Broad-headed Snake Management Plan - BSO Project Approval - Schedule 4, Condition 17; BSO EPBC Project Approval (2010/5350) Condition 7 and ...
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Illawarra Coal Broad-headed Snake Management Plan BSO Project Approval - Schedule 4, Condition 17; BSO EPBC Project Approval (2010/5350) Condition 7 and Dendrobium Mine EPBC Project Approval (2001/214), Condition 5
ILLAWARRA COAL BROAD-HEADED SNAKE MANAGEMENT PLAN
Review History
Revision Description of Changes Date
0 New Document May 2007
1.0 Converted to new document format December 2010
2.0 Inclusion of Stage 4 as part of EPBC Approval requirements May 2013
3.0 Updated following review comments from OEH and DoE 11 April 2014
Persons involved in the development of this document include:
Name Title Company
David Gregory Specialist, Land and Biodiversity Illawarra Coal
Bruce Blunden Manager Surface Approvals Illawarra Coal
Joanne Page Manager Environment Illawarra Coal
Matt Richardson Director Niche
Chris McEvoy Team Leader Environmental Approvals Niche
Emma McIntyre Senior Environmental Scientist Niche
Dr Frank Lemckert Team Leader Ecology Niche
Current Version Approval:
Version Dated Name Title
2.0 15 May 13 Joanne Page Manager Environment
3.0 18 March14 Scott Coleman Manager Environment
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TABLE OF CONTENTS
1 INTRODUCTION............................................................................................................... 4
1.1 Objectives ................................................................................................................ 4
1.2 Scope ...................................................................................................................... 5
1.3 Statutory Requirements ............................................................................................ 5
1.4 Roles and Responsibilities........................................................................................ 5
1.5 Consultation ............................................................................................................. 6
2 MANAGEMENT AND MITIGATION OF IMPACTS............................................................ 7
2.1 Broad-headed Snake ............................................................................................... 7
2.2 Significance of Broad-headed Snake population within the Study Area ..................... 9
2.3 Habitats of the Broad-headed Snake within the Study Area ...................................... 9
2.4 Potential impacts on Broad-headed Snake ............................................................. 10
2.5 Management Strategies ......................................................................................... 11
2.6 Summary of Impact Minimisation Measures ............................................................ 18
3 PROVISION OF REGIONAL FUNDING .......................................................................... 21
3.1 Provision of Funding............................................................................................... 21
3.2 Actions to be Funded ............................................................................................. 21
3.3 Impacts on Other EPBC Act Listed Species............................................................ 21
3.4 Funding Arrangements ........................................................................................... 21
3.5 Documentary Evidence of Funding ......................................................................... 22
4 REFERENCES ............................................................................................................... 23
ATTACHMENT A: FIGURES .................................................................................................... 25
ATTACHMENT B: OEH BROAD-HEADED SNAKE AND SOUTHERN BROWN BANDICOOT
PROPOSAL .................................................................................................................... 31
List of Figures
Figure 1: Broad-headed Snake Location Map.................................................................. 26
Figure 2: Previous records of Broad-headed Snake......................................................... 27
Figure 3: EPBC Act listed species in 10km search area................................................... 28
Figure 4: EPBC Act listed species recorded near study area ........................................... 29
Figure 5: Potential Broad-headed Snake relocation sites within the West Cliff surface lease area 30
List of Tables
Table 2-1: Requirements of BSO Project Approval and EPBC Approval ............................ 4
Table 2-2: Roles and Responsibilities................................................................................ 6
Table 2-1Summary of the Pre-clearing surveys that have been undertaken in relation to clearing of
vegetation for coal wash emplacement operations in Stage 3 .......................................... 12
Table 2-2: Impact minimisation measures for the protection of the Broad-headed Snake at West Cliff
....................................................................................................................................... 19
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1 INTRODUCTION
1.1 Objectives
The objectives of this Management Plan are to meet the requirements of the:
• BSO Project EPBC Approval 2010/5350 and Dendrobium Mine EPBC Approval 2001/214;
• BSO Project NSW EP&A Act (DoPI) Approval
The Conditions of these Approvals and the sections where these requirements are addressed are
outlined in Table 1. Note: A separate management plan has been prepared for Southern Brown
Bandicoot.
Table 2-1: Requirements of BSO Project Approval and EPBC Approval
DEVELOPMENT CONSENT INSTRUMENT AND CONDITION REFERENCE
BSO Project Approval - Schedule 4, Condition 17
The Proponent shall prepare and implement a West Cliff Emplacement Area Separate MP
Management Plan for the project to the satisfaction of the Director-General. This plan
must be prepared in consultation with OEH and be submitted to the Director -General
for approval by the end of June 2013.This plan must include:
(d) management strategies for the protection and conservation of the Broad-headed Section 2
Snake and the Southern Brown Bandicoot.
BSO EPBC Project Approval (2010/5350) Condition 7
Within 1 year of the date of this approval the person taking the action must provide for This
the Minister’s approval a Southern Brown Bandicoot and Broad-headed Snake Management
management plan or plans. The plan or plans must include: Plan
(a) measures to avoid, mitigate and manage impacts on the Southern Brown Section 2
Bandicoot, Broad-headed Snake and their habitats occurring as result of the action;
(b) provisions for the contribution of no less than $250,000 (GST exclusive) in Section 3.1
funding towards regional Southern Brown Bandicoot and Broad-headed Snake
programs. This funding must not be expended on the measures referred to in
condition 6a;
(c) a description of actions to be funded and undertaken to inform and/or enhance Section 3.2
the conservation of these species, including through survey or research, threat
abatement with specific reference to predator controls and habitat restoration or
rehabilitation, including public reporting or publication of information gained by
these actions;
(d) a demonstration that management actions to be undertaken will not adversely Section 3.3
impact EPBC Act listed species;
(e) a description of funding arrangements or agreements including work programs Section 3.4
and responsible entities; and
(f) measures for the provision of documentary evidence within 30 days of the Section 0
funding having been expended and/or that funding commitments have been met.
