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Impact Assessment

Re-development of Proposed Lot 23A DP 556743

14-82 Madeline Street, Strathfield

On the

Green and Golden Bell Frog

1.0 Introduction:

The Green and Golden Bell Frog Litoria aurea is an endangered species and is listed

under Schedule 1 of the NSW Threatened Species Conservation Act 1995. These frogs

have been detected in a number of sites in the Greenacre-Enfield-Strathfield area. A

dedicated conservation area for the Green and Golden Bell frogs has been constructed at

Juno Parade in Greenacre and a second conservation area has been constructed in the

Enfield Marshalling Yards (by Sydney Ports), not far from Madeline Street.

The Madeline Street Site (Project Area) is a large, irregular shaped site (Figure 1). The

site has been used for various industries in the past and contains the remnants of the past

activities as well as standing and functional factory buildings. The site is leased by

Recyclecare Services Pty Ltd, and it is proposed establish a new Materials Recovery

Facility (MRF) on site.

As Green and Golden Bell frogs have been detected on both the eastern and western sides

of the site, and that the site is close to the edge of the Cooks River canal, Strathfield

Council required that a Seven Part Test Impact assessment be carried out for the proposed

works.

This report presents the results of previous frog surveys on the site and habitat

assessments. On the basis of the survey data and the development plans for the site a

Mail Address: 69 Bestic St. Rockdale NSW 2216 A.C.N. 065 241 732

e-mail: 1arthur@tpg.com.au A.B.N. 32 065 241 732

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Seven Part test of impact assessment has been prepared along with recommendations to

ameliorate potential impacts.

2.0 Greenacre-Enfield-Strathfield Green and Golden Bell Frogs The Green and Golden Bell Frog Litoria aurea, was first recorded at the Juno Parade site

at Greenacre in 1995 but was later found elsewhere in Greenacre and Enfield (Greer

1995, AMBS 1999, White pers. obs.). This species was previously known from other

locations in Greenacre including the Cox’s Creek Reserve (White 1993), residential sites

between the reserve and the brick pit (Greer 1995, White unpub. data) and the Enfield

Marshalling Yards (Greer 1995). Green and Golden Bell Frogs in these sites were

monitored in 1993 and 1994 as part of a study on the dispersal and movements of frogs in

urbanised areas (White and Pyke unpubl. data).

Other studies have been carried out on the Green and Golden Bell frogs in the Enfield

area. In 1993, a detailed study of the Bell frogs in the Cox’s Creek Reserve was carried

out as part of a Fauna Impact Statement (White 1993) for the construction of a warehouse

complex alongside the reserve. In 1994 a frog survey and tracking study of Bell frog in

the Cox’s Creek Reserve was conducted (White unpubl. data). Bell frogs were located in

the Enfield Marshalling Yards and Enfield brick pit and in residences in Hebe Street and

Sylvanus Street Greenacre. In 1995, Greer undertook a specific survey for Green and

Golden Bell Frogs in the same general area. This survey was in response to Review of

Environmental Factors associated with the re-development of the marshalling yards by

State Rail. As part of this work, a detention pond on the State Rail site was modified to

become a Bell frog breeding site. Irregular surveys were undertaken in 1996 and 1997

(White and Pyke unpubl. data) in an effort to locate other breeding sites for the Green and

Golden Bell Frog in the Enfield/Greenacre area. In 1999, AMBS undertook a frog survey

of the Enfield brick pit on behalf of Hannas.

The various surveys have amassed sufficient information to permit an assessment of the

Bell frog populations in the Enfield-Greenacre area. Several important facts have

emerged from this work:

1. the Enfield-Greenacre Bell frogs appear to be an isolated from all other known Bell

frog populations. Potential movement corridors between the Greenacre-Enfield

population and their closest neighbours (at Homebush) was investigated in 1994. Possible

corridors beside industrial areas, golf courses, rail easements and power easements were

surveyed (White and Pyke unpubl. data) and were found to be unsuitable for frog

dispersal.

2. the original Enfield-Greenacre Bell frog population was small. The maximum number

of adult frogs seen in a single evening between 1993 and 1999 was 12. Larger numbers of

juvenile frogs were occasionally seen in both the brick pit and marshalling yards (White

pers. obs., Greer 1995). The implication of these sightings is that survivorship of tadpoles

and/or juvenile frogs was low.

