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APPLICATION FOR EIS SCOPING DOCUMENT
SUPPORTING DOCUMENT
Canberra Brickworks Precinct Blocks 1, 7, and 20; Section 102,
Yarralumla ACT
FINAL
November 2019
Canberra
2/99 Northbourne Avenue Turner ACT 2612 PO Box 6135 O’Connor ACT 2602
T| 1300 793 267 E| [email protected]
www.umwelt.com.au
This report was prepared using Umwelt’s ISO 9001 certified Quality Management System.
APPLICATION FOR EIS SCOPING DOCUMENT SUPPORTING DOCUMENT
Canberra Brickworks Precinct Blocks 1, 7, and 20; Section 102, Yarralumla ACT
FINAL
Prepared by
Umwelt (Australia) Pty Limited on behalf of
Doma Group
Project Director: Karina Carwardine Project Manager: Caitlin Adcock Report No. 8137/R02/V4 Date: November 2019
Disclaimer This document has been prepared for the sole use of the authorised recipient and this document may not be used, copied or reproduced in whole or part for any purpose other than that for which it was supplied by Umwelt (Australia) Pty Ltd (Umwelt). No other party should rely on this document without the prior written consent of Umwelt.
Umwelt undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this document. Umwelt assumes no liability to a third party for any inaccuracies in or omissions to that information. Where this document indicates that information has been provided by third parties, Umwelt has made no independent verification of this information except as expressly stated.
©Umwelt (Australia) Pty Ltd
Document Status
Rev No. Reviewer Approved for Issue
Name Date Name Date
FINAL Karina Carwardine 5 November 2019 Karina Carwardine 5 November 2019
Application for EIS Scoping Document Supporting Document 8137_R02_Scoping Document_V4.0
Table of Contents
1.0 Introduction 1
1.1 Scope of this Report 1
1.2 Document Review 2
2.0 Project Description and Objectives 3
2.1 Project Area 3
2.2 Existing Environment 3
2.2.1 Heritage 3
2.2.2 Landform, Geology and Soils 6
2.2.3 Surface Water Hydrology and Drainage 6
2.2.4 Biodiversity 6
2.2.5 Bushfire Risk 7
2.3 The Project 7
2.4 Associated Project 8
2.5 Stakeholder Engagement and Community Consultation 9
2.6 Planning Context 10
2.7 Planning and Development Act Triggers 13
2.7.1 Impacts to Threatened Species or Community 14
2.7.2 Impacts on a Heritage Place or Object 19
2.7.3 Land on the Register of Contaminated Sites 23
3.0 Conservation Values 26
3.1 Flora, Fauna, and Landscape Diversity 26
3.2 Uncommon, Rare, or Endangered Flora, Fauna, Communities, Natural Landscapes, or Phenomena 26
3.3 Location Importance for Demonstrating Principal Characteristics of the Range of Landscapes, Environments, or Ecosystems Identified as Characteristic of their Class 27
3.4 Location Importance for Providing an Understanding of the ACT’s History 27
3.5 Decision under the EPBC Act 28
4.0 Preliminary Risk Assessment 29
5.0 References 31
Application for EIS Scoping Document Supporting Document 8137_R02_Scoping Document_V4.0
Figures
Figure 2.1 Locality Plan 4 Figure 2.2 CBP and Associated Projects 5 Figure 2.3 Blocks and Land-use Zoning 12 Figure 2.4 Ecological Impacts 17 Figure 2.5 Heritage 22 Figure 2.6 Contamination 25 Tables
Table 1.1 Form 1M Information Requirements 1 Table 2.1 Schedule 4 Triggers Relevant to the Project 13 Table 2.2 Summary of Preliminary Risk Assessment Relevant to Golden Sun Moth 14 Table 2.3 Summary of Preliminary Risk Assessment relevant to Protected Trees 18 Table 2.4 Summary of Preliminary Risk Assessment relevant to Heritage Places or Objects 19 Table 2.5 Summary of Preliminary Risk Assessment relevant to Contaminated Land 23
Appendices
Appendix 1 33 Appendix 2 Error! Bookmark not defined. Appendix 3 3
Preliminary Risk Assessment Regulated Trees from dsb Landscape Architects (2015) Master Plan
Application for EIS Scoping Document Supporting Document 8137_R02_Scoping Document_V4.0
Introduction 1
1.0 Introduction
1.1 Scope of this Report
This report is provided for the information of the Environment, Planning and Sustainable Development Directorate (EPSDD) as supporting documentation for an Application for a Scoping Document for an Environmental Impact Statement (EIS) for the development of the Canberra Brickworks Precinct (the Project).
Information presented in this document and the accompanying preliminary risk assessment (PRA) (Appendix 1) addresses the information requirements outlined in Section 9 of Form 1M ‘Application for Scoping Document, Environment Significance Opinion, s211’1 and the associated guidelines (ACTPLA, n.d.) as summarised in Table 1.1.
Table 1.1 Form 1M Information Requirements
Required Information under Form 1M Location in this Report
1 A statement outlining the objectives of the Project and why it is needed.
Section 2
2 A description of the nature/type of project proposed by providing location map(s) of the project site(s), preliminary design drawings and satellite/aerial photographs.
Section 2
3 A preliminary risk assessment (PRA) based on the ‘Preparation of an Application for Scoping and Preparation for an Environmental Significance Opinion’ (guidance document) (ACTPLA, n.d.)
Sections 2.7 and 4,
Appendix 1
4 A description of the natural conservation values of the site based on the considerations listed in the guidance document (ACTPLA, n.d.).
Section 3
5 Not Applicable to Applications for Scoping
6 Any decision made under the Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth) (EPBC Act)
Section 3.5
7 Not Applicable to Applications for Scoping
The Doma Group (Doma) have engaged Umwelt Environment and Social Consultants (Umwelt) to complete the PRA and supporting documentation for the Project. The PRA has been prepared as a component of the EIS that is proposed to be undertaken through the Bilateral Assessment process under Part 8 of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) with the Australian Capital Territory (ACT) Government EPSDD.
1 Approved form AF2017-201, approved by Ben Ponton, Chief Planning Executive, Planning and Land Authority, on 29 September 2017 under section 425 of the Planning and Development Act 2007 and revokes form AF2017-201.
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Introduction 2
1.2 Document Review
In preparing this report and the PRA, a number of documents have been reviewed from specialist investigations and surveys that have been completed specifically for this Project and the adjacent proposed upgrade of Dudley Street, including but not limited to the:
• Stage 1 Site Investigation Report for Canberra Brickworks by AECOM (2016) and appendices particularly:
o Preliminary Geotechnical Site Investigation for the Canberra Brickworks, November 2013 by SMEC.
o Preliminary Environmental Site Investigation for Canberra Brickworks, February 2014 by SMEC.
o Stage 1 Environmental Site Assessment for Canberra Brickworks, March 2015 by Robson Environmental.
o Canberra Brickworks and Environs Ecological Assessment, December 2014 by Umwelt.
o Yarralumla Brickworks Precinct Tree Assessment: Tree Management Report, November 2015 by dsb Landscape Architects.
o Bushfire Risk Assessment Report for Canberra Brickworks Precinct, January 2016 by Australian Bushfire Protection Planners Pty Limited (ABPP).
o Stage 1 Aboriginal Cultural Heritage Assessment, August 2014 by Navin Officer.
o Heritage Assessment of the Canberra Brickworks and Environs by Lovell Chen, March 2016.
• Conservation Management Plan for the Canberra Brickworks by Lovell Chen, April 2010 and draft updated Conservation Management Plan, June 2017 prepared by GML.
• Phase II Environmental and Geotechnical Site Investigations by SMEC, October 2016 and November 2016.
• Golden sun moth surveys of Canberra Brickworks by Biosis, May 2017.
• Golden sun moth survey and ecological assessment of Dudley Street Road Reserve, February 2017 by Umwelt.
• A draft of the Community Engagement Plan for the Canberra Brickworks by Elton Consulting, June 2017.
• Online Heritage resources.
• Canberra Brickworks and Environs Planning and Development Strategy, 2013 prepared by the Land Development Agency (LDA).
A summary of the findings of these reports has been provided in this report and in the PRA.
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Project Description and Objectives 3
2.0 Project Description and Objectives
2.1 Project Area
The Project Area is located in south-west Yarralumla, to the west of central Canberra in the Australian Capital Territory (ACT) (see Figure 2.1). The Project Area is known as the Canberra Brickworks Precinct (CBP) and is Territory Land located on Blocks 1, 7, and 20, Section 102, with an area of 16.1 hectares (ha).
Current access to the CBP is from Denman Street only. The Project Area is surrounded by Bentham Street to the north; low density residential development of Yarralumla to the north, north-east and east; open space both sides of Dudley Road to the south; and the Royal Canberra Golf Club to the west (see Figure 2.1). The golf club forms a major part of the heritage listed Westbourne Woods that encompasses the arboretum and nursery that were established in 1914 (GML, 2017).
2.2 Existing Environment
2.2.1 Heritage
The Canberra Brickworks were operational in the Project Area from 1913 to 1976. The Project Area has been largely vacant since that time. The Canberra Brickworks are of historical significance at a Territory level as the first industrial manufacturing facility in the ACT, and they had an integral role in the development of Canberra providing material for construction of early buildings (LDA, 2013). The heritage significance of the Canberra Brickworks is recognised in its listing along with the brickworks railway remnants on the ACT Heritage Register.
The Project Area itself contains the buildings of the former brickworks, associated quarry, and railway remnants with landscape trees throughout the quarry area and along the boundaries (see Figure 2.2). A small recycled timber furniture store currently operates from the Canberra Brickworks buildings; otherwise public access is generally limited by fences that surround the property.
For discussion purposes in this report, the Project Area or CBP is further separated into the following areas:
• Canberra Brickworks, also known as Yarralumla Brickworks, containing all of the existing buildings and occurs in Block 1, Section 102 in the north-western portion of the Project Area (Figure 2.2).
• Former quarry or ‘brick pit’ that occurs in the north-eastern portion of the Project Area within the existing boundary of the Canberra Brickworks heritage site (Figure 2.2). It is generally bounded by Bentham Street, Denman Street, and neighbouring residences to the east of the Project Area.
• ‘Railway Remnants’ occurs to the south of the brickwork buildings (Figure 2.2) in part Block 7, Section 102.
• Former worker’s accommodation ‘Brickworks Accommodation Village’ occurs in Block 1, Section 102 to the south of the brickwork buildings and east of the railway remnants (see Figure 2.2).
• Partly cleared land in the east and south-east of Block 7 near the entrance off Denman Street.
There have been no sites of indigenous heritage value recorded within the CBP, and the area does not contain locations of potential value (Navin Officer, 2014).
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Project Description and Objectives 6
2.2.2 Landform, Geology and Soils
The topography of the Project Area is variable and has been significantly modified by quarrying and landfill. The Project Area ranges in elevation from approximately 570 metres Australian Height Datum (AHD) to 590 metres AHD, and generally slopes to the west towards the Royal Canberra Golf Course and north-west. A small portion of the Project Area, towards Dudley Street, slopes to the south and south-west.
The Project Area is underlain by the Yarralumla Formation, the only fossiliferous marine unit within the extensive volcanic marker horizons of South Canberra (SMEC, 2013). Excavations at the quarry have exposed the Yarralumla Formation and are recognised as one of the only locations from which the Yarralumla Formation can be closely observed (SMEC, 2013). The Canberra Soil Landscape sheet maps the Project Area as Williamsdale soil landscape; which is characterised by undulating rises and local relief, typically below ten percent in natural terrain. Test pit data has identified that fill soil is approximately 2.5 to 3 metres in depth (Robson, 2015) overlying natural soils. The majority of the CBP is comprised on natural silty clays, underlain by siltstone, sandstone, or Dacite bedrock. In locations which have been historically disturbed, the soils have been modified due to the typically hard-setting, erodible and potentially dispersive soil (SMEC, 2013).