Dendrobium Mine EPBC Project Approval (2001/214), Condition 5
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BHP Illawarra Coal must submit for the Minister’s approval a plan for managing the All Sections
impacts of the action on the Broad-headed Snake Hoplocephalus bungaroides. The
plan must be implemented. No vegetation may be cleared as part of West Cliff Coal
Emplacement Stage 3 until the plan has been approved by the Minister.
1.2 Scope
This Plan applies to potential impacts on the Broad-headed Snake from Stages 3 and 4 of the West
Cliff Emplacement construction and operations. The Plan addresses the requirements of:
• Bulli Seam Operations NSW EP&A Act - Project Approval Condition 17 d) and
• Bulli Seam Operations - EPBC Approval Condition 2010/5350 Condition 7 and Dendrobium
Coal Mine - EPBC Approval 2001/214 - Condition 5.
This plan will formally replace the current (approved) Broad-headed Snake Management Plan that
was developed in 2007 for the Dendrobium 2001/214 EPBC Approval Condition 5.
1.3 Statutory Requirements
1.3.1 Project Approval and Statement of Commitments
Potential impacts generated by the existing and future BSO were assessed during preparation of the
BSOP Environmental Assessment 2009 (EA) and BSOP Environmental Impact Statement 2011 (EIS).
The results were assessed under the Environmental Planning and Assessment Act 1979 (EP&A Act)
and Regulations, and Environmental Protection and Biodiversity Conservation Act (EPBC Act). All
activities carried out as part of the BSOP will be in accordance with Project Approval (08_0150), the
EPBC Approval.
The Environmental Assessment and Approvals are located on the BHP Billiton website at:
http://www.bhpbilliton.com/home/aboutus/regulatory/Pages/default.aspx
1.3.2 Legislation and Guidelines
Other legislation and relevant licences, leases and permits are contained in the Environmental
Management Strategy (ICHMPP0239).
1.4 Roles and Responsibilities
The table below outlines the roles and responsibilities associated with this Management Plan.
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Table 2-2: Roles and Responsibilities
Responsibilities Role
Meeting the commitments (including auditing, Site Environmental Representative
investigation and reporting) of this Management Plan.
Implementation and periodic review of this Environmental Specialist
Management Plan.
Provision of suitable resources to manage the West Cliff Coal Preparation Plant Operations
Emplacement in accordance with this Plan. Manager
Day to day operation and maintenance of West Cliff Coal Preparation Plant Supervisor
Emplacement Area in accordance with this
Management Plan.
Monitoring and relocation (if required) of the Broad- Ecologist or wildlife specialist (with
headed Snake. experience in relation to the Broad-headed
Snake)
1.5 Consultation
As required, the components relating to the Broad-headed Snake and Southern Brown Bandicoot from
the West Cliff Coal Wash Emplacement Area Management Plan have been prepared in consultation
with Department of the Environment (now DoE) and the NSW Office of Environment and Heritage
(OEH).
DoE and OEH have been provided drafts of this Plan for comment with responses addressed within
this version of the Plan where appropriate.
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2 MANAGEMENT AND MITIGATION OF IMPACTS
This Section addresses Condition 17(d) of the BSO Project Approval and Condition 7(a) of the EPBC
Approval in relation to the Broad-headed Snake as follows:
17 (d) management strategies for the protection and conservation of the Broad-headed Snake and the
Southern Brown Bandicoot;
7 (a) measures to avoid, mitigate and manage impacts on the Southern Brown Bandicoot, Broad-
headed Snake and their habitats occurring as result of the action.
As mentioned in Section 1, this plan will formally replace the current (approved) Broad-headed Snake
Management Plan that was developed in 2007 for the Dendrobium 2001/214 EPBC Approval
Condition 5.
2.1 Broad-headed Snake
The Broad-headed Snake Hoplocephalus bungaroides is a species of national conservation
significance. It is listed as Vulnerable under provisions of the Federal Environment Protection and
Biodiversity Conservation Act 1999 (EPBC Act) and as Endangered under New South Wales’
Threatened Species Conservation Act 1995 (TSC Act).
Plate 1: Broad-headed snake
Stuart Cohen © DEC
Records of Broad-headed Snake are restricted to the Sydney Basin Bioregion of NSW (Cogger 2000).
The species occurs in association with Triassic sandstones within the Sydney Basin, and is typically
found among exposed sandstone outcrops within vegetation types ranging from woodland to heath.
Within these habitats, they generally seek shelter in rock crevices and exfoliating rock with males and
non-gravid females also using tree hollows during the warmest periods of summer (Webb and Shine
1998b). Research has found that the rock outcrops used by Broad-headed Snake have relatively
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specific characteristics, being generally western facing and with a relatively open canopy (Webb and
Shine 1998a, b).
Furthermore, the rock crevices within these outcrops are quite specific, with rocks having to be
exposed to direct sunlight (no overgrowth; Pringle et al 2003), be a rock on rock substrate and have
relatively specific crevice structures and rock thicknesses that provide specific microclimates (Croak et
al 2008).
These highly specific rock characteristics lead to a paucity of suitable rocks being available in any
given outcrop area and so there may significant competition for suitable rocks between resident
snakes and hence, the loss of suitable crevices may be a significant problem for local populations.
Individual snakes have been found sheltering in hollows in tree species including Eucalyptus
gummifera, E. punctata, E. piperita and E. agglomerate and prefer larger trees, trees with multiple
hollows or dead trees. These hollows are typically located in positions where they are relatively
unshaded by surrounding vegetation. Individual snakes use between one and nine trees and may
spend long periods within a single hollow, up to 48 days (Webb & Shine 1997a).
