re: Ballarat Planning Scheme Amendment C191 Permit Application No 2014/829 Marvella Heights St Pauls Way, Bakery Hill, Ballarat
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- Dora Lynch
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1 Tree Consultants & Contractors 25 Sep 2015 Tel (03) Planning Panels Victoria Level 1 8 Nicholson Street East Melbourne 3002 Dear Sir, re: Ballarat Planning Scheme Amendment C191 Permit Application No 2014/829 Marvella Heights St Pauls Way, Bakery Hill, Ballarat Introduction A high density development is proposed for Marvella Heights St Pauls Way, Bakery Hill, Ballarat. In May of this year, Galbraith and Associates undertook an assessment of all the trees on and close to the site, as a result of an earlier request by Best Hooper Lawyers. Subsequently Galbraith and Associates produced a report dated the 1/June/15, based on the overall ground floor plan dated May. The following is essentially a reproduction of that report, but updated to reflect the impact of the current plans. This statement includes a description of the overall treed nature of the site, an assessment of each tree (or group of trees if relatively homogeneous) providing species type, data on sizes, condition, the worth for retention estimates for each site tree, origin of the trees (whether exotic, Australian, Victorian or indigenous) and tree protection zone guidelines for the higher worth trees. It also includes a discussion on an exploratory trench which was undertaken in May under my supervision for the purposes of determining whether a driveway can be constructed close to a large healthy oak near the north-west corner, as well as a discussion on the impact of the latest plans. Each tree is located and numbered on the accompanying copy of the existing site conditions survey and discussed in the accompanying excel tables of data. The design plan upon which I base my assumptions is drawing TP-08 sheet 9 of 35, the proposed overall ground floor site plan by Project Now dated July
2 The Trees- General There are approximately 65 live trees on the site. Deciduous exotic trees make up only a small fraction of the total but include those five individuals which are probably the highest worth for retention trees on the site - four English Oaks - trees 18, 27, 43 and 53 (Quercus robur, one of which may well be a hybrid) and a Dutch Elm (Ulmus x hollandica) - tree 41. Each is situated adjacent to either a government road or to St Pauls Way. Several of the oaks are likely to be aged greater than 80 years and have well-developed spreading crowns. In some cases, particularly the Dutch Elm, tree surgery works are needed, but the useful life expectancy of these trees is greater than 30 years. In addition, the elm requires treatment for Elm Leaf Beetle, which is currently causing significant leaf skeletonising and defoliation. The evergreen exotic trees that are present are relatively small and insignificant; they include Kohuhu (Pittosporum tenuifolium) and Variegated Pittosporum (Pittosporum eugenioides Variegatum ). A range of Australian species, principally eucalypts, make up the balance of the trees on the site. All are the result of plantings dating to approximately 32 years ago. Seven of these plantings belong to four species which are native to the local area, namely Candlebark (Eucalyptus rubida), Manna Gum (Eucalyptus viminalis), Snow Gum (Eucalyptus pauciflora) and Blackwoods (Acacia melanoxylon). The Candlebark, which is situated on the southern boundary (through which there is a natural drainage of water), is the most substantial of these. It is multi- stemmed as a result of having been lopped to ground level in the past. Non-local Australian species can be divided into those that are native to Victoria and those that occur naturally only in other states. The first group mainly comprises Southern Mahogany (Eucalyptus botryoides) - which on this site is characterised by trees of asymmetric form and a tendency to shed branches, Yellow Gum (Eucalyptus leucoxylon) - most of which are healthy but are structurally only fair, Buxton Gum (Eucalyptus crenulata) - principally two uncommonly large, overmature trees and Red Ironbark (Eucalyptus sideroxylon) - two trees of no and limited retention worth respectively. Also present are a couple of overmature Bracelet Honey-myrtle (Melaleuca armillaris) and a struggling Coast Banksia (Banksia integrifolia). Non-Victorian species are of greater variety. The most prominent are six Willow Peppermint (Eucalyptus