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3. there appears to be regular movements of Bell Frogs between the Juno Parade site, the

marshalling yards and Cox’s Creek Reserve (White and Pyke unpubl.data). Animal

exchange between these areas may be critical for the survival of each satellite group.

4. secure breeding sites are scarce in the Enfield/Greenacre area. Prior to the construction

of the Frog Habitat Area at Juno Parade, there were only three instances of tadpoles being

observed: in 1994 in the Cox’s Creek Reserve (none of these tadpoles survived to

adulthood), in 1995 in the modified frog ponds in the marshalling yards (Greer 1995) and

in 1996 in the brick pit (White). Juvenile frogs were found above the brick pit in 1995

(Greer 1995, pers. com.) and around the pond in the marshalling yard in the same year

(Greer pers. com.). The Juno Parade site had successful breeding most years after its

construction (in 1997).

The data indicates that Bell Frogs move between the Juno Parade site, marshalling yard

and Cox’s Creek Reserve and these three groups should be considered as satellite

populations (meta-populations) of a common source. Movement between sites

(particularly to and from Cox’s Creek Reserve) is perilous and some frogs are killed

during these movements. Movements may be dispersal events or foraging trips. (White

pers. obs). In additions, wider movements periodically occur and frogs are reported from

Strathfield and Bankstown during dispersal events. No breeding sites are known for

Green and Golden Bell Frogs in these suburbs but regular sightings have been made in

the past five years (especially in the Strathfield area).

3.0 The Madeline Street Project Area

The Madeline Street Project Area is a large, irregular shaped area of land marked in red

on Figure 1.

The Project Area has previously been used as an industrial and recycling site. A number

of factory buildings are present on the site. The northern half of the site is dominated by a

large brick and metal factory building that is being used for the sorting and packing of

recycled materials.

The Project Area is almost entirely paved. The only parts of the site not paved are along

the northern boundary fence and these consist of a thin strip of exotic grasses and pasture

weeds. This narrow strip of weeds and grass constitutes the only potential foraging

habitat for Green and Golden Bell frogs in the Project Area (Figure 4).

Further to the north (outside of the Project Area) is a typha-lined pit that could provide

shelter for Green and Golden Bell Frogs (Figure 2).

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Figure 1

Location and Extent of the Madeline Street Project Site.

To the south of the site (and the adjoining industrial lots) lies the Coxs Creek Canal. This

canal directs stormwater eastwards and units with the Cooks River Canal to the east of

the site. The Coxs Creek Canal passes close to or through some notable Green and

Golden Bell frog areas, namely the Juno Parade Frog Habitat Area, the Coxs Creek

Reserve and the Enfield Marshalling Yards, to the west of Cosgrove Road.

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Figure 2

Northern Boundary adjoining 2-12 Madeline

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Figure 3

Current Survey Plan for the Madeline Street Site

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4.0 Frog Surveys

Targeted surveys for the Green and Golden Bell Frog were carried out as part of a

previous study over three nights in October and November 2011 under weather

conditions conducive to detecting these frogs (ie. following rain). An initial day survey of

the site was carried out on the 4th

of October for the purposes of site familiarisation as

well as the identification of potential habitat for the Green and Golden Bell Frog.

Night frog surveys were carried out on the evenings of 10th

of October and the 3rd

and

16th

of November 2011. Rain had fallen within the previous 24 hours on each occasion

and night air temperatures at 9.00 pm were 16o, 19

o and 18

o respectively. Each survey

focussed on the grassed and wet areas along the northern boundary of the site; especially

the pit area. Call imitation was used repeatedly at the site after an initial listening period

during which all calling frogs were identified and noted. Call imitation was carried out at

three locations along the northern boundary including one site near the pit.

Following call imitation, all of the vegetated areas along the northern boundary were

searched using headlamps. Following this a less intensive search was made of the areas

around the smaller buildings and shipping containers and areas where frogs could

potentially shelter.

The pit was the only site where there was open water. The pit was netted using a short-

handled dip net. All tadpoles captured were transferred to a plastic tray, identified (Anstis

2002) and returned to the site of capture.

