Pursuant to Section 93(3) of the Environment Protection and Biodiversity Conservation Act 1999 the following recommendation report for the sale of the Ingleburn Defence site by the Department of Defence (EPBC 2007/3567) is available for public comment until 22 January 2008. Please send comments to: Email: epbc.referrals@environment.gov.au Fax: 02 6274 1620 Or post to: Commonwealth and Territories Section Approvals and Wildlife Division Department of the Environment and Water Resources GPO Box 787 Canberra ACT 2601

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[Draft] Recommendation report

Recommendation That the proposed sale of the Ingleburn Defence site by the Department of Defence be approved subject to the following conditions: Conditions Relevant

paragraph /section in report

1. The proposed purchaser of the Ingleburn Defence site must enter into a conservation agreement with the Commonwealth to protect and conserve the biodiversity of the area; in particular the ecological communities – Cumberland Plain Woodlands and Sydney Coastal River-Flat Forest, prior to concluding the sale of the site.

2. The conservation agreement mentioned in paragraph 1

must require the purchaser to retain and manage at least 90% of the Cumberland Plain Woodlands on the Ingleburn Defence site in accordance with the parameters outlined in the ‘Recovering Bushland on the Cumberland Plain: Best practice guidelines for the management and restoration of bushland’ (2005). The conservation agreement must address the conservation of the ecological communities on the site in accordance with the following criteria:

o maintain maximum connectivity;

o minimise fragmentation and edge effects by maximising the edge to area ratios;

o restore and rehabilitate the site; and

o maximise conservation of areas of high density Cumberland Plain Woodlands (10ha or more).

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3. The Department of Defence must enter into a contract

with the purchaser of the Ingleburn Defence site, which includes a covenant that binds the purchaser to preserve and maintain the Military Heritage Precinct and the Mont St Quentin Oval.

4. The Department of Defence must complete an existing

conditions report consistent with NSW Heritage Office (1998)1 and Heritage Office (2006)2 for the Kitchen/Dining Hall Complex and the remaining prefabricated cottages prior to sale of the Ingleburn Defence site.

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1. NSW Heritage Office (1998) Heritage Information Series – How to prepare archival records of

heritage items. 2. Heritage Office (2006) Heritage Information Series – Photographic recording of heritage items

using film or digital capture. Material on which the decision maker’s findings are based

a) Referral Document signed 10 July 2007 by the proponent

b) Civitas (2004) Edmondson Park Background Report. Dated November 2004.

c) Civitas (2005) Edmondson Park Background Report – Addendum Report. Dated August 2005.

d) Eco Logical Australia (2003a) Edmondson Park Ecological Assessment. Summary Report. Edmondson Park Master Plan (project No. 05-11) Dated August 2003. Report prepared for the Edmondson Park Steering Group.

e) Dallas, M. 1999b. Attachment A, Preliminary Archaeologist Assessment of the Department of

Defence Land at Ingleburn, NSW. Report to the Department of Defence.

f) URS Australia, (2002) Flora and Fauna Opportunities and Constraints Study, Ingleburn Defence Site, Ingleburn, Final Report

g) Godden Mackay Logan (2001) Heritage Analysis, Ingleburn Defence Site – Lecture Hall

Building, Heritage Assessment and Use-options Study, Ingleburn Defence Site – Godden Mackay Logan, September 2000.

h) Manidis Roberts Consultants (2004) Ingleburn Military Heritage Precinct, Plan of Management

i) RAPI Award for Excellence in Planning, Environmental Planning or Conservation ESD, Ingleburn

Military Heritage Precinct, November 2001.

j) Egis Consulting (2000) Defence Site, Ingleburn Village, Structural Investigation

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k) Bushfire and Environmental Services (2002) Fire Management Plan, Ingleburn Defence Land

l) Eco-logical Australia (2004) Environmental Impact Assessment – Ingleburn Fire Trail Maintenance.

m) Correspondence with Liverpool City Council to support listing of Ingleburn Military Heritage

Precinct on the NSW Heritage Register, September 2006.

