Major flaws in Westconnex EIS Biodiversity study

Biodiversity effects are defined narrowly in focusing on potential impacts on Threatened Species.

By Debra Little

Methodology and EIS statements re “the highly modified nature of the project footprint” (20-14)

Typically an EIS downplays or dismisses the habitat value within a project footprint in order to remove or limit the biodiversity-promoting value that is there, and/or to understate the impacts of the project. This EIS is no exception.

The EIS field surveys ( observations in the field) are very limited in duration and season (as usual in an EIS) – the “short duration of surveys” is acknowledged (20-3) as well as “it is possible that seasonal species were not identified”(20-3): for this EIS it was 1 day (12/2/15: no number of hours specified) and one night (27/2/15: also no duration specified) in one area (not specified where), with additional surveys on 12/3/15 and 26/6/15 “to investigate areas not covered by the previous surveys” (20-3). (It is not specified where if a physical location is referred to, nor whether it was day or night, and the duration).

Repeated sampling over some time period is really needed to develop anything representing a comprehensive survey. And if you are not (inclined to be) looking for it, you don’t tend to find it, and if you are quite time limited as all EIS’s are, you are falling well short of what is a satisfactory, let alone a rigorous survey process.

Threatened Fauna Species

The EIS acknowledges that Grey-headed Flying-foxes (GHFF) use the area when foraging for food. An evening field study, consisting of two evenings only, confirmed this.

The project footprint is well within the nightly foraging range of the Clyde/Duck River camp, as well as other urban Sydney GHFF camps.
Urban GHFF camps have become important to the survival of the species which is now classed as Vulnerable under Federal and State legislation.
Neither street trees nor private garden trees have been included in loss of area calculation (see more on this below). Trees in these “unaccounted for” areas can be and are very important food resources for GHFF feeding.

This foraging habitat should have been quantified in their assessment and their conclusion re GHFF foraging habitat impact. As a result the area and significance of foraging habitat has been understated.
On 20-16, the EIS states that “These planted trees do not constitute habitat critical to the survival of the Grey-headed Flying-fox.”
As there is currently no declaration by either the NSW or Federal Government as to what constitutes critical habitat this statement is disingenuous.

Stating under the heading Cumulative Impacts (20-20) that the combined Westconnex projects would result in “the removal of mainly planted vegetation and associated fauna habitats” (20-20) is not an adequate assessment of the whole Westconnex’s project impact on Grey-headed Flying fox foraging habitat.

Grey Headed Flying Fox by Andrew Meares
Grey Headed Flying Fox by Andrew Meares

This species in its increasingly urban environment relies on much planted vegetation. Indeed the number of urban camps now in the Greater Sydney area is a result of the available food provided by such urban planted landscapes in proximity to camps – themselves also located in some cases amongst planted vegetation, especially as suitable habitat elsewhere in the species range has significantly contracted since European occupation (estimated at 50 % loss: Eby,P).

The whole Westconnex project – combined M4E and New M5 will impact on urban GHFF foraging habitat to a significant degree.

Micro – bats (Large-footed Myotis and Eastern Bentwing Bat)

Given the very limited field surveys undertaken and poor quality recording of calls during these, the EIS cannot substantiate claims about the extent of use of existing infrastructure as roosting sites, nor claims about breeding habitat. The EIS claims there is no breeding habitat in the study area, but a breeding habitat can also include roof and wall cavities in the absence of tree hollows.

Nor is there substance to the claims about re-colonising new roosting sites eg. continuing to use culverts post construction disruption (20-16). There is no evidence quoted to indicate this will happen.


It’s stated as being substantially planted vegetation – “Planted trees and gardens”, including parkland, involving 15.7 hectares made up of 12.9 hectares of planted trees and screening vegetation (although inconsistently, the EIS also refers to 13.3 hectares on page 27-11), and 2.8 hectares of grassland with scattered trees (i.e. parkland).

The EIS has not quantified the loss in area and nature of vegetation from private gardens and street trees. This should have been done since they claim they are providing in this EIS “a detailed assessment of ecological issues including impacts on flora and fauna”.

The EIS included these areas in the 83 species number cited (20-6); it also should have been straight-forward to map the coverage, and so approximate area covered by this private/street vegetation. This was not done. This downplays the role (and given the aforementioned, the extent) of vegetation of any sort. Irrespective of whether it is planted or remnant, it is potentially important and can play an ecological role (ref. Fly-fox info. above).