nicholii), each of which is over mature, a River She-oak (Casuarina cunninghamiana) in fair condition and a large symmetrical specimen of White Peppermint (Eucalyptus pulchella). Although this last mentioned individual appears to be a good specimen although somewhat marred by some cankers on its lower branches, in keeping with other individuals of this species in Melbourne it is unlikely to have a long safe useful life expectancy. Others that are present, as small specimens and/or in fair/poor condition, include Swamp Mahogany (Eucalyptus robusta), Lemon-scented Gum (Corymbia citriodora), Wallangarra White Gum (Eucalyptus scoparia), Red-flowering Gum (Corymbia ficifolia) and Snow in Summer (Melaleuca linariifolia). 2
3 Impact of the Proposal It is proposed to retain trees 18, 27, 41, 43 and 53. Each has been provided ample space for successful retention and the ongoing provision of amenity for many years to come. Tree 27 With respect to tree 27, I am informed a protrusion of the driveway needs to be built well into its TPZ (Tree protection zone, as per the methodology of calculation from the relevant Australian Standard 4970:2009 'Protection of trees on development sites') for fire truck access. It must be ensured that this protrusion is built on the existing grade. This CFA and truck turning area will have to be built up with a porous material such as scoria whose edges are secured in a post and sleeper type construction. The sites for the post holes for the sleepers must only be chosen after non root destructive hand digging to 600mm depth or the required depth of the post hole, whichever the shallower, reveals that there are no roots of significance, the loss of which could cause a long term deleterious impact on the tree. Minor crown lifting pruning will be required to provide access clearance for the trucks. Such pruning can be readily undertaken without having any impact on the longevity or health of the tree. Trees 41 and 43 In relation to tree 41, a driveway from Marvella Way into townhouse TO1 is proposed to be constructed partially over the outer edge of its TPZ. It is apparent however that the drive is to be on or above grade where it encroaches on the TPZ, hence there will be no impact on the root zone from this. Furthermore I recommend a porous surface be used, such as the product 'Stoneset'. With respect to both trees 41 and 43, a power kiosk is proposed to be situated between them. The slab for the kiosk sits on ground and the pit beneath is considerably smaller than outlined on the plan. This will have no impact on the trees, however any conduit heading north or south from the kiosk must be avoided. If it cannot be avoided, then it must be inserted beneath the root zones in a non root destructive manner such as by careful hand digging, pneumatic or hydraulic trenching. The total TPZ area encroachment from both the kiosk and drive is 9.1% of tree 41, and 6.9% of the TPZ area of tree 43 from the kiosk. Proposed crossover next to Tree 53 A vehicular crossover is proposed to be constructed near the north-west corner of the site, from St Pauls Way into the site 3m east of the trunk centre of tree 53, a large mature English Oak in good condition. It is proposed to use the product 'Stoneset' which has the advantage over standard crossovers such as asphalt or concrete or gravel by having the following properties: it is porous unlike asphalt and concrete, thereby allowing water and air penetration, and unlike gravel, is sufficiently rigid to prevent localised soil compaction and erosion. Thus it is seen as being sympathetic to the functioning of the root zone below. However in order to construct the product, at least a 220mm excavation is required in order to have the surface of the new material match that of the surrounding. Therefore non root destructive exploratory trenching was undertaken 3m east of the trunk centre to a depth of 250mm for 7m in length in order to determine what roots if any would be intercepted as a result of installing the product. The results are shown in the following photos: 3
4 The above is a sketch of the route of the exploratory trench 4
5 The above shows the base of tree 53 with the beginning of the exploratory trench and proposed crossover at the edge of St Pauls Way marked by the white stake. First half of the trench 5
6 View looking from the road southward. The largest root intercepted was 20mm thick (arrowed) View looking to the south end of the trench. A copper pipe is arrowed. 6