4.1 Results of Frog Surveys

No Green and Golden Bell frogs were detected during the surveys. Two other frog

species were found on the site; namely the Striped Marsh Frog Limnodynastes peronii

and the Common Eastern froglet Crinia signifera. Striped Marsh Frogs were also

detected as tadpoles.

4.2 Potential Green and Golden Bell frog Habitat in the Local Area

Although no Green and Golden Bell frogs were found on the Madeline Street site, a small

area potential habitat for these frogs is present. The pit area appears to provide potential

shelter and foraging habitat, but not breeding habitat. Shelter habitat is limited to the

bulrushes fringing the pit; foraging habitat is more widespread and includes the grassed

areas along the northern boundary fence (Pyke and White 2001). The maximum extent of

potential habitat is depicted on Figure 4.

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Figure 4

Extent of Potential Green and Golden Bell frog Habitat

4.3 Bell Frog Entry onto Madeline Street Project Area

For the areas of potential habitat (marked in yellow in Figure 4) along the common

boundary with 2-12 Madeline Street to be used by Bell Frogs, there must be some route

by which dispersing Bell Frogs could enter and exit the site. There appears only one

likely entrance and exit portal for Bell frogs at this site and that is via the Cooks River

Canal and up the open drain that leads into 2-12 Madeline Street. This is not a

particularly easy route of entry and it is unlikely that Bell frogs would remain in the

general area for long as the potential habitat areas are so limited.

The other possible route that was investigated was via the Coxs Creek Canal. This canal

passes to the south of the site but there are few points where frogs could climb out of the

canal to reach the land above. If Bell Frogs were to disperse along the Cox Creek Canal,

they could proceed to its junction with the Cooks River Canal and travel upstream to the

drain opening onto the Madeline Street Site. This again is not an easy route to access the

site.

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The potential entry point from the Cooks River canal is currently blocked off. The land to

the north of the Project Area (2-12 Madeline Street) is currently being re-developed as a

warehouse facility and frog exclusion measures are in place as part of those works. Part

of the development proposal for that site includes the creation of breeding ponds and a

Frog Habitat Area (FHA) for Green and Golden Bell frogs. A Green and Golden Bell

Frog Conservation Plan has also been prepared for that site (Biosphere 2013).

5.0 Re-development of the Madeline Street Site

A recycling facility has existed on the Madeline Street site since 1993, having been

operated by Recyclecare since 1997. Recyclecare is proposing to expand this activity

through the creation of a new Materials Recovery Facility (MRF) on site. The existing

operation currently takes place within Building 1 (Figure 6) and receives approximately

20,000 tonnes per annum (tpa) of paper and cardboard, which is baled and sent for

recycling off-site.

The re-development proposal involves the removal of existing machinery from Building

1 and the assembly of new MRF machinery in its place. The new MRF facility will

process dry commercial and industrial waste and source-separated municipal solid waste

(MSW), recovering the following waste streams:

Paper and cardboard;

Mixed metals (steel/tin/aluminium);

Glass; and

Mixed plastics.

A new paper and cardboard recovery (PCR) facility would be constructed in Building 2

(Figure 5) and all PCR operations will now be carried out in Building 2.

The Strathfield MRF and PCR operations would, once fully operational, be capable of

processing up to a total of 99,900 tonnes of recyclable waste per annum for transfer to

various resource recovery facilities for recycling off-site (manufacture into new

products). Of the total, 69,900 tpa would be processed by the new MRF, with 30,000 tpa

processed by the relocated PCR facility.

The hours of operation are as follows (Table 1):

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Table 1

Hours of Operation of New Facility

Day Hours of Operation MRF Shifts PCR Shifts

Monday –

Saturday 24 hours per day

(MRF: 4am Monday

– 4am Sunday)

(PCR: 00.01am

Monday – 7am

Sunday)

Shift 1: 4am-4pm

Shift 2: 4pm-4am

Shift 1: 7am-

3pm

Shift 2: 3pm-

11pm

Shift 3:

11pm-7am

Sunday No operations during

most hours

(MRF: Closed 4am

Sunday until 4am

Monday)

(PCR: Closed 7am

Sunday until

11.59pm Sunday)

4am – 4pm

Plant

Maintenance and

cleaning only

No shifts

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Figure 5

Plan of Madeline Street Site

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Part of the site preparation will entail the refurbishment of existing factory buildings and

sheds. No alterations to the site drainage will be carried out; the existing drains receive

stormwater from the site and direct it through underground culverts, across the adjoining

lot to the north, to discharge into the Cooks River Canal (Figures 6 and 7).

