woodland that meets the Federal assessment benchmarks, and woodland which meets the State benchmarks. It is those areas outside Certification and meeting the Federal benchmarks which are the subject of the present assessment and this submission. These constitute 2.87 hectares of Cumberland Plain Woodland.
An 'offset' has been proposed for the vegetation loss within the Growth Centres Area (however as neither in-perpetuity protection or a trust fund for restoration of this area are proposed, this does not actually constitute an offset). However no offset has been proposed for the 2.87 hectares of Cumberland Plain Woodland loss which is the subject of the present assessment.
A genuine offset incorporating on-title permanent protection and an in-perpetuity fund for vegetation maintenance is required to achieve a maintain-or-improve outcome for the 2.87 hectares of Cumberland Plain Woodland removed outside the Growth Centres. The minimum ratio of vegetation lost to vegetation restored ever found to maintain biodiversity values in Australia by peer-reviewed research is 1:20. This reflects the severity of impact that vegetation loss has on even highly degraded ecosystems. As such a minimum offset area of 57.4 hectares is required to meet a maintain-or-improve outcome for Cumberland Plain Woodland. This is additional to the offset proposed for offseting the vegetation lost within the growth centre.
I note that there is sufficient Cumberland Plain Woodland on this property to provide the land for such an offset (refer aerial Figure 2-2 EIS volume 1). This includes the so-called 'moderate condition CPW in non-certified areas in south-west of Study Area' shown on page 478, which is in fact high condition woodland.
When will the critically endangered Cumberland Plain Woodland finally be protected? If this patch must be destroyed the applicant must be required to provide a sufficiently sized offset, calculated on the research evidence of 1:20 minimum ratios and not on political expediency.