The EIS therefore makes no real assessment of the nature and quality of the planted vegetation which can stand in to some extent for remnant vegetation if well planned and maintained.
Dismissing it (just) as planted eg on 20-13 “All the above creek lines only have planted vegetation within their riparian corridors ….” fails to provide any further detailed (qualitative or quantitative) assessment as to ecological value as claimed.

All city vegetation is important in the context of preventing, and countering the urban heat island effect, a recognised phenomenon. For instance, see , and there are urban biodiversity benefits of both planted as well as remnant vegetation well acknowledged by others.
For instance see September 2015 (Vol. 16, No. 3) of Ecological Management and Restoration (EMR) (pp. 206-213). Trees and shrubs (although the latter is not mentioned in the EIS) certainly “have the potential to provide nesting and shelter habitat for common birds and possums” (20-12). Not mentioned is that they also provide food resources either directly, or indirectly. This is a sloppy omission, but again it downplays and limits the vegetation’s role.

Statement that vegetation connectivity is limited

Some animal species manage quite well in small and fragmented patches, and providing that patch distance is not too great other species are able to move between and utilise such patches.

Suburban gardens are an example of this even where there is no direct house to house connectivity and there are roads and footpaths separating areas; an example animal species would be the once common Superb Blue Wren, a small bird species which moves between home gardens finding necessary resources (nesting sites, shelter, food) quite satisfactorily. Ditto Blue Tongue Lizards, also once common but now in decline in urban areas. Given the EIS has not quantified nor assessed the ecological role of private gardens and street plantings (see above), EIS comments about connectivity do not tell the whole story and so the potential connectivity (and ‘stepping stones’) that exist via this vegetation is ignored.


Garden and house in Walker Avenue, Haberfield would be bulldozed
Garden and house in Walker Avenue, Haberfield would be bulldozed

There is some acknowledgement that existing patches “may be used as ‘stepping stones’ for fauna movement”. No “may” about it. And such stepping stones are especially important for fauna crossing and leaving cities. It is known this does happen, and is important for migratory species, such as annual migrations of Yellow-faced Honey eaters observed through Sydney. Lack of connectivity disadvantages some, but by no means all native species.

Cumulative Impacts

20.4.7 of the EIS says “These losses in biodiversity are likely to be restricted in area (note the “likely” – this is again unsubstantiated opinion ), given their location in highly modified environments” (26-10).

Highly Modified environments are synonymous with cities – that’s why we especially need to preserve the green spaces and associated vegetation that are there. We can’t afford to lose more ‘havens’ within highly modified areas.

This is where cumulative impacts are more acutely felt, and to dismiss them leads to a death by a thousand cuts scenario.

It is fatuous to say (20-15) that “The removal of planted vegetation would result in minimal fragmentation (ie loss of connectivity between vegetation), given the already fragmented state”.

There is no mention of any compensatory parkland or other green space creation. Why should Westconnex be permitted to simply demolish the 15.7 hectares described in the EIS without creating any alternative/s.

If anywhere, in large cities with inevitably limited green space, and in such a generally modified environment, there should be mandatory, compensatory creation of green-spaces.

This is not generally done – just increased pressure on existing, contracting green-space areas.

The conservation of urban biodiversity has profound benefits for human well-being – physical and psychological health – *(Turner et al 2004: Global Urbanisation and the separation of humans from nature, Bioscience **54 585-590)* yet this social value to people is not addressed at all.**

There is also no attempt to assess the loss to biodiversity across the whole Westconnex project M4 widening, King Georges Interchange, M5 duplicate and the linking M4/M5 project. A Southern Motorway (F8) is also referred to in the EIS which would threaten wetland. This is a serious deficiency in the EIS.


3 thoughts on “Major flaws in Westconnex EIS Biodiversity study

  1. Hi, my name is John McCarthy and I work as an environmental lawyer in NSW. I just had a brief look at the summary of the EIS and it is apparent that the EIS flora and fauna surveys would not satisfy the requirements of the NSW Threatened Species Act NSW 1995 and therefore this project would seem to be open to challenge in the Land and Environment Court NSW. I have worked on quite a few Threatened Species cases, see Torquil Cameron V Nambucca Shire Council regarding the seasonality of studies and the requirement of 12-month study periods for Flora and Fauna. At this stage, I would contact the NSW Environmental Defenders Office for advice if you have not already done so. Regards, John


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