n) Correspondence with Liverpool City Council to confirm re-listing of Commonwealth Heritage List items on Liverpool Local Environmental Plan Heritage List, November 2006.

o) Correspondence relating to the establishment of the Heritage Precinct Interim Management

Committee and/or minutes of meetings of the Committee.

p) Plan showing Commonwealth Heritage Listed items overlayed on the zoning plan.

q) Ingleburn Site Aerial Photograph, 1999.

r) HLA Envirosciences (2003) Non-Indigenous Heritage Assessment, Edmondson Park, New South Wales,

s) Australian Museum Business Services (2003) Aboriginal Heritage Management Plan,

Edmondson Park Composite Site Master Plan.

t) URS Australia (2003) Edmondson Park Infrastructure Planning.

u) Clouston Associates (2003) Edmondson Park Release Area, Revised Community Planning Study, Part 2 - Open Space and Recreation Plan.

v) Liverpool Local Environmental Plan 1997 (Amendment No 83) and Maps, Liverpool City Council

for Edmondson Park, March 2006.

w) Campbelltown (Urban Areas) Local Environmental Plan 2002 (Amendment No 12) and Maps, Campbelltown City Council for Edmondson Park, March 2006.

x) Liverpool City Council, Edmondson Park Locality Development Control Plan Template, October

2006.

y) Campbelltown City Council, draft Edmondson Park Locality Development Control Plan Template, August 2005.

z) Liverpool Contributions Plan 2006, Edmondson Park, Liverpool City Council.

aa) Draft Edmondson Park (Campbelltown) Section 94 Contributions Plan, Campbelltown City

Council, March 2005.

bb) Letter from Landcom to DEC re “assumed concurrence” for Cumberland Plain Woodland, October 2006.

Background 1. The action involves the sale of 311ha of Commonwealth land in south western Sydney. The most likely

purchaser is the NSW Government which intends to develop it, along with approximately 500ha of

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adjacent land. The two sites are referred to as Edmondson Park, and are situated in the Campbelltown and Liverpool City Council areas.

2. The land to be sold is the former Ingleburn Defence site. This area has been deemed surplus to needs, and the former Government has directed that the site be sold. Prior to its sale, the Department of Defence proposes to remediate the Ingleburn Defence site to a standard suitable for proposed urban land uses. The Department of Defence also proposes to demolish buildings that are no longer needed, and do not have heritage value.

3. The 500ha of land adjacent to the Ingleburn Defence site is either owned by Landcom or is in private ownership. The privately owned land is predominately 2ha residential blocks and market gardens.

4. The Ingleburn Defence site, and the additional 500ha adjacent, contains approximately 440ha of native vegetation. Some 271ha of this is the endangered ecological community, Cumberland Plain Woodlands.

5. In November 2004, the then Minister for the Environment Senator the Hon Ian Campbell, issued a media release stating that negotiations had commenced on developing conservation agreements on Commonwealth land at Llandilo, Orchard Hills, Ingleburn and Holsworthy. This did not eventuate as the Commonwealth could not enter into a conservation agreement with itself, however the sale of the Ingleburn Defence site will now allow the Commonwealth to enter into such an agreement with the purchaser.

6. A number buildings on the Ingleburn Defence site are listed on the Commonwealth Heritage List (CHL), and the Register of the National Estate.

7. The NSW Government has proposed a conservation and development footprint for Edmondson Park, which includes the Ingleburn Defence site. A number of assessments have been completed on the values of the Ingleburn Defence site including a Heritage analysis, and an ecological assessment encompassing Edmondson Park.

8. The assessment approach for this proposed action is Assessment on Referral Information. Public consultation is included in this process.

Environmental record 9. The Department of Defence has developed an Environmental Management System which outlines its

environmental and heritage responsibilities. Assessment 10. The sale of the Ingleburn Defence site will have consequential impacts on its natural and cultural

heritage values, as the NSW Government proposes to develop the land for urban purposes. This assessment will therefore consider the consequential impacts that are likely to occur as a result of the proposed Edmondson Park development. The Ingleburn Army Camp and the Prefabricated Cottages Ingleburn Village on the Ingleburn Defence site are both on the CHL. The Ingleburn Army Camp listing comprises 120ha of the Ingleburn Defence site (311ha), and includes both natural and historic heritage values, while the Prefabricated Cottages village listing only has historic heritage values. Details of these listings can be found by searching the Australian Heritage Database at http://www.environment.gov.au/cgi-bin/ahdb/search.pl.

