Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



The Manager

Commonwealth and Territories Section

Approvals and Wildlife Division

Department of the Environment, Water, Heritage and the Arts

GPO Box 787



Dear Madam/Sir


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:

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.


Yours faithfully





Geoff Robertson


14 October 2008


Copied to:

AG Environment Minister

ACT Chief Minister

ACT Senators

Deb Foskey, ACT MLA

Mick Gentleman, ACT MLA

ACT Commissioner for Sustainability and the Environment

ACT Conservator of Flora and Fauna

Limestone Plains Group