RECOMMENDATION REPORT

Commercial Development on

Jandakot Airport

(EPBC 2007/3599)

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Recommendation report Recommendation That authorisation not be given for the proposal to reduce the conservation precinct, and clear 102ha of native vegetation to construct the 4th runway, roadworks and facilitate commercial development at Jandakot Airport, WA (EPBC 2007/3599) under the Airports Act 1996.

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Material on which this recommendation report was based

Preliminary Documentation and Public Comments: i. Jandakot Airport Roadworks and 4th Runway Draft Major Development Plan – Public

comment and exposure draft version (July 2007). ii. Jandakot Airport – Request for Additional Information – Exposure Draft Major Development

Plan Fourth Runway and Road Works (September 2007). iii. Jandakot Airport letter, dated 15 January 2008 (response to public comments), including:

• Jandakot Airport Roadworks and 4th Runway Draft Major Development Plan – Draft Version (January 2008);

• Request for Additional Information – Jandakot Airport – Fourth Runway and Roadworks draft Major Development Plan – Copies of Comments Received, Section 95B(1)(b)(ii), EPBC Reference 2007/3599 (January 2008), (including copies of 4 public comments regarding the Additional Information received from): - Department of Environment and Conservation WA (January 2008), - Department of Planning and Infrastructure WA (December 2007), - Urban Bushland Council WA (December 2007), - Birds Australia WA (December 2007); and

• Request for Additional Information – Jandakot Airport – Exposure Draft Major Development Plan Fourth Runway and Road Works (January 2008), (addresses public comments by the above 4 parties).

iv. Jandakot Airport – Roadworks and 4th Runway – Draft Major Development Plan (January 2008) (addresses the 11 public comments received under s92(1B)(a) and s92(2)(a) of the Airports Act 1996).

Other Documents: v. Two letters from Ken Hurst Park, dated 8 December 2007 and 2 January 2008, providing

comment on the proposal. vi. Jandakot Airport Holdings Pty Ltd – Request for Additional Information (January 2008),

including the following documents: • Bamford, M.J., Staffer, V. & Wilcox, J. (2002), Fauna Survey of Jandakot Airport,

unpublished report prepared for Jandakot Airport Holdings Pty Ltd. • Cardno BSD (2005), Jandakot Airport Land Caladenia huegelii (Declared Rare Fauna)

Search, November 2005, unpublished report prepared for Jandakot Airport Holdings Pty Ltd.

• Mattiske Consulting Pty Ltd (undated), Flagging and Establishment of Buffer Zones Around Caladenia huegelii – Jandakot Airport, unpublished report prepared for Jandakot Airport Holdings Pty Ltd.

• Mattiske Consulting Pty Ltd (2001a), Bushland Condition Survey of Jandakot Airport Lease Area, unpublished report prepared for Jandakot Airport Holdings Pty Ltd.

• Mattiske Consulting Pty Ltd (2001b), Declared Rare and Priority Flora Survey of Jandakot Airport, unpublished report prepared for Jandakot Airport Holdings Pty Ltd.

• Mattiske Consulting Pty Ltd (2001c), Vegetation Mapping of Jandakot Airport Lease Area, unpublished report prepared for Jandakot Airport Holdings Pty Ltd.

• Mattiske Consulting Pty Ltd (2006), Review of Flora, Vegetation and Fauna Values in the Proposed Industrial Area at Jandakot Airport, unpublished report prepared for Jandakot Airport Holdings Pty Ltd.

• Letter to Jandakot Airport Holdings from the WA Department of Conservation and Land Management, dated 22 April 2004, regarding Declared Rare Flora – Caladenia huegelii.

• Letter to Jandakot Airport Holdings from the WA Department of Conservation and Land Management, dated 17 August 2005, regarding Declared Rare Flora – Caladenia huegelii.

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• Letter to Jandakot Airport Holdings from the WA Department of Conservation and Land Management, dated 10 November 2005, regarding Declared Rare Flora – Caladenia huegelii (Grand Spider Orchid) and Drakaea elastica (Glossy-leaved Hammer Orchid).

• Letter to Jandakot Airport Holdings from the City of Canning, dated 09 June 2004, regarding Rehabilitation Works by Jandakot Airport on Portion of Reserve.

vii. Jandakot Airport Holdings Pty Ltd – Options Brief – Submission to the Hon Mark Vaile MP, Deputy Prime Minister and Minister for Transport and Regional Services (August 2007).

viii. Jandakot Airport Holdings Pty Ltd – Master Plan (2005). ix. Jandakot Airport Holdings Pty Ltd – Variation to Master Plan (2008). x. Jandakot Airport Holdings Pty Ltd – Environment Strategy (2004). xi. Jandakot Airport Holdings Pty Ltd – Variation to the Environment Strategy (2008). xii. Australian Heritage Database – Place Details (Place ID: 18051 and 105483). xiii. P.F. Berry – Counts of Carnaby’s Cockatoo (Calyptorhynchus latirostris) and Records of

Flock Composition at an Overnight Roosting Site in Metropolitan Perth (2007). xiv. Bansi Shah – Conservation of Carnaby’s Black-Cockatoo on the Swan Coastal Plain,

Western Australia (December 2006). xv. Birds Australia and the Department of Conservation and Land Management (WA) –

Conserving Carnaby’s Black-Cockatoo – Future Directions (July 2003). xvi. R.E & C. Johnstone and T. Kirkby – White-tailed Black Cockatoos (Baudin’s Cockatoo

Calyptorhynchus baudinii and Carnaby’s Cockatoo Calyptorhynchus latirostris) on the Southern Swan Coastal Plain (Bunbury – Dunsborough) Western Australia.

xvii. Belinda Cale for the Carnaby’s Black Cockatoo Recovery Team – Carnaby’s Black-Cockatoo (Calyptorhynchus latirostris) Recovery Plan 2002 – 2012 (2003). (Western Australian Recovery Plan).

xviii. Department of Environment and Conservation (DEC) Kensington – Grand Spider Orchid (Caladenia huegelii) Interim Recovery Plan 2008 - 2012 (January 2008).

xix. Australian Network for Plant Conservation – Guidelines for the Translocation of Threatened Plants in Australia, Second Edition (2004).

xx. Two letters to the Department of Infrastructure, Transport, Regional Development and Local Government from Jandakot Airport Holdings Pty Ltd, both dated 13 February 2008, regarding the Draft Variation to the Jandakot Airport Environment Strategy (2004) and Draft Variation to the Jandakot Airport Master Plan (2005).

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Background

1. On 11 July 2007, the former Department of Transport and Regional Services (now the Department of Infrastructure, Transport, Regional Development and Local Government), referred an exposure draft Major Development Plan (draft MDP (2007)) for the proposal to reduce the conservation precinct, and clear 102ha of native vegetation to construct the 4th runway, roadworks and facilitate commercial development at Jandakot Airport, for a decision on the assessment approach under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). The proposal triggers the Major Development Plan (MDP) process because it is on leased Commonwealth airport land.

2. Section 160 of the EPBC Act requires the Department of Infrastructure, Transport, Regional Services and Local Government (Department of Infrastructure) to seek advice from the Minister for the Environment, Heritage and the Arts (Minister for the Environment), prior to the adoption or implementation of a MDP on leased Commonwealth airport land under the Airports Act 1996 (Airports Act). This recommendation report will be considered by the Minister for the Environment when providing advice to the Minister for Infrastructure, Transport, Regional Development and Local Government.

