Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Referrals Section (EPBC Act)
Approvals and Wildlife Division
Department of the Environment and Water Resources
GPO Box 787
CANBERRA ACT 2601
Dear Madam/Sir
Project ref no. 2007/3554
Block 17 Section 102 Symonston
This project, referred under the EPBC Act, proposes to provide services to land (such as sewerage and electricity, to convert it into a site that may be used for the purposes of a caravan park and camping ground) and the issue of a lease to a developer. The site may include a population of the grassland earless dragon Tympanocryptis pinguicolla which is listed as an endangered species under both Commonwealth and ACT legislation. FoG believes that this proposal should be rejected or at least warrants further investigation prior to any approval under EPBC, as it may have significant impact on the grassland earless dragon, i.e. it may destroy both members of a population of this species and its habitat.
Friends of Grassland (FoG) is a community group dedicated to the conservation of native temperate grassy ecosystems, such as grasslands and woodlands. FoG is based in Canberra and its members, numbering about 200, include professional scientists, landowners, land managers and interested members of the public. FoG advocates, educates and advises on matters to do with conservation of grassy ecosystems, and carries out surveys and other on‑ground work.
FoG's reasons for believing that the proposed works, and future proposed development, may have a significant impact on the grassland earless dragon and its habitat are as follows.
- The future of this species is far from secure. The policy of the ACT Government was to protect every remaining population of the species until the issue of retaining a long stay caravan park at Symonston emerged. The ACT Government strategy regarding the species is set out in A vision splendid of the grassy plains extended: ACT lowland native grassland conservation strategy, Action Plan No. 28. The Action Plan identifies two broad areas of known habitat, one in Jerrabomberra Valley - Queanbeyan, and one in the Majura Valley. The site in question is part of the first complex, although it is isolated from the main area. The policy in the Action Plan is to protect these populations, only allowing broad scale development that would not interfere with the species habitat.
- The grassland earless dragon has been recorded in areas around Cooma, but this is thought to be a separate sub-species. No other populations are known, although there may be small isolated populations elsewhere. Surveying for the species is both problematic and costly; FoG members have been involved in such surveys. Unfortunately, the last survey of this site was undertaken in 1999, according to the applicant, and there is no more information about the current status of the species.
FoG is on the public record as being opposed to the development of this site, although sympathetic to the plight of the residents at the long-stay caravan park. Our opposition has been greatly strengthened with the recent crash in grassland earless dragon numbers; for example, poor management at the Majura Field Firing Range has resulted in surveyed numbers there falling, according to our best advice, by 80%. Developments at Canberra Airport have seen removal of individuals and habitat from that site. Elsewhere, the impacts of the drought in the Jerrabomberra Valley, have seen numbers drop by 20%. It has always been difficult to obtain precise numbers for the species, but only several hundred individuals may remain in the wild. This is an appalling picture for the species survival and, in the circumstances, FoG's view is that all remaining habitats should be protected.
If the proposed works and subsequent developments were to be allowed - which FoG does not support - it is critical that the area subject to works/development is minimal, that as much habitat is conserved as possible to protect and buffer the species from the proposed land use, and that a regime of effective management is put in place to enhance habitat and species conservation outcomes in the long term. FoG's experience, gained from observing management on Defence lands at Majura and the Canberra Airport, is that conservation management is not guaranteed if left in private or inexperienced hands.
Yours faithfully
Kim Pullen
President
3 August 2007