Biodiversity Values Ecological Communities

11. The Ingleburn Defence site has important ecological communities – primarily the Cumberland Plain Woodlands and Sydney Coastal River-Flat Forest (see Attachment A). The Cumberland Plain Woodland was once found in abundance in the Cumberland Plains region west of Sydney, but is now reduced to a few fragmented stands. Cumberland Plain Woodlands, which also includes Shale Plain Woodland, was the first endangered ecological community to be listed under the EPBC Act. It is also

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listed under NSW legislation. The NSW Threatened Species Profile for Cumberland Plain Woodland states that only 9 percent of the original extent of this ecological community remains intact. Only about 13 percent of that occurs in National Parks or land zoned for conservation. According to the Commonwealth Heritage List summary statement of significance for the Ingleburn Army Camp, only 9% of the pre-1750 extent of Sydney Coastal River-Flat Forest remains. That ecological community is listed under NSW legislation, but not under the EPBC Act.

12. The proposed Edmondson Park site contains approximately 271ha of Cumberland Plain Woodlands, of which approximately 160 ha is within the Ingleburn Defence site. The CHL summary statement of significance for the Ingleburn Army Camp states, “(T)his large area of woodland habitat, particularly taken together with vegetation external to the site boundary, contributes significantly to the overall stock of Cumberland Plain Woodlands left to the west of Sydney and contributes to a local and regional bushland corridor with connections to other woodland areas to the north of the site.” The assessment by Eco Logical Australia (2003) states that “(E)dmondson Park contains significant natural values. It contains some of the largest remaining stands of Cumberland Plain Woodland in good condition in the Sydney Basin. It also contains some of the some of the least disturbed stands of the remaining Sydney Coastal River Flat Forest in the Sydney Basin.”

13. Eco Logical Australia carried out an assessment for the Edmondson Park Steering Group on the following three native vegetation communities in the proposed Edmondson Park site (including the Ingleburn Defence site) - Cumberland Plain Woodlands (EPBC listed and NSW listed), Sydney Coastal River-flat Forest (NSW listed) and Native Grasslands (not listed but considered to have high conservation value). Each community was assessed according to its conservation values. Those values included recovery potential, remnant size and condition. Based on this assessment, remnants of those ecological communities were classified into three groups, those having high, moderate and low ecological constraint. Table 1 gives a breakdown of the number of hectares in each of these groups for the three vegetation communities.

Table 1 Conservation Value Assessment Summary (based on data in Eco Logical Australia (2003))

Vegetation Community

High Ecological Constraint

(ha)

Moderate Ecological Constraint

(ha)

Low Ecological Constraint

(ha)

Total (ha)

Cumberland Plain Woodland 135.82 71 64.37 271.19

Sydney Coastal River-flat Forest 12.64 4.46 2.18 19.28

Native Grasslands 49.09 49.09 Total 148.46 124.55 66.55 339.51

14. Tables 2, 3 and 4 describe the areas to be cleared, modified and reserved for each of the vegetation communities as a result of the proposed Edmondson Park development. Eco Logical Australia (2003) states that areas proposed to be retained in riparian corridors will be modified in terms of composition and structure. It is assumed that it is proposed to clear areas that fall within the development footprint.