3. The initial proposal in the draft MDP (2007) included the following: • clearing 36ha of native vegetation for construction of a new runway, taxiways and

associated works; • clearing 4ha of native vegetation for new roads to the east and the south; • clearing 62ha of native vegetation to facilitate commercial development; • establishment of an ‘orchid park’ on 10ha of land adjacent to an area proposed for

commercial development, for the retention of approximately 120 endangered Grand Spider-orchids (Caladenia huegelii) in situ;

• translocation of approximately 80 Caladenia huegelii from areas proposed to be cleared to the ‘orchid park’; and

• a five year research proposal relating to the conservation and distributional status of Grand Spider-orchids, to establish a basis for understanding the biological and ecological factors that influence the rarity and conservation of native Western Australian orchids.

The proposal will result in a reduction in the size of the airport’s conservation precinct from 270ha to 210ha.

4. On 7 August 2007, the delegate for the former Minister for the Environment and Water Resources decided that the proposed action would be assessed by preliminary documentation, under section 95A of the EPBC Act.

5. On 16 August 2007, additional information on the potential impacts of the action was sought under the EPBC Act. Jandakot Airport Holdings Pty Ltd (JAH) submitted additional information on the proposal on 27 September 2007.

6. On 12 November 2007, the Department notified JAH that there was enough information to assess the proposal by preliminary documentation, although not all of the matters raised in the Department’s request for additional information had been fully addressed. The Department instructed JAH to publish the information for public comment and noted significant concerns about the following matters: • Impacts on the endangered Grand Spider-orchid (Caladenia huegelii) from the:

- translocation of approximately 80 Caladenia huegelii and the uncertainty of whether those plants will survive and propogate in the long-term;

- fragmentation of an important population of the species; - loss of connectivity to adjacent habitat and Caladenia huegelii populations, such as at

Ken Hurst Park; - isolated nature of the proposed Orchid Park within a commercial business zone; and

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- potential impacts on the orchid’s wasp pollinator from loss and fragmentation of habitat.

• Impacts on the environment on Commonwealth land from the: - proposed reduction in size of the conservation area at the airport, including in areas

that provide habitat connectivity to areas beyond the airport; - loss of good quality remnant banksia woodland; - loss of habitat for listed threatened species, including the Grand Spider-orchid

(Caladenia huegelii) and Carnaby’s Black-cockatoo (Calyptorhynchus latirostris); and - loss of habitat for other important species, including the Southern Brown Bandicoot

(Isoodon obesulus) and Western Brush Wallaby (Macropus irma).

7. JAH initially advertised the preliminary documentation for public comment on 22 November 2007 under section 95A of the EPBC Act. However, the advertisements did not meet the statutory timeframe requirements of the Act. JAH readvertised the proposal, however the second advertisements also failed to meet statutory timeframe requirements. JAH then readvertised the information for public comment from 4 December 2007 to 2 January 2008 (20 business days).

8. To avoid confusion regarding the information provided for assessment, the JAH documents will henceforth be referred to as the draft MDP (2007), revised draft MDP (2008) and additional information. The revised draft MDP (2008), which JAH amended following the public comment period, is the current proposal for assessment under the Airports Act and EPBC Act.

9. A total of 18 public comments were received on the proposed development. 11 comments were received in relation to the draft MDP (2007), and 7 in relation to the additional information. 16 submissions either raised significant concerns about the proposal or opposed it (refer to paragraph 11), and 2 submissions supported it (refer to paragraph 12). JAH responded to public comments on the draft MDP (2007) in the revised draft MDP (2008). All of the public submissions are addressed in this recommendations report.

10. Public submissions on the draft MDP (2007) and additional information were made by 3 individuals and the following organisations: • WA Department of Environment and Conservation (2 submissions); • WA Department for Planning and Infrastructure (Aviation Policy); • WA Department for Planning and Infrastructure (Environment and Sustainability

Directorate – 2 submissions); • Urban Bushland Council WA Inc (2 submissions); • City of Cockburn; • Airservices Australia; • Jandakot Special Rural Association; • Kardinya Residents Association; • Birds Australia WA; • Friends of Ken Hurst Park (2 submissions); and • WA Native Orchid Study and Conservation Group.

11. 16 submissions raised concerns about the proposal, including: • Impacts on the Grand Spider-orchids from:

- fragmentation of an important population of the species, - loss of habitat, - translocation, - disruption of ecological processes, and - urban edge effects;

• Impacts on the Carnaby’s Black-cockatoo from loss of feeding habitat; • Loss and fragmentation of regionally significant remnant Banksia woodland;

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• Impacts on species of State conservation significance from loss and fragmentation of habitat, additional roads through conservation areas and urban edge effects;

• Lack of information regarding the research proposal, impacts on and surveys for species impacted by the proposal;

• No compensation or offset proposed for species impacted by the proposal or the clearing of regionally significant bushland;

• Additional roads creating changes in traffic patterns and disturbance to the environmental values of the conservation precinct; and

• Increased in aircraft noise.

12. 2 submissions generally supported the proposal. These were from the WA Department of Planning and Infrastructure (Aviation Policy) regarding the development of aviation facilities, and the City of Cockburn (paragraphs 56 and 71).

13. An alternative to further development at the airport is discussed in the Jandakot Airport Options Brief (August 2007). It involves relocation of the airport to a site 40 kilometres south at Keysbrook in the Peel region.

14. On 8 January 2008, officers from the Environment and Infrastructure Departments met with the WA Department of Environment and Conservation (WA DEC), the WA Department of Planning and Infrastructure (WA DPI), and several non-government organisations (NGOs) including the Urban Bushland Council, Friends of Ken Hurst Park and Birds Australia WA, to discuss concerns that were raised in public submissions.

15. On 9 January 2008, officers from the Environment and Infrastructure Departments met with representatives from JAH to discuss the proposal. JAH was informed that the NGOs had raised concern about the poor quality of baseline information provided in the draft MDP (2007) and additional information. JAH advised that it had more baseline information that was not made available during the public consultation process. JAH subsequently provided that information to the Department with a letter dated 11 January 2008.

16. On 18 January 2008, a revised draft MDP (2008) was received by the Department (see map of current zoning for Jandakot Airport at Attachment A). This included the following changes to the proposal: • an increase in the size of the land swap for the proposed ‘orchid park’ from 10ha to 20ha,

which would result in approximately 250m of connectivity with Ken Hurst Park; • retention of 127 Caladenia huegelii in the ‘orchid park’ (rather than 120); and • translocation of 75 Caladenia huegelii into the ‘orchid park’ (rather than 80).

17. In addition to seeking authorisation for the proposed development, JAH has sought to vary the Airport’s Master Plan (2005) and Environment Strategy (2004), which have been approved under the Airports Act 1996. The Master Plan is a functional guide for the planning of the airport, integrating land use, environmental and transport issues. The Environment Strategy is a companion to the Master Plan. It is a policy framework that guides the management of environmental impacts arising from airport operations. Variations to those documents are required if the proposal to reduce the size of the conservation precinct, is to be approved under the MDP. While the Minister for the Environment has no formal role in the approval of those documents, issues concerning the variations are discussed in this report because they have implications for the assessment of the MDP proposal (refer to paragraphs 25 – 49).