The Broad-Headed snake is an ambush predator, spending up to four weeks in the same retreat site
(Webb & Shine 1997a) and preying on small reptiles and mammals that enter the retreat (Webb &
Shine 1997a; Wells 1981). Snakes feed very infrequently, with less than 20% of captured adults
showing signs of having fed recently (Webb & Shine 1994). Juveniles feed more frequently than adults
(Webb & Shine 1994; Webb & Shine 1998c). Juvenile snakes feed primarily on Velvet Geckos
(Oedura lesuerii) (up to 70% of prey items) and occasionally on small skinks (Downes 1999; Webb &
Shine 1998c). Adult snakes also consume Velvet Geckos, although they only comprise 27% of prey
items (Webb & Shine 1998c). Other prey items include lizards, snakes and small mammals (Downes
1999; Shine 1983b; Webb & Shine 1998c). Broad-headed Snakes show a greater specialisation or
specificity of prey than is typical of Australian snakes (Webb and Shone 1998c), which may be related
to limited prey types occurring within their preferred habitats.
The Broad-headed Snake has been recorded to have a sedentary life cycle for a snake. Individuals in
southern areas of its range have been found to occupy home ranges that are only 3.43 (±2.86 SD) ha
(n = 18) with all snakes avoiding sharing space (Webb & Shine 1997b). Despite this low home range
size and habitat specificity, recent research has indicated that there is a relatively high exchange of
genes amongst populations, although this appears to occur only along lines of outcropping (Dubey et
al 2011). The Broad-headed Snake also has a notably long reproductive cycle, with adults reaching
maturity only a six years for female snakes and five years for males (Webb et al. 2003). Females are
able to produce offspring only every second year (Webb et al 2002) and with litter sizes of 4-12 (Webb
& Shine 1998c). This relatively low reproductive rate, relative to other Australian elapid snakes,
appears to be related to low prey availability or low prey capture rates (Webb et al. 2003).
Stages 3 and 4 of the Emplacement Area contain areas of suitable habitat for the species in the
Sandstone Scribbly Gum Woodland, Sandstone Gully Apple Peppermint Forest and Sandstone Gully
Peppermint Forest. These vegetation units contain areas of suitably exposed sandstone that also
have adjacent forests containing large hollow bearing trees that can be used during summer.
Common prey species, such as the Velvet Gecko (Oedura lesueurii) and the Southern Leaf-tailed
Gecko (Phyllurus platurus), have also been recorded within Stages 3 and 4 of the Emplacement Area,
indicating that prey species are available.
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To date, the Broad-headed Snake has been definitively recorded only once in the Stage 3
Emplacement Area (refer Figure 2: Previous records of Broad-headed Snake). Another record nearby
the Stage 4 Emplacement is still the subject of some conjecture. Several records of the species exist
within 10 km of the West Cliff operations (DECCW Atlas of NSW Wildlife – See Figure 3: EPBC Act
listed species in 10km search area). Most of these records occur to the north and east of the site,
including within Dharawal National Park. Locally, the species has a patchy distribution, almost
certainly reflecting its specific habitat requirements.
2.2 Significance of Broad-headed Snake population within the Study Area
The local Broad-headed Snake population within the West Cliff Colliery Surface Lease and surrounds
is considered to be of national conservation significance and, as such, Stages 3 and 4 of the
Emplacement Area may be considered to support an ‘important population’ of the species, as defined
by the EPBC Act.
An important population is one that is necessary for a species' long-term survival and recovery and
may include populations that are:
• Key source populations either for breeding or dispersal,
• Populations that are necessary for maintaining genetic diversity, and/or
• Populations that are near the limit of the species range.
Under provisions of the EPBC Act, an action has, will have, or is likely to have a ‘significant impact’ on
a ‘Vulnerable Species’ if it does, will, or is likely to:
• Decrease the size of an important population of a species, or
• Reduce the area of occupancy of an important population, or
• Fragment an existing important population into two or more populations, or
• Adversely affect critical habitat, or
• Disrupt the breeding cycle of an important population, or
• Modify, destroy, remove or isolate or decrease the availability or quality of habitat to the extent
that the species is likely to decline, or
• Directly or indirectly result in invasive species that are harmful to a vulnerable species
becoming established in the vulnerable species’ habitat, or
• Interferes substantially with the recovery of the species.
2.3 Habitats of the Broad-headed Snake within the Study Area
Known and potential habitat for the Broad-headed Snake occurs within the West Cliff Colliery Stages 3
and 4 of the Coal Wash Emplacement Area and the remainder of the surface lease (Figure 1: Broad-
headed Snake Location Map). This habitat includes:
• Rocky outcrops, crevices, caves and overhangs;
• Open forest and woodland with hollow-bearing trees (particularly dead trees); and
• Fallen hollow timber and bark.
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The individual recorded by Biosis Research (2001) was observed in March 2001 during a spotlighting
survey and was crossing a dirt track between open woodland habitat on a ridge, within the site (refer
to Figure 2: Previous records of Broad-headed Snake).
The Broad-headed Snake spends a significant amount of time inactive in retreat-sites and moves only
short distances between winter sites (i.e. rocky outcrops). The species’ movement is more frequent
and extensive within woodland (summer) habitat, with males and non-gravid females moving up to
780 m from winter sites into woodland during summer (Webb and Shine 1997a).
Plate 2: Potential Broad-headed Snake habitat (winter habitat). Image: © Biosis Research
2.4 Potential impacts on Broad-headed Snake
Key Threatening Processes (KTP), as listed under Schedule 3 of the TSC Act, are actions that have
the ability to significantly impact threatened species and/or their habitats. KTP’s relevant to the
proposal that would impact on actual and potential habitat for the Broad-headed Snake include:
• ‘Bushrock Removal’- the emplacement operations involve the removal of bushrock, including
large rock platforms and outcrops that provide potential habitat for the species;
• ‘Clearing of Native Vegetation’; and
• ‘Loss of Hollow-bearing Trees’.
The emplacement operations have the potential to negatively impact on the local population of Broad-
headed Snake either directly through mortality and habitat removal, or indirectly by changes to habitat
conditions, fragmentation of suitable habitats and loss of prey items.