Table 2 Impact on Cumberland Plain Woodlands of Edmondson Park Development (based on data in Eco Logical Australia (2003)) Conservation Value

To be cleared (ha)

To be modified (ha)

To be conserved (ha)

High Ecological Constraint

28.22 (21%) 4.34 (3%) 103.06 (76%)

Moderate Ecological Constraint

58.04 (82%) 11.31 (16%) 1.65 (2%)

Low Ecological 59.47 (92%) 3.75 (6%) 1.15 (2%)

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Constraint Total 145.73 19.4 106.06 Table 3 Impact on Sydney Coastal River-flat Forest of Edmondson Park Development (based on data in Eco Logical Australia (2003)) Conservation Value

To be cleared (ha)

To be modified (ha)

To be conserved (ha)

High Ecological Constraint

1.22 1.21 10.21

Moderate Ecological Constraint

1.05 3.41 0

Low Ecological Constraint

0.95 1.23 0

Total 3.22 5.85 10.21 Table 4 Impact on Native Grasslands of Edmondson Park Development (based on data in Eco Logical Australia (2003)) Conservation Value

To be cleared (ha)

To be modified (ha)

To be conserved (ha)

Moderate Ecological Constraint

27.84 0.8 20.45

15. The Department notes that most of the high and moderate ecologically constraint NSW listed Sydney Coastal River-flat Forest is proposed to be conserved. Almost half of the moderate ecological constraint Native Grasslands impacts are also proposed be to be conserved.

16. The Civitas (2005) ‘Edmondson Park Background Report’ (November 2004), states that 154 ha of the proposed Edmondson Park area will be retained for conservation parks. The Cumberland Plain Woodlands comprise 106 ha of this area. Table 2 shows that a total of 145 ha of Cumberland Plain Woodland will be cleared and a further 19 ha will be modified – this is a total of 164 ha or 60% of the ecological community located within the proposed Edmondson Park area.

17. Currently there is no recovery plan for the Cumberland Plain Woodlands ecological community. However, a recovery plan is being drafted by the NSW Department of Environment and Climate Change (DECC), and is expected to be submitted to the Department of the Environment, Water, Heritage and the Arts soon. The web site of the NSW National Parks and Wildlife Service states that the recovery plan for the Cumberland Plain Woodlands “aims to halt the loss of biodiversity and achieve a net gain in the extent and condition of bush on the Cumberland Plain. This will start the 'recovery' of the ecological communities and will lead to the creation of a viable bushland network across the landscape, with each remnant playing a supporting role to the others.”

18. The DECC web site profile of the Cumberland Plain Woodlands ecological community states that “(T)he main threat is further clearing for urban or rural development, and the subsequent impacts from fragmentation.”

19. The DECC web site on priority actions for Cumberland Plain Woodland states that there is a need to “(D)evelop and implement Cumberland Plain Reservation Strategy and create a protected bushland network through targeted land acquisition as land becomes available.” The DECC web site on the profile of the species further states that the following action is required to recover the species “(P)rotect habitat by minimising further clearing of the community. This requires recognition of the values of all remnants of the community in the land use planning process, particularly development consents, re-zonings and regional planning.”

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20. The NSW guidelines ‘Recovering Bushland on the Cumberland Plain: Best practice guidelines for the management and restoration of bushland’ (2005, NSW DEC), state that the clearing of the Cumberland Plain Woodlands has led to fragmentation of the landscape, resulting in isolated small remnants that are more vulnerable to impacts, provide less habitat, and support fewer species. The more fragmented a landscape is, the more difficult it is to successfully manage it as a network across the landscape (Major et al. 1999; Smith et al. 2000). It also states that “it is critical to retain all existing native vegetation where possible.”

21. High conservation areas in the Edmondson Park site are proposed to be connected through riparian parks. Civitas (2004) Edmondson Park Background Report states that riparian parks are to be retained or enhanced in a natural state to protect native vegetation and archaeological sites, and will act as corridors outside the conservation areas. However the low area to edge ratio of those parks is likely to significantly reduce connectivity between the high conservation areas of the Cumberland Plain Woodlands on the Ingleburn Defence site.

22. The NSW Scientific Committee in making its determination of the Cumberland Plain Woodland as an endangered ecological community, stated that the woodlands are likely to become extinct unless the factors threatening its survival cease to operate. Threats include but are not limited to the clearance of habitat for housing and other developments, invasion by exotic plants and increased nutrient loads due to run off from gardens. Further, this Committee states that although some areas of Cumberland Plain Woodland occur within conservation reserves, that in itself would not be sufficient to ensure the long term conservation of the community. The NSW guidelines ‘Recovering Bushland on the Cumberland Plain: Best practice guidelines for the management and restoration of bushland’ (2005, NSW DEC), state that only 880ha of Cumberland Plain Woodland is currently in conservation reserves.

