Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
26 September 2008
Commonwealth and Territories Section
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
CANBERRA ACT 2601
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
Extension of Taxiway Bravo, Canberra International Airport
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 the 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 closely followed matters at Canberra Airport, as outlined in our most recent submission to you dated 5 May 2008 which was a response to earlier stages in the application process on this matter.
Before commenting on the draft recommendation, FoG welcomes the fact that the Commonwealth has allowed that matter to be dealt with under the processes provided by the EPBC Act, whereas on previous occasions, matters involving the airport have bypassed the EPBC Act processes.
FoG wishes to express its appreciation of the quality of the background material released with the recommendations. This has been most helpful in our deliberations. This material clearly points out the serious destruction of areas of Natural Temperate Grassland, an endangered ecological community, and habitat for the several fauna species mentioned. That material also clearly shows that the Grassland Earless Dragon (GED) has undergone further serious decline in recent years in the area of the airport. That, and the large GED declines elsewhere, raise serious concerns about the long term survival of this reptile, and underscores that there is some urgency to undertake strong remedial action.
Reluctantly, FoG supports the recommendations for the construction of the taxiway in principle, recognising that this action is one of a series of actions which has, over time, allowed the Canberra International Airport to destroy areas of NTG and habitat for GED and other threatened species.
FoG welcomes the requirement, as FoG has advocated that offsets be required and that these must be submitted before approval to proceed is given. It agrees that the offset ought to include setting aside areas of NTG and Golden Sun Moth habitat, and funding suitable research into the affected fauna. The recommendations do not say anything about the monetary value of such offsets. FoG believes that these offsets ought to be commensurate with the huge destruction of NTG and fauna habitat, and it believes that the nature of these offsets should be made known before any approval is given. As a matter of good faith, offsets offered should also include an element for past destruction. FoG also supports the concept of a Construction Environment Management Plan to mitigate the impact on areas surrounding the construction area. This is consistent with FoG’s recommendation on mitigation outlined in our letter dated 5 May.