As a legacy of past land uses the Project Area has been subject to extensive contamination assessments. These are summarised further in Section 2.7.5.
2.2.3 Surface Water Hydrology and Drainage
There are no watercourses within the CBP; the nearest surface water body being Warrina Inlet of Lake Burley Griffin, approximately 600 metres to the north-west of the Project Area. Surface water flow has been significantly modified by the historic use of the site, especially relating to the quarry use and fill. The main catchment in the Project Area encompasses the brickworks, quarry, former workers accommodation and cleared land off Denman Street. Surface water runoff from this catchment drains to the north-west corner then via a drainage reserve through the Royal Canberra Golf Course into the Warrina Inlet of Lake Burley Griffin. The drainage reserve includes both piped infrastructure and overland flow path (SMEC, 2013).
2.2.4 Biodiversity
The Project Area has been subject to numerous ecological surveys since 2010 (Rowell 2010, 2011 and 2012; Umwelt 2014 and 2015b; Biosis 2017) as part of the planning and early design phases of the Project. All surveys were undertaken in accordance with the relevant guidelines; and ecological values detected are discussed in Sections 2.7.1-2.7.3.
The Project Area was grazing land prior to its use as the brickworks and has been cleared of native vegetation. Vegetation across the CBP has been heavily modified and is dominated by exotic species; including landscaping trees, garden escapees, and weeds. Areas near the site boundaries and in the quarry contain a planted overstorey – primarily of Pinus radiata species (Umwelt, 2014). The vegetation within the CBP has no conservation significance.
Small patches of exotic grassland near the entrance to the CBP are dominated by a weed of national significance: Chilean needlegrass (Nassella neesiana). This weed species is known to support golden sun moth (Synemon plana) and the patch within the CBP has been confirmed as habitat for this critically endangered species (Biosis, 2017).
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Project Description and Objectives 7
The areas of the quarry and historic landfill are highly modified and do not contain any natural features. The exotic composition of the vegetation provides limited opportunities for native species and is unlikely to represent areas of importance.
We note that validation of these previous results is scheduled to occur in November 2019. The results of these surveys will be incorporated into the EIS.
Further consideration of impacts of the Project on threatened species is provided in Section 2.7.1 and the conservation values of the Project Area are discussed in Section 3.0.
2.2.5 Bushfire Risk
A preliminary assessment of bushfire hazard risk has identified that vegetation to the west of the CBP, in the adjoining Block 1, Section 127, Yarralumla, may present a low risk of severe bushfire event to development of the CBP if it is left unmanaged. This assumes that vegetation within the Canberra Golf Club land and along Dunrossil Drive continued to be managed. Grassy woodland vegetation on the North Curtin Horse Paddocks to the south of the CBP may present a high risk of severe bushfire event to development of the CBP if it is left unmanaged (ABPP 2016).
2.3 The Project
The proposed Project is urban development at the site of the former Canberra Brickworks. The development has been guided by the Yarralumla Neighbourhood Plan (ACT Planning and Land Authority, 2004) and the 2013 ACT Government’s Land Development Agency (LDA) Canberra Brickworks and Environs Planning and Development Strategy, which sought to promote the adaptive re-use to the site and its surrounds with respect to its heritage significance. The Doma Group were successful in the tender to purchase the site from the LDA in April 2017 and propose a mixed use residential, commercial, and retail development that utilises much of the Canberra Brickworks heritage elements.
The Project will provide a maximum of 380 residential dwellings and recreational parkland around the re-purposed Canberra Brickworks buildings. Details of the Project are being refined and a graphic representation has not been included herein, however, a summary of the intent of the Project has been provided in this section.
While the Project Area is currently only accessible off Denman Street, the Project has been designed so that the primary access will be from the south via Dudley Street with only local traffic to discrete residential precincts off the minor access roads from Bentham Street and Denman Street. The Project has been designed to only allow for emergency vehicle access between these three roads. Adequate car parking will be provided within the CBP for residents and public car parking for offices, retail and recreational users. This will be developed in accordance with the ACT Parking and Vehicular Access Code.
Given the heritage value of the CBP, the residential development will be low density, with a focus on maintaining the urban parkland that fits in with the existing landscape and surrounding urban areas. The Project would be divided into four distinct precincts including:
• Low density dwelling house precinct to the east of the gravel pit with access via a public cul-de-sac off Bentham Street. This precinct includes the residential zoned land and will include a 20 metre buffer between the proposed development and existing residential dwellings, in accordance with the Yarralumla Precinct Map and Code requirements. Design of this precinct will consider visual impacts to existing residents.
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Project Description and Objectives 8
• Southern precinct around the proposed entrance off Dudley Street will include residential buildings set back from the entrance road with a mix of houses, terraces and apartment buildings no taller than three storeys.
• Higher density more urban setting residential precinct to the west of the brickworks although again no taller than three storeys. The Railway Remnants will be retained within open space/parkland. This precinct will be accessed off Dudley Street.
• Brickyard Heritage Precinct includes the re-purposed buildings to allow for retail and commercial spaces including cafes and industrial crafts; interpretive features; and auxiliary facilities for residents, such as a gymnasium, swimming pool, and gardens. This precinct will be accessed off Dudley Street.
In recognition of the heritage values of the Canberra Brickworks and former quarry the Project would see the majority of ‘core’ and ‘supporting’ individual heritage elements and the essential industrial characteristics of the Canberra Brickworks heritage site retained, conserved, and sensitively re-used.
The former quarry area will be used as urban parkland that will be sensitive to the geological heritage values of the quarry while allowing a recreational space that is linked to existing and proposed walking and cycle paths.
The tree management report by dsb Landscape Architects (2015) has identified that many of the trees on site should be removed and the landscaping plan implemented from an early stage. The Project includes landscaping to provide privacy for existing neighbours; define entrances, streetscapes and pathways; to screen infrastructure elements; and provide parkland and open space. The landscape plan is being refined in development of the Project.
An inner asset protection zone (IAPZ) within the western boundary of the lease will not be required as the requirements are being met by existing management outside the site (i.e. within the Canberra Golf Club, Dunrossil Drive/Cotter Road area and in Block 1, Section 127, Yarralumla).
It is proposed that development of the Project will occur in stages. The initial stage is focused on remediation, infrastructure, adaptation and repurposing of heritage buildings and stage 1 residential development. Remediation includes demolition, site clean-up, storage of reusable material and removal of hazardous materials in accordance with site contamination report. Site preparation and civil works will include: construction traffic management (access from Dudley Street and construction workers carpark); establishment of bushfire management zones; heritage protection works; service infrastructure upgrades; vegetation management and landscaping; and, the conservation and adaptive use works of key heritage elements including establishment of parks and heritage interpretation.
The second stage will include progressive development of residential precincts in response to market demand and finalising landscaping.
The Project is in keeping with the ACT strategies and aims of the ACT Planning Strategy (Environment and Sustainable Development Directorate 2012) to: establish a more compact, efficient city focusing urban intensification around Civic, town and group centres; and a more sustainable city that uses its resources and infrastructure more efficiently.
2.4 Associated Project
The Project is linked to a secondary project to upgrade Dudley Street and to construct an access road into the CBP (Figure 2.2). The access road will service the majority of the proposed residential development and proposed redevelopment of the brickworks buildings.
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Project Description and Objectives 9
Dudley Street is currently a 6 metre wide single carriageway (minor collector road) and has been approved to be upgraded to a 10 metres wide single carriageway (a major collector road) to meet current demand and improve public safety. To reduce inconvenience and impacts to the public, it is proposed to construct a 130 metres long access road (minor collector road) from Dudley Street into the CBP.
The Dudley Street access road was approved by the Department of the Environment and Energy (DoEE) on 27 February 2019 (EPBC 2017/8072), and then subsequently approved by the National Capital Authority (application number 101340). A s211 Exemption application (NI2019-183) was submitted to the EPSDD, followed by an Impact Track development application. This was approved in July 2019.
As such, the Dudley Street access road project has received all necessary planning approvals, subject to conditions.
2.5 Stakeholder Engagement and Community Consultation
The CBP has been the subject of public interest for many years, and public consultation has been extensive and continues to occur. A Community Engagement Plan (Elton, 2017) has been prepared, and is continually being refined throughout the design stages. The consultation history (as summarised below), has provided Doma Group with a strong understanding of the general aspirations of the site and have assisted the development of the Project.
The ACT Government, through the then Land Development Agency (LDA), began consultation in 2010. The following key themes for any potential future development of the CBP were identified (Elton, 2017):
• heritage conservation and preservation
• appropriate development for the location and surrounding landscape and uses
• maintenance of access and connectivity
• preservation and maintenance of open space
• increased amenity and vibrancy.
In 2015, the LDA established a Community Panel to build on the key themes above to develop a list of objectives to guide the future development of the CBP. The Community Panel has played a key role in the tender phase of this Project and continues to be a key participant in the consultation process. The objectives raised by the Community Panel include the following (Elton, 2017):
• maintenance/enhancement of the unique heritage of the CBP
• result in a quality development that showcases the heritage buildings
• Pittman (Quarry) Park is readily accessible
• maintain pedestrian/cycle networks
• ensure minimal disruption to existing land users, especially residents
• consider local environmental issues
• have a sustainable built form.
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Project Description and Objectives 10
The latest Community Engagement Plan includes the following key elements:
• regular project updates to all stakeholders
• broader updates provided through the website and social media
• utilisation of existing marketing channels that were established by the LDA
• alignment of communication with project program milestones
• utilisation of a range of tools, including one-on-one meetings, monthly meetings with the Community Panel, email updates, website maintenance, public presentations and ‘pop-up’ information stalls, collection of ‘memories’ for the museum, and a quarry party following completion of Stage 1.
The first phase of the engagement milestones has been completed. The next phases will align with Project milestones, as detailed in the Community Engagement Plan.
Indigenous stakeholders identified as Representative Aboriginal Organisations (RAOs) were consulted via email and telephone as part of the Aboriginal Cultural Heritage Assessment (Navin Officer, 2014) in July and August 2014. A representative on one RAO (Buru Ngunnawal) attended the field survey. The Aboriginal Cultural Heritage Assessment concluded that no known Indigenous heritage sites occur and there are no areas of archaeological potential. The Cultural Heritage Assessment has been approved by the ACT Heritage Council on 11 September 2014 (Lovell Chen, 2016).
2.6 Planning Context
The Project Area is located on Territory Land and the Territory Plan is the key statutory planning document that applies to the Project Area. The Territory Plan identifies that the Project Area is zoned CZ6 (Leisure and Accommodation Zone) and with a small part in the north east corner of Block 1 zoned RZ1 (Suburban Zone) (see Figure 2.3).
The Project Area is governed by the Yarralumla Precinct Map and Code (RC1). The code identifies additional controls for the CBP such as floor area for shops and offices, and a maximum three storey residential and two storey other uses development. The code also sets out a minimum setback of 20 metres to the northern and eastern boundary.
The Project is permissible in the CBP and has been designed to reflect zoning and code requirements. The Project will require approval from the EPSDD in accordance with the Planning and Development Act 2007 (ACT) (PD Act). The Project triggers the need for an Environmental Impact Statement (EIS) under the PD Act (i.e. impact track assessment) as a result of potential impacts to protected species, potential impacts to ACT listed heritage matters, and as the Project Area is included on the register of contaminated sites (see Section 2.7.3).