23. On 14 December 2007 the NSW Government announced that a Conservation Plan for the North Westa and South West Growth Centres had received Biodiversity Certification. The Ingleburn site falls into the South West Growth Centre. This means the NSW Threatened Species Protection Act has been ‘switched off’ for developments in the growth centres and that approximately 65% (1329 ha) of all CPW occurring in them may be cleared. To offset this loss $530 million dollars will be made available to purchase land to protect CPW elsewhere.

24. The Ingleburn Defence site contains the majority of the Cumberland Plain Woodland found in the proposed Edmondson Park area – approximately 160 ha. This site also contains the majority of the high density and core habitat support Cumberland Plain Woodland within the Edmondson Park area. Given that value of the site as described in paragraph 12, and the concerns raised by the NSW Scientific Committee, DECC and the NSW National Parks and Wildlife Service in paragraphs 17, 18, 19, 20 and 22, it is important to preserve the connectivity between areas of high conservation value and to preserve the areas of high density in order to prevent the further fragmentation and degradation of the ecological community.

Listed threatened species - Fauna

25. The Ingleburn Defence site is potential habitat for a number of EPBC Act listed threatened and migratory species. However no EPBC Act listed threatened species were found during fauna surveys. See Attachment B for further analysis of impacts on listed threatened and migratory species.

26. State listed species that are present or may be present in the area include:

• Eastern False Pipistrelle, East Coast Freetail Bat and Great Broad-nosed Bat Those species roost in tree hollows and forage in and around open forest and woodlands. Clearing that will result from the development of the Edmondson Park site will reduce the availability of resources for this species.

• Common Bent-wing Bat This species roost in caves, mines and tunnels. Those features are absent from the site and so

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the development will not affect roosting habitat. However they forage over forests and nearby cleared areas, so the development will result in the removal of some habitat.

• Cumberland Land Snail This species occurs in many of the woodland remnants. Populations identified in the south of the site will be largely captured in proposed conservation areas and so be unaffected. Populations in the north of the site occur mainly in areas that will be managed as riparian corridors. These areas will suffer disturbance to their ground layers leading to soil compaction, modification of soil biota and thus food resources for the snail.

Other Flora

27. No Commonwealth listed threatened flora species have been recorded within the area proposed for development. Four species (Persoonia nutans, and Pimela spicata, both EPBC listed, and Acacia pubescens and Pultenaea pendunculata both State listed) are known from within 5 km of the site. However, none were detected in targeted surveys and it is considered unlikely that they occur there.

Summary Biodiversity Values

28. To mitigate the above impacts, the Department of Defence states that it will include as a condition of sale, a requirement for the purchaser to enter into a Conservation Agreement over the Ingleburn Defence site with the Minister for the Environment, Heritage and the Arts. The proposed agreement could protect biodiversity values on the Ingleburn Defence site and potentially the areas adjacent.

29. Under the conservation agreement the Department recommends that the purchaser be required to retain and manage at least 90% of the Cumberland Plain Woodlands on the Ingleburn Defence site in accordance with the parameters outlined in ‘Recovering Bushland on the Cumberland Plain: Best practice guidelines for the management and restoration of bushland’ (2005). The conservation agreement must address the conservation of the ecological communities on the site in accordance with the following criteria:

• maintain maximum connectivity;

• minimise fragmentation and edge effects by maximising the edge to area ratios;

• restore and rehabilitate the site; and

• maximise conservation of areas of high density Cumberland Plain Woodlands (10ha or more).

The impact of the proposal on biodiversity would not be unacceptable if such a conservation agreement were implemented.

Historic Heritage Values

Ingleburn Army Camp

30. The Ingleburn Army Camp is listed for its historical association with the Australian Army, the aesthetic characteristics of certain buildings and the social association with military personnel and the community. The Ingleburn Army Camp was one of Australia’s major army camps from 1939 – 1970s and was the first purpose-built infantry training camp for World War II.