7 Results of the Trenching for the Crossover near Tree 53 and Conclusion The root growth intercepted was minor and its loss will be insignificant to the ongoing health and longevity of the tree. Tree roots were few and far between and the largest was approximately 15mm diameter. One can be very confident therefore that the crossover can be constructed without having any adverse impact on the tree. In relation to building M3, this intrudes 8.2% into the TPZ, which is minor and acceptable according to the Aust Std. Tree 18 A new entry is to be constructed into Daniel Lane from Marvella Way to the south of tree 18. It is essentially following the existing concrete drive in approximately the same position, however the level will have to be raised somewhat once it becomes Daniel Lane. The concrete path is also to be laid on grade, hence there will be little or no impact on the root zone as a result. The M3 building only makes a very small encroachment of 3.3% by area into the TPZ. Thus the conditions will change very little here with respect to the tree. General Tree Protection Measures During demolition, care must be taken to avoid felling trees or large parts thereof onto the trees to be retained. Avoid any excavation or level changes within more than 10% of the TPZ areas of the trees to be retained. Before construction commences, sturdy high visibility tree protection fence at least 1.8m tall must be constructed around the site trees to be retained. The fences must be constructed to the TPZs or to as large an area as possible, yet which still allows construction to proceed in a safe and efficient manner whilst protecting the tree. The fences must not be moved during the construction period unless after discussion with the project arborist. Mulch must be laid to a depth of some 75mm within the fences. Any necessary pruning ought be undertaken some time before construction commences. During construction, no fill nor rubbish can enter the fences, nor excavation for any purpose within them, (unless under arboricultural supervision and signed off by the project arborist as not being harmful to the SULE of the tree). Examples are avoiding any excavation for drains and services within more than 10% of the TPZ areas, unless by non root destructive means such as horizontal boring at greater than 800mm depth or by pneumatic or hydraulic means under arboricultural supervision. The soil around the trees must receive periodic irrigation over the summer and autumn periods of construction, such that the root zones are never allowed to dry out. 7
8 Notes on Terminology In order to understand the column headings of the table of data, I have provided the following explanations: DBH diameter of trunk over bark at breast height In a number of cases where the tree has forked into multiple trunks below breast height ( m) the diameter is measured below the fork and an estimate is made for the single trunk equivalent at breast height, or else figures for each of the individual stems can be given. HxS This is the estimated height (H) of the tree and its average crown spread (S). SULE Safe useful life expectancy in years. Taken in the context that the area is to be developed for residential use, and that sensible distances are maintained between the buildings and the trees, this is the estimate of time that the tree will continue to provide useful amenity without imposing an onerous financial burden in order to maintain relative safety, and avoid excessive nuisance. Condition This descriptor can be encapsulated by three terms, namely Health (H), Structure (S) and Form (F). Health is largely governed by the ease in which the metabolic functions are occurring throughout the tree. Symptoms of health include the amount, distribution, density, size and colour of the foliage. Structure refers to the structural stability of the tree and its branches. A well structured tree is not likely to shed branches or stems, or snap in the trunk or blow over, whereas a poorly structured tree is more likely to. Form basically refers to the symmetry of the tree. A tree with a straight trunk and symmetrical crown and evenly distributed branches is referred to as having good form, whilst a lopsided leaning tree may have fair poor form. Worthiness of Retention (WOR): The worth for retention of a tree is based on the assumption that the site is to be re-developed, and that there is the opportunity for new tree planting. It is based on a number of factors. These factors are: 1. structure, health, form and safe useful life