Appendix H: Herpetofauna Management Plan

Appendix H: Herpetofauna Management Plan HERPETOFAUNA MANAGEMENT PLAN July 2014 The Assessment of Ecological Effects (AEcE) report prepared for the ...
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Appendix H: Herpetofauna Management Plan

HERPETOFAUNA MANAGEMENT PLAN July 2014 The Assessment of Ecological Effects (AEcE) report prepared for the proposed Oneroa Beachfront Cycle and Walkway identified the presence of native common skinks (Oligosoma polychroma) at several locations within the project footprint. In order to effectively avoid and/or mitigate adverse effects on the skink populations which may arise as a result of earthworks and vegetation clearance in association with the project, the AEcE report recommended the implementation of a Herpetofauna Management Plan (HMP). An HMP will ensure any potential adverse effects are adequately avoided, remedied and mitigated primarily through relocation operations from the project footprint prior to, and during the commencement of works. HMPs utilising the methodology outlined here have been successfully implemented in similar situations elsewhere in New Zealand. The following sections detail ecological management actions which will address the actual and potential adverse ecological effects (and the likely requirements of resource consent(s)) identified by the AEcE report. The mitigation proposed for native lizards will involve capture of individuals which are residing within the works footprint, and subsequent relocation to suitable habitats outside of the impacted areas. The lizard capture-relocation operation will be supervised by an experienced herpetologist holding a current DOC permit for the handling of protected native lizards. The capture methodology will employ techniques targeted to cover the species likely to be present in addition to those already confirmed on site. The implementation of the HMP presented here will be timed so that capture events are coordinated to occur during optimal conditions. Specifically, outside the winter months during favourable weather (calm and precipitation free days/nights). The program will employ staged capture sessions as well as lizard captures during supervised habitat clearance. 1.1

Artificial Cover Objects

The use of Artificial Cover Objects (ACOs) is an effective means to capture native lizards by targeting locations of high quality habitat. ACOs are sheets of Onduline roofing material measuring approximately 0.5m x 0.5m which are strategically placed in locations likely to be utilised by terrestrial herpetofauna. The ACOs are left in place undisturbed for approximately two weeks in order to promote an artificial refuge attractive to lizards. Following the initial installation and settling period, inspecting the ACOs provides an efficient means to capture the herpetofauna which colonise them. The two week establishment phase will be timed such that capture will commence outside of the winter months, at least six weeks before any earthworks and/or vegetation clearance is scheduled to begin. The placement and number of ACOs to be installed as part of the network on site will be determined by an experienced herpetologist. ACOs will be monitored a minimum of six occasions in the time period leading up to the commencement of works, with more frequent checks in the two weeks immediately before. 1.2

Diurnal Habitat Searches

Diurnal habitat searches for lizards involve examining all habitats available, and searching these areas by hand. This generally involves turning over debris during daylight hours under which animals may be sheltering, and capturing any native lizards present. Diurnally active herpetofauna can also be caught during the habitat searches if they are encountered opportunistically, for example while they are basking or foraging. At least three full days of habitat searches will be performed within the two weeks leading up to commencement of site works.

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Nocturnal Spotlight Searches

Searching for active lizards via spotlighting habitat is an established technique for monitoring herpetofauna naturally cryptic during daytime hours. Several species of native lizards are much more conspicuous under a high powered artificial light-source following nightfall when compared to natural daylight. Spotlights and headlamps of a suitable brightness will be used to search for and capture lizards in the canopy of plants, foliage, on stems and branches, and at ground level. At least two nights of searches will be performed within the two weeks leading up to site works. 1.4

Supervised Habitat Clearance

Lizards will be effectively captured in conjunction with vegetation clearance where appropriate. This involves cooperation and coordination with works contractors, and requires an experienced herpetologist on site during the habitat clearance and removal. In certain cases, for example where dense vegetation is present or debris are too large for a searcher to move unaided, the use of machinery may be the only viable option to remove resident lizards. During the works, any herpetofauna revealed will be captured and relocated away from the impacted area. Areas where potential lizard habitat is scheduled to be removed will be searched prior to works commencing, as well as during and immediately after vegetation clearance. Herpetofauna responses to disturbance are difficult to predict therefore it is vital that contractors liaise closely with the project herpetologist to maximise numbers of animals relocated. 1.5