31. Significant features of the camp include: • the Ingleburn Military Heritage Precinct, formed in the late 1990s has historical, characteristic and

aesthetic values. This area contains: o the Bardia Barracks entrance gates and sentry boxes; o the Guard House and Cell Block; o Chaplain’s Office and former Post Office; o three P-1 type huts;

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o the Lecture Hall building which has historical values for its role as a recreation centre for National Service trainees and as an educational facility; and

o the Memorials which have social values due to association with former military personnel and the regiments who occupied the site.

• the Mont St Quentin Oval, entry gates and flagpole, have historical value as the oval served as the original parade ground for WWII troops; and

• the Kitchen/Dining Hall Complex which has historical values for its association with the expansion of the camp as a training school;

32. Upon disposal the Ingleburn Defence site will come under NSW jurisdiction and so lose its protection under the EPBC Act. Unacceptable impacts on the heritage values of the site may result unless proper protection measures are put in place.

33. The Liverpool and Campbelltown Councils have made provision for listing the following as heritage items: the Lecture Hall building, the Ingleburn Military Heritage Precinct, the Mont St Quentin Oval (including the entry gates) and the Mess Hall (Kitchen/Dining Hall complex). The Ingleburn Military Heritage Precinct has also been recommended for nomination to the NSW State Heritage Register.

34. Campbelltown Council will acquire the Mont St Quentin oval and use it for Australian Rules Football as well as recognising its heritage values.

35. Provided the Military Heritage Precinct is listed on the State Heritage Register, it will continue to be protected and maintained.

36. There appear to be no plans for the Dining/Mess Hall. Given this and its dilapidated condition there is a high risk of it being removed if urban development proceeds.

Prefabricated Cottages Ingleburn Village

37. The listing on the CHL of the Amals Sagverks Aktiebolag and Riley-Newsum prefabricated cottages situated in the Ingleburn Village states that these cottages are rare survivors of their type. Eight cottages are included on the CHL for the Ingleburn site, however only six cottages remain. The current physical status of the other two is unknown. The cottages are significant for their association with post-war development and use of the camp, are representative of a form of standardised prefabricated housing design and have a social association with those who lived at the camp and to the local community. Three of the listed cottages remaining are vacant and are fenced off to prevent vandalism. Those cottages are rare survivors of their type.

38. The Liverpool Council has made provision for the listing of the Ingleburn Village Site for its heritage values, with the village location given as Part of Lot 1, DP 831152. This is the parcel of land on which the cottages are situated. A plan attached to Amendment 83 to the Liverpool LEP shows two circles encompassing the CHL listed cottages. On the plan these two areas are designated "Heritage Item".

39. Lot 1 DP 831152 is to be rezoned for a new Town Centre as part of the Edmondson Park development. The Liverpool Council Edmondson Park Locality Development Control Template (October 2006, page 105) states that Liverpool Council "does not consider retention of the six prefabricated cottages in the [to be constructed] town centre as appropriate".

Summary Historic Heritage Values

40. To mitigate the above impacts, the Department of Defence states that the heritage values of the site can be adequately protected by a covenant in the sale contract.

41. There appear to be provisions in place to maintain and manage the Military Heritage Precinct and the Mont St Quentin Oval, although details on how these will be managed are not available.

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42. The proposed Edmondson development has the location of the prefabricated cottages in the Ingleburn Village zoned for commercial development. It is unclear what the fate of these cottages is but it appears they will be removed. Similarly it is unclear what the fate of the Dining/Mess Hall will be.

43. To ensure the appropriate management of the Military Heritage Precinct and the Mont St Quentin Oval the Department recommends that a covenant should be included in the contract of sale requiring the purchaser to preserve and maintain these sites.

44. Given the risk that the prefabricated cottages and the Dining/mess hall may be removed during the development of Edmondson Park the Department recommends that the Department of Defence be required to complete an existing conditions report of these buildings to ensure archival records exist describing their heritage values.