Land to the west and south of the Project Area are designated capital land under the National Capital Plan as part of the National Capital Open Space System associated with Lake Burley Griffin and Foreshores. The National Capital Plan is the strategic plan for Canberra and the Territory to ensure that developments are planned in accordance with national significance recognising the unique purpose, setting, character and symbolism of Australia’s national capital. The Project Area is not designated National Capital Land and is not expected to impact the National Capital Plan or require approval from the National Capital Authority.
The requirements of the EPBC Act also need to be considered for the project. In accordance with the EPBC Act, the project has been referred (2017/8074) to the Commonwealth DoEE.
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Project Description and Objectives 11
As an EIS is required under the PD Act and the ACT EIS process has been accredited by the Commonwealth in accordance with the bilateral agreement between the Australian and ACT Governments, the Project can be assessed using an accredited assessment process. Accordingly, the referral has requested that the project be assessed using the ACT EIS process. The EIS will include additional information as identified in this Scoping Document, such that the Minister for the Environment has sufficient information to decide under the EPBC Act.
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Project Description and Objectives 13
2.7 Planning and Development Act Triggers
A review of all available documentation relating to the Project has identified items that will, or may, trigger impact track assessment pathway under Schedule 4 of the PD Act (Table 2.1). Table 2.1 does not include items that have been determined to be not applicable to the Project.
Table 2.1 Schedule 4 Triggers Relevant to the Project
Part Item Trigger Report Section
4.3 1 Proposal that is likely to have a significant adverse environmental impact on 1 or more of the following, unless the conservator of flora and fauna provides an environmental significance opinion indicating that the proposal is not likely to have a significant adverse environmental impact:
(a) a critically endangered species;
(b) an endangered species;
(c) a vulnerable species;
(d) a conservation dependent species;
(e) a regionally threatened species;
(f) a regionally conservation dependent species;
(g) a provisionally listed threatened species;
(h) a listed migratory species;
(i) a threatened ecological community;
(j) a protected native species;
(k) a Ramsar wetland;
(l) any other protected matter.
Section 2.7.1
4.3 6 Proposal that is likely to have a significant adverse impact on the heritage significance of a place or object registered under the Heritage Act 2004, unless –
(a) the heritage council produces an environmental significance opinion that the proposal is not likely to have a significant adverse impact; or
(b) the proposal is the demolition of a building that is affected residential premises, and the heritage council has approved a statement of heritage effect in relation to the proposal.
Section 2.7.2
4.3 7 Proposal involving land included on the register of contaminated sites under the Environment Protection Act 1997.
Section 2.7.3
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Project Description and Objectives 14
2.7.1 Impacts to Threatened Species or Community
Ecological surveys undertaken by Umwelt (2015b) and Biosis (2017) and a tree survey completed by dsb (2015) have determined that golden sun moth (Synemon plana) and trees protected under the Tree Protection Act 2005 (ACT) (TP Act) are present in the Project Area. No other ecological values were detected in the Project Area.
The following Sections 2.7.1.1 and 2.7.1.2 provide detail on golden sun moth and protected trees, respectively.
2.7.1.1 Golden Sun Moth
Table 2.2 Summary of Preliminary Risk Assessment Relevant to Golden Sun Moth
Phase of
development
Activity Effects Risk
Rating
Mitigation / Management
measures
Design Site
Investigations
Intrusive site investigations (e.g.
geotechnical, contamination test
pitting) are undertaken prior to
PD Act and EPBC Act Approval
resulting in impacts to MNES
prior to approval being gained,
and potential non-compliance
with either Act.
MEDIUM Liaise with EPSDD and DoEE prior
to intrusive site investigations if
they are to occur prior to an
approval decision being made.
Ensure EMP for site investigations
identifies go / no-go zones and
environmental controls.
Design Off-site
impacts
Increased run off from
impervious surfaces, such as car
parks, increases flow
downstream and impacts areas
beyond the Canberra Brickworks
boundaries.
HIGH Design will meet the requirements
of the WSUD General Code
(ACTPLA, 2007) to ensure post-
development flows do not exceed
pre-development flows.
WSUD infrastructure will be
maintained to standards set out in
the WSUD General Code.
Design Offsetting
significant
impacts
No offsets are available within
the ACT for golden sun moth.
HIGH Consult with DoEE and ACT
Government at early stage to
determine whether biobanking is
an appropriate option for
offsetting, due to the deficit of
local golden sun moth sites
(completed)
Obtain biobanking credits for
golden sun moth in local region to
provide appropriate offset for
golden sun moth.
Construction Vegetation and
Habitat clearing
Clearing vegetation outside
approved disturbance area due
to unclear demarcation of
boundaries results in non-
compliance with PD Act and
EPBC Act approval.
MEDIUM Conduct pre-clearing surveys to
determine clearing boundaries.
Establish no-go zones, site
boundaries, and fences prior to
construction commencing by
implementing an industry best
practice Construction
Environment Management Plan
(CEMP) to prevent unauthorised
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Project Description and Objectives 15
Phase of
development
Activity Effects Risk
Rating
Mitigation / Management
measures
access into adjacent areas.
Inform EPSDD and DoEE
immediately if any impacts
outside approved area occur.
Construction General
Construction
Activities
Construction activities change
water regimes including flow
rate, quality, sedimentation, and
erosion; resulting in
environmental impacts beyond
the approved development area.
MEDIUM Develop and implement industry
best practice CEMP that includes
and implements management
plans to avoid or minimise
environmental risks (e.g.
sedimentation, erosion, weeds,
storm water runoff, etc.).
Conduct construction activities in
accordance with EP Act
requirements.
Golden sun moth is listed as endangered under the Nature Conservation Act 2014 (ACT) (NC Act) and critically endangered under the EPBC Act.
Surveys undertaken by Umwelt (2014; 2015b) and Biosis (2017) have recorded 0.9 ha of occupied golden sun moth habitat within the Project Area. In addition, a golden sun moth survey was also undertaken in 2016 for the associated project at Dudley Street (Umwelt, 2017). This survey recorded golden sun moths within the Project Area in locations that were not observed by Biosis (2017). This is demonstrated in Figure 2.4. This additional area consists of 0.27 ha of low-quality mixed feed species.
The total area of golden sun moth habitat within the Project Area is 1.17 ha. It is noted that all identified habitat within the Project Area consists of low-quality exotic pasture, primarily Chilean needle grass (Nassella neesiana). (Figure 2.4)
It has not been confirmed whether breeding occurs within the Project Area, or whether it is just utilised for foraging by individuals breeding in the higher quality habitat surrounding Dudley Street to the south (see Figure 2.4).
The Biosis (2017) surveys recorded the highest density of golden sun moth at the Project Area (12 flying male moths per hour); which was consistent with the densities recorded in surveys undertaken by Umwelt (2017) within the adjacent roads upgrade area. Generally speaking, 2017 recorded higher than average densities of golden sun moth in habitat dominated by Chilean needlegrass, and lower densities in native areas. This is thought to be linked to the high spring rainfall received and subsequent abundance of exotic grass species throughout Canberra; noting that the key drivers of golden sun moth population variance are still being researched and understood.
Golden sun moth surveys are scheduled to occur in November/December 2019 to confirm their continued presence, and current extent within the Project Area.
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Project Description and Objectives 16
Impacts and Mitigation/Management Measures
The entire patch within the Project Area boundary is anticipated to be directly impacted by the proposed development (see Figure 2.4). Indirect impacts off-site will be managed through design and construction management practices, including:
• Ensuring that the Project incorporates Water Sensitive Urban Design (WSUD) in accordance with the WSUD General Code to prevent offsite impacts to retained habitat.
• Limiting works to the approved construction area through pre-clearance surveys, demarcation (fencing) and training to all site personnel.
• Implementing sedimentation and erosion controls and water management controls through preparation and ongoing review of a Construction Environmental Management Plan (CEMP).
Due to the low-quality, and non-native golden sun moth habitat present, alternative mitigation methods such as translocation, or retention of habitat within open space, are likely to create adverse ecological outcomes through the spread of noxious weeds (Chilean needlegrass). This will be explored further in the EIS.
The associated, recently approved, Brickworks access road project undertook substantial avoidance of the higher quality golden sun moth habitat in the locality to ensure that the Project as a whole did not result in unacceptable impacts to the species.
The PRA identified that the availability of offsets for golden sun moth in the ACT is a high risk. There is limited habitat available suitable as an offset that is unallocated to future Government projects.
As such, the proponent has undertaken discussions with DoEE and the EPSDD regarding the purchasing of Biobanking credits in NSW as a viable offsetting option for the Project. Based on these discussions, this is likely to be the pathway taken by the proponent.
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2.7.1.2 Protected Trees
Table 2.3 Summary of Preliminary Risk Assessment relevant to Protected Trees
Phase of
development
Activity Effects Risk
Rating
Mitigation / Management
measures
Construction Site access and
management
Uncontrolled access by
vehicles leads to damage
to heritage elements or
trees to be retained.
MEDIUM Establish no-go zones, site
boundaries, and fences prior to
construction commencing by
implementing an industry best
practice CEMP to prevent
unauthorised access into adjacent
areas.
Inform EPSDD and DoEE
immediately if any impacts
outside approved area occur.
In 2013 dsb Landscape Architects undertook a tree assessment within the Project Area and adjoining road works area. In general, the Project Area is unmanaged and weed species are prevalent. The majority of trees on site are pines including Pinus radiata, P. ponderosa and P. sylvestris with English elm (Ulmus procera) and a copse of oak trees (Quercus palustris, Quercus cerris and Quercus sp.) (dsb 2015). Neighbours have also planted a variety of trees along the eastern boundary and in the north west of the Project Area. The pine trees in the CBP and to the south of the CBP are likely to be self-seeded secondary forest growth from the nearby Forestry Institute site and Westbourne Woods (LDA 2013).
Under the TP Act, protected trees include ‘registered’ trees, and ‘regulated’ trees. There are no registered trees located within the Project Area (dsb, 2013). There are numerous regulated trees within or directly adjacent to the Project Area (see Appendix 2) of which 15 are considered of high quality (dsb, 2013). None of the regulated trees are native species.
In 2015, dsb prepared a tree management plan for the Project Area, which included recommendations as to which trees should be retained and/or enhanced, and which should be removed. These recommendations were incorporated into the Master Plan for the Project and will continue to be considered during the landscape design phase.
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2.7.2 Impacts on a Heritage Place or Object
Table 2.4 Summary of Preliminary Risk Assessment relevant to Heritage Places or Objects
Phase of
development
Activity Effects Risk
Rating
Mitigation / Management
measures
Design Design Development The Project results in
impacts to the heritage
values of the Yarralumla
Brickworks and Railway
Remnants due to the
recommendations of the
Conservation
Management Plan not
being appropriately
implemented during the
design phase.
HIGH Consider the Conservation
Management Plan and its
recommendations throughout the
design phase (completed).
Update the Conservation
Management Plan based on the
proposed actions of the Project (in
preparation).
Design the development to be as
least intrusive to the Yarralumla
Brickworks and Railway Remnants
as practicable.
If development is likely to
significantly affect the heritage
values of the Yarralumla
Brickworks or the Railway
Remnants, then seek advice from
the ACT Heritage Council.
Design Design Development Material selection and
finishes result in
additional impacts to the
heritage values of the
Yarralumla Brickworks as
they are not consistent
with the Conservation
Management Plan.
HIGH Incorporate the recommendations
and management guidelines of
the Conservation Management
Plan into the design of the CBP
buildings.