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A summary of potential impacts associated with the Project are outlined below.
2.4.1 Direct Impacts
Direct impacts that may result from the active emplacement within Stages 3 and 4 of the emplacement
area include:
• Death and/or injury of Broad-headed Snakes due to the disturbance and removal of known
and potential habitat for this species;
• Direct loss of habitat such as hollow-bearing trees, hollow logs and exposed sandstone rocky
outcrops;
• Increased predation due to loss of sheltering habitat;
• Relocation of individuals during habitat translocation;
• Direct road-kill mortality by construction vehicles (although unlikely due to nocturnal nature of
Broad-headed Snake); and
• Creation of artificial barriers to movement (eg, Isolation of rock outcrops from adjacent hollow-
bearing trees to the extent that snakes can no long move between these two critical
resources).
2.4.2 Indirect Impacts
Potential indirect impacts that may result from the active emplacement within Stages 3 and 4 of the
emplacement area include:
• Loss of prey habitat and hence prey availability leading to starvation and reduced recruitment;
• Reduction in genetic diversity within the regional population due to a reduction or loss of the
West Cliff population, or to disrupted capacity for the species to move within and through
Stages 3 and 4 of the Emplacement Area; and
• Reduction in quality of surrounding habitat due to noise and dust from the proposal.
2.5 Management Strategies
Clearing practises will incorporate appropriate controls to minimise mortality and injury to Broad-
headed Snakes occupying the site. These are summarised in the following sections.
2.5.1 Pre-clearance Surveys
Prior to the first stage of clearing, the area to be cleared will be marked using flagging and surveyed
by an ecologist or suitably trained site environmental representative to locate record and mark specific
habitat features that are proposed for preservation and redistribution to the emplacement (e.g. rocks
and boulders, stags and large hollows).
The pre-clearing surveys (relating to the Stage 3 coal wash emplacement operations) that have been
undertaken to date are summarised in Table 2-1.
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Table 2-1Summary of the Pre-clearing surveys that have been undertaken in relation to clearing
of vegetation for coal wash emplacement operations in Stage 3
1
Area in ha Purpose of clearing Report Reference
6.5 Coal wash emplacement Niche, 2011
0.4 Coal wash emplacement Niche 2012
0.25 Slurry pond Illawarra Coal, 2013
Monitoring of Broad-headed Snake individuals and translocated habitat has not yet been required as
neither the animal nor significant habitat for the species has been disturbed as part of the Stage 3
emplacement area.
2.5.2 Two-stage Clearing
The primary mitigating measure for protection of Broad-headed Snakes within the West Cliff
Emplacement Area is two-stage clearing.
Where possible, (i.e. where access to trees by the excavator is safe and practical), clearing of hollow
bearing trees will be performed in a two stage process where surrounding vegetation is cleared
separately, before the removal of habitat trees to allow fauna an opportunity to move.
The process is summarised below (from Niche, 2011):
Site Operator or Clearance Contractor
• Clear all vegetation not marked during the pre-clearance survey (stage1) and engage an
ecologist or suitably qualified site environmental representative to undertake stag watching
and spotlighting prior to stage 2 clearing
• Following a 48 hour grace period, clear all remaining habitat trees (stage 2).
Note: during both stages 1 and stage 2, engage the ecologist or suitably trained site
environmental representative to implement fauna recovery procedures (detailed below) as
necessary.
• If any habitat tree is found or suspected (based on fresh tree markings or scats) to contain any
threatened species during the clearing operation, leave the tree in place for a minimum of 24
hours and, if possible, re-inspect prior to felling.
• In the presence of the ecologist - mechanically shake or agitate habitat trees prior to felling to
encourage any remaining animals to either leave the tree or at least show themselves and
possibly be removed (including the removal of the tree hollow), where possible.
• Following stage 2 clearing hollow-bearing limbs from trees which have been felled should be
removed using chainsaws and take to predetermined locations (Section 2.5.4)
1
Table includes areas cleared for Stage 3 under the Broad-headed Snake Management Plan that was
developed in 2007 for the Dendrobium 2001/214 EPBC Approval Condition 5 (Version 1 of this plan).
Future clearing activities in Stage 3 and Stage 4 will be undertaken in accordance with Version 3
(current version).
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• Keep on-site at all times the contact details of the project ecologist or site environmental
representative, veterinary care and local animal welfare groups (e.g. WIRES, the Native
Animal Trust Fund).
Ecologist or Suitably Trained Site Environmental Representative
• The ecologist or suitably trained site environmental representative will typically identify all
potential fauna habitat that should be retained (where safe and practical) prior to the first stage
of clearing (Section 2.5.1). They will attend the site, inspect habitat features (such as hollows
and rock outcrops) and map and flag features to be retained until stage two of the clearing
regime. A map showing the location of all features to be retained will be supplied to the
clearance contractors prior to the first stage of vegetation clearing.
• Prior to the second stage of clearing, the ecologist will Identify capture and release areas for
fauna which may be captured during the vegetation clearing process.
• The ecologist or suitably trained site environmental representative will also be engaged to
undertake a dusk and dawn stag watching exercise and also a spotlighting survey of the
habitat trees retained in the first stage of clearing so that any hollows observed to be occupied
or used can be identified. These hollows will be afforded special attention during the second
stage of clearing as they are most likely to contain fauna which may be injured during the
clearing exercise.
• Immediately following the second stage of clearing the ecologist or suitably trained site
environmental representative will systematically check all felled habitat trees for any remaining
fauna. Hollows in felled habitat trees potentially supporting fauna and where there may be a
risk of injury to fauna must be left on the ground for at least 24 hours and rechecked for the
presence of fauna prior to processing/removal or placed on the edge of adjoining habitat. The
ecologist or suitably trained site environmental representative will keep equipment for fauna
rescue available for use at short notice in the site vehicle.
