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6/08/2019 1 NORTH EAST LINK PROJECT JOINT PERSENTATION OF BRETT LANE, CAMERON MILLER AND PATRICK MAIDEN Overview Complex assessment, involving a range of ecological specialisations Joint presentation aims to ensure an integrated understanding of ecological impacts across terrestrial and aquatic ecosystems Joint presentation: Brett Lane – Peer review, native vegetation, threatened flora and fauna, Environmental Performance Requirements Cameron Miller – Matted Flax-lily Translocation Plan, Studley Park Gum Management Framework and Native Vegetation Offsets (Collectively Vegetation Offsets) Patrick Maiden – Aquatic Ecosystems

NORTH EAST LINK PROJECT - Amazon S3 · • Final Ecology Technical Report (Appendix Q to the EES) ... • Grey-headed Flying-fox Aquatic Ecosytems. 6/08/2019 7 Baseline Ecological

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Page 1: NORTH EAST LINK PROJECT - Amazon S3 · • Final Ecology Technical Report (Appendix Q to the EES) ... • Grey-headed Flying-fox Aquatic Ecosytems. 6/08/2019 7 Baseline Ecological

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NORTH EAST LINK PROJECTJOINT PERSENTATION OF

BRETT LANE, CAMERON MILLER AND PATRICK MAIDEN

Overview

• Complex assessment, involving a range of ecological specialisations

• Joint presentation aims to ensure an integrated understanding of ecological impacts across terrestrial and aquatic ecosystems

• Joint presentation:• Brett Lane – Peer review, native vegetation, threatened flora and fauna,

Environmental Performance Requirements

• Cameron Miller – Matted Flax-lily Translocation Plan, Studley Park Gum Management Framework and Native Vegetation Offsets (Collectively Vegetation Offsets)

• Patrick Maiden – Aquatic Ecosystems

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Overview - Brett Lane

• My role and documents reviewed

• Context

• Investigations undertaken

• Baseline ecological findings (PM – Aquatic Ecosystems)

• Impacts of the project (PM – Aquatic Ecosystems; CM – Vegetation and flora offsets)

• Environmental Performance Requirements

My role• Retained in mid-2018 to review

• Ecology methods• Draft Ecology Technical Report• Final Ecology Technical Report (Appendix Q to the EES)

• Prepare a Peer Review Report (Appendix M in Final Ecology Technical Report)

• Subsequently reviewed:• Studley Park Gum draft and final survey reports

• Chaired the expert conclave (30-31 July 2019)

• Cameron Miller will talk to:• Studley Park Gum Management Framework• Matted Flax-lily Translocation Plan• Native vegetation offsets

• Patrick Maiden will talk to:• Aquatic ecosystems and species

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Context

• EES Scoping Guidelines• Ecology: “To avoid or minimise adverse effects on vegetation (including remnant,

planted and regenerated) listed rare and threatened species and ecological communities, habitat for listed threatened species, listed migratory species and other protected flora and fauna, and address offset requirements for residual environmental effects, consistent with relevant State policies.”

• Public Works Order• Ecology: “The EES is to document investigations of potential environmental effects of

the Public Works, including the feasibility of design alternatives and relevant environmental mitigation and management measures, in particular for:

• a. potential effects on biodiversity, including through loss, degradation orfragmentation of habitat or through other causes (e.g. shading, light, noise andvibration), as well as related ecological effects…”

Summary

• We are satisfied that the information presented in the EES and its technical appendices:

• Comprehensively describes the ecological attributes and values of the Project Area in a manner that addresses state biodiversity policies and legislation

• Accurately identifies those ecological attributes and values impacted by the project

• Provides a strong framework of Environmental Performance Requirements (EPRs) to guide detailed design, construction and operation of the project.