Environmental record 18. On the basis of information available, JAH does not appear to be, or have been, subject to

proceedings in relation to a conviction for an offence or ordered to pay a pecuniary penalty, under a Commonwealth, State or Territory law for the protection of the environment or the conservation and sustainable use of resources.

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Assessment

19. Jandakot Airport occupies a 622ha site in south-west Western Australia. The airport currently comprises three runways and associated taxiways, tenant leased property, and approximately 400ha of remnant Banksia woodland, which is reasonably intact and in mostly good to excellent condition.

Environmental and regional context

20. The Banksia woodland at Jandakot Airport is one of the largest and best remaining remnants of this vegetation type on the Swan Coastal Plain. Approximately 400ha of it is listed on the Register of the National Estate (Place ID: 18051), and it is also an indicative place on the Commonwealth Heritage List (Place ID: 105483). Much of the site is also recognised as a Bush Forever site in Western Australia (Site No: 388) (refer to Attachment B – Map 1 Bush Forever Protection Areas – July 2004). Under JAH’s current Environment Strategy (2004) approximately 270ha of land is protected within the conservation precinct, which mostly comprises Banksia woodland.

21. The Banksia woodland at Jandakot Airport provides habitat linkage to other Bush Forever sites on the Swan Coastal Plain, including Ken Hurst Park to the immediate north of the airport (Site No: 245) and Acourt Road Bushland, Banjup (Site No: 389) (managed as part of the Jandakot Regional Park) to the southeast. The Jandakot Airport site is important for maintaining significant regional corridors to the north and south of the airport, which ensure the maintenance of genetic diversity of flora and fauna species.

22. Jandakot Airport provides important habitat for a number of listed threatened species and species of regional significance, including the: • Grand Spider-orchid (Caladenia huegelii) – endangered under the EPBC Act; • Glossy-leaved Hammer-orchid (Drakaea elastica) – endangered under the EPBC Act; • Carnaby’s Black-Cockatoo (Calyptorhynchus latirostris) – endangered under the EPBC

Act and threatened under the Western Australian Wildlife Conservation Act 1950; • Western Brush Wallaby (Macropus irma) – Priority 4, Western Australian Wildlife

Conservation Act 1950; and • Quenda (Southern Brown Bandicoot) (Isoodon obesulus fusciventer) – Priority 4, Western

Australian Wildlife Conservation Act 1950. 23. Jandakot Airport sits within an urban matrix that includes:

• conservation (Ken Hurst Park), recreational and urban areas to the north; • regional travel networks, including the Roe Highway and freight railway line to the north; • council and privately owned land to the east, including mineral extraction sites; • a conservation area to the southeast (Acourt Road Bushland, managed as part of the

Jandakot Regional Park) (refer to paragraph 20); • rural residential areas to the south and southwest; and • residential areas to the west and northwest. A map showing the location of Jandakot Airport within a regional context is at Attachment C.

24. Jandakot Airport partially overlies the northern margin of the Jandakot Groundwater Mound, which is one of two main shallow unconfined groundwater resources in the Perth metropolitan area. This shallow sand aquifer covers an approximate area of 760km2 from the Swan River in the north to the Serpentine River in the south. It is a significant source of drinking water for Perth, and recharges deeper confined aquifers such as the Leederville and Yarragadee aquifers. The Jandakot Groundwater Mound is highly susceptible to contamination from overlying sources.

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Conservation Precinct on Jandakot Airport

25. The extent of the existing conservation precinct at Jandakot Airport is unclear owing to discrepancies between the airport’s Environment Strategy (2004) and Master Plan (2005) that are referred to in paragraph 17.

26. JAH’s published Environment Strategy (2004) states that a review ‘has resulted in an expansion of the conservation precinct from 200ha to 280ha in an attempt to manage Jandakot Airport in a more sustainable manner’ (p. 28). A minor variation to the Environment Strategy (2004) was approved in 2005, which reduced the conservation precinct to 271.2ha. However, the Environment Strategy published on JAH’s website still refers to 280ha of land in the conservation precinct.

27. According to JAH’s approved Master Plan (2005) the conservation precinct is 270ha, and JAH states that it ‘increased the conservation precincts to approximately 270 hectares after conducting a review of the development precincts’ (p. 13-11).

28. JAH’s draft MDP (2007) states ‘Jandakot Airport Master Plan 2005 includes figures of both 250 and 270 hectares (for the conservation area), but should read 250ha’ (p. 86). However, the 250ha mentioned in the Master Plan (2005) is not a direct reference to the conservation precinct, but rather the extent of native vegetation that will remain on site to support Carnaby’s Black-cockatoo feeding habitat (p.13-15). In addition, JAH’s revised draft MDP (2008) incorrectly states: ‘As part of the approved December 2005 Master Plan, approximately 210 hectares of bushland has been set aside for conservation purposes’ (p. 78).

29. The WA DPI (Environment and Sustainability Directorate) notes that: ‘within the MDP (p. 33) JAH states that the Jandakot Airport Master Plan (2005) should have read 250 hectares to be set aside for conservation purposes, but does not explain how the number was calculated, given that, as stated above, the minor variation to the Environment Strategy, also approved in 2005, was for the retention of 270 hectares’ (November 2007).

30. In January 2008 the WA DEC commented in relation to the proposed reduction of the conservation reserve, that JAH has ‘not demonstrated that the remaining habitat would be sufficient to support viable populations of species, in particular of larger fauna species’ (p. 9).

31. JAH’s proposed variation to the Environment Strategy (2008) states that the calculation of area for the conservation precinct did not take account of the clearing required for the fourth runway in the Master Plan (2005), and should have identified 214ha set aside for conservation (p. 4). This contradicts JAH’s published statements that its intent was to increase the area for conservation, as referenced in paragraphs 26 and 27.

32. The Department notes that there are significant inconsistencies in the information on the area of the conservation precinct published by JAH in past and recently submitted documents. This has caused public concern and confusion. JAH has not addressed the concerns raised about the environmental consequences of the reduction of the conservation precinct to 210ha, although it has previously stated in the Environment Strategy (2004) that it had expanded the size of the conservation precinct to manage the airport in a more ‘sustainable manner’ (p. 28).

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Proposed clearing

33. The revised draft MDP (2008) (p. 7) states that JAH proposes to build a fourth runway that involves clearing 36ha of vegetation, as described in the Master Plan (2005). However, the Master Plan (2005) makes no mention of clearing 36ha of vegetation for the fourth runway.

34. The WA DPI (Environment and Sustainability Directorate) made the following comments in relation to that clearing in the draft MDP (2007): ‘JAH also does not explain why 36 hectares are needed to be cleared for the runway, considering Option 1 only indicates that an area of 20 hectares were required to be cleared’ (November 2007). JAH (February 2008) has subsequently written, in response to a request from the Department of Infrastructure for clarification, that the 36ha is a mistake, and the actual clearing required is 26ha. It states: ‘The reason the area has increased from 20ha to 26ha is because we have progressed the design of the runway to more accurately reflect the area required for the fourth runway.’

