To: Phil Mansfield - Property Manager cc: From: Brendon Graham - Natural Areas Manager Geoffrey Doret – Greenweb OffIcer Date: 13 April 2012 File Ref: EM/08/852474 Subject: Woronora Cemetery expansion 1. Purpose of Memo I refer to the proposal to expand the Woronora General Cemetery as shown in the attached copy of Drawing No.907223.1.1 supplied by Ian Baker Consulting Pty Ltd. This memo briefly describes the characteristics of the area intended for the proposed development and outlines the reasons why it is not supported. 13 April 2012 Subject : Woronora Cemetery expansion proposal Page 2 2. Summary It is understood that the Woronora General Cemetery under its current regime cannot adequately continue to provide final resting places for the growing population. The proposal to expand the cemetery into the adjoining public bushland is not considered a sustainable solution that can be supported. The environmental, cultural and recreational impacts of the proposal are considered unacceptable. The planning instrument that guides decision making for land use in the Sutherland Shire also precludes the development of the site. 3. Location Woronora Cemetery is located on a broad plateau 100m in elevation above the Woronora River in the suburb of Sutherland. The proposal is to expand the cemetery further west into an adjacent area of bushland. The bushland is part of the public open space called Prince Edward Park. Prince Edward Park is located on the southern side of the Woronora River valley on a broad spur between the confluence of Forbes Creek and the Woronora River. 4. Historical background of Prince Edward Park The area first came under Council's control when it was renotified as Crown Reserve No 44051 for Public Recreation in 1909. In 1911, Council named the Crown Reserve as "Boyle Park" after Councillor Edward (Ted) Boyle. In June 1920, Council resolved to rename the park after His Royal Highness Prince Edward, the Prince of Wales (later to become King Edward VIII). Prince Edward had arrived shortly before in Australia on a tour to thank Australians for the part they had played in World War 1. He apparently was a popular figure who was greeted with great enthusiasm wherever he went, and was given the 13 April 2012 Subject : Woronora Cemetery expansion proposal Page 3 affectionate title of the "Digger Prince". Councillor Boyle later received alternate recognition through renaming of the former Station Street as Boyle Street in 1942. The adoption by the Geographical Names Board of the name "Prince Edward Park" in 1973 recognised the name as pre-existing and confirmed it as the official name for the park. To revoke part of Prince Edward Park for a cemetery would be considered a decision that lacks recognition of the historical background and intent of the original reservation for public recreation. 5. Site description The area of Prince Edward Park that is being considered to accommodate the expansion of the cemetery is located on Crown land identified as Part Lot 7028 DP 752064. Under the Sutherland Shire Local Environment Plan (SSLEP) 2006 the property is zoned Zone 14 Public open Space (Bushland). The proposed site contains bushland of high quality with significant environmental, heritage and recreational values. The area is currently serviced by several public walking tracks including an important and popular lookout at the top of the escarpment. There are currently walking tracks linking First Avenue at the southern side of the cemetery with a track near the oval coming from Linden Street at the northern side of the cemetery and a track that leads from the north-west corner of the proposed area to Prince Edward Park Road and onto the Woronora River. A small intermittent creek drains from the cemetery to the south- west into Forbes Creek. The site is also located within Council’s Greenweb. Greenweb is a strategy to conserve and enhance Sutherland Shire's bushland and biodiversity by identifying and appropriately managing key areas of bushland habitat and establishing and maintaining inter connecting linkages and corridors. Greenweb has been incorporated into Council’s Sutherland Shire Development Control Plan 2006 (SSDCP2006) and was gazetted by the Department of Planning NSW on 15th November 2006. It has been mapped into; core habitat areas (known as Core), areas which act to support core habitat areas (known as Support) and areas where the creation of vegetated links would assist long term biodiversity (known as Restoration). It is this map that now forms part of SSDCP2006. The land marked for acquisition for cemetery use at 114R The Grand Parade, Sutherland is located in Council’s Greenweb and is identified as a Core area. The SSDCP2006 defines Core as; Areas of high significance to the sustainability of the Greenweb as they contain either key habitat areas, key linkages, threatened species or endangered ecological communities. These key habitats are of a size that maintains their viability and are generally larger than 3.5 hectares. The land proposed for requisition full-fills this role as it is a large area of natural bushland well in excess of 3.5 hectares, providing important habitat as well as opportunities for wildlife movement acting as an important corridor along the Woronora River. 