• The ecologist or suitably trained site environmental representative will relocate all uninjured
animals that are rescued to suitable predetermined locations within adjoining bushland.
Captured animals will be released immediately or held for the shortest time possible
(preferably less than 24 hours).
• Nocturnal animals captured in the clearing process will be released at dusk. If an animal is
reluctant to move away, then it shouldn’t be released and the ecologist or suitably trained site
environmental representative shall take responsibility for contacting a fauna welfare group or
veterinarian and will deliver the animals to that group.
• Any animals kept for any purpose should be secured in a cloth bag, stored with an appropriate
material (woollen cloth) for warmth and placed in an appropriate nonsealed container until its
release or for transport to an approved carer. Species such as reptiles known for their ability to
escape poorly secured cloth bags, and possums and particularly Koalas, should be placed
within double lined canvas bags.
• The ecologist or suitably trained site environmental representative will prepare a record
detailing the findings of the survey and relocation efforts. This should include details of: Any
live animals that are sighted, captured, released, injured, shocked, escape or killed as a result
of clearing operations and fauna rescue. Tree species being used for breeding or roosting by
fauna, including tree locations, sizes, heights and depths of hollows.
Fauna will be relocated within suitable habitats that are within the West Cliff Mining Lease area. On
this basis, no licensing is required for fauna relocation. If, however, animals are relocated further
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afield, say beyond 1 km of the site or outside a species normal home-range, this is likely to trigger
OEH license requirements.
Any translocation proposal may require referral to the department administering the Environment
Protection and Biodiversity Conservation Act 1999 for any species listed under the Act.
It should be recognised that the above control measures will not always be possible to implement
safely, given the presence of uneven ground and structurally unsound trees.
The general practice of dealing with injured or captured fauna will be for the site operators to notify the
the ecologist or site environmental representative who will arrange for fauna rescue or veterinary
treatment. If the ecologist or site environmental representative is not present when an injured or
juvenile animal is found, the following steps will be implemented:
• Contact ecologist or site environmental representative who will advise how to best manage the
injured or captured animal
In the event that the ecologist or site environmental representative is not contactable:
• Cover animal with a towel or blanket to minimise stress and place in an appropriate hessian or
cloth bag.
• Move animal to designated holding area.
• Contact the local animal welfare group or veterinarian immediately.
2.5.3 Management of captured Broad-headed Snakes
In the event that an individual is found during the two-stage clearing process, the following process will
be followed (listed by order of preference):
1. The individual will be salvaged and transferred to a Captive Breeding Program
BHPBIC is currently investigating options for a Captive Breeding Program through a zoo or affiliated
institution.
2. If no suitable captive breeding program is available, any individuals found will be relocated to
pre-determined suitable habitat within the West Cliff surface mining lease area (Figure 5).
Pre-determined sites for relocation will need to take into account the species home ranges and be
evenly spaced to avoid social conflict. Ideally, predetermined relocation sites should not be inhabited
by another Broad-headed snake at the time of relocation.
Pre-determined relocation sites will necessarily consist of the following:
• Occur on Hawkesbury Sandstone within the current known range of the species and provide
rocky outcrops with a westerly or north-westerly aspect, and horizontal crevices (Webb and
Shine 1998c);
• Have large adjacent areas of woodland that support large stags or trees bearing numerous
hollows (Webb and Shine 1997b). The adjacent woodland will ideally be larger than the area
supporting rocky outcrops (Webb and Shine 1997a) and contain preferred species of ‘habitat
trees’ (trees most often selected by Broad-headed Snakes) such as Eucalyptus gummifera, E.
punctata, E. agglomerata and E. pipperita (Webb and Shine 1997b);
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• A population of the Velvet Gecko must be present (Webb and Shine 2000) and supported by
suitable habitat e.g. loose rock on rock substrate (Webb and Shine 1998c); and
• ‘Habitat trees’ should occur at approximately 5 per hectare, be evenly spaced, and be located
both on plateaus and below cliff lines (Webb and Shine 1997b).
Broad-headed Snakes exhibit strong site fidelity (Webb and Shine 1997a) and therefore may not take
to the new habitat in which they are relocated. Furthermore, the presence of another adult Broad-
headed Snake may lead to home range overlap and hence competition for resources. Therefore, any
Broad-headed Snake(s) collected from within the emplacement area and relocated elsewhere will be
monitored to observe success (see Section 2.5.7).
Consideration should be given to either the modification of currently unsuitable habitat to make it
suitable (removal of overgrowth) or the construction of suitable habitat within the mine rehabilitation
sites, noting the very specific requirements to make a site suitable for this species.
Any other fauna located within the emplacement area during the pre-clearing survey will also be
relocated. In particular, any Velvet Geckos (and other lizards) encountered will be relocated to the
same pre-determined sites for Broad-headed Snakes to provide prey for the relocated snakes.
Prior to any relocation of the Broad-headed Snake and other fauna off the West Cliff lease site or
more than 1km from the location it is found, an appropriate permit under provisions of the NSW
National Parks and Wildlife Act 1974 will be required to be issued by OEH.
In addition to the above, the following relocation actions will ideally be followed for any Broad-headed
Snakes salvaged:
• Suitable sites for snake (and other fauna) translocation will be determined by a suitably
qualified ecologist or wildlife specialist;
• Where possible, snakes will be translocated from the initial capture point to the nearest site
considered suitable for the long-term habitation by the species, but not more than 1 km from
that point (where possible) to reduce the possibility for unfavourable genetic mixing; and
• Snakes will be released at sites as soon as practicable after capture.
2.5.4 Monitoring of Relocated Snakes
Post-clearing management and monitoring will be undertaken in consultation with a suitably qualified
ecologist or suitably trained site environmental representative. Monitoring will target any relocated
Broad-headed Snakes in translocated habitats during the following periods:
• Two days during winter to target rocky outcrops;
• Three days during summer to target woodland with hollow-bearing trees as well as deeper
rock crevices.