expectancy, 2. size, prominence in the landscape, 3. species rarity, 4. whether indigenous, 5. whether an environmental weed. 6. importance for habitat of native wildlife 7. whether of historical or cultural interest Any tree with a WOR rating of 3 or less should be seriously considered for removal before development begins because it is dead, nearly dead or dangerous, a weed, is causing or is likely to cause a severe nuisance in the near future, or just of very little significance and readily replaceable with new plantings. Trees rated 4-6 are of some significance. Some of these trees may respond to treatments such as formative pruning, removal of dead wood, weight reduction pruning etc. Trees rated 7 or higher are of high significance (the higher the ranking the more so), primarily because of their good health, structure, form, prominence in the landscape and SULE, although all they still may need substantial works done on them as already detailed, if they are to be retained. Tree Protection Zone (TPZ) According to the Australian Standard AS Protection of Trees on Building Sites, the TPZ is the principal means of protecting trees on development sites. It is a combination of the root area and crown area requiring protection. It is an area isolated from construction disturbance, so that the tree remains viable. The radius of the TPZ is calculated by multiplying the DBH by 12. The radius is measured from the centre of the stem at ground level. An area of 10% of the TPZ is deemed acceptable to violate if 10% of the area of the TPZ is made up in 8
9 other directions. Thus if encroachment is from one side only, encroachment to as close as approximately 8 times the DBH (2/3 the listed TPZ radius) is permissible according to the Standard. The AS should only be construed as a rough guide. It is only used in this statement because various local authorities now demand it in their assessments of development applications. Many factors such as the type of encroachment on the TPZ, species tolerance, age, presence of spiral grain, soil type, soil depth, tree lean, the existence of onsite structures or root directional impediments, level of wind exposure, irrigation and ongoing tree care and maintenance are each highly influential on the size and success of the TPZ estimation, therefore the figures derived from the Standard and provided in this report must be treated as rough guides only. Tree Origin Categories Each tree has been classified as to whether it is indigenous (I), native to Victoria (V), native to Australia (A), exotic (E) or an environmental weed (W). An indigenous species (I) is one that is known to grow naturally in the local area, even if the individual tree has been planted and is from a seed source or provenance foreign to the area. A species classified V is one which has a part or all, even if very small, of its natural range within Victoria, although it may occur outside the state as well. It does not however occur naturally in the local area. A species classified A is native elsewhere in Australia than Victoria. It does not occur naturally in the local area. A species classified E has its natural range occurring outside Australia. A species classified W is a seriously invasive environmental weed. 9
10 Summary Deciduous exotic trees make up only a small fraction of the total but include those five individuals which are probably the highest worth for retention trees on the site - four English Oaks - trees 18, 27, 43 and 53 (Quercus robur, one of which may well be a hybrid) and a Dutch Elm (Ulmus x hollandica) - tree 41. Each is situated adjacent to either a government road or to St Pauls Way. Several of the oaks are likely to be aged greater than 80 years and have well-developed spreading crowns. In some cases, particularly the Dutch Elm, tree surgery works are needed, but the useful life expectancy of these trees is greater than 30 years. A range of Australian species, principally eucalypts, make up the balance of the trees on the site. All are the result of plantings dating to approximately 32 years ago. It is proposed to retain trees 18, 27, 41, 43 and 53 which are probably the best trees on the site. Declaration: I hereby declare that I have made all the enquiries that I believe are desirable and appropriate, and no matters of significance which I regard as relevant have to my knowledge been withheld from the respected Tribunal. GALBRAITH & ASSOCIATES Rob Galbraith The following pages set out details of my qualifications and experience: 10
