Native vegetation and biodiversity

In general:

  • CIS does not address how EWL proposal is inadequate and short-sighted in protecting remaining ecological values, with no real assessment of construction impacts, only offering vague statements about minimising and mitigating

  • CIS does not properly assess the value to the community of flora, fauna and aquatic assets in different precincts.

  • CIS describes Moonee Ponds Creek, Royal Park, Trin Warren Tam-boore wetlands and Merri Creek as ‘modified’ to justify wholescale destruction and/or modification.  In fact, this further reinforces the community need to further protect these ‘urban’ assets from any impacts (including removal or destruction)

  • CIS lacks significant detail regarding practical, considered and viable measures to meet the performance requirements across all performance objectives

  • CIS confirms contractor will essentially determine the best approach to meet the performance requirements (subject to legislative and other requirements)–too open-ended and non-specific in stating how impacts or can be avoided or mitigated.  It will also be market-driven.

  • CIS does not address how the removal of existing mature trees will impact fauna, and in what time frame a net increase of tree canopy will be achieved. Reinstatement of trees does not account for the fact that mature trees will be destroyed.

  • CIS does not specifically state the full range of vegetation and trees requiring removal, citing a loss of 93 scattered trees (differs from City of Melbourne appraisal of 5000+ trees lost in Royal Park), merely stating that minimal removal is required. Why aren’t saplings accounted for in the total amount of trees lost? What is minimal?  Who decides?

  • CIS does not specify areas in need of protection – including preserved remnant grasslands – in terms of specific protection boundaries

  • CIS does not address what different design and construction methods were considered to avoid the permanent loss of vegetation and biodiversity in Royal Park, so that the stakeholders can assess the value of the proposed scheme in relation to fully investigated options.  What other design options were considered?

Precinct 1 – Merri Creek & Yarra Bend

  • CIS claims no discernable impact on Merri Creek yet there will be permanent loss and destruction of an extensive range of native vegetation (eg. plains grassy woodland, floodplain riparian woodland and escarpment shrubland) and wildlife habitat for birds, reptiles and mammals such as Ringtail and Brushtail Possums, Swift Parrot and Grey-headed Flying-fox.

  • Locals have observed the recent presence of platypus.  No mention in the CIS.  How will they large-scale machinery and nearby construction works affect these mammals?

  • CIS describes broad, vague measures involving design and construction refinement to ‘maybe’ minimise impacts on this native vegetation and fauna habitat without specific intent, methodology and criterion that are all open to interpretation.  No guarantees provided.

  • CIS prescribes fencing of no-go zones along Merri Creek to protect biodiversity values. Why are specific zones not identified in CIS? Who identifies the extent of no-go zones?  CIS had been issued prematurely.

  • The CIS prescribes the requirement to minimise the removal of trees and remnant vegetation. ‘Minimise’ is not an enforceable performance criteria. What is considered minimal removal? Who decides?

  • CIS describes prescribed requirement to design the bridge widening over Merri Creek to minimise additional shading of the waterway. This is just an arbitrary objective.  Who determines what is minimal shading of the waterway?  Any shading will have impact. The only real way to minimise shading of the waterway is to not widen the bridge.

  • CIS refers to urban design framework to achieve substantial net increase in tree canopy and contribution to the urban landscape across the corridor (eg. along Alexandra Pde). Totally ignores the destruction of existing established urban street-level vegetation as active habitat for birdlife and mammals.  What’s the timeframe for re-establishing?

Precinct 3 – Royal Park and Moonee Ponds Creek:

  • Permanent loss and destruction of remnant grassy woodland near south edge of Elliot Avenue where interchange works are proposed, and near natural escarpment to the east of Ross Straw Field, near Upfield line, in Royal Park West. These are the only pockets of remnant vegetation in the municipality according to City of Melbourne.  These are areas for nocturnal retreats, nesting and denning for birds and animals.  The latter is protected habitat for regionally significant White’s Skinks.  Why is this not addressed in CIS?

  • Permanent loss and destruction of plains grassy woodland at the southern end of Trim Warren Tam-boore storage wetland.  CIS does not mention blushing bindweed (Convolvulus erubesccens) in this area – not an uncommon native grassland species, but is the last inner Melbourne population.

  • Destruction of plains grassy woodland  near a drainage line located north-east of the Trin Warren Tam-boore Wetlands, in Royal Park, on the east side of Manningham Street.

  • CIS claims “direct removal of up to 93 scattered locally native trees (planted and remnant) in Royal Park during construction.  According to City of Melbourne 5000+ trees (valued at $17milllion) will be lost resulting in loss of foraging habitat for trees will certainly result in the loss of foraging habitat for the Swift Parrot, Grey-headed Flying-fox and other fauna.  CIS provides no details of benchmark for ‘minimal removal’ of trees and remnant vegetation which makes this requirement meaningless.  Who determines what is acceptable removal?

  • Trim Warren Tam-boore storage wetland (west side of Oak St) will be permanently covered over by road viaducts (coming form western end portal, then heading south and north) with pylons inserted into it, resulting in loss of cover, aquatic habitat and water quality, impacting aquatic fauna permanently.  Will affect birds like Hardhead and others.  CIS provides insufficient clarification on how impacts to wetland will be minimised.

  • Treatment wetland on east side of Oak St will be affected by temporary works as it is in project boundary.  CIS has no detail on how the works will be contained beyond wetland zone.

  • Moonee Ponds Creek will have permanent piers, pylons and overhead viaduct freeway – additional shading and light disturbances impacting on passage of fish.  Loss of eucalypts leading to reduced foraging habitat for Swift Parrot and birds/animals.  CIS inadequately addresses how, despite being modified, it is highly valued by the community as a place for birds and fish and the EWL proposal will undermine further rehabilitation of this waterway environment.

  • CIS inadequately addresses details of construction footprint and how it will be refined to minimise destruction of natural remnant vegetation including old trees that provide habitats for animals

  • CIS inadequately addresses impacts of different methods of construction (cut-and-cover?) of tunnel in these areas – who decides?

  • CIS fails to acknowledge that EWL ignores Royal Park Masterplan (1984) and that vegetation in Royal Park considered “areas of exceptional value” in terms of State Significance (Refer to Cultural and Historic Significance of Royal Park by Christine Dyson, 1984)

  • CIS provides no detail of no-go zones and who determines these

  • Some of the grassy woodland vegetation occurs in temporary works areas and CIS suggests ‘micro-aligning’ to reduce impact – what does this mean?  Why has it not been already applied to the scheme under consideration in the CIS? Insufficient details