13 April 2012 Subject : Woronora Cemetery expansion proposal Page 4 There has also been several recordings of threatened fauna species in this area, including Phascolarctos cinereus – Koala and Ninox strenua – Powerful Owl, both of which are listed as Vulnerable under the NSW Threatened Species and Conservation Act 1995. It also contains the Endangered Ecological Community Southern Sydney Sheltered Forest on Transitional Sandstone Soils which is also listed under this Act. Core areas are of high significance for the conservation of local habitats and provide connectivity for the movement and interchange of both flora and fauna which is important to maintain healthy populations and diversity. Should such a clearing event occur in a Greenweb area, the impact is far more pronounced as this is where Council has identified land that will assist in the long term sustainability of the natural environment and as such has far more greater conservation value 6. Impacts to vegetation The vegetation in the area marked as section 19 on the map provided is considered to be Southern Sydney Sheltered Forest on Transitional Sandstone Soils. This community is listed as an Endangered Ecological Community on the Threatened Species Conservation Act (1995). It is characterised by an open canopy of trees with an average height of 15 metres. The canopy is dominated by Grey Gum Eucalyptus punctata, Red Bloodwood Eucalyptus gummifera, Scribbly Gum Eucalyptus haemastoma and Blackbutt Eucalyptus pilularis. Occasional Turpentine trees Syncarpia glomulifera are present indicating the presence of clay/ shale soils that have washed down from the ridge above. The understorey is extremely diverse with a range of woody shrubs, climbers, grasses and herbaceous plants. Species include Old Man Banksia Banksia serrata, Broad-leaf Hakea Hakea dactyloides, Black She-oak Allocasuarina littoralis, Eggs and Bacon Dillwynia retorta, Gymea Lily Doryanthes excelsa and several grevillea and wattle species. Vegetation in the area marked on the map as 8 and 9 has been mapped as Sydney Turpentine Ironbark Forest. Remnant Turpentine Syncarpia glomulifera, Scribbly Gum Eucalyptus racemosa and Smooth-barked Apple Angophora costata trees are located in this area. Sydney Turpentine Ironbark Forest is listed as an Endangered Ecological Community on both the NSW Threatened Species Conservation Act and the federal Environmental Protection and Biodiversity Conservation Act (1999) due to its extremely limited distribution. The proposal is likely to remove or significantly affect over 13 hectares of bushland. The site has been mapped as a Core area of the Sutherland Shire Greenweb. Greenweb identifies existing and potential vegetation corridors across the shire. Bushland is also protected under the provisions of SEPP 19 Urban Bushland. SEPP 19 applies to this site and generally aims to protect bushland because of: (a) its value to the community as part of the natural heritage, (b) its aesthetic value, and (c) its value as a recreational, educational and scientific resource. Clearing bushland is recognised as a major cause for the loss of biodiversity resulting in flora and fauna species becoming extinct or endangered. As a consequence Clearing of Native Vegetation was listed in 2001 as a Key Threatening Process on the Threatened Species Conservation Act. 13 April 2012 Subject : Woronora Cemetery expansion proposal Page 5 The proposal would not be permissible under the SSLEP 2006. It does not satisfy the Zone 14 Public Open Space (Bushland) objectives: (a) to enable development that facilitates recreation and preserves natural bushland areas located on publicly owned land, (b) to allow development that does not adversely affect natural bushland or wildlife corridors, (c) to protect public open space that is of environmental significance, (d) to ensure that flora and fauna habitats are protected and preserved for their aesthetic, educational and scientific value. The existing cemetery has an impact on the adjoining bushland lower down the slope. Increased run off and higher nutrients from the facility have resulted in weed invasion and degradation of the small creek lines. Extending the cemetery to the top of the escarpment as proposed would likely result in similar environmental problems in the currently good quality bushland below the escarpment. The proposal cannot be supported as it would result in a significant impact to an already endangered ecological community within Prince Edward Park. 7. Impacts to rare plants Several rare plants listed on the Rare or Threatened Australian Plants (ROTAP) database have been recorded in Prince Edward Park (but not necessarily on the subject site). Extensive surveys would be required to confirm the existence or absence of rare plants within the footprint of the proposal. Vegetation including any rare plants below the escarpment could be indirectly affected by the proposal. Rare plants recorded in Prince Edward Park Species Hibbertia nitida Common Name Shiny Guinea Flower Status Rare 2RC Melaleuca deanei Deane’s Honeymyrtle Rare 3RC- Syzygium paniculatum Magenta Lillypilly Rare 3ECi Tetratheca neglecta Black-eyed Susan Rare 3Rc Grevillea longifolia Rare 2RC Description Small shrub to 1m with shiny leaves and yellow flowers. Found scattered on sheltered slopes. (Likely to be on the subject site). Small shrub to 1m with dull green/ grey leaves. Found on dry sandstone ridges. A medium size tree with glossy leaves found along water courses and moist areas. Low shrub to 500mm with purple flowers. Found scattered on ridges and protected slopes. (Likely to be on the subject site). Medium shrub with long serrated edged leaves and red flowers. Restricted to creek banks. 