Release Site Selection and Enhancement

All native herpetofauna captured from within the works footprint will be relocated to areas of suitable habitat outside of the impacted site. Release sites will be selected by the project herpetologist based on requirements of the species captured. Release sites will be primarily identified by matching habitat present where individuals are captured, with animals preferentially released into the largest patches of vegetation on site which will be retained and enhanced. Quality of release habitat will be the highest available on site, and will be increased where deemed necessary by the project herpetologist. This may involve planting vegetation favourable for herpetofauna, and providing artificial refuges by using log disks or driftwood harvested from beach grooming activities. Habitat availability in relation to quality and associated stocking density will be considered by the project herpetologist when selecting release sites. Release sites will be monitored for three years by an experienced ecologist following the relocation of the captured herpetofauna. Pest control will also be implemented within the same timeframe by installing a minimum of one bait station at each release site for the control of rats. Brodifacoum baits will be used in bait stations accessible to rodents. Bait will be replenished once every season for the three year monitoring period.

Appendix I: Ecological Assessment and Supplementray Commentary

PROPOSED BEACHFRONT CYCLE AND WALKWAY – GREY STREET TO MIDWAY SURF CLUB, GISBORNE Assessment of Ecological Effects For Gisborne District Council June 2014

REPORT INFORMATION AND QUALITY CONTROL Prepared for:

Kylie Cranston Projects and Development Team (Engineering and Works Department) Gisborne District Council

Date:

June 2014

Document File Name:

Gisborne Boardwalk: Assessment of Ecological Effects

Author:

Rachel Turner Consultant Ecologist

Reviewer:

Rebecca Harrison Senior Environmental Planner

Approved for Release:

Simon Chapman Ecological Services Manager

Version History:

Final

Version:

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CONTENTS 1 2

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4 5 6

Page

INTRODUCTION ............................................................................................................................................. 1 METHODOLOGY ............................................................................................................................................ 1 2.1 Vegetation ............................................................................................................................................ 1 2.2 Avifauna................................................................................................................................................ 2 2.3 Herpetofauna ........................................................................................................................................ 2 RESULTS ........................................................................................................................................................ 2 3.1 Vegetation ............................................................................................................................................ 2 3.2 Avifauna................................................................................................................................................ 4 3.3 Herpetofauna ........................................................................................................................................ 5 3.4 Other Terrestrial Fauna ........................................................................................................................ 5 ASSESSMENT OF ECOLOGICAL EFFECTS ................................................................................................ 6 RECOMMENDATIONS ................................................................................................................................... 7 REFERENCES ................................................................................................................................................ 7

List of Tables Table 1. Avifauna species recorded at Midway-Waikanae Beach on 26 February 2014 ......................................... 4

List of Figures Figure 1. Site map depicting extent of ecological habitat assessed (red line). ......................................................... 1 Figure 2. High densities of tolerant exotics have limited native ecotones of the dune environment (left) and encouraged foot traffic through the dunes (right). ........................................................................................... 3 Figure 3. Human traffic through the dunes has negatively impacted native species and hindered regeneration ..... 3 Figure 4. Recent invasions (left) and planted exotics (right) should be eradicated .................................................. 4 Figure 5. Dead Australasian gannet found in the back dunes (leftt); Southern black backed gull (right). ................ 4 Figure 6. Adult common skink .................................................................................................................................. 5 Figure 7. Beach grooming activities (left), are supporting significant colonies of false katipo spiders (right) ........... 6 Figure 8. Native terrestrial invertebrates present include lax beetle (left) and seashore earwig (right) .................... 6

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INTRODUCTION

The Projects and Development Team (Engineering and Works Department), Gisborne District Council, is currently in the process of determining the best possible alignment for the construction of a proposed 3 metre wide combined walkwaycycleway (walkway) within the Midway Beach reserve area. It is understood that the proposed walkway will extend from the beach end of Grey Street to the Midway Surf Club and will be constructed predominantly from timber with possible paved areas. This ecological assessment has been prepared at the request of the Projects and Development Team and will contribute to the alignment selection process. The purpose of this ecological assessment is to describe the existing ecological values of the area between Grey Street and the Midway Surf Club (Figure 1), with a view to identify ecological values and the potential ecological effects of a walkway in this area. Recommendations will also be made regarding appropriate measures to avoid, minimise, mitigate and/or offset any potentially significant adverse ecological effects.

Figure 1. Site map depicting extent of ecological habitat assessed (red line).