The use of an endoscope to inspect tree hollows would be useful, but arrangements would be required
to access large hollows in large trees and this may be difficult under workplace health and safety
considerations. The aim of the monitoring is to determine, as far as is possible, if translocated snakes
remain and survive at the selected translocation sites and to provide an ongoing assessment of the
status of the local population of the Broad-headed Snake.
Monitoring will be undertaken in a sensitive manner as the movement of rocks can break them or,
“seal” around the edges that provides specific microclimates used under rocks. The breaking or
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moving of rocks can result in them becoming immediately unsuitably for further use and reduce an
already limited resource. The use of properly constructed artificial rocks may alleviate this issue.
Snakes that are translocated to new sites may move immediately in an attempt to return to their
previous home ranges or to a new location that they may consider more suitable. Such movements
will lead to an unknown loss of snakes from the study and their long-term fate unknown.
Monitoring surveys in winter targeting rocky outcrops will ideally be conducted during the day (to
identify basking snakes) and at dusk (when the snakes are most active) (Webb and Shine 1997b).
2.5.5 Habitat Translocation
Winter Habitat
Rocky outcrops, crevices, caves and overhangs provide winter habitat for the Broad-headed Snake
(Goldingay and Newell 2000). Suitable winter habitat occurring within the Stages 3 and 4 of the
Emplacement Area will be identified during the pre-clearing survey. Details on the rocks to be
removed will be recorded to ensure that similar types and levels of rock habitat are made available at
the new site, noting the highly specific requirements for crevices in terms of needing rock on rock
crevices of the right sized and right aspect.
Great care will need to be taken when translocating rocky outcrops as gravid females and offspring
may be present even in summer. A qualified ecologist or suitably trained site Environmental
Representative will be present on site prior to clearing to check sites suitable crevices and be
available to care for any injured snakes or to relocate unharmed individuals.
Rehabilitation of the Emplacement area behind the line of clearing for the Broad-headed Snake, in
terms of winter habitat, will include the following:
• Translocated rocky outcrops and boulders will ideally be positioned with a westerly or north-
westerly aspect and crevices should remain horizontal (Webb and Shine 1998c);
• The Velvet Gecko should also be translocated (Webb and Shine 2000). Suitable habitat for
this prey species is the same as for the Broad-headed Snake’s winter habitat and includes
loose rock on rock substrate (Shine et al. 1998, Webb and Shine 1998c);
• The above shelter sites will ideally be evenly spaced and not clumped together to encourage a
greater number of Broad-headed Snakes to the area (Webb and Shine 1997a). If shelter sites
are too close together, they are likely to remain uninhabited due to home range overlap.
Shelter sites will ideally be placed at least 300 m apart and close/adjacent to suitable summer
habitat (translocated hollow-bearing trees or limbs within rehabilitating sections of the old
Emplacement areas; Webb and Shine 1997a);
• Artificial rocks/concrete pavers will be added to the Emplacement area behind the line of
clearing to increase habitat opportunities for prey items and the Broad-headed Snake if
insufficient natural rock cannot be sourced from the Emplacement Area for this purpose. A
qualified ecologist will determine if natural rock to be translocated is sufficient. Webb and
Shine (2000) recommend the use of large pavers (30 – 45 cm wide and 5 – 10 cm thick), as
well as a range of smaller pavers (e.g. 19 cm wide) and thicker pavers (e.g. > 30 cm thick)
placed with a variety of crevice sizes (up to 10 mm). The artificial rocks will be placed in both
shaded and exposed areas to provide a range of suitable micro-climates for the snake and its
prey depending on the time of year. Furthermore, artificial rocks (and translocated rocks) will
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be placed on rocky substrate (not on soil) as Velvet Geckos actively select these rocks due to
specific temperature requirements (Webb and Shine 1998c). Where possible, specifically
constructed artificial rock should be used to provide crevices of the exact size and shape and
rock thickness preferred by the Broad-headed Snake (Croak et al 2011). These concrete
rocks can be molded to provide an exact fit as would occur with naturally exfoliating rock. The
dispersion of artificial rocks (and translocated rocks) will vary to take into account social
interactions between reptiles (Webb and Shine 2000). Advantages of using concrete pavers
as artificial rocks include: they are inexpensive, long-lasting and unlikely to be attractive to
rock-thieves (Webb and Shine 2000); and
• Hollow logs will also be translocated to provide additional retreat-sites for the Broad-headed
Snake and its prey (Webb and Shine 1997b).
Summer habitat (hollow-bearing trees/limbs)
Woodland, supporting hollow stags and hollow-bearing trees, provides summer habitat for the Broad-
headed Snake (Webb and Shine 1997b). Suitable summer habitat occurring within the Stages 3 and 4
of the Emplacement Area will be identified during the pre-clearing survey.
Felled hollow-bearing trees will be left alone for a short period of time to allow fauna to escape and/or
be relocated and the hollows inspected prior to the tree being removed from the site. A qualified
ecologist or suitably trained site Environmental Representative will be contacted to care for any injured
snakes or to relocate unharmed individuals.
Rehabilitation of the Emplacement area behind the line of clearing for the Broad-headed Snake, in
terms of summer habitat, will include the following:
• Large stags (standing dead trees containing hollows) (Webb and Shine 1997b) will be
translocated to the Emplacement area behind the line of clearing, where possible. Stags are
actively selected by Broad-headed Snakes and are a favoured summer habitat resource
(Webb and Shine 1997b).
• The preferred live habitat trees of the Broad-headed Snake that occur within the Emplacement
area include (in order of likely preference): Eucalyptus gummifera, E. punctata, E.
agglomerata, E. piperita and E. sieberi (Webb and Shine 1997b). Large, hollow-bearing trees
(with stem hollows and hollow branches) of these species will also be considered for
translocation to the Emplacement area behind the line of clearing, where possible. Due to the
large number of hollow-bearing trees within the emplacement area, it is not anticipated that
even a small proportion of these trees would be translocated. Hollow-bearing stags will be
used in preference to living hollow bearing trees during the rehabilitation of the emplacement
area.
