BMCS SUBMISSION TO Draft LEP 2002

SECTION I - supplementary submission

Four additional items are included in this supplementary submission to the written instrument of DLEP 2002. They are:

• Proposed additional clause: Provisions for specific land uses - Cemeteries

• Proposed additional Schedule - Rare Plants

• Schedule 6 - Weeds of the Blue Mountains

• Dictionary - definition of nature based recreation
  
  

PART 4 Div 8: PROVISIONS FOR SPECIFIC LAND USES - CEMETERIES

The Society recommends that a clause be added to the written instrument in part 4

Division 8. to cover cemetery development. There should be an additional clause for "Provisions for Specific Land Uses for Special Use Cemeteries".

Clause 120 requires that development on community land must be consistent with the adopted plan of management. However it would be useful to specify some of the general requirements from The Conservation Management Plan for Blue Mountains Cemeteries in this DLEP including :

• retain the native bushland as a "common thread" in landscaping;

• there shall be no expansion of cemetery works into Protected Areas;

• cemetery development shall avoid ecological buffer areas, riparian buffers and vegetation corridors

• there should be no excavation on slopes of over 20%;

• retention of existing native vegetation of at least 25 m wide on the topographic low sides or an equivalent planting to create a buffer for the protection of groundwater;

• preparation and compliance with a stormwater management strategy.

PROPOSED ADDITIONAL SCHEDULE X - RARE PLANTS

It is proposed that Rare Plants to be included in a separate Schedule or added to Schedule:5 in this DLEP.

Rare plants are defined in DLEP 2002 as those plants listed in Briggs & Leigh (1995). This is a static document which may or may not be updated in the future. Unfortunately new species may become rare in the future and some species which are already recognised as rare or threatened are not listed in this document.

It would be clearer and less open to dispute if DLEP 2002 contained a listing of rare flora species specific to this LGA , with provision for regular revision.

SCHEDULE:6 - WEEDS OF THE BLUE MOUNTAINS

We commend the Council for including this schedule and for the provisions in cl: 54 which prevent their use in some new developments and Council landscaping works.

A procedure needs to be set up for regular updating of this list as more information becomes available. Plants with weed potential (including so called "sleeper weeds") will continue to manifest as invasive in the Blue Mountains in the future. A list of authorities (eg. Blue Mountains Bushcare Network, Australian Association of Bush Regenerators, Weeds CRC) which should be consulted for this updating procedure could be included.

General construction of list

Trees and shrub categories on the draft list are not always clear, as some species listed as shrubs also grow to tree size while some of the tree species are usually shrub sized.

Use of alphabetical order for species based on their common names is not particularly helpful; many species have several common names, particularly with cultivars being created and sold.

It would be much more useful to group plants alphabetically according to their genus name and to include known alternative common names as well as synonyms (previous or impending scientific, cultivar or variety names)

Plants listed alphabetically according to genus allows easier assessment, for example, if a development in the lower Blue Mountains proposes to use "Mount Morgan Wattle" there is the possibility that this species would be given the go ahead, despite being on the list as Queensland Silver Wattle. On the other hand any proposed use of "wattles" or "acacias" could be checked against the part of the list for Acacias (in this example - Acacia (Racosperma) podalryiifolia - Queensland Silver Wattle, Mount Morgan Wattle).

Suggested additions to the list

The following additions are suggested to make the list more comprehensive and specific to the Blue Mountains environment at the current time.

Trees

Two Pittosporum species native to New Zealand are included on the draft list, a further species, Pittosporum tenuifolium from New Zealand has been found extensively in bushland in Katoomba. The Victorian P. bicolor is known to hybridise with the native P. undulatum, creating potential for a further control problem.

Grevillea robusta (silky oak) invasive throughout Sydney area, a known weed in the lower Blue Mountains.

Tecoma stans (Tecoma) is appearing increasingly in bushland and edge areas in the lower mountains, including Lapstone and Glenbrook. This tree weed is a known problem in coastal areas of NSW with similar climate to the lower mountains

Shrubs

Genista spp. & Cytisus spp. ( ie both of these genera in total) should be added to the list. Genista monspessulana and Cytisus scoparius are both noxious weeds in the LGA and as such are on the list. Other species of these genera are currently minor weeds in the Blue Mountains but have the potential to become widespread here as populations increase, as they have in other parts of NSW ( eg Genista stenopetala ). With a similar reproductive biology and ecological function to Cape Broom, a generic listing of Genista species (and Cytisus Species) would help avert a future weed problem and associated costs such as controlling and listing as noxious.