• Identifies and describes strategies for offsetting and compensating for the impact of the project on affected native vegetation and threatened flora species, together with additional documentation provided to the IAC

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Investigations undertaken

• 10 km search region for existing information review – databases listed Appendix Q in s. 5.4.2

• Literature review (Appendix Q, Table 9) and stakeholder engagement (Tables 18 & 19)• Short-listing of threatened species (EPBC Act, FFG Act, DELWP Advisory Lists) for

further investigation (based on suitable habitat and search region). • Native vegetation assessment as per ‘Guidelines’ (Oct 2017 – Nov 2018)

• Detailed mapping and habitat scoring of remnant indigenous patches and scattered trees• Refinement of patches and scattered trees to exclude patches and trees not established

specifically for conservation purposes (e.g. amenity plantings on Eastern Freeway, roads and parks) while including planted vegetation that has a clear biodiversity intent (based on relevant EVC species composition)

• Seasonally appropriate threatened species searches for species considered likely to occur for flora (Oct 2017 to Dec 2018, incl two springs and summers) and fauna (May 2017 to Dec 2018, incl. two springs) (Appendix Q – Table 10)

• Aquatic ecosystems (June 2017 – July 2018)(Appendix Q – Tables 10 & 15) incl. fish surveys at 8 sites in Koonung Ck, 1 each in Plenty R and Banyule Ck

• Additional Studley Park Gum survey (May – June 2019)• Database review for Groundwater Dependent Ecosystems• Large tree groundwater impact assessment

Baseline Ecological Information – Native Vegetation• Project Area includes three bioregions: Highlands Southern Fall, Victorian Volcanic

Plain and Gippsland Plain• It supports 52.109 ha of patches and 147 Large Trees (92 in patches + 55 scattered)• An additional 32 large trees are deemed lost due to groundwater drawdown),

totalling 179 large trees• Some 77 per cent of the native vegetation consisted of Plains Grassy Woodland

(18.713 hectares), Swampy Riparian Woodland (15.264 hectares) and Floodplain Riparian Woodland (6.396 hectares). Remining EVCs included:

• Valley Grassy Forest, Swamp Scrub, Creekline Grassy Woodland, Creekline Herb-rich Woodland, Grassy Woodland, Aquatic Sedgeland, Riparian Woodland, Tall Marsh, Swampy Woodland, Grassy Dry Forest, Streambank Shrubland

• Most vegetation is in moderate to poor condition (condition score mostly 0.2 – 0.45; small area > 0.5), due to long period of intense urban development

• Key remnant areas include:• Simpson Barracks• Banyule Creek• Yarra River and floodplain• Koonung Creek

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Baseline Ecological Information – Flora Species

• Project Area includes 327 plant species (193 native, 134 introduced)

• 48 rare or threatened species have been recorded historically in the region

• Three found in the Project Area: Matted Flax-lily, Arching Flax-lily and Studley Park Gum

• River Swamp Wallaby-grass previously recorded in the Project Area

• Six other EPBC Act and FFG Act listed threatened plant species have a moderate to high likelihood of occurring in the Project Area

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Baseline Ecological Information - Fauna

• 400 terrestrial vertebrate fauna species have been recorded or are likely to occur in the Project Area (305 birds, 53 mammals, 28 reptiles, 14 amphibians, 31 non-native), partly reflecting the high density of engaged amateur observers)

• 74 of these are threatened:

• 27 – EPBC Act

• 58 - FFG Act

• 63 - DELWP Advisory Lists• Three species with a moderate to high likelihood of occurring regularly

include:• Powerful Owl

• Swift Parrot

• Grey-headed Flying-fox

Aquatic Ecosytems

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Baseline Ecological Information – Aquatic habitats and species

• The Yarra River and associated floodplain includes the most diverse and intact aquatic ecological values in the Project Area

• Tributaries of the Yarra in the Project Area include Banyule and Koonung Creeks, which are more degraded by heavy adjacent urban development affecting:

• Runoff and flow rates

• Water quality

• Channel modification• Riparian zone modification

• 32 fish, three turtles, two aquatic mammals have been recorded or are likely to occur in the Project Area

Baseline Ecological Information – Aquatic habitats and species

• Threatened species in the aquatic habitats of the project area include:• Australian Grayling• Australian Mudfish• Macquarie Perch (naturalised)• Murray Cod (naturalised)• Murray River Turtle• Broad Shelled Turtle

• Groundwater Dependent Ecosystems (GDE’s):• Banyule Creek (lower reaches)• Bolin Bolin Billabong• Yarra Flats• Banyule Flats• Deeper-rooted trees in Simpson Barracks and Yarra Floodplain (BL)

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Mitigation and offsetting approaches

• 95 plants/patches in the project area may be subject to removal - some are very close to the edge of the project boundary – the intent of FF2 is to further minimise impacts where achievable.

• Residual impacts and offsets are to be determined under the EPBC Act (separate process).

