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
Belconnen Naval Transmission Station (BNTS) remediation activity
Friends of Grasslands (FoG) provide the following comments on EPBC referral 2008/4367, a proposal to undertake remediation work at the Belconnen Naval Transmission Station.
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 is not opposed in principle to the removal of hazardous material that threatens human or environmental health, and agrees that such work should be carried out in ways that minimise damage to the environment. FoG is not opposed to remedial work on sites of low or no biodiversity value. However, FoG has serious reservations (see below) about the various proposed remediation activities at BNTS, given that the area is of high conservation value as it contains very significant occurrences of both nationally and Territory listed threatened grassland/woodland ecological communities and species which are fragile and very vulnerable to disturbance. FoG notes that the report states that the proposal is likely to have 'significant impacts' and suggests that every effort should be made to avoid or minimise these; FoG's view is that the report does not adequately address the threats to long term conservation and related management.
Stated land use after disposal of the site. The proposal indicates that Defence is remediating the site prior to disposal, and that subsequently the land will be developed for housing; the emphasis is on avoiding risk to humans. However, FoG understands that the ACT Government - through both the relevant conservation Action Plan and Chief Ministerial statement - is committed to conserving at least part of the current BNTS as a grassland reserve. As noted in the report, the ACT Commissioner for the Environment's recommendations for management of the site also included 'legal measures to protect and preserve the high conservation value of the grassland and species when the land is transferred…'. Accordingly, the need for remediation across BNTS should be considered in that context, as the standard for residential housing may be different from the standard for such a reserve. The report essentially 'writes down' the relative impact of the proposed works against the likely future disturbance for suburban development (see paras 12, 24, 30, 33, 36 and 47.ii. at least); and this is not an honest assessment.
The nature of proposed works. FoG notes that the proposed remediation varies across BNTS in response to the particular risks identified, and agrees with a targeted approach. However, it seems that, at least in some places, the extent of works is beyond what is required. For example, there are very good reasons to avoid disturbance at areas RAC6 (flaked lead paint to soil) and RAC10 (demolition waste in drainage sites) given that these include Natural Temperate Grassland (NTG) and habitat for Golden Sun Moth. It is possible that less intrusive alternatives to what is proposed may be possible, e.g. pickup of flaked paint (avoiding soil removal/disturbance) and removal of demolition without use (or with only minimal use) of heavy machinery in the drainage lines.
FoG assumes that the suggestion (last dot point para7) that disposal of 'abandoned infrastructure' will not be 'within BNTS'.
Mitigation. FoG notes that Defence has an EMS (para 11), but has no idea how that relates to the approach being proposed; e.g. there is some chance that Defence's EMS does not address the particular needs of a significant remnant NTG. Regarding mitigation specified at para 18, FoG suggests:
- all machinery going on site needs to be clean of weed seeds, and a 'brush down' (18.i.) may not be sufficient (e.g. does that remove caked on mud underneath?)
- any new tracks should be avoided (18.ii.)
- any restoration, including use of seed mixes (18.iv.), should be consistent with the protection and long term management of NTG - considering things like source of seed, , species selection and appropriate methods/timing of works.
- the relevant ACT Government grassland specialists should be involved in 'rescue and translocation' (18.v.) which should be avoided wherever possible.
- FoG also suggests the following:
- wherever heavy machinery is proposed to be used, avoid soil compaction and disturbance by use of the smallest/lightest equipment possible, and with rubber tyres if possible;
- wherever excavation is required its extent should be minimised
- if material is to be stockpiled, the NTG and any site or potential habitat for threatened species should be avoided
- if necessary, temporary fences should be erected to limit movement by vehicles across the site
- all contractors should be informed about the natural values being protected at the site before they go on site, and reminded as appropriate with signs on site, and that should be in contracts
- any avoidable damage during the proposed works should be remediated at the cost of the contractor, and that should be in contracts
- any 'imported fill' or landscaping materials should be absolutely weed free (perhaps that is what 'validated imported fill' means).
FoG notes that in some areas (see third last dot point in para7) there is potential to revegetate sympathetically with natural site values; this is encouraged.
FoG's view, contrary to the report, is that it is not easy to remove soil and vegetation, and then 'put the native vegetation back' in native grassland environments. FoG is unaware of any such remedial work being carried out successfully. Such works are likely to lead to a deterioration of the vegetation and the opening up to soil/seed loss and weed invasion.
Ongoing monitoring. FoG supports the concept of follow up monitoring. However, the proposal indicates process rather than specifics for this, and also does not specify the intended response. For this proposal, FoG suggests that monitoring should include at least: weed recruitment; erosion; and success of revegetation.
Ecologically sustainable development. It is unfortunate that the report addresses the 'five principles' so superficially and unconvincingly. For example: integration should have considered the conservation intentions stated in the relevant Action Plan or Recovery Plans for the communities/species further threatened by the works.
In summary, FoG's view is that the proposed mitigation would destroy or degrade areas of threatened ecological communities and species - as listed in the report - without sufficient justification. FoG's view is that before any remediation occurs, this proposal is reworked to protect those significant conservation values.
14 October 2008
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