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. 2007/3756

Transfer of Defence land at Majura ACT

 

This project, referred under the EPBC Act, proposes to transfer land from the Department of Defence at Majura to the Department of Transport and Regional Services for on-sale to Canberra Airport Group (CAG) which proposes to construct an access road into the airport. The road construction stage will potentially affect an endangered ecological community ('high quality Natural Temperate Grasslands') and four threatened species listed under both EPBC Act (one critically endangered, two endangered and one vulnerable) and ACT legislation - the golden sun moth Synemon plana, the striped legless lizard Delmar impar, the grassland earless dragon Tympanocryptis lineata pinguicolla and the button wrinklewort Rutidosis leptorrhynchoides.

 

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 over 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 development may lead to significant impacts relevant to EPBC follow.

• An endangered ecological community and four threatened species occur on the site. The community and these species continue to be threatened by other proposed works in the Majura and Jerrabomberra valleys, and elsewhere in the ACT.
• Agreed conservation management of known and already protected populations on Defence/Canberra Airport land has failed to protect the community/species; most recently this has been through other construction and also overgrazing by the local kangaroo population. Whether or not the land that is not subjected to road construction is under future Department of Defence or CAG management, FoG remains concerned for the conservation of the community/threatened species.
• The 'alignment and size' of the road are 'yet to be determined', which means that the future extent of road construction works and, therefore, medium to long term affects on the community/species, is not known. What is known, is that this type of construction activity - involving as it does significant earthworks, import of road base/fill, significant drainage works and placement of a perimeter fence - is potentially extremely damaging to fragile grassland, component plants and resident ground dwelling reptiles and insects. It is certain that any road will have significant impacts and not a comfort to read that simply the 'scale will be determined by negotiation between [CAG] and DEW'.
• Future impacts of related works are unknown, i.e. possible widening of the road to three lanes, and construction of a gravel management track.
• Once the land is transferred, the Territory Plan will not apply. However, the Territory Plan provides land use coverage including reference to conservation measures in the ACT (such as the relevant Action Plan[1] which addresses protection and management of the community/species). Given that the EPBC Act and Airport Master Plan are not delivering good conservation outcomes for the threatened community/species, FoG is very concerned that this current 'protection' will be removed. 

FoG is very concerned that, although this proposal is just the first stage in the project - which (together with on-sale) does not directly physically threaten the community/species, CAG's expectations regarding road construction will be being raised as these decision steps are taken. FoG's view is that no implicit commitment to final approval for road construction on any alignment should be given until further information is available on the actual intentions regarding construction (i.e. placement and extent).

 

FoG is keen to ensure long term conservation outcomes for lowland native grassland remnants and the threatened species they contain. There appear to be various purposes for the proposed road, which should become clearer in a proposal seeking approval for construction. However, FoG's view is that further development of land in/around Canberra Airport 'to [improve] commercial development opportunities' is not supportable; the grassland is far too valuable to the local, regional and national community for conservation. A solution to the current traffic congestion - caused to a significant extent by commercial development to date at the Canberra Airport, approved without sufficient mitigation - should be found without destroying more grassland.

 

Threatened grassland and species are being lost - forever - through many 'small' decisions; this is an alarming example of cumulative impacts not being resolved through environmental protection legislation. FoG looks forward to your consideration of these comments, and effective administration of the EPBC Act.

 

Yours faithfully

 

 

 

 

Kim Pullen

President

18 October 2007

 

1] A vision splendid of the grassy plains extended: ACT lowland native grassland conservation strategy, Action Plan No. 28