• Where translocation of entire live or dead trees is not possible, hollow-bearing limbs and/or
trunks will be translocated on to trees in surrounding habitat or on to erected on poles within
the emplacement area. Hollow branches must be erected in a horizontal position to help
facilitate behavioural thermo-regulation (Webb and Shine 1997b). Branches of various lengths
and hollows of various sizes will be translocated.
• Summer habitat will be translocated adjacent to winter habitat and be evenly spaced. Webb
and Shine (1997b) suggest 5 habitat trees should be translocated per hectare. Translocated
summer habitat and/or adjacent existing woodland should be larger than the area supporting
rocky outcrops (Webb and Shine 1997a). Where possible habitat trees will be translocated to
both plateau areas and areas below cliff lines (Webb and Shine 1997b); and,
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• To ensure summer prey (e.g. small arboreal mammals) is available, translocated habitat must
be suitable for such prey items as well. Suitable habitat for summer prey species is the same
as for the Broad-headed Snake’s summer habitat (i.e. tree hollows), although other habitat
features required for prey items should be translocated as well. For example, hollow logs,
shrubs and dense leaf litter could provide potential habitat for Antechinus spp. and skinks.
Banksias should be translocated where possible to provide habitat for the Eastern Pygmy
Possum Cercartetus nanus.
2.5.6 Habitat Protection during Construction
In addition to the actions provided in the above sections, the following practices will be adopted during
construction:
• Best practice sediment control measures will be adopted during clearing, as outlined in the
West Cliff Coal Wash Emplacement Area Management Plan;
• The emplacement area will be clearly demarcated and regularly surveyed to prevent
unnecessary clearing or access by construction vehicles and plant to surrounding potential
habitat;
• Construction materials and spoil must not be stored, dumped or stockpiled within surrounding
habitat; and
• Induction of the Emplacement Area Supervisory personnel will include information about the
Broad-headed Snake and its habitat within the Stages 3 and 4 of the Emplacement Area,
along with protection measures that will be in place and enforced during the construction
period;
• Inclusion of general information on threatened species (including key Site contacts for
threatened species) for all West Cliff Emplacement personnel.
2.5.7 Timing and Seasonality of Actions
The Broad-headed Snake uses rocky outcrops through most of the year; and woodland with hollow-
bearing trees in summer, although gravid females and juveniles may use the outcrops year-round.
Vegetation clearing should be targeted to occur between January and May to avoid the primary
breeding and nesting periods of most hollow-dwelling species, where possible (Niche, 2011).
Management actions provided in this plan may need to change in light of new information, or if
measures for the long term maintenance of the Broad-headed Snake population are found to be
inadequate. Any material change to the proposed management and monitoring program will be
undertaken in consultation with appropriate regulatory authorities.
2.6 Summary of Impact Minimisation Measures
Measures to minimise impacts of the Project (Stage 3 and 4 emplacement areas) on the local
population of the Broad-headed Snake are outlined in Table 3.
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Table 2-2: Impact minimisation measures for the protection of the Broad-headed Snake at West Cliff
No. Performance Objective Performance Target Management/Mitigation Measures Monitoring & Reporting Methods
1.1 Protection of Hoplocephalus - Minimise loss of - Conduct pre-clearance surveys in the Stage 3 and 4 - Document by preparation of pre-
bungaroides within the Hoplocephalus emplacement areas (Section 2.5.1) and subsequent clearing survey reports for every
approved emplacement and bungaroides individuals two-stage clearing (Section 2.5.2), to give animals emplacement phase cleared including
development footprints within the approved the opportunity to move away. use of GIS coordinates for survey
emplacement footprints results.
due to construction and - Salvage and transfer captured individuals to a
operations. captive breeding program (either a Zoo or affiliated - Success of captive breeding programs
institution). If this is not possible, individuals found to be reported in Annual
will be relocated to pre-determined suitable habitat Environmental Management Report
within the West Cliff surface mining lease area. (Annual Review).
- Vegetation clearing will be targeted to occur between - Document numbers of individuals
January and May to avoid the primary breeding and trapped and released. Observation of
nesting periods of most local hollow-dwelling animal condition. Record release
species. location.
- Monitoring of relocated individuals.
Results from monitoring of relocated
individuals will be provided in the
Annual Environmental Management
Report (Annual Review).
1.2 Re-establishment of suitable - Establishment of suitable - Placement of hollow logs and rock outcrop elements - Permanent photographic points within
habitat on completed and rocky and woodland of habitat for the Broad-headed Snake in translocated compartments
rehabilitating emplacement habitat components to rehabilitated areas.
areas support Hoplocephalus - Annual Emplacement Rehabilitation
bungaroides individuals - Installation of artificial habitat (eg concrete paving Inspection program undertaken
within 5 years of
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No. Performance Objective Performance Target Management/Mitigation Measures Monitoring & Reporting Methods
commencement of slabs) if necessary as per Webb and Shine (2000). - Reports from the annual monitoring
rehabilitation. program to be attached to the Bulli
Seam Annual Environmental
Management Report (Annual Review).
- Broad-headed Snake surveys in
installed artificial habitat areas (where
applicable)
1.3 Monitoring and Reporting - Annual monitoring report - Reporting of project to DoE and other stakeholders - All monitoring referred to above (i.e.
undertaken and submitted as submitted and pre-clearing surveys, capture and
scheduled Management Plan review - Annual review of monitoring and management transfer of animals, implementation of
each year (within 3 months two-stage clearing, success of
of the 12 month - Adjustments made to systems and methods as translocation efforts, progress in
anniversary of the approval required rehabilitation of emplacement sites,
(15 May 2012) as per success of captive breeding
EPBC Approval Condition programs).
14.
- Annual compliance report to DoE.