11 1. Name and Professional Address of Expert Robert Cameron Galbraith Arboriculturist 40 Glyndon Road Camberwell Vic 3124 Tel: Fax: Qualifications and Experience 1977 Attained Degree in Forest Science from Melbourne University Forest inventory work and road locating in Gippsland, Tasmania and Northern Territory 1982 Foreman of a contract re-vegetation crew at various MMBW parks Attained the National Certificate of Horticulture in Arboriculture at Merrist Wood College, England, with Distinctions Foreman of a large Melbourne tree surgery company Tree surgery sub-contractor Manager of the Arboricultural Services Division of Rivett Enterprises. Arboricultural Consultant for Rivett Enterprises Principal, Galbraith & Associates - Arboricultural Consultants and Contractors. Consultants to Royal Botanic Gardens Sydney, Major Projects Victoria, St Kilda Botanic Gardens, Melbourne Parks & Waterways, Vic Urban, Office of Housing Department of Human Services, legal firms, insurance companies, developers, town planning consultants, architects, landscape architects, local government (Cities of Albury, Bayside, Boroondara, Manningham, Moreland, Stonnington, Whitehorse). Contracting in arboricultural services for private, government and commercial clients. VOLUNTARY ARBORICULTURAL INDUSTRY WORKS Arboricultural Association of Australia (President, 1994, 95, 96) Major contributor to the Australian Standard AS Pruning of Amenity Trees. 3. Area of Expertise My area of expertise is in amenity tree management. 4. Expertise to Prepare this Report My expertise is based on substantial experience in forestry and arboriculture, with many years directly working with thousands of different trees in differing situations. The tasks of climbing, dismantling, pruning and excavating near 11
12 trees, particularly in Melbourne, is, and has been, virtually a daily routine over many years. I keep well abreast of important and relevant research in arboriculture, reading widely and conferring regularly with colleagues in the arboricultural field. 5. Instructions Received in Relation to this Matter I have received instructions from Best Hooper Lawyers. They have been to provide a statement of evidence for Panels Victoria discussing the trees on and close to the subject site, along with the likely impact of the proposal and recommendations regarding the trees proposed to be retained 6. Facts/Matters/Assumptions/Reference Documents used to prepare this Report The design plan upon which I base my assumptions is drawing TP-08 sheet 9 of 35, the proposed overall ground floor site plan by Project Now dated July Other Persons Relied Upon Nil 12
13 Tree Comments, TPZs (m) and Indicative SRZs for dead No. Botanical name (Common Name) Origin DBH (cm) HxS (m) Condition WOR trees 1 Eucalyptus leucoxylon (Yellow Gum) V 52 14x9 F 5 Large branch failure on south side. Weight reduce if retaining. TPZ 6.2m. 2 Melaleuca armillaris (Bracelet Honey Myrtle) V 22,16,14,14,13 6x9 F/P 3,8 Over-mature. 3 Eucalyptus leucoxylon (Yellow Gum) V 27 11x8 F 3 Stressed. 4 Eucalyptus pauciflora (Snow gum) I 15,10,9,8 6x7 F/P 4 Leaning and one-sided to south. 5 Eucalyptus scoparia (Wallangarra White Gum) A 16 7x6 F/P 3 As above. 6 Eucalyptus crenulata (Buxton Gum) V <10 6A Eucalyptus crenulata (Buxton Gum) V 8,6,5,4,3 6x6 F/P 3 Approx location added to plan. 7 Melaleuca linariifolia (Snow in Summer) A 31 8x5 F/P 3 Lopsided, leans to south. 8 Eucalyptus crenulata (Buxton Gum) V 44,42 18x16 F/P 2 In decline. 8A Eucalyptus scoparia (Wallangarra White Gum) A 13,9,6,5 9x5 F 3 Stump regrowth. 8B Melaleuca linariifolia (Snow in Summer) A 21,16 9x5 F/P 3 9 Eucalyptus nicholii (Willow Peppermint) A 29 13x8 F/P 3 10 Eucalyptus nicholii (Willow Peppermint) A 36 13x9 F/P 3 11 Eucalyptus botryoides (Southern Mahogany) V 64,27 17x14 F 4 Health and structure fair only. 12 Eucalyptus nicholii (Willow Peppermint) A 57 equiv 13x10 F/P 2 Major co-dominant failure on north side. 13 Eucalyptus scoparia (Wallangarra White Gum) A 28,16,11 11x10 F/P 3 Basically one-sided to SW, leaning. 14 Cotoneaster glaucophyllus (Cotoneaster) E 18 equiv 3x4 F 2 approx 15 Acacia melanoxylon (Blackwood) I 51 15x11 P 2 In decline - dead branches, failures. 16 Eucalyptus botryoides (Southern Mahogany) V 70 21x17 F/P 4 Most of crown spread is N-S. Rangy form, large branch failures on east side. 17 Eucalyptus botryoides (Southern Mahogany) V 56 15x16 F/P 4 Suppressed - lopsided to south. Some minor dieback. 