Figure 6

Stormwater Catchment Plan

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The Stormwater Discharge plan (Figure 7) details the location of the culverts as well as

the location and dimensions of the service pits, manholes and riser mains.

Figure 7

Stormwater Drainage Plan

7.0 Potential Impacts and Amelioration Measures

7.1 Site Development

At present Green and Golden Bell Frogs are not in the Madeline Street Project Area and

it is unlikely that they can enter the site as the only apparent portal from the Cooks River

canal is closed off. For these reasons there does not appear to be any need to put in place

additional barriers to prevent frogs entering the Project Area.

All of the works proposed within the Project Area entail the refurbishment of the MRF

facility and the processing of recyclable materials. There are no earthworks included in

this project, nor will there be toxic or hazardous materials brought onto the site as a result

of the operation of the site.

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No soil, mulch or compost will be imported into the Project Area and water will also not

need to be brought into the area.

7.2 Frog Protection Measures

During refurbishment works:

1. No Frog Exclusion Fences will be required in the area.

2. There will be no unsealed surfaces on site (and so no need trio import water onto

the site)

3. No sediment and silt control fences will be required for these works.

4. In the event of surface liquids (either as stormwater or chemical spills) being

released onto the site, they will be prevented from directly reaching the Cooks

River Canal by entrapment pits. Clean stormwater will be directed into the

underground stormwater system; chemical spills will be contained on site and

cleaned up as appropriate.

5. No soil or landscaping materials will be imported onto the site.

During operation of the site:

1. The internal stormwater system will collect and road run-off on the site. The

stormwater will be directed to diversion pits before entering the main

underground culverts and ultimately being discharged into the Cooks River Canal.

2. Cement or concreting, vehicle re-fueling, truck washing, engine degreasing or

other activities on site that may create polluted run-off will not be released

directly into the stormwater system. The collection and holding of liquid

industrial wastes will be managed on site.

3. Night lighting: night lighting will be concentrated around the work areas and

lights will be angled so that there is minimal light spillage onto the adjoining site.

8.0 Considerations under the TSC Act 1999

Under the New South Wales’ Threatened Species Conservation Act 1995, impact

assessment is carried out using the Seven Part test. The impact assessment in this report

assumes that all recommended amelioration measures described above will be in place as

required.

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8.1 Seven Part Test

In order to assess the effectiveness of the proposed amelioration measures in removing or

reducing potential impacts on Green and Golden Bell Frogs in the immediate vicinity of

the Madeline Street Project Area, the following Seven Part Test was carried out:

1. in the case of a threatened species, whether the action proposed is likely to have an

adverse effect on the life cycle of the species such that a viable local population of the

species is likely to be placed at risk of extinction,

The Green and Golden Bell frog is an endangered species listed on Schedule 1 Part 1 of

the Threatened Species Conservation Act 1995. Bell Frogs have been recorded at Coxs

Creek Native Reserve, FreightCorp Pond in the Enfield Marshalling Yards, at Cook Park

and in houses at Greenacre and South Strathfield. The installation of the barrier fence

across the drain exit to the Cooks River Canal (in 2-12 Madeline Street) will prevent Bell

frogs from accessing the site and being directly injured or killed by the proposed works.

The proposed upgrading of the recycling facilities on the Madeline Street site will have

negligible impact on Bell Frogs in the Greenacre- South Strathfield area.

As the proposed works will not have a significant impact on the local Bell Frog

community, the works will not place the local Green and Golden Bell Frog population at

risk of extinction. 2. in the case of an endangered population, whether the action proposed is likely to have

an adverse effect on the life cycle of the species that constitutes the endangered

population such that a viable local population of the species is likely to be placed at

risk of extinction,

The Greenacre-South Strathfield Bell Frogs have not been listed as an endangered

population because of the legal status already afforded to them as an endangered species. 3. in the case of an endangered ecological community or critically endangered

ecological community, whether the action proposed:

(i) is likely to have an adverse effect on the extent of the ecological community such

that its local occurrence is likely to be placed at risk of extinction, or

(ii) is likely to substantially and adversely modify the composition of the ecological

community such that its local occurrence is likely to be placed at risk of extinction,

Not applicable.