• Proposed mitigation method is to undertake salvage and translocation.

• Matted Flax-lily Salvage and Translocation Plan:

• pre-clearance surveys

• salvage

• translocation (site TBC - 3 primary sites and 6 additional/secondary sites identified)

• post-translocation management, monitoring and reporting.

• Successful translocation has previously occurred at multiple sites.

Matted Flax-lily (MFL)

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• In total 184 individuals have been identified with high or moderate confidence.

• 49 individuals will be impacted by the project (46 direct and 3 indirect).

• No legislative requirements to specifically offset impacts to SPG (this will be included in general vegetation offsets, including large trees offset as per the Guidelines).

• Proposed mitigation method is to establish a new population of at least 98 SPG in an appropriate recipient site (2 plants established for every 1 plant removed). Additional plants will be established as part of general landscaping.

• Studley Park Gum Management Framework:

• collect seeds from impacted trees (Seed Collection and Propagation Plan)

• propagate seeds

• translocate seedlings into recipient site (site TBC – 11 potential site in three broad areas identified)

• post-translocation management, monitoring and reporting.

Studley Park gum (SPG)

Project Impacts – Native Vegetation• Final impacts will depend on final design within the Project Area; complete

removal within the Project Area is considered unlikely so the impact assessment is a conservative, worst-case outcome

• Expert Conclave agreed exploration of design options to address the ‘minimise’ principle in the Guidelines was lacking (it is a require,ment of the Guidelines for removal destruction and lopping of native vegetationreferenced in the EES Scoping document (and the proposed Incorporated Document)

• Measures to avoid and minimise impacts on native vegetation dom include• Tunnel under the Yarra River

• EPR FF2 requires contractor to design to avoid and minimise impacts within the Project Area

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Native Vegetation offsets

Required offset Proposed third-party offsets

Details In Register?

9.384 general habitat units (GHU) within appropriate CMA(minimum strategic biodiversity value (MSBV) score 0.164)

9.384 GHUs within appropriate CMA

(MSBV score 0.164 )

Yes

22.945 species habitat units (SHU) for grey-headed Flying-fox (Pteropus poliocephalus)

~25 SHUs for grey-headed flying-fox

No*

179 large trees (general, species or combination)

>1000 large trees available

Yes

*Landowner ready to register credits and working with an offset-broker

Project Impacts – Fauna• Few threatened species occur in the affected area consistently• Direct habitat removal (native vegetation, scattered trees and non-indigenous

native plantings) will reduce populations of a range of non-threatened species of local interest

• No threatened fauna species will be affected significantly• Powerful Owl use the Project Area sporadically, and have not been recorded consistently• Swift Parrot occasionally pass through the area on migration and most of the trees in the

Project Area are not their preferred feed trees and there are few records in the Project Area where the most impacts on trees will occur

• Grey-headed Flying-fox occur throughout the Project Area in small numbers and at Yarra Bend Park near the Project Area a significant roost of over 60,000 in some recent years occurs consistently in summer, with smaller numbers using it year-round.

• Most fauna species potentially affected occur in the Project Area and nearby because they are adapted to highly fragmented or altered habitats within urban areas and consequently will persist despite the project

• Net gain in canopy cover of planted trees will partly offset this

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Project Impacts – Terrestrial Groundwater Dependent Ecosystems • Residual impacts will occur through loss of habitats on the Trinity Grammar

Wetlands,

• Groundwater dependent terrestrial vegetation in the Simpson Barracks will be affected, with up to 32 large trees affected and an unknown number of additional trees

Protection of Yarra River• Tunnel mostly avoids impacts to High value aquatic

ecosystem, including threatened fish species.

• Prevention of water quality pollution through surface water design will avoid indirect impacts to Yarra from drainage.

• Avoidance of high intensity noise/vibration construction during critical times avoids impacts to threatened Australian Grayling. (EPR FF8)

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Direct Impacts to Koonung Creek• Waterway modification – diversion and covering of

Koonung Creek.

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Koonung Creek –existing conditions in location to be modified to covered waterway

Koonung Creek – Upstream of the existing covered waterway

Direct Impacts to Koonung Creek• Waterway modification – diversion and covering of Koonung

Creek.

• Loss /degradation of aquatic habitat will occur though this does not support significant aquatic ecological values.