35. The revised draft MDP (2008) proposes clearing of 4ha of vegetation for road works on non-aviation land at Jandakot Airport. It states: ‘This land is not required for aviation activities and it’s position adjacent to the arterial road network makes it a suitable location for the proposed development as identified in the Jandakot Master Plan 2005’ (p. 7). However there is no reference in the Master Plan (2005) to a proposal to construct a road linking Ranford Road to the east, and Jandakot Road to the south through the conservation precinct.

36. JAH proposes to clear 62ha of native vegetation for commercial development. In the draft MDP (2007) JAH proposed a 10ha land swap from the existing conservation precinct for 10ha in the land earmarked for commercial development to establish an ‘orchid park’. In the variation to the Master Plan (2008), JAH stated that it ‘proposes the establishment of a 20 hectare orchid park. As this…will reduce the non-aviation development area, JAH proposes a land swap with 10 hectares of [land that has limited conservation value as it] contains extensive dieback in the north eastern part of the airport’ (p. 5).

37. The area described in the variation of the Master Plan (2008) as low value land that contains extensive dieback is also shown as vegetation of primarily good to excellent condition in the Jandakot Airport Bushland Condition Mapping (September 2006). Whilst the variation to the Master Plan (2008) notes that the proposed land swap involves the establishment of a 20ha orchid park for 10ha of the conservation precinct, this proposal to conserve an additional 10ha is not reflected in a proposal to increase the size of the conservation precinct to 220ha in the variation to the Master Plan (2008), the variation to the Environment Strategy (2008) or the revised draft MDP (2008).

38. JAH’s current Master Plan (2005) notes the importance of the airport site for the Southern Brown Bandicoot (Isoodon obesulus) and Western Brush Wallaby (Macropus irma). It states that further research will be required to understand the impacts of clearing on those species, which ‘would be submitted as part of the MDP process’ (p.13-15). The Department requested further information on the impacts of the proposal as noted in paragraph 5, however JAH’s response did not include any further research information as mentioned above.

39. The Friends of Ken Hurst Park (January 2008) state: ‘the proposed clearing will weaken, not strengthen, sustainability due to loss of connectivity and sufficient vegetation to buffer impacts’ (p. 2). The WA DPI (Environment and Sustainability Directorate – December 2007) commented in relation to the Southern Brown Bandicoot, Western Brush Wallaby and Carnaby’s Black-cockatoo that: ‘within the additional information, there is no analysis on how the proposed developments at Jandakot Airport will affect these protected species’.

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40. The Department notes that in January 2007 JAH cleared approximately 28ha of Banksia woodland for future commercial development in three areas immediately south and north of the Hope Road. It should be noted that Bamford stated in his Fauna Survey report (2002): ‘the proposed development in the general location of Site 1 [north of the Hope Road] raises concerns in that it could isolate some areas of native vegetation [and] it will lead to some loss of habitat…One species that may particularly suffer as a result is the Brush Wallaby’ (p.13).

41. The Department notes the inconsistent information published by JAH in the past, and in recently submitted documents, about the extent and impacts of the proposed clearing. In addition, the Department notes that JAH has not addressed various concerns about the environmental consequences of the proposed development. Given the inadequate and inconsistent information provided by JAH, it is not possible to undertake an informed assessment of the extent of likely impacts of the proposed clearing, including the extent of impacts on species of regional significance. Nevertheless, the Department considers that the clearing of 102ha of remnant Banksia woodland at Jandakot Airport would be likely to have a significant impact on the environment on Commonwealth land and listed threatened species. It would also have a significant impact on regional habitat corridor values, as discussed in paragraphs 42 – 49 below.

Regional corridors

42. As described in paragraph 21, the native vegetation at Jandakot Airport forms part of a regional corridor linking other Bush Forever sites to the north and south. Fauna species that are likely to utilise the corridor include the Southern Brown Bandicoot (Isoodon obesulus) and Western Brush Wallaby (Macropus irma). Being small to medium ground dwelling mammals, those species are vulnerable to predation from foxes and domestic animals and therefore require vegetated corridors to move through. Any reduction in the vegetation in the northern part of the airport will compromise the ability of those species to persist in the area. Bamford (2002) notes: ‘Linkage with the Jandakot Botanic Park and other areas of native vegetation is important as many of the species present are prone to local extinction in isolated bushland remnants’ (p. 13).

43. The Environment Strategy (2004) states: ‘Due to surrounding airport land uses and the alignment of the parallel runway (06R/24L), which was constructed in 1991, the faunal corridor between the northern and southern half of the airport bushland has been compromised. JAH are currently holding negotiations with neighbouring landholders on the north eastern and eastern side of the airport to acquire land for revegetation purposes, reinstating the corridor and therefore recreating the link between Ken Hurst Park and Jandakot Regional Park’ (p. 52).

44. The Environment Strategy (2004) also states: ‘JAH are currently negotiating acquisition of approximately 40ha of adjoining land for revegetation purposes. If acquired, this area will be vested to the Commonwealth Government and incorporated into the cadastral boundary of Jandakot Airport, becoming an addition to the conservation precinct’ (p. 28).

45. Figure 9 (Concept Plan) of the draft MDP (2007) refers to: ‘revegetation by others to create a habitat corridor’ on the private land to the east of the Airport boundary (p. 23). That reference was absent in Figure 9 (Concept Plan) of the revised draft MDP (2008) (p. 23). Nevertheless, the revised draft MDP (2008) states: ‘JAH have held and will continue to hold negotiations with landholders on the Northern and Eastern sides of the airport to acquire land or at least promote revegetation to create a link between Ken Hurst Park and Jandakot Regional Park’ (p. 28).

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46. Corridor connectivity was discussed with JAH at the meeting mentioned in paragraph 15. JAH stated that it had a letter from the City of Canning giving the company access to revegetate council land to the north-east of the airport. A copy of that letter from the council was subsequently provided to the Department in January 2008. The council letter, dated June 2004, stated that JAH could access the land to undertake survey work and costings associated with proposed revegetation works, but further works would require another assessment.

47. A number of submissions gave qualified support to the proposal to revegetate adjacent land. The WA DPI (Environment and Sustainability Directorate – November 2007) stated: ‘The green corridor link is supported, however the native vegetation already on the site should remain, rather than other degraded areas being rehabilitated. The removal of the vegetation will reduce the linkage with Ken Hurst Park, and will reduce the effectiveness of the identified regional green corridor.’

48. The Department notes that the regional corridor is weak and requires augmentation on private land along the eastern boundary of the airport. The proposed commercial precinct and fourth runway would further reduce the effectiveness of the existing corridor by fragmenting habitat connectivity between the Jandakot Airport, Ken Hurst Park and parts of the Jandakot Regional Park (refer to Paragraph 21).

49. JAH’s proposal to revegetate land east of the airport has the potential to enhance the tenuous corridor to maintain habitat connectivity between Ken Hurst Park and Jandakot Regional Park. However, the information submitted by JAH to date is preparatory, and significant more work is required to assess its potential. Indeed, JAH has not provided any evidence to suggest that the proposal has progressed since 2004. Given JAH’s view that the corridor has already been compromised (as referenced in paragraph 43) and that further work is required to reinstate it, and given the vague status of the revegetation proposal, the proposed new commercial precinct will further reduce the connectivity of vegetation between Ken Hurst Park and Jandakot Regional Park. The Department considers that actions that further compromise the corridor function are unacceptable.

