Grey-headed Flying-fox: Response to SIS 2005, for the Dept of Environment & Heritage.
to the Species Impact Statement (Cumberland Ecology April 2005)
for the Coffs Harbour-Clarence Valley Regional Water Supply Project
For the Federal Dept of Environment & Heritage
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Grey-headed Flying-fox (Pteropus poliocephalus) (Vulnerable TSC & EPBC Acts)
No consideration was given to the grey-headed flying-fox by the initial Environmental Impact Statement for the proposed Shannon Creek dam and infrastructure (ERM 1999). Subsequently the species was afforded no consideration by the public response process (Commission of Inquiry, 1999). Similarly the grey-headed flying-fox received no mention in the proposed access road Development Application (Greenloaning Biostudies 2004), and also has gained no recognition by North Coast Water's referral of the proposed modifications of regional water supply project to the Dept of Environment & Heritage (DEH).
In part this omission is rectified by preparation of a SIS (Cumberland Ecology 2005), although with the predictable finding that the entire regional water supply project and all attendant infrastructure components will have no significant impact on the grey-headed flying-fox.
The Draft Recovery Plan (June 05) recognises that the prime threat to the grey-headed flying-fox is loss and degradation of foraging habitat, and that development and forest clearance continues to reduce food production from eucalypts and other native species on which the flying-fox depends (page 18).
In the SIS, 8-part test (pB.214), Cumberland Ecology (CE) notes that grey-headed flying-fox's distribution has contracted southwards, and that the availability of native fruits, nectar and pollen varies over time and throughout the range of the species, so that at time flying-foxes are forced to migrate, sometimes hundreds of kilometres, in response to food availability (Peggy Eby).
Not mentioned in the SIS is the vital importance of a reliable food supply close to the flying-fox camp during the breeding season, and later to aid the survival of the new-birth young. Also not noted is the fact that if the mother animal is away on enforced lengthy missions foraging for food, the mortality rate of young animals left in the camp is high during times of prolonged wet weather, excessive heat events, and through stress or hunger. With the ongoing clearing of forest tracts that provide reliable food for the flying-fox, not only is the impact of encroaching development restricting the choices of camp sites for these animals (Hall & Richards Australian Natural History Series) but also the food source within easy flying distance of those camps.
Mostly grey-headed flying-foxes can be identified by their size, which is considerably larger than the little red flying-fox which on occasion shares the same habitat. By their size, grey-headed flying-fox are known to regularly frequent the local natural forested lands east of the Shannon Creek dam site (Lots 119/59, Clarence Valley Council). This forested tract supports a high diversity of eucalypts that generally provide sustenance for flying-foxes throughout the year. However many eucalypt species are opportunistic, and during prolonged dry spells are inclined to dormancy.
For a number of years, from 1979 to c1989, flying-foxes were seasonally identified flying in towards and across this forested tract in thick droves, so that during the early dusk a patch of sky in their flight-path would contain in the region of 200 flying-foxes at any one time. The main migration was seasonal, and determined, in a north-east to south-westerly direction from the Susan Island Nature Reserve, with the animals spreading out in separate streams only as they gained the forest boundary with Lot 2 Shannondale Estate. At that point many continued on deeper into the forest, while many numbers clustered on the fringe, where their foraging and noisy interaction carried on through the night. There was no doubting that this habitat, in such close proximity to the important Susan Island camp, was most definitely extremely significant for the flying-foxes.
More recently the numbers of flying-foxes have dwindled, so that in most years none are seen in the sky, being missed simply by lack of numbers. At other times just a few animals are heard foraging for food, usually within flowering Eucalyptus henryi (broad-leafed spotted gum) along the disused road reserve on the common boundary between Lot 119 and Lot 2 Shannondale Estate. The last record of this species was 10th March 05, when an estimated 6-8 animals were feeding nightly among a small remnant patch of grey-box woodland to the east of the Shannondale Estate (NPWS Wildlife Atlas, GPS 483445 : 6702278).
Cumberland Ecology (SIS) suggests there is some potential for the species to feed on flowering eucalypts in the area. Yet Richards (2004) provides a list of local eucalypt species known to be regularly utilised by flying-fox within the Shannon Creek area. These are - Blackbutt, Red Bloodwood, Baileys Stringybark, Needlebark Stringybark; Swamp Mahogany; Swamp Turpentine and Broad-leafed Paperbark. This area of forest habitat supports a number of other food species listed by Hall & Richards (2000) as significant to the grey-headed flying-fox . The full list comprises :
Eucalyptus globoidea (winter-flowering)
Eucalyptus grandis (winter-flowering)
Eucalyptus psammitica (winter-flowering)
Eucalyptus robusta (winter-flowering)
Eucalyptus tereticornis (winter-flowering)
The SIS fails to note many of these species as being useful to flying-foxes. Yet by the earlier regular visitations of large numbers of grey-headed flying-foxes, and by the Recovery Plan's definition (RP p 15), this remnant bushland adjoining and adjacent to Shannon Creek has to be recognised as a food source critical to the survival of the species, by reason of its being:
productive during winter and spring
known to support populations of >30,000 individuals within an area of 50km radius from the camp
productive during the final weeks of gestation and during the weeks of birth, lactation and conception (ie, Sept-May)
Cumberland Ecology, in preparing the 8-part test for flying-fox, fails to reconfirm his knowledge of the significantly important winter food resource within the area: Eucalyptus globoidea (white stringybark); E grandis (Flooded gum), and E tereticornis (Forest red gum). The preferred swamp mahogany (E robusta), which forms a part of an endangered ecological community, comes within this winter-flowering category, as does the rare, poorly known sandstone mahogany, Eucalyptus psammitica, which also forms the base of an endangered ecological community (pending determination), and is also enjoyed by flying-foxes. Another food source, not mentioned in the 8-part test is the Pink bloodwood (Corymbia gummifera), which is highly favoured by flying-foxes.