Construction Site access and
management
Uncontrolled access by
vehicles leads to damage
to heritage elements or
trees to be retained.
MEDIUM Establish no-go zones, site
boundaries, and fences prior to
construction commencing by
implementing an industry best
practice CEMP to prevent
unauthorised access into adjacent
areas.
Inform EPSDD and DoEE
immediately if any impacts
outside approved area occur.
Construction General Construction
Activities
Earthworks result in the
destruction of previously
unidentified Aboriginal
or European cultural
heritage items.
MEDIUM Develop and implement an
Unanticipated Discovery Plan
during clearing and construction
activities, including training
personnel in Unanticipated
Discovery procedures.
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Phase of
development
Activity Effects Risk
Rating
Mitigation / Management
measures
Operation Residential and
recreational use
Use of the Canberra
Brickworks results in
detrimental effects to
the heritage values.
HIGH Restrict access to sensitive
heritage features through
landscape and building design.
Undertake regular maintenance
work.
Include heritage listed places in a
heritage interpretation strategy to
educate the public on their values
and actions for their protection.
There are two places listed on the ACT Heritage Register present within the Project Area:
• Yarralumla Brickworks: Comprising the elements assessed as being of exceptional and moderate significance, within Block 1, Section 102, Yarralumla. The Yarralumla Brickworks is of significant historical value as the first industrial manufacturing facility within the ACT and for its role in providing the base materials used in the construction of many of the early buildings in Canberra Heritage features generally include remaining built elements such as the kilns and chimney stacks, office, and crusher houses; the on-site quarry and associated geological features; and, the remains of the brickworks workers’ accommodation village (ACT Heritage Council, 2001).
• Yarralumla Brickworks Railway Remnants: Covers part of Block 7, Section 102, Yarralumla, extending south form the Yarralumla Brickworks. This listing consists of the remnants of the original earthen railway embankment, cutting, and terraces (ACT Heritage Council, 2013).
The Yarralumla Brickworks (also known as the Canberra Brickworks) is also listed under two non-statutory lists by the Australian Institute of Architects and the National Trust of Australia (ACT) (GML, 2017).
Particular care has been taken in the consultation process and subsequent design process of the Project to make the most of the heritage and geological features identified in the Project Area (see Figure 2.5). A Conservation Management Plan prepared by Lovell Chen (2010) for the Project Area has been endorsed by the ACT Heritage Council; and is currently being updated by GML (2017). The recommendations regarding the ongoing management and significance of the individual heritage values have been considered and incorporated into the designs for the Project. The Project will see the majority of the ‘core’ and ‘supporting’ heritage elements and the essential industrial characteristics of the Yarralumla Brickworks retained, conserved, and sensitively re-used.
Given the heritage value of the Project Area, especially to local Yarralumla residents, significant community consultation has occurred as part of the planning and design phases of the Project’ and will continue to occur in accordance with the Community Engagement Plan (Elton, 2017). In particular, this has included the establishment of a community panel, made up of numerous community and resident’s groups, which acts as an advisory body for the Project (Land Development Agency, n.d).
2.7.2.1 Historic Archaeological Assessment
The 2010 Conservation Management Plan (Lovell Chen, 2010) recommended that an Archaeological Assessment be undertaken to identify areas of historical archaeological sensitivity, consider the likely nature and significance of the sub-surface remains, and provide guidance on the management of any identified archaeological remains (Lovell Chen, 2016). An Archaeological Assessment was undertaken by Lovell Chen (2016); and concluded that archaeological remnants are likely to survive at the site. These
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Project Description and Objectives 21
archaeological remnants ranged in archaeological potential from low to high, and were associated with the following elements of the Canberra Brickworks:
• kiln and dormitories
• cottage, stables, coal store
• railway remnants
• railway siding extension
• flues/subsurface workings
• married quarters and Brickworks Hostel
• single men’s quarters
• rubble heap/refuse dump.
The Archaeological Assessment concluded that the artefacts are unlikely to be of sufficient significance to warrant retention in-situ or to preclude development of the Project Area; however, they have the potential to enhance the understanding of the history of the Project Area if kept on display as part of the Project (Lovell Chen, 2016).
Impacts and Mitigation/Management Measures
In recognition of the heritage values of the Canberra Brickworks and former quarry the Project would see the majority of ‘core’ and ‘supporting’ individual heritage elements and the essential industrial characteristics of the Canberra Brickworks heritage site retained, conserved, and sensitively re-used. The Brickyard Heritage Precinct would be re-purposed to allow for retail and commercial spaces including an artisanal food, drink and produce hub; specialist arts and crafts retail with studios; bike mechanic; interpretive features; and auxiliary facilities for residents, such as a gymnasium, swimming pool, and gardens.
The former quarry area will be used as urban parkland that will be sensitive to the geological heritage values of the quarry while allowing a recreational space that is linked to existing and proposed walking and cycle paths.
Heritage consultants will be engaged throughout the life of the Project to assess and guide the maintenance and interpretation of the heritage values of the Canberra Brickworks. During construction a Chance Find Protocol will be incorporated into the CEMP. A Heritage Management Plan will then be prepared for the ongoing maintenance of the site once operational.
2.7.2.2 Indigenous Heritage Values
The Project Area is located on Ngunnawal traditional land. A Stage 1 Aboriginal Cultural Heritage Assessment (ACHA) was completed by Navin Officer (2014). The ACHA determined that there are no known Indigenous heritage sites or areas of archaeological potential within the Project Area; and that any archaeological deposits would have been disturbed as a consequence of past land use. Indigenous stakeholders (i.e. Representative Aboriginal Organisations) were consulted during the preparation of the ACHA. The ACHA was approved by the ACT Heritage Council on 11 September 2014 (Lovell Chen, 2016).
There are no statutory implications regarding cultural heritage for the Project.
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2.7.3 Land on the Register of Contaminated Sites
Table 2.5 Summary of Preliminary Risk Assessment relevant to Contaminated Land
Phase of
development
Activity Effects Risk
Rating
Mitigation / Management
measures
Construction General Construction
Activities
Discovery of previously
unidentified
contaminated soil during
construction results in
delays to program
implementation or
increased costs due to
remediation.
HIGH Undertake remediation of
identified contaminated sites prior
to general construction
commencing.
Develop and implement an
Unexpected Finds Protocol for all
earthworks and construction
activities on site, including training
personnel in Unexpected Finds
procedure.
The Canberra Brickworks (Blocks 1, 7 and 20) is registered as a contaminated site under the Environment Protection Act 1997. A number of investigations have been completed to provide site contamination data on the legacy of the former land uses, including the former quarry operation and demolished workers accommodation.
Studies have been completed on site since 2006 with most recent being:
• Phase 1 preliminary geotechnical (SMEC 2013) and environmental site investigation (SMEC 2014)
• Phase 2 detailed environmental and geotechnical site investigations (SMEC 2016a)
• groundwater investigations (SMEC 2016b)
• Geosyntec (2016) independent review of the Phase 2 assessment.
Phase 1 investigations identified 30 areas of environmental concern (AECs) within the Project Area (SMEC, 2014). The site ecological and health risks associated with the brickworks, quarry and former workers accommodation areas were considered moderate to low (SMEC 2014).
Phase 2 investigations (SMEC 2016a) of the Project Area identified:
• widespread use of fill material (predominantly bricks with concrete, ash, reworked material and trace amounts of metal pipe) to a thickness of 0.1 to 3.3 metres over the operational portion of the former brickworks and former quarry pit
• chemicals of potential concern were low or below detection limits with the exception of some heavy metals, particularly lead, exceedances of health and/or environmental investigation levels at some locations
• concentration of airborne asbestos was below detection limits (0.01 fibres/ml) in all samples
• non-friable asbestos fragments were identified at two locations.
The southern portion of the site was concluded to be suitable for proposed low and medium density housing however further investigation was recommended for the remainder of the site, particularly the 10 AECs (see Figure 2.6) and the pit area.
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The groundwater assessment (SMEC 2016b) identified benzene and metals present in the groundwater. The presence of metals (cadmium, copper, nickel and zinc) was to be either a reflection of underlying geology or presence of contaminated material.
Geosyntec’s independent review of the Phase 2 report concluded that the results of investigation to date have only identified a small number of discrete contamination issues, and the widespread presence of fill material does not appear to be associated with widespread chemical or asbestos impact (excluding the asbestos dump area). Uncertainties remain at the site, and unexpected contamination issues may still exist despite a reasonable level of judgemental and systematic investigation, particularly given the inherent variability of fill material (Geosyntec 2016). As recommended by Geosyntec, the design has filed an environmental management plan (EMP) with an unexpected finds protocol.
In addition to the asbestos containing material (ACM) identified in the AEC, Robson Environmental (2015) identified an asbestos dump (1,260 square metres in area) to the west of the Canberra Brickworks in Block 1, which encroaches on the adjoining Block 20, Section 102 and possibly Block 1, Section 102 (see Figure 2.6). Asbestos was identified in mixed-waste that includes soil, brick, tile, metal, glass, wood, ash and slag to a depth of 0.5 metres below ground level in the upper layer of fill (Robson 2015). It is proposed that asbestos impacted material will be managed by onsite encapsulation in a cell designed to contain the impacted soil with at least one metre of clean soil placed over the soil.
Chemical contaminants that may leach into the environment may be destroyed onsite through bioremediation. Doma have engaged ARCADIS Australia Pacific to prepare a remedial action plan. The results of the existing and further investigations will be summarised in the EIS.
It is proposed that remediation works will be undertaken for the site and will be assessed under a separate development application.
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Conservation Values 26
3.0 Conservation Values
The following section provides a description of the conservation values of the Project Area. Consideration has been given to the ‘Preparation of an Application for Scoping and Preparation of an ESO Guideline’ (ACTPLA, n. d.); however, given the nature of the Project Area and its heritage significance, this section does not focus only on natural but heritage conservation values also.
The Yarralumla Brickworks is of historical value as the first industrial manufacturing facility within the ACT and one of only three remaining pieces of industrial heritage (the other two being the Kingston Power House and the Cotter Pumping Station). As the Project Area has been left relatively unmanaged since the Yarralumla Brickworks ceased production in 1975, it does not demonstrate existing processes or systems of the ACT.
It is a relatively intact, representative example of large urban brickworks from the early twentieth century, where the key built features demonstrate the evolution of a range of historical industrial processes that were associated with brick and clay production (ACT Heritage Council 2001). The railway remnants also highlight the systems employed to construct the city of Canberra within a short timeframe, a relatively undeveloped area, and constraints on transport and technology (ACT Heritage Council 2013).
Given the highly disturbed nature of the Project Area it is not considered important for demonstrating existing natural processes or systems of the ACT.
3.1 Flora, Fauna, and Landscape Diversity
The Project Area was grazing land prior to its use as an urban brickworks and associated quarry and railway. It is currently surrounded by residential areas, and landscaped buffers to the Royal Canberra Golf Course, Cotter Road, Dunrossil Drive, and Dudley Street.
Umwelt (2014) identified vegetation types present within the Project Area, all of which were highly modified and dominated by exotic species. Trees throughout the area are self-seeded non-native species (predominately Pinus species) and may provide opportunistic shelter for bird species; however, they do not represent habitat for threatened bird species.
Small patches of exotic grassland near the entrance to the Canberra Brickworks are dominated by a weed of national significance: Chilean needlegrass, however are also known to support golden sun moth. Due to the highly disturbed nature of the Project Area, it does not demonstrate areas of important flora or fauna diversity.