Some other extremely weedy genera ( see comments below )should also be looked at for listing with this potential in mind.

Hypericum x moserianum ( no common name) should be added in addition to Tutsan. This species is a more dominant weed in swamps and creeklines than Tutsan in some Upper Mountains catchments (eg Gordon Falls). Hypericum x moserianum is often mistaken for Tutsan (H. androsaemum) which explains the fact that it is not commonly seen on local weed lists.

Sacred Bamboo (Nandino domestica)is a bird spread invader particularly in Lower Mountains bushland (eg Birdwood Gully).

Prostrate Cotoneaster (Cotoneaster horizontalis) has similar weed characteristics as the other Cotoneasters listed (eg railway embankment on western side at Blacknheath, swamp at Pitt Park)

Rhododendron ponticum is a rhododendron that is increasingly escaping into

bushland along creeklines in the upper mountains (eg Pope's Glen,

Jamieson Creek, GordonFalls Creek). R. ponticum in highly invasive in the

British Isles.

Perennials and ground covers

Vinca minor , now commonly sold in nurseries, should be added as well as Vinca major. This smaller species appears as invasive as the larger species, but has not manifested as as much of a problem up till now because it has not been as commonly available.

The plant commonly called London Pride by bush regenerators in the mountains is actually Crassula multicava ssp. multicava. More recognisable common names for this plant are Fairy Crassula or Cape Province Pygmyweed.

Saxifraga umbrosa is not known to be a significant weed in the Blue Mountains.

Exotic Violet ( eg Viola odorata). Several species of non-native violets are found extensively in upper mountains creeklines and wet areas ( eg. Valley Of The Waters, Jamison Creek, Upper Kedumba River, Gordon Falls Creek). Most of these infestations can be directly traced back to gardens in the upper catchment.

Self Heal (Prunella vulgaris) is commonly found in most creeklines throughout the mountains which are affetced by urban runoff ( eg Blue Mountain Creek, Birdwood Gully, Everglades Creek)

Lilies and lily like plants

Arum Lily ( Zantedeschia aethiopica) should be added. It is a highly invasive species in Lower Mountains creeklines and wet areas ( Magdala Creek).

Freesia ( Freesia hybrids) commonly invade groundlayer vegetation in middle - lower mountains bushland ( Fairy Dell, Wentworth Falls Lake, Glenbrook Lagoon)

Wild Iris (Dietes spp. ) is a commonly planted landscape specimen which has the potential to spread prolifically by seed on Lower Mountains sites.

Grasses and grass like plants

This section needs to be reviewed based on the following criteria.

Most exotic and non-local native grass species have weed potential, because of their vigorous growth and / or prolific seed set. These qualities also make them useful for soil stabilisation and landscaping purposes.

It is therefore important to include in Schedule:6 those grass species with proven ability to invade and degrade Blue Mountains bushland, while not excluding from use those which are less invasive and have proved useful in stabilisation and similar applications.

Kikuyu Grass ( Pennisetum clandestinum) should be removed from the list. Although Kikuyu can be an invasive grass on the interface of urban and bushland areas it does not generally spread very far into undisturbed bushland in the Blue Mountains because it relies on vegetative spread. It is a much more vigorous invader in coastal areas (hence its inclusion on many Sydney based weed lists). There are a number of other grass species commonly used for lawns and stabilisation works which spread prolifically by seed and are therefore much more invasive (eg Erharta and a number of others which has been included). Given the limited number of lawn and stabilisation species available, Kikuyu could be encouraged as a useful grass species over the others.

Invasive grass species which should be aded to the list are:

Brown Top Bent - Agrostis capillaris

Creeping Bent - Agrostis stolonifera

Cocksfoot - Dactylis glomerata

Parramatta Grass - Sporobolus indica

Plume Grass - Pennisetum setaceum & P. alapecaroides

Prairie Grass - Bromus catharticus

Rye Grass - Lolium spp

Tall Fescue - Festuca elatior

Yorkshire / Creeping Fog - Holcus lanatus / H. mollis

The listing for Miscanthus sinensis should be changed to include the species and all varieties. It is not just Zebra Grass which is invasive.

