Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Referral Business Entry Point, EIA Policy Section (EPBC Act)
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
CANBERRA ACT 2601
I am writing to provide comments by Friends of Grasslands (FoG) on EPBC referral 2008/4170, a proposal for taxiway extension at the Canberra International Airport.
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 advocated for grassland conservation and good management in the Majura Valley - including at the Airport site - over many years. For example, in recent months FoG has commented on:
- referral of transfer of Defence land to CIA (2007/3756) to build a northern access road), in October and December 2007
- a preliminary Draft Master Plan, in February 2007
- relevant aspects of protection/management of the grassland re adequacy of EPBC administration, in letters to the Cth Environment Minister and others
- relevant aspects of protection/management of the grassland in recent submissions to the ACT Commissioner for Sustainability and the Environment's grassland inquiry.
FoG continues to be frustrated by the failure of planning and conservation legal and policy measures - and lack of political will - to protect these grasslands.
FoG's comments on this referral are as follows.
Although we acknowledge that some planning for development has already occurred, FoG's view is that it was not sufficient. For example, the vegetation significance categories used (such as in the 'Airport Environment Strategy and Grassland Management Plan' see 7.1) have not reflected the extent or values of the remnant grassland. Therefore, an assessment of significance of impacts of the proposed works is inadequate.
As with the proposed northern road (ref 07/3756) asserting that aligning works along 'existing gravelled paved surfaces' or 'partly on the existing airside road' will minimise impacts is not comforting. The extent to which the proposed use of access roads for construction expands the impacts of the current use is not clear. In the case of the northern road, the leap is from an informal track to potentially a six lane highway.
Criteria for deciding where to place the 'airside security fence and airside road' are confusing. At 3.1, the referral states that these 'will be constructed to meet aviation security requirements and minimise the impact on the surrounding environment ...' [FoG emphasis], but at 6 under 'Grassland' the referral states that these 'will be constructed prior to works commencing to minimise the impact on grassland ...'. FoG is not sure to what extent the 'safety' requirement may compromise the environmental intent here, but it is likely that it will.
At 4.2(h) the referral states that the population of grassland earless dragons (GED) 'has diminished significantly' due to 'prolonged drought and the effects of overgrazing' (on adjacent Defence land). CIA does not acknowledge that past developments have reduced the area of habitat resulting in likely and actual loss (relocation) of individuals. Developments at the Airport have been a progression of harm to the endangered community and its species. FoG would also like to have more information on whether the recent monitoring is indicative of extinction of GED at the Airport site; if so, perhaps CIA has already failed in its obligations to conserve, as part of their agreed management of Airport land. FoG would like independent verification of the potential for the works site as GED habitat (see 7.1)
The referral fails to indicate what the loss of 10.8ha of grassland (i.e. the endangered community - in its 'varying quality' - with its associated species and habitat it provides, not simply the 'loss of grasses' as stated at 5.1(d)) really means in the overall picture of remnant grassland on this site: part of one of the largest remnants of this grassland in the ACT which intergrades into another endangered community of box/gum woodland, a unique example of connectivity. That is, the referral underplays the significance of loss. Unfortunately, it provides yet another (and very good, in this respect) example of 'death by 1000 cuts' which the current planning and decision making system results in.
Even if FoG (and concerned others) are unable to prevent the works in this location because of what has gone before, rather than the merits of this case (i.e. remnant natural values), the potential for collateral damage to areas adjacent to the works site is worrying. There is insufficient evidence of adequate mitigation proposed.
For example, under '6'.
- Regarding GED, in outlining the locate → identify → record → relocate (likely leading to death) procedures, there is no reference to working with the ACT Government's own experts who are experienced and have an obvious role here; why not?
- Regarding the Golden Sun Moth, the three points are not about 'minimising impacts' but rather monitoring. What is the status of this species here, and how will it be protected?
- The simple heading 'Grassland' does not convey the probable occurrence of the endangered ecological community on the works site. This is the first mention of a 'works area depot', which is not otherwise discussed/mitigated; such a facility must be placed so as to not damage/degrade otherwise unaffected grassland. This is also the first mention of 'clearly mark(ing)' adjoining areas to 'avoid vehicle damage and spillage of spoil; such marking will not be as effective as well placed and adequate fencing to prevent movement of vehicles.
- 'Induction' of personnel is a start, but who exactly? All managers/workers on site should be informed/trained to understand the values of the area and how to protect them, and FoG suggests that there should be specific responsibility given to supervisors and contractors; in the latter case that, if mitigation measures in contracts are breached, there will be a significant financial disincentive that will be used to remediate any damage caused. However, the emphasis should not move from prevention to simply monitoring and correction (fixing a habitat site ripped up by machinery is too late).
Some example approaches to adequate mitigation, based on recent proposed development affecting grassy ecosystems in Canberra and FoG responses follow:
- minimise the need for disturbance
- get experts to assess the appropriate type and location of fencing to protect adjacent areas - all fencing should be specified to be constructed from within the works site
- rehabilitate/revegetate disturbed areas within the works site sensitively and appropriately using local grassland species, and avoid introduction and spread of weeds
- no services (including temporary arrangements) should be routed through adjacent areas of quality grassland/habitat
- no runoff or debris should be directed at the areas of quality grassland.
Finally, although beyond the scope of this proposal, FoG supports the use of generally accepted (including by the Australian Government) 'no net loss' vegetation management policies, and will be advocating for the inclusion of such in the upcoming review of the Nature Conservation Act 1980. The special qualities of remnant, endangered natural temperate grassland and box-gum woodland in the Majura Valley will be lost forever if planning decisions continue to be made on Airport, and Defence, land that result in loss of or damage to various bits of them (small and large) in succession. FoG's view is that a proposal such as this is the type that should not proceed without an adequate offset being provided for by the proponent, in this case perpetual protection and conservation management of a similar (in quality and size) area of natural temperate grassland close by. FoG supports the ACT Government's intention to secure and manage grassland habitat in the Majura Valley, and beyond, despite it being slow to act on its own relevant Action Plan (No.28).
FoG remains unconvinced that CIA either understands or seeks to act in a way that conserves or adequately manages natural temperate grassland and its associated species at the Airport site, despite its commitments and claims of environmental sensitivity. FoG does not support this proposal without significant improvements in mitigation to prevent at least off-worksite impacts, i.e. to protect as much as can possibly be protected if these works really must proceed for safety/carbon emission benefits.
FoG understands that the Limestone Plains Group is writing to your Minister on this matter, expressing concern about the lack of an integrated approach to planning and development between Australian Government departments/agencies. FoG supports this view, and also supports such integration across jurisdictions. Such an approach would need to not only integrate departmental/agency/project objectives, but also those of ecologically sustainable development.
Finally, FoG's position continues to be that the Australian Government should delay any decisions under EPBC relating to grassy ecosystems in the ACT until the ACT Commissioner for Sustainability and the Environment completes and reports on her inquiry into grassland management and conservation. Recommendations from the inquiry will hopefully provide direction for future decision making, including in the Majura Valley.
6 May 2008
cc AG Environment Minister
ACT Chief Minister
Deb Foskey, ACT MLA
Mick Gentleman, ACT MLA
ACT Commissioner for Sustainability and the Environment
ACT Conservator of Flora and Fauna
Limestone Plains Group
 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)