Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Attention: Relevant Officer, Molonglo Strategic Assessment, ACTPLA
Friends of Grasslands (FoG) sought a short extension to comment on these ToR today, but did not receive a response. Accordingly I submit the following very brief comment (and recycled attachment) as FoG has very limited resources, as already noted.
Also already noted is FoG’s ongoing interest in proposed development in the Molonglo Valley and significant investment of effort to date, e.g. in preliminary assessment and Legislative Assembly Committee inquiry processes. FoG’s concern re the ToR is that they cover the range of issues that FoG has already identified in its submissions to earlier processes, for example see attachment based on our submission to the Legislative Assembly inquiry. Please note that I am not up-to-date with the exact ACT Government proposal currently (e.g re moratorium) so apologies if any of the content is no longer relevant.
FoG is heartened that the ACT and Australian Governments have taken this opportunity to work strategically together regarding EPBC implications of the proposal.
20 October 2008
Attachment to comments on draft ToR for SEA Molonglo/Nth Weston
Friends of Grasslands comments re draft ToR on SEA
Terms of reference for the SEA should be broad enough to consider the following.
Ensure that any proposed developments
- are consistent with principles of ecological sustainability
- protect ecosystem function
- avoid or minimise destruction of native vegetation and habitat, particularly threatened woodlands and grasslands and other areas of high conservation value, and suitably buffer such areas
- include specific methods to ameliorate threats to riparian vegetation, especially the river she‑oak community, habitat for the pink-tailed worm lizard and declining and threatened bird species (e.g. suitable fencing to reduce human impact)
- avoid any lake that would destroy pink-tailed worm lizard populations, riparian communities, or habitat for threatened and declining bird species and small mammals
- meet the social and broader environmental needs of the population, e.g. for an aging population, to provide efficient public transport, to increase water efficiency and reduce wastage, and to reduce or preferably avoid greenhouse gas emissions.
Ensure that any further planning and public 'consultation' process is satisfactory, and builds on previous processes. Ministers/agencies/decision makers should all note the very limited resources available to community participants. Accordingly, FoG suggests that its previous submissions to both ACT and AustGovt processes should be considered in any strategic assessment.
Ensure that any proposed developments consider the recommendations of the CC report on the impacts of the proposed developments on endangered woodlands - see below.
Prevent unacceptable potential extent of loss of remnant Box Gum Woodland noting the following. FoG is very concerned that:
- the ecological assessment on which the previous planning proposals were based were inadequate
- the concept of ecologically sustainable development is not even understood let alone integrated into the planning
- the recommendations of the ACT woodland conservation strategy (e.g. Action Plan 27) and the NRM Plan, namely to retain and improve Box Gum Woodland remnants, are not being pursued through the planning proposal for the Molonglo valley
- opportunities to retain and enhance critical remnants may be missed - given the status of these woodlands, the ACT's priority should be to retain and strategically restore them, to improve their condition and extent in line with its own and national policy
- the ACT has no system to assess the extent of potential biodiversity loss and to calculate a remedy (e.g. via offsets), similar to those available in other jurisdictions e.g. NSW and Vic (see further below)
- the inconsistencies between ACT and Cth legislation - leading to differential assessment of values of Box Gum Woodland remnants - have not been dealt with in planning, strategically; given the extent of loss of Yellow Box - Blakelys Red Gum Grassy Woodland and derived native Grassland, the significance of the remnants is obvious and referral under the EPBC Act will be required.
The need for offsets. FoG accepts that there will be cases where natural values will be lost or degraded because of community acceptable developments, but this should only be in exceptional circumstances, and should be offset adequately. Other Australian jurisdictions have updated native vegetation legislation and seek to achieve 'no net loss', for example by: prohibiting clearing, especially of vegetation listed as threatened; and providing for clearing only where there is an offset.
The CC report includes an effective assessment of offsets required to address the extent of clearing proposed in Molonglo (using Victorian and NSW approaches), and makes a very strong case for not only retaining Kama and Central Molonglo in perpetuity (i.e. not to reconsider development of the latter after a moratorium period, ever), but also conserving additional, 'equivalent' areas. Effective offsetting begins with recognising the values of the resource (in this case threatened Box Gum Woodlands), assesses the extent of potential loss to biodiversity, and seeks to minimise and then offset any actual, unavoidable loss.
FoG also notes, and supports, the need for not only securing offset areas, but providing for their active conservation management in the long term. In the case of Central Molonglo, there is also a need to retain its values during the moratorium period, to ensure that deterioration because of neglect does not become a reason to develop it later (as its subsequent quality is no longer considered high enough to warrant protection). Effective management for conservation will need stronger lease clauses for the rural land involved, possibly through Conservator's Directions.
FoG advocates for improvements to ACT conservation legislation (via the Nature Conservation Act 1980 review) to include an appropriately precautionary approach to future clearing, the principle of no net loss, a quality biodiversity assessment system and strong offsetting provisions. Hopefully, such a legislated approach will support better planning in the future.
Placement of the proposed suburban boundaries. FoG's view is that development of Central Molonglo should not proceed, ever, and the intention to gather further information simply defers a decision on this. Given the status of Grassy Box Woodlands (already 95% cleared) and continuing threats to remnant native vegetation across the ACT landscape, FoG suggests that the appropriate time to remove this development option is now. Similarly, with the information reported by CC, FoG supports reducing/avoiding clearing of the Box Gum Woodland and increasing the area proposed to be conserved - whether in reserves or on private lease under long term conservation management agreement - centered on Central Molonglo and including:
- woodland in the south-east section of North Weston, adjoining Tuggeranong Parkway
- woodland in the southern section of East Molonglo
- woodland in the north-east section, adjoining the arboretum
- native pasture between Kama/Deep Creek
- woodland to the west of Straith Nairn.
This approach seeks to retain the integrity of remnants (including shape and size), achieve connectivity between remnants and other areas of native vegetation, and provide opportunities for restoration. This would work towards ecological sustainability. FoG recognises the complexity of managing urban area/reserve edges and buffers - to protect conserved areas - and emphasises the need to factor these into planning as early as possible, including to minimise edge effects.
If proposed monitoring and evaluation of the natural resource values of the area including of vulnerable species (as advised in the moratorium announcement) does proceed, FoG is concerned about whether resources are available and the approach proposed will be adequate.
 based largely on FoG's submission to the ACT Legislative Assembly inquiry of earlier in 2008
 Proposed Molonglo urban developments and their significant impact on endangered woodlands: a report prepared by the Conservation Council ACT Region, June 2008