Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Commonwealth and Territories Section
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
CANBERRA ACT 2601
Narrabundah Long Stay Caravan Park EPBC ref 07/3554
Draft Management Plan
Dear Ms Fletcher
I refer to your email to Geoff Robertson of 22 January in which you requested Friends of Grassland (FoG) comments on the above. We understand that the public comment period has closed - we were unaware of this opportunity as the end of the year is a very busy period in all our lives - but that our comments may still be welcome.
As you are possibly aware, 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 has already provided various comments on the proposed caravan park swap site, including in EPBC and ACT related planning and decision making processes. The following comments are consistent with our earlier concerns.
1.4 FoG is not comforted that there is only a small area (18%) of the identified local habitat area within the site, or that there are 'larger, more botanically diverse areas of NTG and native pasture' in the Jerrabomberra Valley given that the tyranny of small decisions continues to drive loss of significant remnants across the ACT; the cumulative impacts are very significant but not dealt with in current decision processes. If other local habitat were better protected and managed, FoG would be more complacent. FoG notes that 'DEW has requested a draft management plan, including details of proposed mitigation measures and offsets for likely impacts on this species as well as other threatened species ...' (1.1 Background), but that offsets have not been addressed in the DMP.
2.1 FoG notes the range of impacts identified and measures proposed, and comments on a few of them below. As a general comment, there seems to be emphasis on measures/monitoring/correction, and not enough on prevention e.g. through using effective sticks (e.g. real financial loss) if avoidable errors are made: fixing a habitat site ripped up by machinery is too late.
Strategies 1 and 6 (preventing encroachment/intrusion). All fencing should be specified to be constructed from within the project site. A fence 'that cannot be crossed' by cats perhaps should be further specified e.g. electric top wire, top sagging (unclimable).
Strategy 3 (preventing weediness). FoG suggests that the developer is given a list of appropriate species. A site theme could be a local native garden.
Strategy 4 (fire prevention). FoG suggest that while an IAPZ within the site is very appropriate, an OAPZ on the adjoining rural land is not so if it requires site preparation for slashing as that would likely result in disturbance of habitat. The requirement for fuel level to be managed by grazing should suffice. It seems highly inappropriate for fuel management offsite (slashing) to be the responsibility of the caravan park operator.
Strategy 9. FoG supports maintaining and enhancing adjacent habitat, but the management action refers only to 'maintaining' it; that should be fixed.
Strategy 10. FoG is happy to support the broader intention of securing and managing grassland habitat in the Jerrabomberra Valley, and beyond. However, actions at Strategy 10 are existing commitments, already recognised in the relevant Action Plan (No.28), and the ACT Government has been slow to act on them. There is no additional protection for GED habitat, such as a habitat offset, offered in the DMP.
FoG remains opposed to the proposed land swap, especially as an area of known habitat will be destroyed, there are likely to be unavoidable negative impacts on the remainder of the adjacent site, and there is no offset offered.
Another critical concern is that, while until recently the GED population was believed to be somewhat 'secure', poor management (at the Majura Firing Range) and drought have greatly reduced GED numbers at local habitat sites; and proposed development at Canberra Airport is also likely to have significant impacts on habitat. FoG's view is that no actions should be taken, related to GED, until the ACT Commissioner for Sustainability and the Environment has completed her investigation and reporting on grassland management in the ACT, and her recommendations have been accepted.
Further, FoG draws DEW's attention to a recent (18 December) hearing of evidence by the ACT Legislative Assembly's Standing Committee on Planning and Environment into the proposed land swap - see transcript at http://www.hansard.act.gov.au/hansard/2005/comms/plan28.pdf In particular, FoG notes: the evidence of Dr Will Osborne and references to need for further survey, the appropriateness of grazing as a management tool and the relevance of buffers; also, the emphasis by the Conservator (Hamish McNulty) to the need for protection of remaining habitat and connectivity.
FoG is happy to clarify any of these points, and appreciates this opportunity to comment.
(Mr) Kim Pullen
14 February 2008
 ACT Government 2005, A vision splendid of the grassy plains extended: ACT lowland native grassland conservation strategy, Action Plan No. 28 (Arts, Heritage and Environment, Chief Minister's Department, Canberra)