The landscape within the Project Area has also been highly disturbed, particularly by the presence of the former quarry. While it is not a natural feature of the landscape, the former quarry and the geological features associated with it, are of heritage significance and will be conserved as part of the Project. The remainder of the landscape is not particularly diverse, nor is it considered unique within the ACT.
3.2 Uncommon, Rare, or Endangered Flora, Fauna, Communities, Natural Landscapes, or Phenomena
The use of the Project Area as brickworks, including an associated quarry and railway, has disturbed most of the natural values of the site. Umwelt (2015a) identified that all vegetation types present within the Project Area were highly modified and dominated by exotic species. No uncommon, rare or endangered flora species or ecological communities have been identified within the Project Area.
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Conservation Values 27
The introduced trees (predominately Pinus species) may provide opportunistic shelter for bird species; however they do not represent habitat for threatened bird species (Umwelt, 2015a). Golden sun moth (EPBC Act critically endangered and NC Act endangered species) is known to occur near the entrance to the Canberra Brickworks in three small patches of exotic grassland (see Figure 2.4) dominated by Chilean needlegrass. This is a very small and highly disturbed area, which is separated from the Dudley Street population, approximately 200 metres to the south, by a relatively dense stand of introduced trees.
The historic features of the Canberra Brickworks are unique in Canberra and a rare demonstration of its industrial heritage. In particular, it is the location of the only surviving Staffordshire kiln in Australia (ACT Heritage Council, 2001), and the railway remnants are rare in their intactness (ACT Heritage Council, 2013).
The landscape is typical of geomorphology of the area, characterised by undulating rises and local relief (SMEC, 2016). This is not considered rare or uncommon within the Canberra context.
The Project Area also contains geological features, which formed as part of the Deakin volcanics. The only other features of this type are in Deakin, between the Deakin shops, sports oval and aged care centre.
3.3 Location Importance for Demonstrating Principal Characteristics of the Range of Landscapes, Environments, or Ecosystems Identified as Characteristic of their Class
The former quarry is considered of geological importance as containing the type locality for the ‘Yarralumla Formation’. The stratigraphic rock units that are included in the Heritage listing for the Yarralumla Brickworks constitute the reference section against which, all other outcrops within the Yarralumla Formation are compared. It is also the only fossil marine unit within south Canberra, with Site C showing fossils of gracitiopods, trilobites, coral, and crinoids (ACT Heritage Council 2001).
Due to the highly disturbed nature of the Project Area, it is not considered important for demonstrating principle characteristics of the range of landscapes or ecosystems identified as characteristic of their class.
3.4 Location Importance for Providing an Understanding of the ACT’s History
The change in land use from Indigenous cultural uses prior to European settlement, to agricultural grazing within approximately 50 years is consistent with a majority of Canberra, and the Southern Tablelands (Navin Officer, 2014). The Project Area is not considered important for providing a greater understanding of these uses due to the high level of disturbance associated with its use as an urban brickworks.
Similarly, the disturbance of the brickworks and landscape plantings has resulted in little of the natural values remaining on site. Golden sun moth remains in small patches of exotic vegetation that do not reflect the species’ original habitat. The Project Area is not considered important for providing an understanding of the ACT’s natural history.
The historic heritage elements demonstrate a key part of Canberra’s development as the Nation’s Capital. The Canberra Brickworks and the associated railway remnants demonstrate the importance of the construction sector in early Canberra, by providing the red brick synonymous with many Canberra homes and buildings of the era. The features remaining on-site also demonstrate the industrial evolution and technical diversity of the brickworks, which adapted and changed its methodologies over its lifetime (ACT Heritage Council 2001; 2013).
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3.5 Decision under the EPBC Act
An EPBC Act Referral (2017/8074) was submitted to the Commonwealth DoEE for consideration. A decision was made on 19 December 2017, finding that the proposed action is a Controlled Action. The project requires assessment and approval under the EPBC Act before it can proceed.
The assessment approach has been determined to be the accredited bilateral approvals process, with the EIS forming the key assessment document for both Commonwealth and Territory approval.
This application for Scoping is for a Bilateral EIS.
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4.0 Preliminary Risk Assessment
A Preliminary Risk Assessment (PRA) has been prepared and attached as Appendix 1. According to the ‘Preparation of an Application for Scoping and Preparation of an ESO’ guidelines (ACTPLA, undated) the purpose of a PRA is described as:
“Identifying possible impacts requires the consideration of all of the likely activities that will be involved in the construction, operation and decommission of the project with further consideration given to all the impacts that these activities could lead to”
Based on this, objective environmental risks during design, construction, and operation have been identified and assessed. Decommissioning was not considered relevant for the proposed development given its ongoing nature.
The key risks identified in the PRAs can be summarised as follows:
• Ensuring that individual elements of the Project are well situated and designed particularly with regard to heritage values.
• Managing risks associated with contamination.
• Designing the Project to ensure integration into the existing Yarralumla suburb such that noise, traffic and visual impacts on the community are minimised.
• Risks inherently associated with design and construction projects, including construction traffic and amenity impacts.
• Unavoidable impacts to golden sun moth.
Conversely, for consideration while developing the EIS Scoping Document, the following aspects are considered to be of low, or negligible risk:
• planning and land status
• flora and fauna (other than golden sun moth)
• aquatic flora, fauna
• water quality and hydrology
• aboriginal heritage.
Mitigation measures are discussed in detail in Appendix 1; however, the majority of impacts can be mitigated through environmental management to be implemented during construction. High level mitigation will also be realised through detailed design. Mitigation measures used specifically to manage each risk are discussed in the PRAs in Appendix 1.
For impacts that cannot be avoided or mitigated, namely those to golden sun moth, appropriate offsets would be identified through the EIS process.
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It is considered that the proponent has developed a thorough understanding of the environmental, heritage, and engineering conditions and constraints of the Project Area. This is demonstrated through the extent of background studies undertaken to date and the ecologically sustainable development approach used throughout the planning process, including defining the development and conservation areas.
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References 31
5.0 References
ACT Planning and Land Authority (2004) Yarralumla Neighbourhood Plan.
ACT Planning and Land Authority (ACTPLA) (undated) Preparation of an Application for Scoping Preparation of an Application for an Environmental Significance Opinion: A Guide, accessed online (October 2017): http://www.planning.act.gov.au/__data/assets/pdf_file/0009/892755/Application_for_scoping.pdf.
ACT Heritage Council (2001) Entry to the ACT Heritage Register Heritage Act 2004: 20068. Yarralumla Brickworks, Territory Plan Variation Number 118, accessed online (October, 2017): https://www.environment.act.gov.au/__data/assets/pdf_file/0008/148517/440.pdf.
ACT Heritage Council (2013) Australian Capital Territory Heritage Register (Registration Details): Yarralumla Brickworks Railway Remnants, Notifiable Instrument NI2013-507, accessed online (October, 2017): https://www.environment.act.gov.au/__data/assets/pdf_file/0011/348680/249.pdf.
AECOM Australia Pty Ltd (2016) Stage 1 Site Investigation Report for Canberra Brickworks Precinct. Prepared for LDA. March 2016
AECOM Australia Pty Ltd (2017) – Preliminary Risk Assessment Access Road and Dudley Street Upgrade. Prepared for Infrastructure Finance and Capital Works.
Australian Bushfire Protection Planners Pty Limited (ABPP) Bushfire Risk Assessment Report for Canberra Brickworks Precinct. For LDA. January 2016.
Biosis (2017) Targeted survey for the golden sun moth at the Yarralumla Brickworks (Blocks 1, 7 and 20, Section 102, Yarralumla). Unpublished letter to Doma Group, May 2017.
dsb Landscape Architects (dsb) (2015) Yarralumla Brickworks Precinct Tree Assessment: Tree Management Report, unpublished report prepared for the Land Development Agency, Canberra, November 2015.
Elton Consulting (Elton) (2017) Community Engagement Plan Canberra Brickworks, unpublished report prepared for Doma Group, Canberra, draft (June 2017).
GML Heritage (GML) (2017) Canberra Brickworks Precinct: Conservation Management Plan, unpublished report prepared for Doma Group, Canberra, Draft (August, 2017).
Land Development Agency (LDA) (2013) Canberra Brickworks and Environs Planning and Development Strategy. Prepared by Hill Thalis Architecture + Urban Projects with Jane Irwin Landscape Architecture. September, 2013.
Land Development Agency (undated) Canberra Brickworks Precinct: Community Panel, accessed online (October, 2017): http://suburbanland.act.gov.au/uploads/ckfinder/files/pdf/3_Commercial/Canberra_Brickworks/community/Community%20panel%20handout%20-%20271115.pdf.
Lovell Chen (2010) Canberra Brickworks Conservation Management Plan, unpublished report prepared for the Land Development Agency, Canberra.
Lovell Chen (2016) Archaeological Assessment: Canberra Brickworks & Environs, an unpublished report prepared for the Land Development Agency, Canberra.
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References 32
Navin Officer (2014) Canberra Brickworks, Yarralumla, ACT: Stage 1 Aboriginal Cultural Heritage Assessment, an unpublished report prepared for the Land Development Agency, Canberra.
Robson Environmental (2015) Stage 1 Environmental Site Assessment Canberra Brickworks Remediation Project Block 1 Section 102 Yarralumla, Canberra Central ACT. For Capcorp Constructions Pty Ltd. March 2015.
Rowell, A. (2010) Preliminary Assessment of Ecological Values of land in Yarralumla, Curtin and Deakin, ACT. Prepared for the National Capital Authority, Canberra.
Rowell, A. (2011) Yarralumla Brickworks Site and Surrounds, Golden Sun Moth and Natural Temperate Grassland Survey, Prepared for Land Development Agency, Canberra.
Rowell, A. (2012) Environmental Assessment of Blocks for Proposed Diplomatic Subdivision (Stirling Ridge, Near Old Canberra Brickworks, and Land adjacent to Federal Golf Club), Prepared for the National Capital Authority, Canberra.
SMEC (2013) Preliminary Geotechnical Site Investigation for the Canberra Brickworks. For Land and Development Agency, Canberra. November 2013.
SMEC (2014) Preliminary (Environmental) Site Investigation for the Canberra Brickworks. For Land and Development Agency, Canberra. February 2014.SMEC (2016a) Canberra Brickworks: Detailed Environmental and Geotechnical Investigation for the Canberra Brickwork Precinct, Yarralumla, ACT. For Land and Development Agency, Canberra. October 2016.
SMEC (2016b) Canberra Brickworks Site Investigation – Groundwater Addendum Report. Canberra Brickwork Precinct, Yarralumla, ACT. For Land and Development Agency, Canberra. November 2016.
Umwelt (2014) Canberra Brickworks and Environs Ecological Assessment. Unpublished report to the Land Development Agency, December 2014.
Umwelt (2015a) Ecological Assessment at Revised Brickworks Project Area. Unpublished letter advice to the Land Development Agency, 09 November 2015.
Umwelt (2015b) Golden Sun Moth Assessment at Revised Brickworks Project Area. Unpublished letter advice to the Land Development Agency, 21 December 2015.
Umwelt (2017) Canberra Brickworks Access Road Ecological Surveys 2016, Briefing Note prepared for the Chief Minister, Treasury and Economic Development Directorate, ACT Government, Canberra.
APPENDIX 1
Preliminary Risk Assessment
Insignificant (F) Minor (I) Moderate (D) Major (J) Catastrophic / Significant (S)
Negligible complaints or
concerns
Public concern limited to local
complaints
Local public or media
attention and complaints
Attention from media or
heightened concern from
community
Adverse national media or
public attention
People largely unaffected Temporary and localised
effects on peoples livelihoods
Widespread and temporary,
or, localised and permanent
effects on peoples livelihoods
Widespread and temporary,
or, localised and permanent
effects on livelihood and/or
displacement of people
Entire villages, communities
or groups are displaced and
livelihoods are affected
Impacts such as localised or
short term effects on habitat,
species or environmental
attributes.