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METHODOLOGY

2.1 Vegetation Terrestrial vegetation was surveyed on 26 February 2014 as part of a 4-hour site visit, following an initial desktop assessment using high quality aerial imagery and draft design drawings. During the site visit, native and exotic plant species and communities were recorded, and a qualitative assessment of vegetation habitats was carried out. The assessment included areas of vegetation on site most likely be impacted by the proposed works, focusing on the botanical and ecological value of identified plant species and communities.

Ecological Assessment - Beachfront Walkway Gisborne

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2.2 Avifauna Bird populations on site were surveyed through 5 minute bird counts and incidental observations during a 4-hour site visit undertaken on 26 February 2014. In addition, vegetation present within the development footprint was also assessed in relation to habitat provision for avifauna.

2.3 Herpetofauna Herpetofauna populations were surveyed by way of targeted habitat searches during the 4-hour site visit conducted on 26 February 2014. Habitat searches involve inspecting areas of the site likely to be utilised by native lizards for sheltering or foraging. Examples of lizard retreats include beneath dense vegetation, logs and driftwood. Lizards also frequently utilise discarded building materials such as timber and corrugated iron, as well as dumped garden waste. Foraging or basking lizards tend to utilise open areas adjacent to suitable shelter. All lizards encountered were identified and allowed to return to the refuge they had been occupying. Vegetation was also assessed by a qualified ecologist with regard to habitat quality for arboreal and nocturnal lizard species.

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RESULTS

3.1 Vegetation The plant community on site is best described as mixed native-exotic dune vegetation, buffered on the landward side by mown amenity grassland. The native component of the dune vegetation includes high densities of Spinifex sericeus in the fore dune environment throughout the site, and a small patch of pingao (Ficinia spiralis; At Risk: Declining) near the Midway Surf Club. The back dune environment is largely dominated by invasive exotics including kikuyu (Pennisetum clandestinum), buffalo grass (Stenotaphrum secundatum), harestail (Lagurus ovatus), ice plant (Carpobrotus edulis), hawkweed (Pilosella officinarum), and marram (Ammophila arenaria). Knobby club rush (Ficinia nodosa), a native species characteristic of the back dune environment was present in sparse clumps, although some individual plants were in poor condition. Agapanthus (Agapanthus praecox), naked ladies (Amaryllis belladonna), hybrid cannas (Canna spp.), and a range of garden succulents have been either dumped as garden waste, or intentionally planted within the back dune environment (Figure 4). These garden ornamentals have the ability to thrive in the dune environment and are likely to become problematic if allowed to spread. The inherent character of the back dunes appears to have facilitated relatively unbounded human access and utilisation of the dunes. Many private properties lack fencing between the lot boundaries and the reserve area. This feature, in association with vegetation of the back dunes containing a high component of dense, low-growing and tolerant exotics, appears to have encouraged foot traffic throughout the dunes in multiple areas (Figure 2). Native sand-binding species present in the fore dunes are particularly sensitive to trampling, and this is likely to have limited their range throughout the wider dune environment on site. At several points, informal beach access tracks have dissolved native ecotype boundaries and allowed the encroachment of exotic vegetation into the spinifex colonies of the fore dunes. Similarly, the pingao planting near Midway Surf Club has suffered heavy losses through crushing of the stolons (Figure 3). Areas of plant failure have been rapidly colonised by the hardy kikuyu grass, which provides a secondary negative impact on the plantings through smothering.

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Figure 2. High densities of tolerant exotics have limited native ecotones of the dune environment (left) and encouraged foot traffic through the dunes (right).

Figure 3. Human traffic through the dunes has negatively impacted native species and hindered regeneration

Pampas (Cortaderia selloana and/or C. jubata) and lodgepole pine (Pinus contorta) are present in relatively high densities, especially in the vicinity of Midway Beach, and are likely to be contributing to a significant seed bank. These species are aggressive invaders of areas of low nutrient substrates such as dunelands, displacing native species and modifying substrate structure. Pampas and pine both utilise wind dispersal as a facet of their reproduction, and the exposed coastal environment presents an opportunity for seed and pollen to be carried up to tens of kilometres from the parent plant.

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Figure 4. Recent invasions (left) and planted exotics (right) should be eradicated

Large specimen Norfolk pines are spaced in a linear fashion at regular intervals within the amenity grassland, and several small clusters of karo (Pittosporum crassifolium) are also present in the vicinity of the open space near the Midway Surf Club.

