Grange Planning Brain

title: Donnybrook-Woodstock Biodiversity, Growling Grass Frog and Native Vegetation Constraints council: mitchell state: vic category: constraint classification: MAJOR status: approved last_compiled: 2026-05-31 source_docs:

  • Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf
  • Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf
  • Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf
  • 2912017.pdf

Donnybrook-Woodstock Biodiversity, Growling Grass Frog and Native Vegetation Constraints

The Donnybrook-Woodstock biodiversity constraint is not a single mapped exclusion; it is a layered control system made up of conservation areas, Growling Grass Frog habitat, retained native vegetation, scattered River Red Gums, construction controls, fencing obligations, land management requirements and offset/levy mechanisms. The practical planning effect is that urban development can proceed inside the Donnybrook-Woodstock PSP area, but only where subdivision and works avoid, secure, manage or offset the biodiversity values identified through the Melbourne growth-corridor framework and the PSP implementation controls. (Source: 2912017.pdf, p.480-482)

The strongest ecological constraint is the Merri Creek corridor, which Ecology Australia assessed as core permanent habitat and primarily high potential breeding habitat for Growling Grass Frog. The species is listed as Vulnerable under the EPBC Act, listed under the FFG Act and considered Endangered in Victoria, so the corridor has both local PSP implications and Commonwealth/state threatened-species consequences. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.6, p.15)

Background

Donnybrook and Woodstock sit within Melbourne’s northern growth corridor and inside the Urban Growth Boundary, with the study area bounded by Donnybrook Road to the south, the Melbourne-Sydney railway line to the west, the OMR/E6 road reservation to the north and Merriang Road to the east. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.6) The PSP process was being managed by the Metropolitan Planning Authority for PSP 1067 Donnybrook and PSP 1096 Woodstock in consultation with DEPI, Mitchell Shire Council and the City of Whittlesea. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.6)

The precinct is now implemented through Schedule 4 to Clause 37.07 Urban Growth Zone, which applies to land shown as UGZ4 and references the Donnybrook-Woodstock Precinct Structure Plan. (Source: 2912017.pdf, p.475) The planning scheme incorporated documents list includes the Donnybrook-Woodstock Precinct Structure Plan, March 2020, and the Donnybrook-Woodstock Infrastructure Contributions Plan, July 2020, amended March 2022. (Source: 2912017.pdf)

The technical source base for this page is uneven. The manifest includes a Growling Grass Frog habitat assessment, a Donnybrook arboricultural report, a Woodstock scattered tree assessment and the current Mitchell Planning Scheme, but it does not include the full incorporated PSP, the full Native Vegetation Precinct Plan if one exists as a standalone document, the detailed Conservation Management Plan, the Growling Grass Frog concept plan, or the Melbourne Strategic Assessment approval conditions. That means this page can identify the constraint mechanisms and their planning effects, but it cannot quantify all conservation-area land take, lot-yield effects or final PSP design responses. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.20; Source: 2912017.pdf, p.480-482)

Analysis

The Biodiversity Constraint Works Through Conservation Areas, Not Just Permit Triggers

The planning scheme requires a Construction Environmental Management Plan for subdivision, buildings or works on or within 50 metres of land shown as a conservation area in the incorporated Donnybrook-Woodstock PSP. (Source: 2912017.pdf, p.480) This converts the mapped conservation area from a passive environmental layer into an active construction-stage control, because works cannot start until the Secretary and responsible authority approve a plan demonstrating how the conservation area will be protected during works. (Source: 2912017.pdf, p.480-481)

The planning scheme also requires a conservation area fencing plan where subdivision works, buildings or works occur on land including or abutting a conservation area. (Source: 2912017.pdf, p.481) The required fencing plan must show conservation-area boundaries, scattered trees, native vegetation patches, temporary protection fencing and permanent fencing. (Source: 2912017.pdf, p.481) The minimum fencing setbacks are 0.5 metres from a conservation area, 12 times trunk diameter at 1.3 metres for a scattered tree, and 2 metres from a patch of native vegetation. (Source: 2912017.pdf, p.481)

This is a sequencing constraint. The fencing condition prevents construction activity from simply moving around biodiversity features during civil works, because stockpiles, fill, machinery, vehicle parking, excavation and construction activity are prohibited within the fenced area unless the Secretary gives prior written consent. (Source: 2912017.pdf, p.481) The scheme also requires written evidence from a suitably qualified land surveyor that protection fencing has been correctly erected before buildings and works commence. (Source: 2912017.pdf, p.481)

The planning scheme further requires conservation areas to be secured as separate lots or reserves and protected in perpetuity through transfer, vesting, a section 173 agreement, or a section 69 agreement under the Conservation, Forests and Lands Act 1987. (Source: 2912017.pdf, p.482) This means the constraint is not only a design response at subdivision stage; it is also a land-tenure and long-term management outcome. (Source: 2912017.pdf, p.482)