Onsite release with minor
environmental impacts.
Onsite release and some
detrimental effects.
Resulting in off-site release
and some detrimental effects.
Resulting in permanent offsite
detrimental effect.
Negligible environmental
impacts
Localised, long term
degradation of sensitive
habitat, species or
environmental attributes.
Localised and irreversible
habitat damage or loss of
habitat, species or
environmental attributes.
Widespread and persistent
changes to habitat, individual
species or environmental
attributes.
Loss of a significant portion of
a valued species or loss of
effective ecosystem function
on a widespread scale.
No detectable change Some minor detectable
change
Change requiring basic
treatment or medical attention
Change resulting in medical
treatment and hospitalisation
Significant / life threatening
change
No Injuries First Aid treatment Medical treatment, lost time
injuries, plant damage
Extensive injuries, plant
damage
Multiple deaths or deaths,
permanent significant injury
EconomicMinimal losses Several thousand dollars lost
revenue or remediation costs
Half million dollars in lost
revenue or remediation costs
One million dollars in lost
revenue or remediation costs
Several million dollars in lost
revenue or remediation costs
Insignificant (F) Minor (I) Moderate (D) Major (J) Catastrophic / Significant (S)
Remote (R) Extremely rare or previously unknown to occur Remote (R) Negligible (N) Negligible (N) Very Low (L) Low (W) Medium (M)
Unlikely (U) Unlikely to occur during the Project Unlikely (U) Negligible (N) Very Low (L) Low (W) Medium (M) High (H)
Possible (P) Possible under exceptional circumstances Possible (P) Very Low (L) Low (W) Medium (M) High (H) Very High (V)
Likely (L) May occur during the Project or beyond the Project Likely (L) Low (W) Medium (M) High (H) Very High (V) Extreme (E)
Almost Certain (C) Expected to occur during the Project or beyond the Project Almost Certain (C) Medium (M) High (H) Very High (V) Extreme (E) Extreme (E)
LIKELIHOOD
Health /Safety Consequence Descriptions
LIKE
LIH
OO
D
CONSEQUENCE
CONSEQUENCE
Community Consequence Descriptions
Environmental Consequence Descriptions
Risk matrix and criteria for Likelihood and Consequence is derived from: ACTPLA (undated) Preparation of an application for scoping; Preparation of an application for an Environmental Significance Opinion, A guide
Online: http://www.actpla.act.gov.au/__data/assets/pdf_file/0017/21617/Application_for_scoping.pdf
Design Design Development Development disturbance exceeds area assessed and approved, resulting in non-compliance with PD Act or EPBC Act Approval.
Various U J M
- Seek approval under PD Act and EPBC Act to impact entire 16.1ha of the CBP, rather than discrete development footprints.- Seek approval under PD Act and EPBC Act for any likely impacts outside of CBP where MNES or ACT protected matters are identified (completed).- Design works so they occur wholly within approved areas, including mitigation measures for indirect impacts and required transport and utility infrastructure.
Development of CBP is not consistent with actions approved in the Project, resulting in non-compliance with PD Act or EPBC Act Approval.
Various U J M
- Design works so that they are consistent with the PD Act and EPBC Act approval conditions for the Project.- Seek PD Act and EPBC Act Approval for any proposed actions that are inconsistent with the Project.
Development is not appropriately located within the approved area, resulting in environmental or social impacts beyond those assessed and approved under the PD Act and EPBC Act. Various U J M
- Ensure land use is appropriate given adjacent residential areas. - Consider surrounding land uses and existing stakeholders, including adjacent residents.- Consider transport and pedestrian movements throughout the area to limit the impacts of increased access and usage of the CBP. - Ensure development is consistent with the Territory Plan, National Capital Plan, and the PD Act and EPBC Act approval conditions. - Seek PD Act and EPBC Act approval for any proposed development that is likely to have a larger impact due to its locality or land use type.
Presence or extent of threatened species or ecological communities or other protected matters (e.g. native vegetation) is not identified prior to development design, resulting in unanticipated impacts.
Ecological U J M
- Base the impact assessment on site specific, recent environmental studies.- Use a precautionary and risk based approach to impact assessment for the Project.
The Project results in impacts to the heritage values of the Yarralumla Brickworks and Railway Remnants due to the recommendations of the Conservation Management Plan not being appropriately implemented during the design phase.
Environmental P J H
- Consider the Conservation Management Plan and its recommendations throughout the design phase (completed). - Update the Conservation Management Plan based on the proposed actions of the Project (in preparation). - Design the development to be as least intrusive to the Yarralumla Brickworks and Railway Remnants as practicable. - If development is likely to significantly affect the heritage values of the Yarralumla Brickworks or the Railway Remnants then seek advice from the ACT Heritage Council
Proposed mitigation measures (e.g. Water Sensitive Urban Design (WSUD)) are not designed to adequately mitigate indirect impacts into nearby Lake Burley Griffin or urban Storm Water systems resulting in unanticipated impacts to MNES and local residences through increased water flows and decreased water quality.
Ecological P D M
- Design mitigation measures so they adhere to ecological limits (e.g. water flow rates or quality) of adjacent MNES and other environmental values. - Undertake stormwater assessments to ensure the design of the development does not place unnecessary pressure on existing stormwater infrastructure. - Design mitigation measures in accordance with relevant ACT, Australian, or otherwise best practice standards; and with any PD Act or EPBC Act approval conditions.
Proposed bushfire mitigation measures (e.g. inner asset protection zones) are not adequately managed, both within the CBP and on adjacent land (e.g. Block 1, Section 127, Yarralumla ACT) over the life of the Project, increasing the bushfire hazard risk to residents.
Various U S H
- Apply regulated asset protection zones to the CBP and incorporate during design phase. - Collaborate with the adjacent land users (i.e. ACT Government or the Royal Canberra Golf Course) to develop an agreement for the management of inner asset protection zones that fall outside the CBP over the life of the Project. - Design mitigation measures in accordance with relevant ACT, Australian, or otherwise best practice standards; and with any PD Act or EPBC Act approval conditions.
Inappropriate landscape plants are chosen, with regard to ecological and social impacts to surrounding areas. Various P J H
- Ensure landscape species are suitable for urban use and are compatible with surrounding species within Yarralumla. - Consider feedback from relevant community groups regarding the visual aspects of the design.
Canberra Brickworks Precinct Preliminary Risk AssessmentPhase of Development
EffectsWithout the application of mitigation or management measures
Activity
Cons
eque
nce
Cate
gory
of R
isk
Like
lihoo
d
Risk
Rat
ing
Mitigation/ Management Measures
8137_R02 Scoping Document 2 Appendix 1
Phase of Development
EffectsWithout the application of mitigation or management measures
Activity
Cons
eque
nce
Cate
gory
of R
isk
Like
lihoo
d
Risk
Rat
ing
Mitigation/ Management Measures
Design Material selection and finishes result in additional impacts to the heritage values of the Yarralumla Brickworks as they are not consistent with the Conservation Management Plan.
Environmental P J H
- Incorporate the recommendations and management guidelines of the Conservation Management Plan into the design of the CBP buildings.
Material selection and finishes are not consistent with character of the area or land use zoning resulting in visual impacts.
Community P D M- Design development to be consistent with Territory Plan development codes.- The feedback from the relevant community groups will be taken into consideration throughout the design phase, including the development of a landscape management plan.
Delays in decision-making, land sale and design processes results in the development goals of the Project not being achieved.
Service Delivery P J H
- Stage the delivery of the Project in accordance with community needs, as assessed through ACT Government processes such as land release planning.- Progress approval processes concurrently to improve efficiency and minimise potential delays.
Site does not have adequate access for transport, including active transport options.
Service Delivery U J M
- Ensure that active transport is considered during the design phase of the Project. - Ensure that adequate parking and other transport options are incorporated into the design of the Project. - Ensure the design of the Project considers the impacts of the additional residences on local traffic movements and road capacities.- Maintain consultation with the ACT Government to ensure that proposed parking arrangements are suitable according to their policies and land use zoning.
Increased run off from impervious surfaces, such as car parks, increases flow downstream and impacts areas beyond the property boundaries.
Environmental P J H
- Design will meet the requirements of the WSUD General Code (ACTPLA, 2007) to ensure post-development flows do not exceed pre-development flows. - WSUD infrastructure will be maintained to standards set out in the WSUD General Code.
The CBP design does not match the designs for the access road being prepared by the ACT Government, resulting in the roads not aligning.
Service Delivery U J M- Continue consultation with CICW at each stage of detailed design to ensure compatibility (ongoing).
Site Investigations Intrusive site investigations (e.g. geotechnical, contamination test pitting) are undertaken prior to PD Act and EPBC Act Approval resulting in impacts to MNES prior to approval being gained, and potential non-compliance with either Act.
Ecological P D M
- Liaise with EPSDD and DoEE prior to intrusive site investigations if they are to occur prior to an approval decision being made. - Ensure EMP for site investigations identifies go / no-go zones and environmental controls.
Subsurface conditions that may impact construction activities are not identified and inappropriate design concepts developed as a result.
Infrastructure/ Engineering
P J H
- Undertake geotechnical and contamination assessment at CBP, including detailed assessment of fill (underway).- Incorporate identified geotechnical and contamination constraints and recommendations into the design and project planning decisions.
Engineering Inspections; Service Location and Siting
Requirement to install new infrastructure to service development impacts existing infrastructure.
Infrastructure/ Engineering
P I W- Consult with utility entities early in design phase.- Consider utility installation constraints during detailed design phase to ensure the new infrastructure integrates with existing system.
Consultation Incorporating requirements of all stakeholders impacts design outcomes and timing.
Community P J H
- Include all major stakeholders, including YRA, in meetings to ensure adequate communication and consideration of all issues.- Add new stakeholders to the consultation group as required / identified.- Incorporate feedback on draft EIS from major stakeholders prior to submission to ensure all issues are adequately addressed.
Increased negative media attention and political interest affects the community interest or perceptions of the development in general.
Service Delivery P J H- Include major stakeholders early in the process.- Prepare a media strategy that includes addressing negative media attention should it arise. - Conduct the approvals and planning process in a transparent manner.
8137_R02 Scoping Document 3 Appendix 1
Phase of Development
EffectsWithout the application of mitigation or management measures
Activity
Cons
eque
nce
Cate
gory
of R
isk
Like
lihoo
d
Risk
Rat
ing
Mitigation/ Management Measures
Approval and delivery Preparation and approval of the Development Application (DA) documents for the contamination remediation may result in delays for the entire development.
Service Delivery P J H
- Allow for the preparation and approval of the DA in the budget and timeframe- Prepare DA with all necessary information included to allow EPSDD to make a quick decision and avoid having to resubmit application.- Liaise with ACT regulator during preparation to ensure compliance with all requirements.
Delays in approval decisions result in delayed service delivery and financial implications for the project. Service Delivery P D M
- Commence planning and approvals processes early.- Have realistic expectations of potential delays/length of time required for approvals.
Potential environmental impacts are unacceptable and approval is not granted.
Various U S H
- Use the best available information to assess potential impacts of the Project. - Implement the avoid, mitigate, and offset hierarchy for reducing potential environmental impacts.- Liaise with EPSDD throughout the process to identify any potential issues early on in the design stages.
Offsets for significant impacts No appropriate offsets for golden sun moth are available within the ACT.