Proposed Fourth Runway

50. The Master Plan (2005) states: ‘the provision of a fourth parallel 12/30 touch and go runway…will not greatly increase annual capacity [of the airport], rather it will improve safety and efficiency on days when the crosswinds on the 06/24 runways exceed 12 knots forcing operations on to the existing 12/30 single runway.’ (p. ES-1). Additionally: ‘The provision of an additional parallel runway does not increase annual capacity at a General Aviation Airport Procedure (GAAP) such as Jandakot Airport. Only one runway direction can be operated at a time as training circuits would intersect and conflict.’ (p. ES-1).

51. Additionally the Master Plan (2005) states: ‘Jandakot Airport is capable of handling about 514,650 aircraft movements per year…[and]…annual aircraft movements are not expected to exceed the current airport’s capacity within the 20-year planning horizon.’ (p. ES-1). However the draft MDP (2007) identifies: ‘Increased capacity of the 12/30 runways… [will]…meet the growing demand for commercial and training operations.’ (p. 10). The WA DPI (Aviation Policy) supports the construction of the fourth runway, as consultation with aviation training organisations identified that: ‘when [the existing] runway 12/30 was in use significant delays were experienced by the students in gaining access to the runway…’ (p. 1) and: ‘These organisations considered a parallel 12/30 runway as essential to maintain maximum efficiency in conducting aviation training’ (p. 1).

52. The Master Plan (2005) states the: ‘major environmental impact generated by airports is aircraft noise” (p. 13-4). This statement is reiterated in the draft MDP (2007) (p. 62).

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53. Noise impacts are quantified in the draft MDP (2007) using the Australian Noise Exposure Forecast (ANEF). The draft MDP (2007) states that the new 12/30 runway will only be utilised infrequently, and: ‘On an annual average basis the noise impacts should be relatively slight. However, for affected residents, the noise impacts associated with the use of the 12/30 direction runways will be intense, at frequent intervals and of relatively short duration.’ (p. 62). An individual states that the use of ANEF 2025 noise profiles: ‘do not represent the real world noise of air traffic movements…[and]…many residents are being subject to noise outside the guidelines for residential dwellings currently’ (p. 1).

54. JAH is involved in two activities which are aimed at managing aircraft noise. These, as stated in the Master Plan (2005), are the Jandakot Airport Consultative Committee, which reviews concerns such as noise complaints, and the Fly Neighbourly Campaign, which was introduced in January 2000 to reduce noise impacts (p. 13-5).

55. Airservices Australia states that a new runway, with the associated increase in air traffic, will require a new tower or new tower cab and an increase in staff; that positioning of the runway may compromise visibility from the tower during certain manoeuvres; noise may be an issue over new development; and that the relocation of the NDB (Non Directional Beacon) would: ‘require a redesign of all current conventional procedures’ (p. 1).

56. The City of Cockburn (December 2007) is supportive of the draft MDP (2007) provided: ‘All existing houses and residential accommodation located within the new 20-25 ANEF contour (as a result of the proposed fourth runway operation) be acoustically treated at… [JAH’s]… expense to mitigate aircraft noise experienced inside the buildings’ (p. 2).

57. In personal communications with officers from the Department of Infrastructure, Transport, Regional Development and Local Government (February 2008), the Department has been made aware that ANEF and ANEI (Australian Noise Exposure Index) do not comprehensively demonstrate aircraft noise impact at an airport. In the case of Jandakot Airport, an established base for pilot training with a high volume of flying circuits close to the airport, it is also necessary to consider flight paths where such circuits are operated in order to facilitate a meaningful analysis of aircraft noise impact. Section 91(1)(ea) of the Airports Act 1996 requires that an MDP consider the effect of the development on flight paths at the airport. JAH has not provided this information in the draft MDP.

58. As noted in paragraph 57, JAH has provided inadequate information to undertake an informed assessment of likely noise impacts from the proposed fourth runway.

Jandakot Groundwater Mound

59. The Jandakot Groundwater Mound is a significant source of drinking water for Perth, and recharges deeper confined aquifers such as the Leederville and Yarragadee aquifers. The Jandakot Groundwater Mound is highly susceptible to contamination from overlying sources, and as such the proposal may have impacts on it. The Environment Strategy (2004) identifies that contamination sources within the airport generally relate to ‘Leakage from underground fuel storage tanks; Spillage of fuels and chemicals; Domestic Wastewater; Aircraft Washdown; [and] Historical activities such as landfilling.’ (p. 31).

60. It is not clear whether JAH has identified all additional sources of potential groundwater contamination from the proposed commercial development in the draft MDP (2007) apart from domestic wastewater. Stormwater runoff will be managed during construction by directing it ‘to open drains which flow NW away from Priority 1 Source Protection Area’ (p. 83), however the management of stormwater runoff once construction has been completed is unclear.

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61. The draft MDP (2007) states: ‘The proposed sewer will have a material, positive impact on the water mound.’ (p. 5). Further, ‘The proposed civil works include a sewer which will result in an improvement of the water quality to the Jandakot water mound when existing airport buildings are connected to it’ (p. 13), as it will eliminate septic tanks.

62. Both the City of Cockburn (p. 4) and the WA DPI (Aviation Policy – November 2007) (p. 3) state the importance of not allowing refuelling or wash down away from hardstand areas or within the priority 1 Source Protection area for the Jandakot Water Mound to avoid groundwater contamination. The WA DEC (January 2008) advises that ‘the WA Department of Water should be contacted to provide advice on [the Jandakot Water Mound]’ (p. 9).

63. An individual states: ‘Jandakot airport [sic] is part of the Jandakot Groundwater supply area, of which the banksia woodlands help protect from polution [sic]’ (p. 2).

64. The Department notes that the proposed sewer works may reduce existing impacts on the Jandakot Groundwater Mound. However, as noted by the WA DEC, advice should be sought from the WA Department of Water to determine whether JAH has identified all relevant potential impacts, and is suggesting appropriate measures to mitigate those impacts.

Proposed Roads

65. JAH proposes to construct a road to the east to link with Ranford Road, and a road to the south to link with Jandakot Drive. This will require the clearing of 4 hectares of vegetation. The draft MDP (2007) states ‘new roads are required for emergency vehicle access, emergency egress and to service current and future growth at the airport’ (p. 5).

66. The layout of roads as published in the draft MDP (2007) were modified in the revised draft MDP (2008). The draft MDP (2007) shows the northern perimeter road running roughly parallel with the railway line bordering the north-west of the airport property, and totally encloses and isolates the initial proposed 10ha ‘orchid park’ from other remaining vegetation (p. 23). The revised draft MDP (2008) modifies the layout of this road, to divert along a more southerly route allowing for a 20ha ‘orchid park’, and adds a ‘loop’ road out towards and along Jandakot Airport’s boundary with the railway line (p. 23).