3.2 Avifauna A total of three native and two exotic bird species were observed on site (Table 1). The dune environment provides limited habitat opportunities for coastal avifauna, and high public utilisation of the area is likely to confine avifauna populations to highly mobile species and those more tolerant of repeated disturbance, as indicated by the survey results.

Figure 5. Dead Australasian gannet found in the back dunes (leftt); Southern black backed gull (right).

The avifauna field surveys were not exhaustive in that they were limited to a single day, and did not encompass community variations to be expected during the full tidal cycles and during other seasons. It is possible that other coastal species may roost, breed or feed in the area, although further surveys would be required to confirm this.

Table 1. Avifauna species recorded at Midway-Waikanae Beach on 26 February 2014 Scientific Name Larus dominicanus Larus novaehollandiae Ecological Assessment - Beachfront Walkway Gisborne

Common Name

Threat Status (Robertson et al. 2012)

Southern black backed gull

Not threatened

Red billed gull

Nationally vulnerable 4

Scientific Name Morus serrator Passer domesticus Sturnus vulgaris

Common Name

Threat Status (Robertson et al. 2012)

Australasian gannet

Not threatened

House sparrow

Introduced and naturalised

Starling

Introduced and naturalised

3.3 Herpetofauna The native common skink (Oligosoma polychroma) was confirmed in several locations on site indicating the presence of a breeding population. Whilst this species is not uncommon throughout its range, common skinks, like all native lizards, are an absolutely protected species under the Wildlife Act (1953). These animals are opportunistic in their habits, frequently utilising discarded debris and dumped materials such as timber, corrugated iron and garden waste as refuges. Skinks are also common within weed fields and areas of dense, low growing vegetation. Their habitat requirements make common skink one of the few native lizards able to persist within urban and human-impacted environments.

Figure 6. Adult common skink

The dense and low growing nature of the majority of plants present within this coastal zone offers high quality habitat for lizards. Swaths of rank grasses such as kikuyu, and weed invasions by compact species such as agapanthus and pampas provide good shelter for skinks. In addition, adjacent areas of more sparsely growing vegetation (such as the spinifex dominated areas) offer access to basking habitat. The availability of vegetation types favourable to terrestrial lizards extends throughout the majority of the back dunes on site, and appears to be contiguous with similar habitat further along the beach front. Driftwood and piles of flotsam accumulated in and around the dunes as part of beach grooming activities or natural coastal processes is providing further skink habitat. The net effect is a significant ecological corridor of habitat which provides linkages and connections between populations within the wider coastal environment.

3.4 Other Terrestrial Fauna A dedicated survey for populations of the katipo spider (Latrodectus katipo) was conducted in association with habitat searches for native lizards. No katipo spiders were identified, although there is ample suitable habitat for this species. Large tracts of potential katipo habitat were supporting false katipo spiders (Steatoda capensis), an invasive exotic which displaces the native katipo. It is possible that the history of human impact and modification of the site has taken place in a manner that favours the false katipo. Ecological Assessment - Beachfront Walkway Gisborne

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Figure 7. Beach grooming activities (left), are supporting significant colonies of false katipo spiders (right)

Other notable terrestrial invertebrate species identified include native lax beetle (Thelyphassa spp.), native rove beetle (Staphylinidae) and seashore earwig (Anisolabis littorea). Interestingly the invertebrate fauna present within the highly modified dune environment includes a considerable native component, including several species known to be food resources for katipo spiders.

Figure 8. Native terrestrial invertebrates present include lax beetle (left) and seashore earwig (right)

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ASSESSMENT OF ECOLOGICAL EFFECTS

The highly modified nature of the back dune environment, and subsequently tolerant vegetation present signals that the proposal’s overall impact on the current plant communities is predicted to constitute a minor ecological effect. The vegetation established in the areas likely to be impacted by construction is largely dominated by weed species and exotic ornamentals. As a result, the botanical value of these areas is currently low. In consideration of this, the opportunities presented by the proposed walkway with regard to dune restoration planting would amount to a net ecological improvement. The removal of back dune vegetation in association with construction works would allow for reintroduction planting of native back dune species which have been displaced. This vegetation class is conspicuously absent from the current dune plant community, and the invasive species present on site are difficult to control due to the high rate of reinvasion and competitive superiority over native species in certain habitats. Staged weed control followed by infill planting of bare areas would be the most effective and efficient management strategy, and should be integrated with the construction programme. Following completion of the walkway, the formal access ways associated with the structure will discourage free foot traffic through the dunes. Trampling is currently impacting sensitive foredune species and encouraging more tolerant exotic species. Invasive, hardy species such as kikuyu have already established a strong presence throughout the back dune, and have hindered pingao restoration efforts within the foredune environment where Ecological Assessment - Beachfront Walkway Gisborne