Service Delivery L J V
- Consult with DoEE and ACT Government at early stage to determine whether biobanking is an appropriate option for offsetting, due to the deficit of local golden sun moth sites (completed)- Obtain biobanking credits for golden sun moth in local region to provide appropriate offset for golden sun moth.
8137_R02 Scoping Document 4 Appendix 1
Construction Vegetation and Habitat Clearing
Clearing vegetation outside approved disturbance area due to unclear demarcation of boundaries results in non-compliance with PD Act and EPBC Act approval.
Environmental U J M
- Conduct pre-clearing surveys to determine clearing boundaries.- Establish no-go zones, site boundaries, and fences prior to construction commencing by implementing an industry best practice Construction Environment Management Plan (CEMP) to prevent unauthorised access into adjacent areas.- Inform EPSDD and DoEE immediately if any impacts outside approved area occur.
Vegetation clearing results in a loss of visual amenity for local residents.
Community P D M
- Develop and implement industry best practice CEMP which includes rehabilitation/ landscaping plan.- Plan for early establishment of landscaping features as described in detailed designs.- Erect fences and other barricades around construction site such that they reduce the visual impacts of the construction phase.
Site Access and Management Uncontrolled access by vehicles leads to damage to heritage elements or trees to be retained. Environmental P D M
- Establish no-go zones, site boundaries, and fences prior to construction commencing by implementing an industry best practice CEMP to prevent unauthorised access into adjacent areas.- Inform EPSDD and DoEE immediately if any impacts outside approved area occur.
Increased volumes of construction traffic on local roads and construction of access road connections results in traffic disruptions.
Community L D H- Develop and implement industry best practice CEMP which includes a construction traffic management plan.- Engage with YRA regarding any planned traffic disruptions.
General Construction Activities Discovery of previously unidentified contaminated soil during construction results in delays to program implementation or increased costs due to remediation.
Various P J H
- Undertake remediation of identified contaminated sites prior to general construction commencing. - Develop and implement an Unexpected Finds Protocol for all earthworks and construction activities on site, including training personnel in Unexpected Finds procedure.
Earthworks result in the destruction of previously unidentified Aboriginal or European cultural heritage items.
Community P D M- Develop and implement an Unanticipated Discovery Plan during clearing and construction activities, including training personnel in Unanticipated Discovery procedures.
Construction activities result in noise and vibration impacts, reducing local amenity, potentially resulting in community complaints, and non-compliance with EP Act.
Environmental L D H
- Develop and implement industry best practice CEMP which includes a noise and vibration management plan.- Identify sensitive receptors.- Conduct construction activities in accordance with EP Act requirements.- Maintain plant and equipment in accordance with manufacturers recommendations and best practice.
Construction activities result in impacts to air quality (vehicle emissions, dust, etc.), reducing local amenity, potentially resulting in community complaints and non-compliance with EP Act.
Environmental L D H
- Develop and implement industry best practice CEMP which includes an air quality and dust management plan.- Identify sensitive receptors.- Conduct construction activities in accordance with EP Act requirements.- Maintain plant and equipment in accordance with manufacturers' recommendations and best practice.
Construction activities change water regimes including flow rate, quality, sedimentation, and erosion; resulting in environmental impacts beyond the approved development area.
Environmental P D M
- Develop and implement industry best practice CEMP that includes and implements management plans to avoid or minimise environmental risks (e.g. sedimentation, erosion, weeds, storm water runoff, etc.).- Conduct construction activities in accordance with EP Act requirements.
Sparks from construction machinery may start a fire.
Various U S H
- Maintain plant and equipment in accordance with manufacturers' recommendations and best practice.- Observe seasonal and daily fire hazard warnings issued by the ACT Emergency Services Agency.- Implement an approved bushfire hazard management plan during construction and operation.- Keep vehicles on formed roads and paths, away from long grass where possible.- Provide appropriate parking areas for personnel that are away from long grass and other ignition sources.- Avoid unnecessary idling of vehicles.- Equip all vehicles on site with fire extinguishers.- Include fire prevention and fire control instructions in site induction.- Do not undertake hot works outside designated workshop areas.
Canberra Brickworks Precinct Preliminary Risk AssessmentPhase of Development
Activity EffectsWithout the application of mitigation or management measures
Cate
gory
of R
isk
Like
lihoo
d
Cons
eque
nce
Risk
Rat
ing
Mitigation/ Management Measures
8137_R02 Scoping Document 5 Appendix 1
Phase of Development
Activity EffectsWithout the application of mitigation or management measures
Cate
gory
of R
isk
Like
lihoo
d
Cons
eque
nce
Risk
Rat
ing
Mitigation/ Management Measures
Construction Fuel or chemical spills or inappropriate material storage contaminates soil, ground water, and/or local waterways, which could result in environmental degradation and fines under EP Act
Various P D M
- Develop and implement industry best practice CEMP that includes a waste management plan that addresses the storage and stockpiling of raw materials, transport of materials to site, and disposal of materials.- Identify location of site sheds/ storage areas and construction vehicle parking in CEMP away from sensitive areas.- Develop a spill management protocol.
Spread of invasive species off-site, e.g. Chilean needlegrass
Environmental P J H
- Develop and implement industry best practice CEMP that includes a weed management plan that addresses potential spreading of existing invasive species (particularly Chilean needlegrass) through construction vehicles, personnel and vegetation waste. - Identify areas of weed infestation for management and avoidance during and after construction.
Construction activities result in damage to utilities and other essential infrastructure.
Service Delivery P D M
- Liaise with utility and service providers to determine the location and risk of damage of services prior to construction commencing.- Mark and/ or map the location of utilities at risk of damage and provide to contractors prior to construction commencing. - Use hazard identification tools in accordance with WHS standards to identify potential risks to workers.
Compliance Construction activities result in environmental impacts that are not reported or otherwise acted upon adequately.
Various P D M
- Require that contractors appoint a third party to conduct audits on environmental approvals and performance against criteria identified in the CEMP.- Results of audits are to be reported back to the ACT planning approval authority and other agencies as appropriate.- Refer to requirements of EPSDD and DoEE approval under PD Act and EPBC Act respectfully for other monitoring and reporting obligations for associated offsets.
CEMP, including monitoring and auditing requirements, is not implemented effectively leading to various environmental, social, and economic impacts.
Various P D M
- Require as a condition of consent that contractors appoint an independent third party to conduct audits on environmental approvals and performance against criteria identified in the CEMP.- Results of audits are to be reported back to the ACT planning approval authority and other agencies as appropriate.
Risk not adequately identified resulting in incomplete understanding of environmental constraints.
Various P D M- Update PRA as additional information becomes available.- Use most up to date information to inform risk assessment.
8137_R02 Scoping Document 6 Appendix 1
Operation Residential and recreational use
Increased public access to the Canberra Brickworks results in impacts to adjacent residents, including traffic congestion, accidents and parking issues.
Community L D H
- Promote active travel options to residents to reduce the need for vehicle traffic.- Ensure access points, pedestrian paths and roads are maintained and utilised properly to minimise nuisance to surrounding residents. - Maintain public parking on site to reduce overflow on-street parking in neighbouring areas.
Use of the Canberra Brickworks results in detrimental effects to the heritage values. Environmental P J H
- Restrict access to sensitive heritage features through landscape and building design. - Undertake regular maintenance work. - Include heritage listed places in a heritage interpretation strategy to educate the public on their values and actions for their protection.
Roads and infrastructure deteriorate due to increased use requiring more frequent maintenance. Financial L I M
- Include internal access roads and intersections in road maintenance and upgrade program.
Fire hazard management conducted at an inappropriate interval and intensity leading to increased risk to residents.
Ecological P D M- Maintain inner asset protection zones in accordance with the ACT Strategic Bushfire Management Plan.
Re-establishment of weed infestation, leading to increased risk to off-site areas.
Environmental P D M - Develop and implement an industry best practice OEMP, including ongoing weed management and monitoring measures
Mitigation / Management Measures
Risk
Rat
ing
Cons
eque
nce
Ongoing maintenance
Canberra Brickworks Precinct Preliminary Risk AssessmentPhase of development
Activity EffectsWithout the application of mitigation or management measures
Cate
gory
of R
isk
Like
lihoo
d
8137_R02 Scoping Document 7 Appendix 1
APPENDIX 2
Regulated Trees from dsb Landscape Architects (2015)
GROUP
H
GROUP
AE
GROUP
W
GROUP
I
GROUP
J
GROUP
K
GROUP
M
GROUP
N
GROUP
P
GROUP
S
GROUP
T
GROUP
L
GROUP
R
GROUP
U
D
E
N
M
A
N
S
T
R
E
E
T
D
U
D
L
E
Y
S
T
R
E
E
T
CO
TT
ER
RO
AD
D
U
N
R
O
S
S
I
L
D
R
M
A
X
W
E
L
L
S
T
W
O
O
L
L
S
S
T
S
C
H
O
M
B
U
R
G
K
S
T
L
A
N
E
-
P
O
O
L
E
P
L
A
C
E
B
E
N
T
H
A
M
S
T
R
E
E
T
127
GROUP
GROUP
Q
AB
GROUP GROUP
AA AC
GROUP Z
GROUP GROUP
Y AD
GROUP AF
GROUP X
GROUP
GROUP
AF F
GROUP AF
GROUP
GROUP
G
F
GROUP O
GROUP V
GROUP
C
GROUP
B
GROUP
A
GROUP
GROUP
E
D
91
102
90
89
88
103
37
36
41
42
8
22
1
40
38
29
3131313131313131
303030
21
20
14 15
16
17
1 2 3
18
764
1
13
10 9 8
12
1
2
3
15
14
11
13
12
1
19
2
11
13
3
4
12
10
11
5
10
6
1
7
9
12
7
2
88
11
3
10
4
9
55
8
6
77
33
2
4
2
11
31
30
1
2
SCHOMBURGK ST
94 3
AMENDMENT SCALE/NORTHPOINT DIRECTORATE/DEPARTMENT PROJECT DRAWING TITLE
No.