• No threatened aquatic species is likely to be affected significantly as affected habitats are unlikely to support them; they are confined to the Yarra River and this will be protected by the tunnel

• Loss of ecosystem services from this reach of Koonung Creek.

• Existing native fish species capable of passage through additional covered reaches.

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Direct Impacts to Banyule Creek

• Waterway modification – diversion and covering of Banyule Creek

Banyule Creek -Location of ‘permanent’ aquatic habitat

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Direct Impacts to Banyule Creek

• Waterway modification – diversion and covering of Banyule Creek

• Loss /degradation of ephemeral aquatic habitat will occur.

• No fish and very low aquatic ecosystem values impacted.

Indirect Impacts from Surface Water• Water quality and scouring flows are known threats to aquatic

ecosystems in urban waterways.

• All waterways presently modified due to existing urban drainage.

• Prevention of additional impacts of the project managed by drainage and containment design and maintenance during operation to ensure:

• Retention of high flows

• Capture of sediments

• Treatment of pollutants

• Appropriate environmental performance standards contained in SEPP (Waters)2018.

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Indirect Impacts to Bolin Bolin Billabong• Groundwater changes possibly affecting groundwater

dependent ecosystem of Bolin Bolin Billabong water level during ‘dry phase’.

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Bolin Bolin Billabong deep pool –dry phase above, and inundated phase below

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This image cannot currently be displayed.

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Bolin Bolin billabong Inundation phaseHydrology not groundwater dependent, rather EWMP and flooding.

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Bolin Bolin billabong Dry phase hydrology is groundwater dependent.Hence inundation hydrology less relevant

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Bolin Bolin billabong Dry phase hydrology is groundwater dependent.MW Target to “expand zone of permanent pool” Jacobs 2018

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Range of natural variability - may shift.

Hydrograph benchmark at ~1.8m pool depth

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Bolin Bolin billabong Dry phase hydrology is groundwater dependent.MW Target to “expand zone of permanent pool” Jacobs 2018

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Range of natural variability - may shift.

Hydrograph benchmark at ~1.8m pool depth

MW target

Existing

NELP

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Indirect Impacts to Bolin Bolin Billabong• Groundwater changes possibly affecting groundwater dependent ecosystem

of Bolin Bolin Billabong water level during ‘dry phase’.

• Aquatic ecosystem degraded due to historical land modification, altered flooding regime and dominant pest fish species.

• Nevertheless, Bolin Bolin supports native fish, the aquatic ecosystem is considered significant and is thus managed for rehabilitation.

• Does not support threatened species of aquatic fauna

• Impacts to water levels in deep pool uncertain, but expected.

• Mitigation of impacts possible through monitoring of impacts to deep pool, and provision of environmental water to protect aquatic habitat if required.

Indirect Impacts to Other Floodplain Wetlands• Banyule Swamp, Banyule Billabong and other sites of notable aquatic

habitat and other ecological values are not directly impacted.

• Minor impacts of groundwater change predicted to occur are not likely to cause significant impacts to aquatic ecosystems.

• Banyule Swamp - Minor ground movement predicted to occur above the tunnel will have negligible impact on the aquatic ecosystem, with appropriate monitoring and mitigation of changes to levee bank structures if required.

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Response to submissions - MFL

• I consider the proposed salvage and translocation program sufficient to reduce the likelihood of significant impacts on the species.

• A large and significant population will remain at Simpson Barracks and an additional large population will be established at a recipient site(s) - I believe that salvaged MFL plant material should be translocated to two recipient sites to provide an ‘insurance’ site.

• MFL salvage and translocation is a recommended mitigation strategy by DELWP and is a specific action identified under the National Recovery Plan for the species.

• MFL salvage and translocation has been undertaken successfully for multiple projects.

• The location and attributes of the three primary recipient sites are considered suitable for translocation (Marigold Reserve, Harry Pottage (west) & Simpson Barracks).

Response to submissions – SPG

• In regards to the SPG survey effort, additional surveys have been undertaken that represent the most comprehensive study of SPG to date in Victoria. Therefore, the quantification of impacts to SPG has been supported by scientifically rigorous survey and detailed analysis of results.

• I acknowledge that a significant proportion (approximately 36%) of the known SPG population within Simpson Barracks will be impacted by the project (or 24% total population). Based on the reference design at least 83 SPG trees will be retained within Simpson Barracks.