4. in relation to the habitat of a threatened species, population or ecological

community:

(i) the extent to which habitat is likely to be removed or modified as a result of the

action proposed, an

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(ii) whether an area of habitat is likely to become fragmented or isolated from other

areas of habitat as a result of the proposed action, and

(iii) the importance of the habitat to be removed, modified, fragmented or isolated to

the long-term survival of the species, population or ecological community in the

locality,

No habitat will be lost as a result of the proposed works (Figure 4).

5. whether the action proposed is likely to have an adverse effect on critical habitat

(either directly or indirectly),

No critical habitat is present on or near the Madeline Street site.

6. whether the action proposed is consistent with the objectives or actions of a recovery

plan or threat abatement plan, The action will not result in the loss of habitat or a decrease in the population size of

Green and Golden Bell Frogs at Greenacre-South Strathfield.

7. Whether the action proposed constitutes or is part of a key threatening process or is

likely to result in the operation of, or increase the impact of, a key threatening

process.

The proposed development is not a threatening process.

Conclusion: The proposed upgrading of the recycling facilities on the of the Madeline Street site will

not result in the loss of potential habitat and should not impact adversely on Green and

Golden Bell Frogs in the Greenacre-South Strathfield area. The frog-exclusion barrier

already in place will ensure that Bell Frogs cannot enter active work sites and cannot be

accidentally harmed or killed during the works. The proposed works will not prevent Bell

Frogs from dispersing along the Cooks River canal; there will be no significant impact on

the frogs or their life cycle. Amelioration measures proposed during the occupation and

use of the site will ensure that no adverse impacts arise as a result of activities.

Overall, the proposed works will not have a significant impact on the Bell Frogs on

the site or in the Greenacre-South Strathfield area.

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9.0 Relevant References

AMBS 1999. Survey for the Green and Golden Bell Frogs at Enfield brickpit.

Prepared for Hannas Civil Engineering Pty Ltd.

Anstis, M. 2002. A Field Guide to the Tadpoles of South-eastern Australia.. Reed New

Holland, Frenchs Forest.

Biosphere, 2013. Frog Conservation Area Management Plan. 2-12 Madeline Street

Strathfield. Prepared for Lion Plumbing Co.

Greer , A. 1995. Survey of the Green and Golden Bell Frog Litoria aurea in the

Greenacre area, Strathfield, Sydney: with special reference to the Enfield

Marshalling Yards. Prepared for Kinhill Connell Wagner.

Pyke, G.H., and A.W.White. (1996) Habitat requirements of the Green and Golden

Bell Frog Litoria aurea (Anura:Hylidae). Aust. Zool. 30: 224-232.

Pyke, G.H., and A.W.White (1999). Dynamics of co-occuring frog species in three

ponds utilised by the endangered Green and Golden Bell Frog Litoria aurea.

Aust. Zool. 31(1): 230-239.

Pyke, G.H., and A.W.White. (2000). Factors influencing predation on eggs and

tadpoles of the endangered Green and Golden Bell Frog Litoria aurea by the

introduced Plague Minnow Gambusia holbrooki. Aust. Zool. 31(3): 496-505.

Pyke, G.H., and A.W.White. (2001). Review of the biology of Green and Golden Bell

Frog Litoria aurea. Aust. Zool. 31(3): 496-505.

White, A.W (1993) Fauna Impact Statement. Green and Golden Bell frogs. Finemores

Site, Roberts Road, Greenacre. Prepared for Finemores.

White, A.W. (1995) The Green and Golden Bell Frog FrogFacts 5:1-4.

White, A.W., and G.H. Pyke (1996). Distribution and conservation status of the Green

and Golden Bell Frog Litoria aurea in New South Wales.

Aust. Zool. 30: 177- 189.

Dr Arthur White

4 September 2015.