Approved by Drawn by
DESCRIPTION Date
PROJECT NUMBER DRAWING NUMBER AMENDMENT
AutoCAD Saved: Plotted: By:12/21/2015 12/21/2015 11:21
AM ERM
G:\LDA\5. LRP a-f\Canberra Brickworks and Environs\CB+E Strategy_from 2008 to June 2015\Maps and Figures\P01192 CB Precinct Tree Assessment\DWG\P01192 CB Precinct ARBORCULTURAL Amenity Tree Assessment.dwg
CANBERRA BRICKWORKS
ARBORCULTURAL AMENITY ASSESSEMENT
Site Plan
N PRECINCT
1:2200@A3
0 10 20 30 40 50
1:1100@A1
60 8070
TREE ASSESSMENT P01192 00
GROUP
AE
GROUP
W
GROUP
I
GROUP
J
GROUP
K
GROUP
M
GROUP
N
GROUP
P
GROUP
S
GROUP
T
GROUP
L
GROUP
R
GROUP
U
127
S
C
H
O
M
B
U
R
G
K
S
T
L
A
N
E
-
P
O
O
L
E
P
L
A
C
E
B
E
N
T
H
A
M
S
T
R
E
E
T
SEE SHEET 3
FOR TREE GROUP DETAIL 1
GROUP
GROUP
Q
AB
GROUP
GROUP
AA
AC
GROUP Z
GROUP GROUP
Y AD
188
185
190 202
287
184
199
208
193
183 196
210
154
197
152
155
215
217
216
151 219
153
150 212
220
828
156
824
148
157
818
147
158
811
149
159
841 160
161
842
845
162
791
163
224
223
748
226
793
225
750
170
222
143 795
798
171
228
145
227
756
752 144
172
230
229 232
761
757
316 231
70
758
426
178
237
427
69
234
233
331
236
760 763
235 238
766 289
762
328 179
66
325
290
68
323 230
67 65
319 180
59
317
288
86 87
63
58 62
60
57
85
431
89
239
61
768
90
84
181
88
5348
54
430 96 91
56 47
94
97
52
50
49
286
95
109
8351
46
146 263
106
93
55
81
82
428 92
45
105
80
44
78
429
449
439 262
98
104 79
43
240
77
108 42
438
437
41
265
101
442
274
406 107
102
100
74
441
275
261
99
73
76 35
273
75
30
272
260 72
259
38
241
243
103
71
258
27 271
34
242
110
28 244
270
39
36
33
245 256
29
25 269
268
26 267
40
37
30
266
24 257
23 255
265
32
264
405
254
252
134
253
246
251
436 133
247
131
250
435
132
277
433
248
551 129
276
444
249
6 130
5
278
552
434
141
279
135
553
739
432
142
281
741
140
744 306
13
139
554
742 424
15
137 280
128
743 12
2
14
4 124
410
305 138
282
555
740
11
16
1
136
735
560
729
17 283
411
304
127
18
20
558 561
732 412
556 312
19
745 311
10
562 313
22
314
31 117
284
557
725
728
413
408
303 309
310
21
126
302
409
116
425 3
563
730
734
332
113
9
731
307
722
300
111
7
733 727
333
736
559
713 8
726
415
308 121
564
723
717 414
418
423
301
112
114
115
298 120
714
719
738 718
565
123
291
720
293
297
707
118
724
416
422
566
721 737
716
292
296
708 417
119
711
122
421
709
712
715 710
294 704
420
295
299
125
419
703
315
705
394
706
36
41
42
37
8
22
1
40
29
38
3131313131313131
303030
21
20
14 15
16
17
1 2 3
18
764
1
13
10 9 8
12
1
2
3
15
14
11
13
12
1
19
2
11
13
3
4
SEE SHEET 3 FOR TREE GROUP DETAIL 2
LEGEND
TREE QUALITY TRAINING:
EXCEPTIONAL QUALITY RATING
REGULATED TREE
HIGH QUALITY RATING
REGULATED TREE
MEDIUM QUALITY RATING
REGULATED TREE
POOR QUALITY RATING
REGULATED TREE
EXCEPTIONAL QUALITY RATING
NON-REGULATED TREE
HIGH QUALITY RATING
NON-REGULATED TREE
MEDIUM QUALITY RATING
NON-REGULATED TREE
POOR QUALITY RATING
NON-REGULATED TREE
NOT ASSESSED
DEAD TREE
NO TREE AT THIS LOCATION
TREE GROUP QUALITY RATING:
COLOUR RATINGS AS
ABOVE
GROUP AF
SEE SHEET 3
FOR TREE GROUP DETAIL 3
SCHOMBURGK ST
GROUP X
91
102
90
1
2
GROUP
GROUP
AF
F
JOINS SHEET P01192-02
NOTES: SCALE/NORTHPOINT DIRECTORATE/DEPARTMENT PROJECT DRAWING TITLENO. APPROVED BY REVISED BYAMENDMENT DATE
PROJECT NUMBER DRAWING NUMBER AMENDMENT
AutoCAD Saved: Plotted: By:
ARBORCULTURAL AMENITY
CANBERRA BRICKWORKS
ASSESSMENT
PRECINCT
Site Plan
0 7.5 15 22.5 30 37.5 45 52.5 60 67.5 75
P01192 01
TREE ASSESSMENT STUDY
1:1500@A3 1:750@A1
N
21/12/2015 21/12/2015 11:22:22 AM ERM
Drawing FilePath: G:\LDA\5. LRP A-f\Canberra Brickworks And Environs\CB+E Strategy_from 2008 To June 2015\Maps And Figures\P01192 CB Precinct Tree Assessment\DWG\P01192 CB Precinct ARBORCULTURAL Amenity Tree Assessment.dwg
Layout Name: 01 PDF Creation Date: 21/12/2015 11:22:22 AM
GROUP
H
89
CO
TT
ER
RO
AD
D
U
N
R
O
S
S
I
L
D
R
103
GROUP AF
GROUP O
GROUP F
GROUP G
GROUP V
GROUP E
GROUP C
GROUP D
GROUP B
GROUP A
395
396
397
654
334
398
399
336 335
340 337
343
339
367
366 400
653 1027
344 341 338
365342
363 368
346345
364
347 371
1028
369
348
349
1029
357
370
351
1030
354
372
1014
356 350
355
952
1032
360
953
353 359
352
1011
361
1002
957
376
407
377 954
998
391
358 379
390
407
389
988
378 648
362
380 986
944
381 382
404
375
384
383 945
946
385
403 947
972
388 402
386
387
393 910
647
1082
401
392
1015
911
375
1034
1013 912
374 1087
1026
1010
1008
1025
1022
1067
1034
1024
1068
1066
1006
1035
1043
374 984
643
644
1049
1041
1004
1036
983
987
640
JOINS SHEET P01192-01
D
E
N
M
A
N
S
T
R
E
E
T
D
U
D
L
E
Y
S
T
R
E
E
T
W
O
O
L
L
S
S
T
M
A
X
W
E
L
L
S
T
88
LEGEND
TREE QUALITY TRAINING:
EXCEPTIONAL QUALITY RATING
REGULATED TREE
HIGH QUALITY RATING
REGULATED TREE
MEDIUM QUALITY RATING
REGULATED TREE
POOR QUALITY RATING
REGULATED TREE
EXCEPTIONAL QUALITY RATING
NON-REGULATED TREE
HIGH QUALITY RATING
NON-REGULATED TREE
MEDIUM QUALITY RATING
NON-REGULATED TREE
POOR QUALITY RATING
NON-REGULATED TREE
NOT ASSESSED
DEAD TREE
NO TREE AT THIS LOCATION
TREE GROUP QUALITY RATING:
COLOUR RATINGS AS
ABOVE
94
4
12
10
11
5
10
6
1
7
9
12
7
2
88
11
3
10
4
9
55
8
6
77
33
2
4
2
11
31
30
3
1
2
NOTES: SCALE/NORTHPOINT DIRECTORATE/DEPARTMENT PROJECT DRAWING TITLENO. APPROVED BY REVISED BYAMENDMENT DATE
PROJECT NUMBER DRAWING NUMBER AMENDMENT
AutoCAD Saved: Plotted: By:
ARBORCULTURAL AMENITY
CANBERRA BRICKWORKS
ASSESSMENT
PRECINCT
Site Plan
0 7.5 15 22.5 30 37.5 45 52.5 60 67.5 75
P01192 02
TREE ASSESSMENT STUDY
1:1500@A3 1:750@A1
N
21/12/2015 21/12/2015 11:24:21 AM ERM
Drawing FilePath: G:\LDA\5. LRP A-f\Canberra Brickworks And Environs\CB+E Strategy_from 2008 To June 2015\Maps And Figures\P01192 CB Precinct Tree Assessment\DWG\P01192 CB Precinct ARBORCULTURAL Amenity Tree Assessment.dwg
Layout Name: 02 PDF Creation Date: 21/12/2015 11:24:21 AM
GROUP
Q
GROUP
S
GROUP
T
GROUP
R
GROUP
U
GROUP
I
GROUP
J
8
4
5
8
4
4
8
4
3
8
4
2
8
4
1
8
3
6
8
3
5
8
3
4
8
3
1
8
3
0
8
1
1
8
2
9
3
3
0
3
2
6
3
2
7
3
2
4
3
2
2
3
2
1
3
2
0
3
1
8
3
2
9
766
768
8
2
8
8
2
7
8
2
6
8
2
5
8
2
4
8
2
3
8
2
2
8
2
0
8
1
9
8
1
8
8
1
7
8
1
6
GROUP AB
GROUP
GROUP
AA
AC
GROUP Z
GROUP
GROUP
Y
AD
188
190
186
189
185
187
206
205
192
204
191
791
287
184
748
793 201
203
198 183
182
193
750
199
194
798
795
195 202
200
209
196
210
752
756
761 757
758 316 208
154 155
760
763 151
213 762
211
207
197
214
331
215
152 328
217
325 323
216
219
317 319
153
LEGEND
TREE QUALITY TRAINING:
EXCEPTIONAL QUALITY RATING
REGULATED TREE
HIGH QUALITY RATING
REGULATED TREE
MEDIUM QUALITY RATING
REGULATED TREE
POOR QUALITY RATING
REGULATED TREE
EXCEPTIONAL QUALITY RATING
NON-REGULATED TREE
HIGH QUALITY RATING
NON-REGULATED TREE
MEDIUM QUALITY RATING
NON-REGULATED TREE
POOR QUALITY RATING
NON-REGULATED TREE
NOT ASSESSED
DEAD TREE
NO TREE AT THIS LOCATION
TREE GROUP QUALITY RATING:
COLOUR RATINGS AS
ABOVE
220
212
431
150
156
148
430
157
149
147
158
159
160
163
161
141
142
140
135
13
224
262
139
138
137
14
165
223
12
15
140
16 164
2
11
168 221
166
225
1
10
17
170
167 222
20
226
171
19 22
314 169
313
312
18
117
310
227
229
311
307
309
116
173 21
177
113
9
228
230
172 112
7
175
176
111
174
232
8
231
70
178 237
298
114
115
308
121
123
120
69
233
293
235
236
234
238
297
118
122 119
0 5 10 15 20 25 30 35 40m
0 5 10 15 20m
0 5 10 15 20 25 30 35 40m
CANBERRA BRICKWORKS
ARBORCULTURAL AMENITY
ASSESSMENT
PRECINCT
Details
SCALE AS SHOWN
TREE ASSESSMENT STUDY
P01192 03
DETAIL 1
DETAIL 2
DETAIL 3
NOTES: SCALE/NORTHPOINT DIRECTORATE/DEPARTMENT PROJECT DRAWING TITLENO. APPROVED BY REVISED BYAMENDMENT DATE
PROJECT NUMBER DRAWING NUMBER AMENDMENT
AutoCAD Saved: Plotted: By:
N
21/12/2015 21/12/2015 11:26:52 AM ERM
Drawing FilePath: G:\LDA\5. LRP A-f\Canberra Brickworks And Environs\CB+E Strategy_from 2008 To June 2015\Maps And Figures\P01192 CB Precinct Tree Assessment\DWG\P01192 CB Precinct ARBORCULTURAL Amenity Tree Assessment.dwg
Layout Name: 03 PDF Creation Date: 21/12/2015 11:26:52 AM
APPENDIX 3
Master Plan
2SJB Architects
1Masterplan
Quarry Parklands
Brickyard
Ent
ry P
laza
Rail Play
Quarry Drive
Denm
an S
t
Bent
ham
St
House
Terrace
Apartments (Flat Roof)
Apartments (Attic)
Cafe
Lane-Poole Pl
T| 1300 793 267 E| [email protected] www.umwelt.com.au
Newcastle Perth Canberra Sydney Brisbane Orange
75 York Street Teralba NSW 2284
First Floor 12 Prowse Street West Perth WA 6005 PO Box 783 West Perth WA 6872
2/99 Northbourne Avenue Turner ACT 2612 PO Box 6135 O’Connor ACT 2602
50 York Street Sydney NSW 2000
Level 13 500 Queen Street Brisbane QLD 4000
Office 1 3 Hampden Street Orange NSW 2800