Merri Creek Is the Binding Growling Grass Frog Constraint

Ecology Australia found that the Merri Creek waterway and associated riparian habitat within the study area represents core permanent habitat for Growling Grass Frog. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.15) Core permanent habitat was defined in the report as habitat critical for long-term population persistence, generally involving a permanent waterbody or waterway that provides continuity of habitat and breeding habitat in most years. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.15)

The Merri Creek corridor is also a movement link within and between sub-populations, which matters because the report describes the local Growling Grass Frog population as operating through metapopulation dynamics, with occupied wetland clusters blinking in and out through local extinction and recolonisation. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.7, p.15) In planning terms, this means the corridor cannot be assessed only as a set of individual breeding pools; the continuity between pools, wetlands, tributaries and terrestrial habitat is part of the ecological function. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.11, p.15)

The report classified the majority of Merri Creek within the study area as high potential breeding habitat, with a small south-western section classified as moderate potential breeding habitat. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.15) The high-potential sections generally had more in-stream wetlands, more favourable aquatic vegetation cover, more open water and less overshading from woody species. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.15) The moderate-potential section was identified because it appeared to have reduced hydroperiod, fewer in-stream pools and less favourable aquatic vegetation, although the report cautioned that the distinction was subjective. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.15)

The report recorded Growling Grass Frog at four locations along Merri Creek, including three within the study area boundary. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.14) It also recorded Eastern Gambusia, a predatory fish, and noted that this species is highly likely to be present throughout Merri Creek when full. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.14) The implication is that habitat design and management cannot rely only on water permanence; it must also manage vegetation structure, water quality, connectivity and predator conditions. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.10-11, p.14-15)

Darebin Creek Is a Linking Habitat Constraint With Lower Existing Breeding Value

Ecology Australia assessed Darebin Creek as linking habitat rather than high or moderate breeding habitat. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.16-17) The creek was described as an ephemeral drainage line with little to no aquatic vegetation, substantial rock cover and fringing vegetation dominated by exotic pasture grasses. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.16-17)

The planning consequence is different from Merri Creek. Merri Creek is a core habitat and breeding constraint, while Darebin Creek is primarily a movement and future-enhancement constraint. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.15-17) Ecology Australia noted that the quality of Darebin Creek habitat may improve over time as increased inflows occur from surrounding development, and that stock exclusion would likely improve the quality of existing in-stream wetlands. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.20)

This creates a design sensitivity. If stormwater and open-space planning increases hydroperiod without controlling water quality, sediment, weeds and predators, the result may be a wetter corridor without reliable threatened-species benefit. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.8-10, p.16, p.20) If stormwater and conservation planning are coordinated, Darebin Creek may function as an improved movement link and local habitat network. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.16, p.20)

Native Vegetation Removal Is Partly Shifted From Permit-by-Permit Assessment to the Growth-Corridor Levy System

The Schedule to Clause 52.17 states that no permit is required to remove, destroy or lop all native vegetation in the levy area on land shown as UGZ4 or IPO3, within the meaning of the Melbourne Strategic Assessment Environmental Mitigation Levy Act 2020. (Source: 2912017.pdf, p.818) The same schedule expressly excludes native vegetation identified as to be retained on Plan 9 in the incorporated Donnybrook-Woodstock PSP from that exemption. (Source: 2912017.pdf, p.818)

The mechanism is important. Native vegetation inside the relevant levy area is not unconstrained; rather, its treatment is shifted into the Melbourne Strategic Assessment and PSP retention framework, with retained vegetation still protected by the incorporated PSP. (Source: 2912017.pdf, p.818, p.849) Clause 52.20-8 requires information about native vegetation before removal inside the levy area, and for vegetation outside the levy area it requires information, offsetting in accordance with the Guidelines, and evidence that the required offset has been secured. (Source: 2912017.pdf, p.849)

The Commonwealth EPBC approval note in the UGZ schedule states that the 5 September 2013 EPBC Act approval applies to all actions associated with urban development in growth corridors in the expanded Melbourne 2010 Urban Growth Boundary, has effect until 31 December 2060, and removes the need for individual EPBC assessment where the approval conditions are satisfied. (Source: 2912017.pdf, p.484) This means the Donnybrook-Woodstock biodiversity pathway depends on compliance with the strategic approval conditions, not on each project independently repeating the full Commonwealth referral process. (Source: 2912017.pdf, p.484)

Tree Retention Is Both an Ecological Constraint and a Public-Safety Design Constraint

Treetec identified 33 individual trees and seven groups of two or more trees in Donnybrook with high or very high Arboricultural Retention Value. (Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.2) All high-retention trees recorded by Treetec were indigenous eucalypts limited to River Red Gum and Manna Gum. (Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.2) Treetec later summarised the result as 23 individual trees and one tree group of very high retention value, plus 10 trees and six tree groups of high retention value. (Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.27)