Objectives outlined in the Recovery Plan, relevant to Clarence Valley Council's landholding, include identifying and protecting foraging habitat that is critical to the survival of grey-headed flying-foxes, and protecting and increasing the extent of key winter and spring foraging habitat.
Yet while all of these food species occur in many numbers across the Shannon Creek study site, and mainly across the eastern forested tract, this area is now planned to be dissected by roads and other infrastructure in two separate places. To date there is no plan by the Clarence Valley Council to undertake a proper assessment of the area's fauna and flora values, as required under the newly amended Threatened Species Conservation Act, nor is there any commitment to protect the forested land from future subdivision and development.
Much of the dry rainforest food recourses surrounding the proposed dam site will be impacted by the project, either by clearing, by altered hydrology, and eventually by a rim of compacted dry earth as the dam level recedes, acting as a support vector for weeds and radiating summer heat in close proximity to the gully habitat.
These details are not admitted, nor considered, by the 8-part test. Nor, although required for the SIS process by the TSC Act, are there any suggested alternatives to reduce any of the proposed impacts to the many identified threatened species.
If the CV Council was to adopt a decision to protect the full forested habitat, Lots 119/59, east of Shannon Creek, then as well as the flying-fox, other fauna species that would benefit, of interest to the Federal Minister, would include swift parrot; koala; spotted-tailed quoll; peregrine falcon, and needletail swift. A good many other species of interest to the State of NSW would also benefit by that protection.
Response to The 8-Part Test (Cumberland Ecology)
Part (a) - whether the life cycle of the species is likely to be disrupted such that a viable local population is at risk of extinction
CE admits that clearing for the construction of the storage facility and associated infrastructure will involve removal of approximately 100 hectares of "potential" foraging habitat for flying-fox. He then claims this represents just 3% of the total foraging habitat for flying-fox within the study area.
The Species Profile (Vol 3, Table 3.6) in fact indicates 152.13 hectares of forest and woodland habitat for flying-foxes are to be removed by the various components of the project, while a re-addition of the presented figures concludes that 187.14 hectares are in fact to be removed, a greater than 80% increase in CE's approximation. Yet the only consideration to food resources for grey-headed flying-fox is given to species listed earlier as having some potential to serve as forage.
CE also claims that as no roosting colony has been identified within the study area, then no breeding habitat will be removed and consequently there will be no disruption to the life cycle of the grey-headed flying-foxes by dam construction, access road, design modifications, power supply and upgrade of existing roads.
By the Recovery Plan food resources are equally as critical as roosting habitat to the survival of the grey-headed flying-fox, and ...loss of foraging habitat is consistently identified as the primary threat to grey-headed flying-fox (p18). As demonstrated above, with the close proximity of the major roost on Susan Island, this forested tract where the diversity remains virtually intact has to be recognised as just such a vital food source.
By this part also, as required by the TSC Act, Div 2.110(h), CE should have suggested l an alternative option to the proposed clearing of two corridors through the forest for infrastructure; l a possible alternative to the proposed water supply project in general, and l should have discussed the likely future impacts should this remnant forest be sold for subdivision and development.
Part (c) - whether a significant area of known habitat is to be modified or removed
There has been no research whatsoever into the use by flying-fox of this local area. CE claims that "No significant known area of habitat will be removed" yet he is unaware of any known habitat. Therefore his conclusion is random at best, and is based on guesswork.
CE in this part fails to reiterate the 100 hectares of "potential" habitat proposed to be removed by the project. Neither does he examine the finding by the The Species Profile (Vol 3, Table 3.6) that 152.13 hectares of forest and woodland habitat for flying-foxes are to be removed by the various components of the project (which in fact equate to 187.14ha, as discussed above).
There is no consideration by these figures of the further food resources proposed to be removed by the workers' compound, to be constructed within the valley loop below the proposed dam wall. Although mainly grassland, there are considerable numbers of old and regrowth trees within this loop that will be destroyed, while the entire area across the Shannon Creek and escarpment bases will be impacted by prolonged construction activity.