• The proposed mitigation approach of establishing a new population of SPG is currently beyond what is required – SPG is included in native vegetation offsets, no additional offset requirements.

• The establishment of a new population will contribute to the overall population and may lead to the continued survival of the species in the local area.

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Response to submissions – vegetation• The updated Ecological Offsetting Strategy details offset availability and locations and

indicates that the required offsets can be achieved through a third-party offset broker.

• Whilst offsetting within the local environment is desired, this is not required under the Guidelines – offsets must meet regional requirements.

• Understorey plants are adequately considered as they are included during assessment of ‘patches’ of native vegetation in both impacted areas and offset sites.

• In accordance with the Guidelines and the final NVR report, species offsets are required only for Grey-headed flying-fox.

• Seeds from high value native trees and shrubs within the project area will be collected for use in both conservation and amenity plantings, as outlined in the Seed Collection and Propagation Plan.

Responses to the conclave (MFL)

• The count of Matted Flax-lily across the Simpson Barracks may include double and

multiple counting as it adds counts from multiple surveys over time. The count of

Matted Flax-lily outside the project area also includes plants that may no longer exist.

• The areas where MFLs were found in the EES study do not include some areas where

MFL was found in previous studies, suggesting possible decline outside the project

area. There is potential that some of these plants may be present, but not visible at the

time.

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Census (total count)

Random meander -rapid survey of a selected area

Re-analysis of MFL at Simpson BarracksReviewed GHD/AECOM 2017, Jacobs 2016, HLA 2006/7 and Defence 2006 mapping and only counted records 10-15m apart:

• 83 within the project boundary (GHD/AECOM summer 2017 survey) – consistent with EES• 123 – outside the project boundary (GHD/AECOM summer 2017 survey) – consistent with

EES• 18 – outside project boundary (Jacobs 2016 survey) – 3 more than quoted in EES• 9 – outside project boundary (HLA 2006/7 survey) – 2 less than quoted in EES• 38 – outside project boundary (Defence 2006 survey) – 12 less than quoted in EES

This equates to 271 plants/patches (12 less than quoted in EES because an even more conservative approach in checking for potential double counting has been applied).

I strongly believe that this is an underestimate of the total population size as we did not survey all parts of the Barracks.

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Responses to the conclave (MFL continued)

• There is no evidence of successful reproduction in translocated populations of MFL.

• As an objective, the successful creation of a self-sustaining population of Matted Flax-lily (sexual reproduction and recruitment) will be extremely difficult to evaluate.

Yes, however, flowering and fruiting has been observed in several translocated populations. These plants are obligate re-sprouters (plants that rely primarily on re-sprouting to regenerate) and generally grow and expand from vegetative growth. The assertion that because sexual reproduction has not been recorded does not mean:

A. it has not occurred,

B. that all translocations are a failure.

Existing MFL translocation – Quarry HillsThis image cannot currently be displayed.

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• Translocation >6 yrs old

• Plants thriving

• Plants flowering and showing vegetative growth

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Existing MFL translocation – South Morang

• Translocation from 2014

• Overall plants doing well

• Some weed management issues

• Plants flowering and showing vegetative growth

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Existing MFL translocation – Plenty Gorge

• Translocations from 2014 (SMREP)

• Initially plants did poorly, a new contractor was engaged – subsequently the site and plants are doing well

• Some weed management issues being addressed by contractors

• Plants flowering and showing vegetative growth

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Responses to the conclave (SPG)

• There is uncertainty whether the Studley Park Gum mitigation plan would provide for a self-sustaining and ecologically functioning population. Additionally, given its hybrid status, the identity of propagated material cannot be guaranteed in the short term (i.e. 10 to 15 years). The management plan will need to take this into account and this is likely to involve a long-term commitment with no guarantee of success.

• Response. The current Studley Park Management Framework (Version D, 29 July 2019) had an amended Plan Goal:

‘The goal of this translocation is to initiate and deliver the establishment and ongoing management of a new population of Studley Park gum to ensure their conservation. To achieve this goal, it is proposed to establish a minimum of 98 Studley Park gum trees in a recipient site. This goal is based on a replacement ratio of two translocated Studley Park gums established for each individual impacted by the project’.