67. The draft MDP (2007) states that vertebrate fauna such as wallabies and Quenda may be adversely affected by new roads. The roads are proposed to be fenced with fauna proof fencing to prevent road kills, and: ‘JAH will provide 1m x 1m box drainage culverts or similar as fauna underpasses’ (p. 76) to allow movement between each side of the roads. It also intends to bury chain mesh to prevent burrowing under fences, and: ‘fencing will be installed along the outer verge of the road similar to that installed along the Roe Highway near Jandakot…[in order to]…lead the animals to the culvert crossing and prevent the animals crossing the roads on the surface’ (p. 76).

68. The draft MDP (2007) also states that road batters will be revegetated with local native species following construction of roads, and that edge effects on Quenda habitat will be minimised with the use of a weed management programme (p.76).

69. The WA DEC (December 2007) states: ‘the draft MDP includes a proposed road to the east passing through the conservation precinct 2C… This road will further degrade the bushland area and limit movement through this remaining link between Ken Hurst Park and conservation precinct 2C’ (p. 9). An individual also states it ‘would impact on the efficiency of the corridor for fauna use and would increase edge effects into the bushland on either side’ (p. 1), and identifies the same effects from development of the southern road linking with Jandakot Drive.

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70. The WA DPI (Environment and Sustainability Directorate) expressed concern about the location of the proposed eastern road connection, as shown in Figure 5 (p. 19) of the draft MDP (2007). As it would go through Bush Forever site 388, and it ‘should be realigned to the existing road reserve south of where the proposed road is, to connect to Ranford Road’ (p. 2). The revised draft MDP (2008) corrected the alignment of this road, as shown in Figure 5 (p. 19), to follow the existing road reserve.

71. The City of Cockburn (December 2007) is supportive of the road proposal in the Draft MDP (2007), provided JAH prepares a detailed traffic assessment: ‘outlining the impacts on the City’s infrastructure outside of Jandakot Airport Holdings land generated by the proposed development to the satisfaction of the City of Cockburn.’ (p. 1). The City of Cockburn also considers that JAH should ensure any infrastructure (including roads, drainage, reserves and other infrastructure) which is intended to be transferred to council management should be constructed according to the council’s standards. The council supports the proposed roads to the east linking with Ranford Road, and south linking with Jandakot Drive, as they provide an alternate traffic route to Hope Road in the case of an emergency. The council also states that JAH would need to apply for approval before constructing or modifying any roads outside of Jandakot Airport.

72. An individual raised concerns in a public submission over noise and security problems for residents surrounding Jandakot Airport as a result of changes to traffic patterns from the construction of roads through the airport property.

73. In order to make an informed assessment of the impacts of the proposed roads, the Department requires more detailed information on the positions of culverts in relation to faunal use, the length the road that will have culverts, and fencing and funnelling strategies. As noted in paragraphs 32 and 41, research information required to inform such decisions has not been provided. The Department concludes that JAH has not undertaken sufficient work to determine the likely success of strategies to mitigate impacts from the proposed roads.

Grand Spider-orchid (Caladenia huegelii)

74. The area of Banksia woodland proposed for commercial development at Jandakot Airport contains an important population of the endangered Grand Spider-orchid. Surveys indicate that at least 216 known orchids occur over approximately 100ha. These orchids form part of a population that extends into the adjoining Ken Hurst Park, which contains 652 orchids over approximately 50ha. The combined population at Jandakot Airport and Ken Hurst Park comprises about 58% of the total number of all known Grand Spider-orchids, making it the largest and most significant occurrence of the species.

75. The Grand Spider-orchid grows through winter, flowers in spring and dies back to become dormant over summer. It is dependent upon a mycorrhizal fungus (Sebacina sp.) for germination, growth and development, which provides an important source of energy and nutrients. The orchid’s pollinator is the male of a single species of thynnid wasp, which is attracted by pheromones emitted by the orchid on warm days.

76. There are 37 known populations of the species, which may include sub-populations. 21 of these 37 populations have had less than five flowering plants recorded at any time over the past decade. Eighty-six percent (86%) of Grand Spider-orchids have been found to occur within three populations, including the Ken Hurst Park and Jandakot Airport population which occur over adjoining properties, the Fraser Road (Banjup) population and the Kooljenerrup Nature Reserve (south-east of Peel Inlet) population.

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77. JAH’s proposed variation to the Master Plan (2008) states: ‘Flora surveys conducted after the approval of the Jandakot Airport Master Plan 2005 identified a number of rare orchids (Caladenia huegelii) within the non-aviation area’. However the orchids were initially found in the non-aviation area during surveys conducted by officers from the former Department of Conservation and Land Management (CALM) in late September and early October 2005. JAH was formally informed of the plants in a letter from CALM dated 10 November 2005, which noted that JAH had been informally told of their existence earlier. The Master Plan (2005) for the airport was approved in January 2006.

78. Threats to the species include development pressure, fragmentation of habitat, degraded habitat, poor recruitment, weed invasion, roadworks, firebreak maintenance, inappropriate fire regimes, recreational activities and dumping rubbish.

79. Conservation of the species is dependent on maintaining viable populations across its range, including the retention of adequate habitat to support the mycorrhizal soil fungus and pollinator wasp. According to the Grand Spider Orchid Interim Recovery Plan (DEC 2008), habitat critical to the survival of the species includes:

the area of occupancy of important populations; areas of similar habitat surrounding important populations (i.e. jarrah/banksia woodland on deep grey-white sands), as these areas provide potential habitat for natural range extension and are necessary to support viable populations of the associated mychorrizal fungus and the pollinating wasp species crucial to the orchid’s survival, and to allow pollinators to move between populations…

80. The Grand Spider Orchid Interim Recovery Plan (WA DEC 2008) identifies the long-term protection of habitat for the species as a means of improving the future security of Grand Spider-orchid populations. This interim plan is not yet adopted as a Recovery Plan for the purposes of the EPBC Act.

81. The additional information provided by JAH (2007) acknowledges that the protection of the Grand Spider-orchid population in the vicinity of Jandakot Airport is locally, regionally and nationally important. This population includes plants at Jandakot Airport, Ken Hurst Park and within the fringes of the Roe Highway, and is significant as the largest known population of the species.

82. The revised draft MDP (2008) proposes to clear a significant portion of Grand Spider-orchid habitat for commercial development. The proposed ‘orchid park’ mentioned in paragraphs 36 and 37 would conserve approximately 127 orchids in situ. JAH also proposes to translocate approximately 75 orchids into the ‘orchid park’. The revised draft MDP (2008) also proposes a five-year research proposal relating to the conservation and distributional status of Grand Spider-orchids.

83. The proposal to translocate 75 orchids at Jandakot Airport involves 34% of the Grand Spider-orchid population on the Jandakot Airport, and 8.6% of largest known population.

84. According to the WA DEC (January 2008), transplanting the Grand Spider-orchid is ‘still experimental with limited success so far’. The WA DEC raises significant concerns about the translocation and research proposal. The WA DEC states: ‘it is unclear…what the full extent of the C. huegelii research proposal is’ and raises several concerns with respect to it. It also claims: ‘it is extremely inappropriate management of a large intact population to reduce (its size)…and then apply these methods to repair the damage done by…clearing of plants and habitat.’ The submission further states the proposal ‘appears to be repeating or continuing research work being undertaken…for the Roe Highway Stage 7’ and that ‘it is not explained…how this research could provide new information…that would significantly enhance the conservation management of the species.’

