Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Mr Peter Garrett
Minister for the Environment
CANBERRA ACT 2600
Proposal to transfer Defence land to Canberra Airport Group
In 2007, your Department requested comments under the EPBC Act on the transfer of land from the Department of Defence to the Canberra Airport Group (CAG) to build a road around the northern end of the Canberra Airport. Friends of Grasslands (FoG) made two submissions on this proposal.
FoG is a community group dedicated to the conservation of natural temperate grassy ecosystems in south eastern Australia. FoG advocates, educates and advises on matters to do with conservation of grassy ecosystems, and carries out surveys and other on-ground work. FoG is based in Canberra and its more than 200 members include professional scientists, landowners, land managers and interested members of the public.
FoG opposes the construction of the road, because of likely impacts on an important remnant of Natural Temperate Grassland (NTG). NTG is a threatened ecosystem now existing only as scattered remnants. Many of the suite of grassland species identified in the proposal are also threatened. The proposed road would cut through the middle of the remnant, with the following significant impacts on the NTG:
- direct destruction of the habitat replaced by the road surface
- fragmentation of the remaining parts of the remnant, reducing their ecological viability
- possible weed invasion.
FoG's view is that the proposed conservation agreement is inadequate. Also, long term implications of a road (e.g. ongoing maintenance and likely widening) are unknown. FoG’s view is that CAG has been a poor custodian of land with important biodiversity assets: CAG has progressively destroyed NTG and habitat for threatened species. FoG considers the proposal (land transfer and road construction) unacceptable.
FoG wrote to the then Minister for the Environment in October 2007 about its views on administration of the EPBC Act, and copied you in to that letter as Shadow Minister for the Environment (copy attached),. While noting the practicalities of administering such a complicated piece of legislation for biodiversity outcomes, participating in the process of assessment is very frustrating. FoG was active in commenting on EPBC referrals in 2007, including the above proposal. The key issues we raised in our letter related to: the complexity of the decision process (in the ACT involving the Territory and National Capital Plans, EPBC and Nature Conservation Act 1980, and strategic conservation action plans under that Act - the Majura proposal was provided as an example); application of significance thresholds and the need to address cumulative impacts; the need to implement recovery planning; and opportunities provided by strategic planning.
FoG also noted in that letter the current inquiry into grassland management and conservation by the ACT Commissioner for Sustainability and the Environment. We are aware that the Limestone Plains Group has already sought a deferral of assessment of this proposal pending an outcome from the inquiry, but that this has been refused by your Department; also that LPG has written to you on this matter. FoG supports LPG's position (as stated in our earlier letter), given the issues of good governance (allowing the inquiry outcomes to matter, implementing the related Recovery Plans also under EPBC), the ongoing concerns about management for conservation of grassland in the Majura Valley, and the implication of poor decisions on NTG and related threatened species' conservation. FoG is available for a meeting on this matter, as requested by LPG.
As FoG has already stated, the Commonwealth Government should lead in biodiversity protection and environmental impact assessment, and FoG would welcome the new Labor Government's positive action in this area.
(Mr) Kim Pullen
19 January 2008