Consultation on draft conditions 45. To be completed following consultation. Social and economic matters 46. The Ingleburn Defence site will form part of the proposed Edmondson Park development which is part

of a larger strategy to accommodate urban growth in South West Sydney. Edmondson Park has the potential for a large number of new residential lots. It is also expected that the re-zoning will bring business growth to the area. A new South West Rail Link is also proposed to traverse the new Edmondson Park site.

Ecologically sustainable development

47. The five principles of ecologically sustainable development have been accounted for as follows:

i. the integration principle;

This report balances the conservation of biodiversity and heritage values of the Ingleburn Defence site with the economic objectives of the proposal to provide housing.

ii. the precautionary principle;

This report has considered the precautionary principle in recommending measures to reduce and prevent environmental degradation. The mitigation measures will ensure the proposal does not have unacceptable impacts on the biodiversity and the heritage values of the Ingleburn Defence site.

iii. the intergenerational principle;

The implementation of a conservation agreement and a covenant will maintain and enhance the biodiversity and heritage values of the Ingleburn Defence site for current and future generations.

iv. the biodiversity principle;

The implementation of a conservation agreement, as recommended in this report, will result in the conservation and protection the ecological diversity of the area.

v. the valuation principle.

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The methods proposed to protect and conserve the biodiversity and heritage values of the Ingleburn Defence site are considered appropriate.

Other legal considerations

48. There are currently no approved national recovery plans or threat abatement plans for the Cumberland Plain Woodland ecological community impacted by the project and so approval of the project will not be inconsistent with an approved recovery plan or threat abatement plan.

49. Providing the proponent abides with the recommendations proposed by the Department, the impacts on listed threatened species and ecological communities are not considered unacceptable. This means that approval of the project would not be inconsistent with Australia’s international obligations under the Biodiversity Convention, the APIA Convention or the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Conclusion 50. The proposed action triggered the following controlling provisions:

• Listed Threatened Species and Ecological Communities; • Activities of a Commonwealth agency impacting on the environment; and • Activities on Commonwealth land impacting on the environment.

51. To protect the Cumberland Plain Woodlands and Sydney Coastal River-Flat Forest the Department recommends a condition requiring the Department of Defence to include a covenant in the contract of sale that obliges the purchaser to enter into a conservation agreement with the Commonwealth to protect and conserve the biodiversity of the area.

52. To protect the historic heritage values of the site the Department recommends the following conditions: • The contract of sale should include a covenant that will require the purchaser to preserve and

maintain the Military Heritage Precinct and the Mont St Quentin Oval; and • The Department of Defence must prepare an existing conditions report for the Kitchen/Dining Hall

Complex and the remaining prefabricated cottages consistent with methods described in NSW Heritage Office (1998) and Heritage Office (2006) ;

53. If the above conditions are implemented the Department considers that the impacts of the proposal will not be unacceptable.

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Additional references Commonwealth Heritage Listings for the Ingleburn Army Camp and the Prefabricated Cottages Ingleburn Village - Australian Heritage Database at http://www.environment.gov.au/cgi-bin/ahdb/search.pl Commonwealth Heritage management principles at: http://www.environment.gov.au/heritage/commonwealth/managing.html Department of Environment and Conservation (NSW), (2005), Recovering Bushland on the Cumberland Plain: Best practice guidelines for the management and restoration of bushland. NSW Heritage Office (1998) Heritage Information Series – How to prepare archival records of heritage items. Heritage Office (2006) Heritage Information Series – Photographic recording of heritage items using film or digital capture. New South Wales National Parks and Wildlife Service (2002). Interpretation Guidelines for the Native Vegetation Maps of the Cumberland Plain, Western Sydney. New South Wales National Parks and Wildlife Service, Sydney Web sites: Department of Environment and Climate Change NSW, Threatened Species – Cumberland Plain Woodland profile Department of Environment and Climate Change NSW, Threatened Species – Cumberland Plain Woodland priority actions Department of Environment and Climate Change NSW, Threatened Species without recovery plan – Cumberland Plain Woodland – endangered ecological community listing NSW National Parks and Wildlife Service – Endangered Ecological Community Information – Cumberland Plain Woodland NSW National Parks and Wildlife Service – Recovery Planning for Cumberland Plain’s Endangered Ecological Communities.