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unrestrained foot traffic is common. Further invasions by kikuyu of the fore dunes are likely if trampling of native species is not discouraged, and supplementary plantings of bare areas created by informal accessways should be considered as part of dune restoration activities. Community identification with the dune environment appears to influence a significant component of the vegetation present within the back dune. Members of the public have actively donated time and resources with an apparent view to improve the value of the site. Such informal activities have included installation of seating, planting of garden ornamentals and establishment of beach access ways. Such investment by members of the general public signifies a sense of identity and connection to the environment, and with minimal expert input and advice, community lead dune restoration projects would likely be possible in association with the boardwalk construction. Appropriate guidance by an ecologist, and support from Council and/or DOC could concomitantly stem the introduction and spread of invasive plants, whilst promoting larger scale restoration of the dune environment. The site is comprised principally of grassed amenity and dune areas. Those habitats are largely suited to introduced bird species, and the loss of the small amount of ground level vegetation as a result of works is not considered to constitute an adverse effect on the avifauna present on site. However, construction-phase noise may have some localised disturbance impacts on birds. Native bird species utilising those environments were identified as being resilient to disturbance and highly mobile. Furthermore, gulls are able to readily habituate to noise and other disturbance events, and have the ability to find alternative habitats nearby. Common skinks were found to be inhabiting the exotic vegetation of the back dune environment, as well as utilising driftwood piles and areas of accumulated debris. The presence on common skinks on site triggers a requirement for appropriate management of herpetofauna to ensure any potential adverse effects on native lizards arising from the proposed development are adequately avoided, remedied and mitigated. Management of native herpetofauna in association with earthworks, vegetation and construction can be effectively guided through the preparation and implementation of a Lizard Management Plan. Any dune restoration works should be designed and implemented with habitat requirements of native lizards in mind.

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RECOMMENDATIONS

The following actions are recommended to ensure that overall adverse effects on the ecological values of the dune and beachfront ecosystem are no more than minor:  

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Manage potential adverse effects on the aquatic communities by implementing sediment and erosion controls in accordance with current best practice industry standards; Avoid and mitigate potential ecological effects on native flora and fauna by: − using light machinery and/or hand tools where possible; − implementing supplementary planting of native vegetation to match that removed at a minimum area ratio of 1:1; − ensuring that any back dune vegetation clearance and weed control to be staged such that cover is replaced with native back dune species; and − relocating endemic lizards from works footprint prior to, and during, the commencement of works by preparing and utilising an appropriate Herpetofauna Management Plan.

REFERENCES

Hitchmough, R., Anderson, P., Barr, B., Monks, J., Lettink, M., Reardon, J., Tocher, M., Whitaker, T. (2013). Conservation status of New Zealand reptiles. New Zealand Threat Classification Series 2. Department of Conservation, Wellington. 16 p. Robertson, H.A., Dowding, J.E., Elliott, G.P., Hitchmough, R.A., Miskelly, C.M., O’Donell, C.F.J., Powlesland, R.G., Sagar, P.M., Scofield, R.P. & Taylor, G.A. (2013). Conservation Status of New Zealand Birds. New Zealand Threat Classification Series 4. Department of Conservation, Wellington. 22 p.

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Appendix A:

Andrew.Stewart Limited PO Box 911310 Victoria Street West Auckland 1142 Telephone 09 303 0311

14 July 2014 Rebecca Harrison Senior Planner Andrew Stewart Limited 137 Armstrong Road R.D.4 Te Puna Tauranga 3174

Dear Rebecca, RE:

ASSESSMENT OF ECOLOGICAL EFFECTS: ONEROA BEACHFRONT CYCLE AND WALKWAY

Thank you for the opportunity to consider the results of the above report with regard to updates of the original proposal and subsequent resource consent application. The following information is intended to supplement the ecological report (attached), which was based on fieldwork carried out during a site visit on 26 February 2014. The initial phase of the ecological assessment was an assessment of ecological values conducted in order to inform the alignment selection process for the Oneroa Beachfront Cycle and Walkway, based on the existing values and potential adverse effects of the draft proposal. I have since reviewed the finalised alignment plans, landscape plans and construction methodologies received (Chow Hill, dated July 2014; Eastern Earth Landscape Architects, dated 10 July 2014), and provide the comments below to more accurately describe the actual and potential ecological effects of the project. I refer to specific sections of the original ecological assessment where appropriate. As described in section 3.1 of the report, the dominant component of the vegetation on site is comprised of invasive exotic species and introduced ornamentals. These plants are more tolerant of the impacted dune environment found on site in comparison with the native dune flora. Notwithstanding this, the immediate foredune has relatively high botanical value at points, with Spinifex sericeus the most abundant native plant species in this zone. The final walkway alignment largely avoids the most valuable vegetation on site, with the majority of its length being situated within the mown amenity grassland and impacted back dune environment. The walkway will encroach on the dune environment for a portion of the timber boardwalk section, although this is restricted to a maximum width of 3m, and will involve limited disturbance through a construction methodology utilising driven piles. Despite the exotic composition, the generally dense, low-growing nature of the vegetation in this area offers high quality habitat for native skinks. Common skink (Oligosoma polychroma) were confirmed to be inhabiting the dune zone throughout the proposed project footprint as described in section 3.3. Any disturbance of the dune vegetation, whilst not significant with regards to native botanical value, will surmount to an adverse ecological effect for native lizard populations through loss of habitat. Additionally, re-construction of the dune contours has been proposed for several locations as means to mitigate localised erosion and historic vehicle access points. High quality herpetofauna habitat is relatively scarce at the proposed dune re-instatement sites, as due to the nature of their current state, the dense vegetation required by terrestrial lizards is absent. Nonetheless, all native lizards are ‘absolutely protected species’ under the Wildlife Act 1953, therefore steps must be taken to avoid, remedy or mitigate any adverse ecological effect resulting from the re-contouring activity. The original ecological report recommended the preparation and implementation of a Herpetofauna Management Plan (HMP) to address the potential impacts of earthworks and vegetation clearance on native lizards. This recommendation has been adopted and I am satisfied the HMP prepared will ensure adequate avoidance, remediation and mitigation of any potential adverse effects on the resident herpetofauna. In my opinion the landscape plans have the potential to provide a net improvement in botanical diversity and habitat quality through planting of native vegetation along the seaward edge of the walkway. Note that achieving the potential ecological benefits of the landscape plans will require the implementation of an appropriate maintenance plan (including weed/pest control and replacement planting where appropriate) for a minimum period of three years. ENVIRONMENTAL & INFRASTRUCTURE RESOURCE MANAGEMENT ANDREW.STEWART LIMITED • PO BOX 911310, VICTORIA STREET WEST, AUCKLAND 1142 TELEPHONE 09 303 0311 • FAX 09 303 0104 • WWW.ANDREWSTEWART.CO.NZ

Concomitant dune restoration is also proposed in five locations as mitigation for localised erosion. These initiatives will further improve the biodiversity of the area through weed control and supplementation of native plant communities, as well as increased species richness through the reintroduction of several native species currently absent. Aspects of the HMP have also been utilised as part of the landscape plans, and plant species which provide favourable skink habitat have been incorporated into the dune planting scheme. This initiative is commendable, as it will improve the in-situ lizard habitat availability and quality, as well as connectivity. The dune restoration areas will effectively create high quality stepping stones of habitat, linked by the plantings fringing the walkway. In their present condition, these ecological corridors are fragmented as a result of erosion and uncontrolled foot and vehicular traffic damaging vegetation communities. Through design, the final alignment and landscape plans will ultimately restore an important ecosystem process currently absent from the site, and in my opinion effectively outweigh any shortterm adverse impacts potentially arising from earthworks and vegetation clearance. I conclude that the ecological effects of the project will be minor in the short-term and positive in the medium- to long-term. I am more than happy to discuss these matters further if required.

Kind Regards,

Rachel Turner Consultant Ecologist Andrew.Stewart Ltd Filename/ref:

Attachment: Proposed Beachfront Cycle and Walkway – Grey Street to Midway Surf Club, Gisborne: Assessment of Ecological Effects

Filename/ref: Supplementary Ecology Commentary on Updated Proposal FINAL

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