Part (d) - Whether an area of known habitat is likely to become isolated from currently intercon-necting or proximate areas of habitat
CE states that grey-headed flying-fox is unconfirmed within the study area. This is an incorrect assumption, as would have been quite easily proven by local research. He then cuts and pastes a good deal of information about corridors, irrelevant to flying-foxes, whose migratory habits are opportunistic, dictated by food, not instinct. Nevertheless CE also admits that this habitat forms "potential" corridors, and that these are to be impacted by the project.
What should have been given serious consideration by this part is the loss, fragmentation and generally increasing isolation and depletion of feeding resources by development across the entire NSW east coast, which is a recognised key threatening process.
CE also states that, "Notwithstanding the potential for the project to impact upon continuity of habitat, large areas of habitat will remain after construction of the Regional Water Supply Project".. and claims as a benefit that "...cessation of cattle grazing and timber harvesting in the buffer, compensatory habitat areas (eg Black Swamp) and other non-developed areas may allow vegetation regeneration.."
The only areas currently benefiting by already cessation of cattle grazing are the proposed inundation zone, the proposed workers' compound area, and the now slowly naturally regenerating valley loop to the north which is proposed to be further impacted by a prolonged revegetation process. There is no consideration of the length of time required, from the end of construction activities, for the depleted food supplies to regenerate to a stage of again providing a useful food resource for flying-fox.
Also there is no suggested alternative to clearing two proposed corridors through the forest instead of just one, and no consideration of the likelihood of subdivision of the eastern forested area as surplus to requirements, once it is serviced by access, power and water.
Part (g) - Whether the development or activity proposed is recognised as a threatening process
The major, and key threatening process by this development, recognised by the Recovery Plan, is clearing of native vegetation. The full habitat to be removed by the project from the current supply is 187ha of native vegetation forest, woodland and swamp vegetation, comprising all species enjoyed and utilised at some time or another by grey-headed flying-fox. Yet CE glosses over this threat and chooses instead to indicate the Commonwealth Phytophthora cinnamomi Threat Abatement Plan as a benefit. The possible enormous risk posed by this already introduced pathogen is generally recognised, though not by this part.
There is no mention of the fact that the pathogen, once introduced, is impossible to eradicate (P cinnamomi Threat Abatement Plan). Neither is there any admission that the methods of control suggested by the TAP are at this stage entirely experimental.
The Phytophthora cinnamomi Plan of Management,
By Table 3.6 (p3.19) CE indicates that the likelihood and consequences of impact by infection of this pathogen are low. Yet the vegetation communities now known to be infected with the pathogen are shown to be Community # 3 (Coastal Swamp Sclerophyll); Community # 5 (Blackbutt; Bloodwood; Angophora); and Community #12 (Coastal Freshwater Wetland). Two of these are listed endangered ecological communities, and all three communities are important foraging habitat for grey-headed flying-fox.
Rather than guessing at a low risk factor, CE should instead have followed the precautionary principal and indicated grave concerns about the possible impact that this invasive die-back disease may have on remaining areas of preferred foraging habitat for the grey-headed flying-fox.
CE's conclusion for his 8-part test, as with his finding for every single other threatened species, is that " ...The approved project components, access road, design modifications, power supply and upgrade of existing roads are unlikely to have a significant impact upon this species".
Grey-headed flying-foxes are, in fact, of particular concern, and must be seen as being particularly at risk by this proposed project.
There has been a troubling increase in abnormalities of newborn flying-foxes in recent years, in some instances comprising 1% of young brought into human care (Peggy Eby, WIRES records). In the main this is believed to be caused by food shortages, specifically during late winter and early spring when female grey-headed flying-foxes are in the early stages of pregnancy. At these times the animals are inclined to try to feed on unripe fruit, which often contains alkaloids produced by the trees especially to deter just such premature feeding.
With habitat constantly being removed from the flying-fox food bank, the numbers of grey-headed flying-foxes are known to be dwindling rapidly, with a regular decreasing trend (NSW flying-fox counts). As recognised by the Recovery Plan, this now severely threatened species is at a vital stage, and any removal whatsoever of any further food resources could well prove to be the cause of further unsustainable decline of the species.
In this case, although it may already be too late to preserve the grey-headed flying-fox in numbers sufficient to maintain a viable population, the proposed destruction of a further 187.14ha of foraging habitat by the proposed Shannon Creek dam has to be considered significant.
The Recovery Plan aims to save the species from precisely such human development activities as is proposed by this unnecessary regional water supply project, which s fails to examine and embrace the benefits of improved technology by cost and future water security s fails to follow legislated laws under the amended TSC Act, and s fails to factor into the decision-making process the threat of climate change and associated stress to the river by prolonged periods of drought.
This SIS, by the TSC Act, is required to suggest alternatives to the proposed impactful activities, which it has failed to do, and there is no recommendation for the full protection of the remaining tract of forested lands that could help support the grey-headed flying-fox in perpetuity.
The Minister is urged in this case to recognise that there are alternatives to this proposed project, and that by the SIS, and by the proposed regional water supply project as a whole, there is not sufficient or satisfactory consideration given to the crucial requirements and current predicament of the grey-headed flying-fox.
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5 Patricia Edwards (2005), Scientific Licence No S11209