Responses to the conclave (general offsets)• There is a risk of the native vegetation offset failing because the sites required may not be

available. At this point in time, available information on at least a portion of the offsets indicates that they do not meet the regulatory requirements (Strategic Biodiversity Value is too low).

• Addressed, see below extract from DELWP for general habitat units (Min SBS 0.164)

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Responses to the conclave (species offsets)

• Requirement to secure 22.945 species habitat units (SHUs)for Grey headed Flying-fox.

• Approximately 25 SHUs available from a landowner (source: Ecology and Heritage Partners)

Determination - Offsets are available that meet the current reference design requirements for GHUs and SHUs.

• The Environmental Management Framework (EMF) for the project (EES Chapter 27) sets out the governance, issues and outcomes expected to be implemented to satisfy the EES Scoping Guideline, namely:

• ‘a transparent framework with clear accountabilities for managing and monitoring the environmental effects and hazards associated with construction and operational phases irrespective of the final form of the ultimate design to be implemented for the project’ (Ch. 27, p. 27-1)

• Refer to Chapter 27 for details

• EPRs are a key component of the EMF and specify processes and outcomes that the project must implement and achieve to avoid, minimise and offset environmental impacts.

Environmental Performance Requirements (EPRs)

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EPR FF1 – Minimise impacts on flora and fauna

• Fauna salvage and translocation in terrestrial vegetation (indigenous and planted) and waterways (incl. pre-clearance fauna surveys)

• Compliance with the Fisheries Act 1995 i.e. capture and handling of native and noxious fish.

• Contingency Plan and reporting requirements should threatened species be detected during construction

EPR FF2 – Minimise and offset native vegetation removal• Minimise removal of native vegetation and fauna habitat – detailed design and

construction phases• Matted Flax-lily and Studley Park Gum• Powerful Owl, Swift Parrot and Grey-headed Flying-fox• Simpson Barracks, Yarra Bend, Trinity Grammar Wetlands and Koonung Creek Valley

• Establish ‘No-Go’ Zones for vegetation to be retained and tree protection zones (i.e. Avoid), including for:

• Grey-headed Flying-fox Camp at Yarra Bend• Bolin Bolin Billabong• Enterprise Drive and M80 Ring Road Plains Grassy Woodland offset site• 49 Greenaway Street, Bulleen• Surface impacts in the Banyule Flats, Warringal Parklands and Heide MOMA

• Minimise all other ecological impacts where possible (i.e. Minimise)

• All unavoidable native vegetation removal must be offset in accordance with the Guidelines or as agreed with the Secretary of DELWP (i.e. Offset)

• Use locally indigenous species for tree canopy replacement

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EPR FF3 – Avoid introduction and spread of weeds and disease

• CEMP to implement best-practice measures to control the introduction and spread of weeds and plant disease (e.g. Cinnamon Fungus),

EPR FF4 – Protect aquatic habitat

• Design and construction to minimise adverse impacts on riparian, riverbed and aquatic habitat, wetlands, waterways and billabongs, as well as habitat connectivity for aquatic fauna

EPR FF5 – Obtain FFG Act Permits

• FFG Act permits for removal of threatened and protected flora to be obtained from DELWP

EPR FF6 – Groundwater dependent ecosystem monitoring and mitigation plan

• To be informed by the outcome of EPR GW 1 and GW 2, namely:• Develop a predictive and numerical groundwater model

• Pre-construction, construction and post-construction groundwater monitoring program to confirm the acceptability of groundwater recovery

• Ensure offsets are obtained for groundwater dependent trees that will be adversely affected by groundwater drawdown.

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EPR FF7 – Implement a salvage and translocation plan for the Matted Flax-lily

• Develop and implement a salvage and translocation plan for this species to the satisfaction of both state and Commonwealth Authorities

EPR FF8 – Minimise noise and vibration impacts on Australian Grayling

• Minimise noise and vibration impacts in or near the Yarra River by:• Selecting suitable work methods

• Avoiding such work during migration (Mar – Jun, Sep – Nov)

• Management and monitoring of noise and vibration as per EPR NV4

EPR FF9 – Protect habitat values in water bodies modified for drainage

• Minimise impacts on waterbirds in Simpson Lake, billabongs and Freeway Golf Course by:

• Retaining dead and alive standing trees in and around them• Where practicable, works to be undertaken outside waterbird breeding

season (Sep – Jan)• Reduce duration of draining and refill ASAP