The Donnybrook arboricultural constraint is concentrated in large remnant trees rather than broad intact woodland. Treetec found that PSP 1067 had been heavily affected by agricultural use and that River Red Gum overstorey had been dramatically reduced from its likely pre-European extent, with the most significant stands restricted to the north-eastern and south-eastern corners of the area. (Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.23)

The ecological value of retained trees is substantial because the large River Red Gums assessed typically supported hollows and evidence of fauna use, including scats, nests and claw marks. (Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.23) The public-safety implication is also substantial because large old River Red Gums can drop large limbs and deadwood, and the report recommends risk management through measures such as discouraging use of fall zones, pruning deadwood, regular risk inspections, targeted pruning, local planting and improved growing conditions. (Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.8-9)

This makes retained trees a spatial-design issue, not simply a vegetation inventory issue. Paths, roads, playgrounds, seating, lots, drainage works and open-space embellishment must respond to Tree Protection Zones and fall-risk management. (Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.8, p.24-27) The UGZ schedule reinforces this by requiring residential subdivision applications to include an arboricultural report identifying all trees on the site and a tree retention plan showing how the application responds to Plan 5 Character and Housing and the PSP tree protection requirements and guidelines. (Source: 2912017.pdf, p.477)

Woodstock Contains Fewer Assessed Trees, But Some Have High Conservation Significance

Biosis assessed selected trees within the Woodstock PSP on 16 July 2013 and updated the assessment on 22 May 2014. (Source: Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf, p.1) All Woodstock trees assessed were River Red Gum, with trees representing remnants of Riparian Woodland along Merri Creek and Plains Grassy Woodland elsewhere. (Source: Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf, p.2)

The Woodstock assessed trees were predominantly small trees, but the survey identified one Very Large Old Tree, three Large Old Trees and one Medium Old Tree. (Source: Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf, p.2) Tree 34 was a Large Old Tree within Conservation Area 34, had hollows and was assigned very high conservation significance. (Source: Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf, p.3) Trees 79, 80 and 81 were scattered trees with hollows or large size attributes and were assigned high conservation significance. (Source: Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf, p.3)

Biosis stated that under the Biodiversity Conservation Strategy the removal of a scattered tree would attract a habitat compensation fee of $13,218 per tree for medium or greater size classes, and that the fee did not apply to small trees. (Source: Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf, p.4) This creates a direct financial signal for tree removal, but the more important planning mechanism remains avoidance and retention where trees are inside conservation areas or identified for retention. (Source: Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf, p.4; Source: 2912017.pdf, p.818)

Weed, Stock and Hydrology Management Are Core to the Constraint, Not Peripheral Maintenance

Ecology Australia found that Growling Grass Frog habitat in Donnybrook and Woodstock was generally modified and degraded by agricultural history, grazing, exotic vegetation, woody weeds and exotic pasture grasses. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.14) It nevertheless found that riparian zones and waterbodies provide suitable habitat because Growling Grass Frog habitat suitability is strongly influenced by hydrology and vegetation structure rather than vegetation composition or land use alone. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.14)

The report identified woody weeds along Merri Creek as a likely significant current impact on Growling Grass Frog habitat quality and recommended woody weed control in riparian and adjacent habitat before long-term precinct-level conservation works commence. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.20) It also noted that Gorse, Hawthorn, Blackberry and African Boxthorn are Regionally Controlled weeds under the Catchment and Land Protection Act 1994, creating obligations for landowners to take reasonable steps to prevent their growth and spread. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.20)

The planning scheme converts this ecological issue into a permit condition by requiring a land management plan for conservation-area land. (Source: 2912017.pdf, p.481-482) That plan must explain how Biodiversity Conservation Strategy values will be maintained, managed and improved, including weed management, revegetation coordination, rubbish removal, hazard removal and contaminated-material management before the conservation area is secured. (Source: 2912017.pdf, p.481-482)

Current Status

The Donnybrook-Woodstock PSP is implemented in the Mitchell Planning Scheme through UGZ4, and the incorporated PSP is listed as the Donnybrook-Woodstock Precinct Structure Plan, March 2020. (Source: 2912017.pdf, p.475; Source: 2912017.pdf) The biodiversity controls are therefore operating as statutory implementation requirements for subdivision and works, rather than as preliminary technical recommendations. (Source: 2912017.pdf, p.477, p.480-482)

The scheme framework requires subdivision applications to address tree retention, stormwater staging, public infrastructure, conservation-area construction management, fencing, land management and long-term conservation-area security. (Source: 2912017.pdf, p.477-482) The technical reports remain important because they explain why those controls exist: Merri Creek supports core permanent Growling Grass Frog habitat, Darebin Creek provides linking habitat, and remnant River Red Gums carry ecological, amenity and risk-management consequences. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.15-17; Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.23-27; Source: Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf, p.2-4)