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85. Other public submissions raise similar concerns about the translocation and research proposal. They also raise concerns about the fragmentation of habitat that would lead to the disruption of ecological processes, such as those associated with the wasp pollinator and mycorrhizal fungus. It is noted that mere survival of translocated plants is insufficient to determine the success of the procedure. It also requires successful natural propagation, which would require several years of monitoring to determine success.

86. The Australian Network for Plant Conservation (ANPC) has published a document titled Guidelines for the Translocation of Threatened Plants in Australia (ANPC 2004). This document is based on guidelines produced by the International Union for the Conservation of Nature and Natural Resources (IUCN) in 1995, and provides one of the most comprehensive reviews of plant translocation published to date. On pages 6 and 7 of the guidelines the ANPC (2004) states that the majority of translocations undertaken to ameliorate or compensate for the loss of individuals as the result of a development activity will fail.

87. The ANPC guidelines (2004) states that created systems have an unknown ecological value and an uncertain future, and so do not compensate for the loss of naturally occurring populations or habitats. The guidelines outline the conditions under which such translocations may occur, including when: • all possible measures have been taken to avoid the impact; and • it can be demonstrated that there will be no irreparable harm to the species as a whole.

88. To date translocation of the Grand Spider-orchid, such as for the Roe Highway Stage 7 project (EPBC 2003/972), has not proven to be successful. This project involved the translocation of 22 Grand Spider-orchids into Ken Hurst Park, and includes a similar research proposal being undertaken by the Western Australian Botanic Gardens & Parks Authority (BGPA). The current research findings of the Roe Highway Stage 7 project were not included within the Jandakot Airport draft MDP (January 2008). JAH simply states that translocation at sites such as the Roe Highway Stage 7 has been ‘successfully undertaken’ (p.82). However, according to the WA DEC comments (January 2008) on the additional information, to date: ‘no…data has demonstrated the success of translocations…in long-term conservation of the species’. Of the 22 orchids transplanted by the BGPA in 2004 ‘only 17 survived to 2005, and only 11 were located in 2006’. This represents a potential loss of half of the orchids transplanted for the Roe Highway Stage 7 project within a 2 year period of translocation.

89. On 9 January 2008, the Department met with JAH to discuss the draft MDP (2007). The Department reiterated its concerns about the likely impacts of the proposal on the largest Grand Spider-orchid population, including the loss and fragmentation of habitat, disruption of ecological processes and the risks and uncertainties associated with translocation. At this time the Department provided JAH with a letter regarding requirements for Part 13 Permits under the EPBC Act (Attachment D), which advised JAH to consider its legal obligations in relation to the proposal to take an EPBC listed threatened species for translocation. It should be noted that a permit to take a listed threatened species on Commonwealth land can only be issued if the action ‘will not adversely affect the survival or recovery in nature of that species’ (under s201(3)(b)(i) of the EPBC Act).

90. In response to concerns expressed in public submissions (paragraphs 11 and 85) and by the Department (paragraphs 15 and 89), JAH provided the revised draft MDP (2008) to include a land swap for a 20ha ‘orchid park’. The current proposal includes approximately 250m of connectivity between Ken Hurst Park and the ‘orchid park’, and the translocation of 75 orchids into the ‘orchid park’. The research proposal remains unchanged.

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91. The Department concludes that the proposal will result in the removal of substantial areas of habitat occupied by Caladenia huegelii individuals that form the largest known population of the species. This will fragment the remaining population and disrupt the ecological processes upon which the orchid is dependant for survival. There is also no certainty that the proposed translocation will succeed, as mentioned in paragraphs 84-88. As a result the proposal to develop the commercial precinct, the largest Grand Spider-orchid population will be placed at risk. In addition, given the likely adverse impact of the proposal to the survival or recovery in nature of the species, a permit to take or move the endangered orchid could not be given under s201 of the EPBC Act.

Glossy-leaved Hammer-orchid (Drakaea elastica)

92. The Glossy-leaved Hammer-orchid grows up to 30 cm high. The leaf emerges in May, and starts to wither by the time the orchid flowers in September. Flowers are first seen in late September, extending to October and rarely in early November. Each plant may not flower every year and plants die back to a dormant underground tuber over summer.

93. The Glossy-leaved Hammer-orchid is restricted to the coastal plain from approximately 130 km north of Perth to approximately 200 km south-west of Perth in south-west Western Australia. Past monitoring has indicated a decline in population numbers and there has been a decline in the area occupied. There has also been extensive habitat loss. Information held by the Department states that of 52 locations in which Glossy-leaved Hammer-orchid has been recorded to occur, currently plants have not been found at 25 locations. This indicates a significant decline in area of occupancy.

94. The draft MDP (2007) does not describe the location of, or impacts on, the Glossy-leaved Hammer-orchid at Jandakot Airport. The revised draft MDP (2008) states that four individuals were found by the former WA Department of Conservation and Land Management (2005). The additional information states ‘JAH engaged Mattiske Consultants to conduct vegetation survey including targeted Caladenia huegelii and Drakaea elastica surveys’. Those surveys were conducted up to early October, and Mattiske Consulting Pty Ltd (2006) makes no mention of finding the Glossy-leaved Hammer-orchid (Drakaea elastica).

95. Information provided by the WA DEC (personal correspondence, January 2008) suggests that the Glossy-leaved Hammer-orchid has been identified within the area proposed for commercial development. However, it is not certain whether the species is located within the area proposed for the ‘orchid park’, or if it is located within the areas proposed to be cleared. Departmental discussions with JAH (January 2008) suggested that the Glossy-leaved Hammer-orchid are found within the vicinity of the proposed ‘orchid park’, but JAH could not confirm whether the plants were within the proposed boundary, or outside of it. JAH did suggest the airport would be prepared to move the boundaries of the ‘orchid park’ to ensure it captures the Glossy-leaved Hammer-orchid, however the revised draft MDP (2008) does not clearly state whether JAH proposes to translocate the plants or change the proposed boundary.

96. Due to inadequate information provided by JAH about the extent and location of the Glossy-leaved Hammer-orchid at Jandakot Airport, the Department cannot determine the likely impacts of the proposal on this species.

Carnaby’s Black-Cockatoo (Calyptorhynchus latirostris)

97. The endangered Carnaby’s Black-cockatoo is endemic to the south-west of Western Australia, extending from the Murchison River to Esperance, and inland to Coorow, Kellerberrin and Lake Cronin. There has been a reduction in the range of the species, largely because of clearing of native vegetation for agriculture and urban development. It occurs in uncleared or remnant native eucalypt woodlands, and in shrubland or heathland.

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98. The Carnaby’s Black-cockatoo feeds on seeds, nectar and insect larvae. It is known to eat seeds of from species of Banksia, Dryandra, Hakea, Grevillea, Allocasuarina and Eucalyptus. The seeds of introduced plant species, particularly pines, are also used as a food source.