Listing of complete genus's

There is a strong argument for including a number of entire genus's in Schedule:6 because many species within the whole genus are known to be serious weeds either in the Blue Mountains or in other areas with similar physiographic characteristics. This principle has already been adopted in the noxious weeds list for the genus Salix.

In case of ambiguity developers should be required to prove without any doubt

that a species within such a genus will not go weedy prior to any approval or planting.

Some generic listings should include exceptions of species that are known to be

non-invasive and are particularly useful (as is currently the case for Salix sp. )

Other suggested generic listings whereby all or most species within a genus are

weeds or potential weeds in the Blue Mountains include the following groups:

1.Erica species, two species (E. lusitanica and E. arborea) are proposed for

inclusion by BMCC on the updated noxious weeds list for Blue Mountains.

Several other species are known weeds in NSW (including Blue Mountains),

Victoria, Tasmania and New Zealand. These include E. melanthera, E.

andromediflora, E. caffra, E. x wilmorei, E. baccans, E. quadrangulatus, E.

scoparia.

2.Ludwigia species (water primroses)(exception of Ludwigia peploides

montevidiensis) The exotic species of Ludwigia are the aquatic and semi-aquatic

equivalent of Lantana, with vast vegetative and seed producing ability, very

difficult to control. There are at least two species established in the Sydney

Region (L. peruviana and L. longifolia).

3.Hypericum species (excluding two small natives, though they are unlikely to be

proposed for plantings). High seed production in many species and difficulty

involved with removal from sensitive vegetation units within the Blue Mountains.

Although Tutsan (H. androsaeum is listed, another species H. x moserianum is

much more widespread. H. kycheuense has recently been found at Leura and

several other species are known weeds in similar climatic areas to the Blue

Mountains, including Robertson in the Southern Highlands. St. John's Wort (H.

perfoliatum) is currently noxious and H. x moserianum and H. androsaeum are

included on the proposal for inclusion on the Blue Mountains noxious weeds list.

4.Pennisetum species (with the exception of P. clandestinum, see comments

under Grasses). This genus is well known for its invasive members. Blue

Mountains Conservation Society has previously written to council regarding

plantings on council land of two of these species (P. alopecuroides and P.

setaceum) other species such as P. macrourum are known environmental weeds

in Victoria and need to be covered in the instance of developers switching to

similar species if they are not on Schedule 6.

5.Achnatherum species. (espartillo) "ornamental" grasses from South America

with high potential for weediness (similar to Nassella species already listed)

The following groups are animal dispersed (several species of birds, fruit bats, foxes, possums) and therefore easily transferred from suburban gardens into bushland areas.

6.Cotoneaster species several species listed in draft, a generic listing would

simplify things as at least two others C. horizontalis and C. rotundifolius are also

known weeds at various locations in the Blue Mountains, and all plants in this

genus have weed potential.

7.Berberis species, has been approached in the draft list by including two

species, at minimum inclusion of a third species; B. thunbergii (including variety

B. t. atropurpurea) would better reflect the current situation in the Blue Mountains;

a large feral stand is known from Mount Wilson and the Blue Space Weed

Mapping project located B. t. atropurpurea in natural bushland near Leura.

8.Prunus species. Several species are weeds in the Blue Mountains. The onus

must be on the developer to prove without any doubt that an ornamental Prunus is

not fertile and will not spread from within the suburban context.

DICTIONARY : definition of NATURE BASED RECREATION

This is a permitted activity in the two Environmental Protection Zones. There needs to be some greater clarification of what is 'compatible' with the 'environmental values and ecologically sustainable management of the land'. (Ref dictionary definition p 424)

Some activities may be 'compatible' with the general values of an area but may cause degradation because of any (or a combination) of the following factors:

• The exact location in or near a sensitive locality (eg proximity to a rare plant population)

• The frequency of the activity (eg regular abseiling events)

• The numbers of participants (eg large groups climbing at a particular location)