8. Impacts to fauna The subject vegetation is part of a major corridor along the entire Woronora valley that provides habitat for a rich diversity of fauna including threatened species. Threatened fauna species recorded within 500m of the site include the Powerful Owl and Koala. Both species are listed as Vulnerable on the Threatened Species Conservation Act 1995. The Koala and the Powerful Owl have a large habitat range and just a few pairs utilise the Woronora Valley. They have both been recorded several times on the site over the past 15 years. Grey Gums one of the preferred food species of the Koala is present on the site. Powerful Owls roost in the dense forest undergrowth during the day and prey on possums in the night. The removal of 13 hectares of bushland would be an incremental loss of habitat for both species. 13 April 2012 Subject : Woronora Cemetery expansion proposal Page 6 The site also provides habitat for many more common fauna species. Mammals using the site for habitat include Brush-tail Possum, Ring-tail Possum, Sugar Glider and Swamp Wallaby. Common reptiles such as the Blue-tongue Lizard, Red-bellied Black Snake and Lace Monitor are also likely to use the site. 9. Impacts to Aboriginal heritage Nine Aboriginal sites are recorded on the Aboriginal Heritage Information System (AHIMS) for Prince Edward Park; six of those are in bushland in close proximity to the proposed expansion of the cemetery in the north west corner. Sites include a shelter with art, an axe grinding groove and shelters with midden. Even if the development did not directly involve the destruction of Aboriginal sites the integrity of an Aboriginal place would be compromised. Altered run-off could change drainage patters and adversely impact on art in shelters. Refer to map of Aboriginal sites in the area on page 7. 10. Impacts to community Bushcare The Prince Edward Park Bushcare Group volunteers have worked in Prince Edward Park since 1994. Records show that over 5760 person hours have been spent in the reserve during this time controlling weeds and promoting the regeneration of bushland. This is valued at $172,800 worth of volunteer environmental work. In addition contractors have been employed at various times over the past several years to a value of $11,300. The area for the proposed expansion is serviced by several tracks that provide easy access to the site which is regularly used for seed collection to provide propagation material at the council nursery. Council have also conducted Bushcare educational bushwalks using the area as part of the loop walk through Prince Edward Park. The proposal is not supported by the Bushcare group who have volunteered over many years to assist with the management of the park. 11. Impacts to recreational opportunities The existing walking tracks (some not shown on the map provided) are popular with walkers, hikers and local residents. An important lookout would be cut off from public access. The area designated for the proposal is less steep that further down the slope and provides the best opportunities for short bushwalks from Sutherland and Loftus. 12. Visual impact If the proposal was to proceed the existing treed skyline would be lost. The impact is likely to be visible from areas of Woronora Heights, Bangor, Sutherland and Woronora. 13 April 2012 Subject : Woronora Cemetery expansion proposal Page 7 13. Soils Soils in this area are derived from Hawkesbury Sandstone making them very skeletal and shallow with many rocky outcrops, ledges and escarpments. This type of landscape would not be conducive for burials. 14. Fire The site is bushfire prone and will require the creation of an Asset Protection Zone (APZ) within the proposed development, effectively reducing its size. The width of the APZ will take into account the vegetation type, slope and aspect of the site. The vegetation type is dry sclerophyll forest on the down side of some steep slopes with a western facing aspect. As such this would usually result in the APZ requiring the greater recommended distance. However the width of the APZ maybe negotiable due to the type of ‘development’ proposed but protection of assets, workers and visitors would still be relevant. 15. Conclusion The proposed expansion of the Sutherland Cemetery into Prince Edward Park is not supported for the following reasons: Significant loss (13 hectares) of an endangered ecological community - Southern Sydney Sheltered Forest on Transitional Sandstone Soils. Inconsistent with the SSLEP 2006 zoning – Zone 14 Public Open Space (Bushland) Potential impact to endangered species recorded within 500m of the site – Koala and Powerful Owl. Bushcare site since 1994. Loss of public open space and popular walking and recreational opportunities. Impact to Aboriginal heritage. Visual impact from loss of vegetation. Inconsistent with SSDCP2006 – Ch 4 Natural Resource Management 1. Greenweb 13 April 2012 Subject : Woronora Cemetery expansion proposal . Page 8 13 April 2012 Subject : Woronora Cemetery expansion proposal Page 9 End of Advice