18 Quercus robur (English Oak) E 70 equiv 11x19 F 7 Apparently lopped at 2m - long ago. Healthy, spreading multi-branched crown. TPZ 8.4m. 19 Quercus robur (English Oak) E 67,52 14x21 P 2 Two-stemmed, has largely split at base. 20 Eucalyptus botryoides (Southern Mahogany) V 40 equiv 11x13 F/P 2 21 Eucalyptus leucoxylon (Yellow Gum) V 47,37,28 14x15 F 5 V crotches between main stems near base. Healthy, needs crown reduction if retained. TPZ 7.9m. 22 Eucalyptus leucoxylon (Yellow Gum) V 29,28 10x10 F 4 Two-stemmed and sprawling. Branch failures. 23 Eucalyptus botryoides (Southern Mahogany) V 43 12x10 F/P 3 Poor structure. 23A Eucalyptus scoparia (Wallangarra White Gum) A 16,13,10 4x10 F/P 2 Approx location added to plan. 24 Corymbia citriodora (Lemon Scented Gum) A 27 12x5 F/P 3 Stressed. 25 Eucalyptus rubida (Candlebark) I 48,35,27,18, 17x14 F 5 to 6 Mature stump regrowth. Fair health but structural issues. TPZ 9.1m. 35 equiv 26 Casuarina cunninghamiana (RiverShe-oak) A 45 14x9 F 5 Health is OK, branch failures on east side. TPZ 5.4m. 27 Quercus robur (English Oak) E 72 16x23 G 8 Main stem covered by ivy but tree apparently has no structural issues. Dense crown, good form. TPZ 8.6m. 28 Eucalyptus sideroxylon (Red Ironbark) V 47,18,14 10x11 F 5 Irregular form, leans out to SE. Several branch failures. TPZ 6.3m. 29 Eucalyptus nicholii (Willow Peppermint) A 45 15x9 F/P 2 In decline. 30 Eucalyptus nicholii (Willow Peppermint) A 44 13x11 F/P 3 Over-mature, leaning, mostly one-sided to south. 31 Eucalyptus nicholii (Willow Peppermint) A 62 approx 15x15 F 5 Over-mature but a reasonably good example of the species assuming lower branch crotches are OK (currently covered by ivy). TPZ 7.4m. 32 Eucalyptus pulchella (White Peppermint) A 75 15x15 F/G 6 Crown density fair only. Has several lesions on main stem (eg on south side), presumably caused by cockatoos; one or two of these however are now likely to be fungal cankers (viewing access to tree is limited by slope, terracing and black-berries). 33 Prunus domestica (Plum) E 17 equiv 4x5 F/P 2 approx 34 Pittosporum eugenioides "Variegatum" (Variegated E 11,9,8,8 4x4 F/P 2 Dead extremities. Pittosporum) 35 Callistemon pallidus (Lemon Bottlebrush) V 20 equiv 4x6 F 3 approx 36 Dead 16,15,14,12 approx 6x5 Dead 1 37 Pittosporum eugenioides "Variegatum" (Variegated Pittosporum) E 13,12,11,9,9, approx 7x7 F 4 38 Eucalyptus crenulata (Buxton Gum) V 44,42 17,14 F/P 2 Over-mature, largely one-sided to south. 39 Ulmus x hollandica (Dutch Elm) E 55,55,49 19x16 F 6 Upright form,narrow basal crotches, some works required including Elm Leaf Beetle control. Health fair only - somewhat stressed. TPZ Eucalyptus viminalis (Manna Gum) I 48 15x12 F 5 Healthy but largely one-sided, with heavy lean to SW. TPZ 5.8m. 41 Ulmus x hollandica (Dutch Elm) E 35,32,30,25 15x14 F 6 As for tree 39, but a smaller, healthier tree. TPZ 7.4m. equiv 42 Eucalyptus sideroxylon (Red Ironbark) V 45 18x9 F/P 2 Major failure, poor form. 43 Quercus robur (English Oak) E 37,28,26,30,25,19,38 44 Eucalyptus conferruminata (Bushy Yate) A 28,24,20 equiv 10x9 F/P 2 Over-mature. 15x18 G 7 Either mature stump regrown stems or a cluster of trees or a combination or both. Dense crown. TPZ (assuming single tree) 9.4m. 45 Banksia integrifolia (Coast Banksia) V 28 equiv 6x6 F 3 Below average health. 45A Callistemon citrinus (Crimson Bottlebrush) V 25 equiv 5x6 P 2 Approx location added to plan. approx 46 Acacia melanoxylon (Blackwood) I 36 approx 13x8 F 4 to 5 Over-mature, fair health, good form. TPZ 4.3m. 47 Juniperus squamata (Nepal Juniper) E 30 approx 5x3 F/P 2 equiv 48 Hakea salicifolia (Willow-leaf Hakea) A 16,14,12 5x5 P 2 49 Pittosporum tenuifolium (Kohuhu) E 13,9,8 5x5 F 4 50 Acacia melanoxylon (Blackwood) I 32 14x6 F/P 2 In decline. 51 Acacia melanoxylon (Blackwood) - dead I 36 13x7 Dead 1 52 Corymbia ficifolia (Red-flowering Gum) A 15 4x3 F 3 Lopsided. 53 Quercus robur (English Oak)(or hybrid) E 95 18x18 F/G 8 Mature specimen, impressive tree. A couple of branch failures but generally well stfructured with a long SULE. TPZ 11.4m. 54 Eucalyptus robusta (Swamp Mahogany) A 40 equiv 13,10 P 2 Fungal decay bracket (Phellinus) near base. 55 Acacia melanoxylon I 52 equiv 12x12 F 3 In decline. 56 Melaleuca linariifolia (Snow in Summer) A 28,24,20,18,16,18,15 6x8 F 4 57 No live tree - only a dead stump at ground level 55cm diameter stump.
14 58 Ulmus x hollandica (Dutch Elm)(approx 12 clumps of suckers) E included stems to 17 dom ht 8m F 3 Approx location added to plan.
15
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