Dependencies

  • Blocks: Development designs that place works, stockpiles, machinery, excavation or construction activity inside required conservation fencing without Secretary consent. (Source: 2912017.pdf, p.481)
  • Blocks: Subdivision progression where conservation areas have not been secured as separate lots or reserves and protected in perpetuity through the required transfer, vesting or agreement pathway. (Source: 2912017.pdf, p.482)
  • Blocks: Subdivision applications that do not provide the required arboricultural report and tree retention response for residential subdivision. (Source: 2912017.pdf, p.477)
  • Blocked by: Secretary approval of Construction Environmental Management Plans, conservation fencing plans and conservation-area land management plans where land is on, abutting or within 50 metres of mapped conservation areas. (Source: 2912017.pdf, p.480-482)
  • Blocked by: Compliance with the EPBC strategic approval conditions for urban development in Melbourne growth corridors, because the scheme note states individual EPBC approval is not required only where those conditions are satisfied. (Source: 2912017.pdf, p.484)
  • Informed by: Growling Grass Frog habitat mapping for Merri Creek, Darebin Creek and Conservation Area 34. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.6, p.13-20)
  • Informed by: Donnybrook high and very high Arboricultural Retention Value tree mapping and Tree Protection Zone recommendations. (Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.2, p.8, p.27)
  • Informed by: Woodstock scattered and patch tree assessment, including conservation significance and habitat compensation fee treatment. (Source: Donnybrook-Woodstock-Scattered-Tree-Assessment-Biosis-August-2014.pdf, p.2-4)
  • Implements: The Biodiversity Conservation Strategy for Melbourne’s Growth Corridors as referenced in the planning scheme land-management condition and the Growling Grass Frog assessment. (Source: 2912017.pdf, p.481-482; Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.6)
  • Conflicts with: Urban development pressure where road, drainage, open-space embellishment or lot layout would fragment Growling Grass Frog movement habitat, alter hydrology, reduce water quality or compromise retained trees. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.8-11; Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.24-27)

The Donnybrook-Woodstock study area crosses municipal governance interests because the MPA prepared the PSPs in consultation with DEPI, Mitchell Shire Council and the City of Whittlesea. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.6) The Donnybrook arboricultural report also noted that nearly all River Red Gums in that report were within the City of Whittlesea and subject to Whittlesea-specific River Red Gum Tree Protection Zone calculation requirements, while Tree 1 was within Mitchell Shire and not subject to the Whittlesea calculation. (Source: Donnybrook-Woodstock-Arboricultural-Report-Tree-Tec-June-2013.pdf, p.8, p.25)

The ecological system is also cross-boundary because Growling Grass Frog records and habitat occur across Merri Creek, Kalkallo Creek, Darebin Creek and Edgars Creek waterways north of Melbourne. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.7) Merri Creek provides connectivity between wetland clusters north and south of the precinct, which makes local works relevant to broader dispersal, genetic interchange and habitat diversity. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.15)

Gaps in This Analysis

The manifest does not include the full Donnybrook-Woodstock PSP plan set, even though the planning scheme requires subdivision responses to Plan 5 Character and Housing, Plan 9 retained native vegetation, Plan 16 Utilities and the conservation areas shown in the incorporated PSP. (Source: 2912017.pdf, p.477, p.481, p.818) Without those plans, this page cannot identify every affected parcel, measure conservation-area land take, calculate lot-yield impacts or map exact tree-retention conflicts. (Source: 2912017.pdf, p.477, p.481, p.818)

The manifest does not include the Growling Grass Frog Concept Plan or Conservation Management Plan that Ecology Australia said would follow from the habitat assessment for Conservation Area 34. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.6, p.20) Without those documents, this page cannot verify the final number, location, staging or design parameters for dedicated Growling Grass Frog breeding wetlands. (Source: Donnybrook-Woodstock-Growling-Grass-Frog-Habitat-Assessment-Ecology-Australia-March-2014.pdf, p.20)

The manifest does not include the EPBC approval instrument or Annexure 1 conditions for the 5 September 2013 Melbourne growth-corridor approval. (Source: 2912017.pdf, p.484) Without that approval, this page can state the strategic approval pathway but cannot test condition-by-condition compliance obligations for Donnybrook-Woodstock development stages. (Source: 2912017.pdf, p.484)

The manifest does not include final offset ledgers, Environmental Mitigation Levy payment records or native vegetation removal reconciliation material. (Source: 2912017.pdf, p.818, p.849) Without those records, this page cannot quantify how much native vegetation has been removed, how much has been retained, or whether offset obligations have been fully discharged for specific development stages. (Source: 2912017.pdf, p.818, p.849)

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