99. Much of the native vegetation found on Jandakot airport is suitable foraging habitat for the Carnaby’s Black-cockatoo, and this includes the 102ha of vegetation JAH proposes to clear in the revised draft MDP (2008). The extent of this vegetation and its location on the Swan Coastal Plain make it an important foraging resource for this species. The WA DEC (January 2008) has stated that the loss of feeding habitat on the Swan Coastal Plain is a threatening process for the cockatoo. According to the WA recovery plan for the species, which has not been adopted under the EPBC Act yet, most of the original food resources for Carnaby’s Black-cockatoo on the Swan Coastal Plain have been lost and the birds are now relying on introduced pine plantations (Cale 2003). Most of these plantations will be harvested over time making the retention of remaining native vegetation crucial.

100. Past decisions taken under the EPBC Act involving the loss of foraging habitat for the Carnaby’s Black-cockatoo on the Swan Coastal Plain reflect the importance of this habitat for the species. These include the Roe Highway extension project (2003/972) which involved the clearance of some 30ha of habitat, a residential development at Mandurah (2006/3063) involving 15.2ha of habitat and a commercial development at Mandurah (2006/3155) affecting 12ha of habitat. The approvals for all of these projects involved the provision of offsets as well as mitigation measures to deal with the impacts on the Carnaby’s Black-cockatoo.

101. Carnaby’s Black-cockatoo is known to access the Jandakot Airport near the proposed runway (WA DEC January 2008) and the area around it for foraging, including feeding habitat at Ken Hurst Park. However, there is little information about the cockatoo’s utilisation of habitat at Jandakot Airport, except that a Fauna Survey of Jandakot Airport (Bamford 2002) states that the Carnaby’s Black-cockatoo is expected to use the site. No targeted surveys for the species were undertaken by JAH in preparation of the draft MDP (2007).

102. A public submission by Birds Australia WA (BAWA) raises concern about the clearing of habitat for the Carnaby’s Black-cockatoo on the Swan Coastal Plain. BAWA claims that the current progressive removal of remaining foraging habitat, following the past broadscale clearing of habitat for agriculture, is now threatening the survival of the species. This view is also expressed by the WA DEC (January 2008), which states in comments on the proponent’s response to the Request for Additional Information: ‘loss of feeding habitat on the Swan Coastal Plain has been identified as a threatening process for Carnaby’s Black cockatoo’ and that ‘loss of…feeding habitat will occur, and there is no evidence in the draft MDP…to support comments on the adequacy of the surrounding banksia woodland to support the transient cockatoo population…’.

103. JAH’s response to the Department’s request for additional information states: ‘land clearing is perhaps the greatest threat to the Carnaby’s Black Cockatoo… on the Swan Coastal Plain’ and ‘it is critical that Carnaby’s habitat destruction be avoided until further research has been done’. Despite this JAH has stated on page 81 of the revised draft MDP (2008) that no significant impact on Carnaby’s Black-cockatoo is expected.

104. The proposal will involve the clearance of some 102ha of native vegetation, most or all of which is likely to represent feeding habitat for Carnaby’s Black-cockatoo. Given that the removal of native vegetation on the Swan Coastal Plain is a recognised threat to this species the Department concludes that the proposal outlined in the draft MDP will have a significant impact on Carnaby’s Black-cockatoo.

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Summary of Impacts

105. The Department considers the proposed changes to Jandakot Airport’s Master Plan (2005) and Environment Strategy (2004) to allow the draft MDP to progress, to have significant impacts on the Commonwealth environment and listed threatened species.

106. The documents provided by JAH have numerous inconsistencies, as outlined in the various sections of this report, and there is insufficient rigour in the analysis of the proposal to make an informed decision on a range of likely impacts, as noted in various public comments.

107. The remnant Banksia woodland at Jandakot Airport is recognised as being significant for the maintenance of biodiversity, habitat and corridor values, however JAH has provided little information to justify a reduction in the conservation precinct from 270ha to 210ha. There is also insufficient detail on proposed offsets for the impacts.

108. Based on the information provided, the Department concludes that the proposal will have significant impacts on listed threatened species and species of conservation significance, as outlined in the paragraphs below: • endangered Grand Spider-orchid (paragraphs 78 – 91); • endangered Glossy-leaved Hammer-orchid (paragraphs 94 – 96); • endangered Carnaby’s Black-cockatoo (paragraph 101 – 104); and • species of State conservation significance (paragraphs 38 – 40, 47 and 48). In particular, the proposal would have adverse impacts on the survival or recovery in nature of the Grand Spider-orchid, and a permit could not be given under the EPBC Act to take or move those plants.

Consultation on proposed decision 109. In addition to the formal consultation process under the EPBC Act and Airports Act,

representatives of the Department of the Environment, Water, Heritage and the Arts and the Department of Infrastructure, Transport, Regional Development and Local Government visited Western Australia in January 2008 to consult with stakeholders about the draft MDP proposal. This included meetings with the WA DEC, WA DPI, local environment groups and JAH.

Social and Economic matters

110. The majority of public comments received were opposed to the proposal. The primary grounds for opposition were based on environmental impacts (refer to paragraph 11).

111. 2 public comments supported the proposal (refer to paragraph 12).

112. JAH states that the proposal would have the following positive social and economic benefits (pp. 9-10 and 18-20, revised draft MDP (2008)): • improved operational capacity and efficiency to secure the financial future of the airport; • improved road-based regional travel networks; • creation of a more viable context for commercial development and employment

generation; • provision of a car-orientated regional destination to serve the Perth metropolitan area; • improved aviation safety and emergency access and egress; and • catering for future aviation growth.

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Ecologically sustainable development

113. In considering those matters, the Minister must take into account the principles of ecologically sustainable development (set out in Section 3A of the EPBC Act). The five principles of ecologically sustainable development have been accounted for as follows:

a. the integration principle;

The environment on Commonwealth land and the conservation of habitat for listed threatened species, as well as the economic and social benefits of the proposal, have been considered in this recommendation report. The Department concludes that insufficient regard has been given to the environmental costs of the proposal and has therefore recommended that the proposal is unacceptable and that the revised draft MDP (2008) should not be authorised.

b. the precautionary principle;

The precautionary principle has been considered in this recommendation report in assessing the likely long-term or permanent damage of the proposal to the environment on Commonwealth land, listed threatened species and species of regional significance, such as the Southern Brown Bandicoot and Western Brush Wallaby.

The assessment process indicates that there is sufficient scientific evidence and certainty that serious and irreversible damage may occur to the largest known population of Caladenia huegelii if the proposal goes ahead.

c. the intergenerational principle;

Currently the native vegetation on Jandakot Airport plays an important role in the maintenance of threatened species and other environmental values in the vicinity of southern Perth. The Department’s assessment of the proposal concludes that were it to proceed, this function would be greatly compromised and future generations would be denied a healthy and diverse environment.

d. the biodiversity principle;

The Department concludes that the conservation of biological conservation was not a fundamental consideration in the formulation of the proposal, and as such has not been adequately addressed.

e. the valuation principle.

The impacts of the project have not all been adequately identified and so the environmental costs of the project have not been fully evaluated.

Other legal considerations 114. Not applicable.

Conclusion 115. To conclude, the proposal by JAH to reduce the conservation precinct, and clear 102ha of

native vegetation to construct the 4th runway, roadworks and facilitate commercial development, is considered unacceptable for the reasons outlined in paragraphs 105-108. Therefore, the Department recommends that the revised draft MDP (2008) should not be authorised.

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Attachment A

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Attachment B

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Attachment C

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Attachment D

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