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3 PROVISION OF REGIONAL FUNDING
3.1 Provision of Funding
This section addresses Condition 7(b) of the EPBC Approval as follows:
(b) provisions for the contribution of no less than $250,000 (GST exclusive) in funding towards
regional Southern Brown Bandicoot and Broad-headed Snake programs. This funding must not be
expended on the measures referred to in condition 7a;
BHPBIC are committing to funding $250,000 towards the regional management of the Southern Brown
Bandicoot and Broad Headed Snake programs as outlined in this Plan (Attachment B).
It is proposed that the project be scheduled over three years commencing July 2014 and finishing
June 2017 with payments scheduled as follows:
• Year 1 $85,000 July 2014
• Year 2 $85,000 July 2015
• Year 3 $80,000 July 2016.
3.2 Actions to be Funded
Illawarra Coal has been consulting with the Office of Environment and Heritage (local and threatened
species unit) regarding EPBC Act Approval Conditions 7(b) to (e) since November 2012.
(c) a description of actions to be funded and undertaken to inform and/or enhance the conservation of
these species, including through survey or research, threat abatement with specific reference to
predator controls and habitat restoration or rehabilitation, including public reporting or publication of
information gained by these actions;
The Office of Environment and Heritage (OEH) has developed a Project Proposal to be funded by
BHPBIC, which addresses points (c) to (f) of the EPBC Act Approval Condition 7.
The OEH letter and Project Proposal is included in this Plan as Attachment B.
3.3 Impacts on Other EPBC Act Listed Species
This Section addresses Condition 7(d) of the EPBC Approval for works conducted by OEH as follows:
(d) a demonstration that management actions to be undertaken will not adversely impact EPBC Act
listed species;
The OEH Proposal addresses the above requirement (see section titled Consideration of Impacts of
the Project).
3.4 Funding Arrangements
This Section addresses Condition 7(e) of the EPBC Approval as follows:
(e) a description of funding arrangements or agreements including work programs and responsible
entities.
OEH has provided a Project Proposal for the Broad headed snake and Southern Brown bandicoot
Recovery Actions (see Attachment B).
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In-line with internal policy, BHPB IC will provide the funding through a Non-order Invoice (NOI). OEH
will provide BHPB IC with three separate invoices, prior to the start of each year i.e. year 1, year 2 and
year 3.
3.5 Documentary Evidence of Funding
This Section addresses Condition 7(f) of the EPBC Approval as follows
(f) measures for the provision of documentary evidence within 30 days of the funding having been
expended and/or that funding commitments have been met.
BHPBIC commit to providing DoE with satisfactory documentary evidence within 30 days of the date
that funding for this Plan has been expended and/or that funding commitments have been met.
This does not include funding related to ongoing management and monitoring actions outlined in
Section 2 aimed to minimise impacts from emplacement operations.
Details of the completed funded projects, relevant results and any recommended or adopted ongoing
actions pursuant to the project results will be included in the Annual Environmental Management
Report (AEMR).
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4 REFERENCES
Biosis Research. 2001.Dendrobium Coal Project Species Impact Statement.
Brennan, K.E.C., Nichols, O.G. & Majer, J.D. 2005, Innovative techniques for promoting fauna return
to rehabilitated sites following mining, Australian Centre for Minerals Extension and Research
(ACMER) and Minerals and Energy Research Institute of Western Australia (MERIWA), Brisbane
(ACMER) & Perth (MERIWA).Cogger, H.G. (2000). Reptiles and Amphibians of Australia - 6th edition.
Sydney, NSW: Reed New Holland.
Croak, B.M., D.A. Pike, J.K. Webb, and R. Shine. 2008. Three-dimensional crevice structure beneath
rocks influences retreat site selection by nocturnal reptiles. Animal Behaviour 76:1875-1884.
Croak, B.M., D.A. Pike, J.K. Webb, and R. Shine. 2010. Using artificial rocks to restore nonrenewable
shelter sites in human-degraded systems: colonization by fauna. Restoration Ecology 18:428-438.
Downes, S. (1999). Prey odour influences retreat-site selection by naive Broad-headed Snakes
(Hoplocephalus bungaroides). Journal of Herpetology. 33:156-159.
Dubey, S., Sumner, J., Pike, D. A., Keogh, J. S., Webb, J. K. and Shine, R. (2011), Genetic
Connectivity among Populations of an Endangered Snake Species from Southeastern Australia
(Hoplocephalus bungaroides, Elapidae). Ecology and Evolution, 1: 218–227.
Goldingay, R.L. & D.A. Newell (2000). Experimental rock outcrops reveal continuing habitat
disturbance for an endangered Australian snake. Conservation Biology. 14 (6):1908-1912.
Illawarra Coal (2013). Pre-clearing Ecological Surveys Stage 3 Slurry Pond Constructions. Internal
Report prepared by Illawarra Coal.
Niche (2011). Pre-clearance Surveys - Stage 3 Coal Wash Emplacement Area. Report prepared for
Illawarra Coal.
Niche (2012). Pre-clearance Surveys - Stage 3 Coal Wash Emplacement Area. Report prepared for
Illawarra Coal.
Pringle, R.M., J.K. Webb & R. Shine (2003). Canopy structure, microclimate, and habitat selection by
a nocturnal snake, Hoplocephalus bungaroides. Ecology. 84(10):2668-2679.
Shine, R., J.K. Webb, M. Fitzgerald & J. Sumner (1998). The impact of bush-rock removal on an
endangered snake species, Hoplocephalus bungaroides (Serpentes: Elapidae). Wildlife Research.
25:285-295.
Webb, J., D. Pike & R. Shine (2008). Population ecology of the velvet gecko, Oedura lesueurii in south
eastern Australia: Implications for the persistence of an endangered snake. Austral Ecology. 33
(7):839-847.
Webb, J.K. & R. Shine (1994). Habitat use by the broad-headed snake, Hoplocephalus bungaroides.
Page(s) 7-24. NSW NPWS. NSW NPWS, Sydney.
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