Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Mr David Rhind
Commonwealth and Territories Section
Environment Assessment Branch
Department of the Environment, Water Heritage and the Arts
GPO Box 787


Dear Mr Rhind


EPBC referral 09/4748 - infrastructure upgrade and construction at Canberra Airport


I am writing to provide comments on the above proposal. Friends of Grasslands (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 and provided submissions relating to other developments at the Airport, the most recent submission being dated 26 September 2008.


FoG has a number of concerns about the current proposal. The first is the continuing loss and fragmentation of natural temperate grassland (NTG) that is occurring at Canberra Airport.  As FoG’s submission to the Canberra International Airport preliminary Draft Master Plan 2008 (27 February 2008) stated, the proposed road will fragment the remnant NTG in a way that the existing narrow gravel track, now infrequently used, does not. FoG notes that the preferred option for this road will have less impact on NTG than some of the alternatives, but the result will still be further loss and fragmentation of habitat.  Apart from the scale of likely roadworks and ongoing use/maintenance, further fragmentation of the NTG remnants will increase the pressure on the both the community and its threatened species, such as the Grassland Earless Dragon (GED). Some of the proposed developments other than the road will also further fragment remaining areas of NTG and GED habitat elsewhere in the Airport grounds, again threatening their long term survival .


FoG would like to reiterate its ongoing concern about the continuing stream of developments occurring at the Airport, each of which both reduces and fragments the remaining NTG. There must be firm boundaries placed on 'no go' areas to conserve NTG and associated threatened species in the Majura Valley, including parts of the Airport site. The conservation area included in this proposal is a first step in this direction, and FoG supports the proposal to place this area under conservation agreement. However, the size of the area concerned is relatively small, particularly as over half of the land is currently Defence land. Also, the land being offered as offset is smaller (about 18 ha) than the total NTG area being lost (about 23 ha). 


In terms of the Biodiversity Offset Strategy:


Proposal 1:


As noted above, the area being offered is smaller than the area being lost. It is also not clear whether the degraded areas (including the existing road) within the proposed conservation area will be restored to NTG.


Proposal 2:


The proposal to 'investigate methods to rehabilitate an area of exotic and native pasture within the Canberra Airport Lease to meet the definition of NTG' is acknowledged. However, there are no specifics in this proposal, and no undertaking to actually rehabilitate any areas.


Proposal 3:


The proposal  that 'the acquisition of land containing NTG will be investigated for the purpose of long term conservation' is acknowledged. FoG supports any move to set up other areas as conservation areas, but again considers that the proposal in its current form lacks specifics and details about what is meant.


Proposal 4:


FoG supports this proposal, although it is not in fact an offset.


Proposal 5:


FoG supports the ongoing management actions listed for NTG, but notes that this proposal is in fact an existing obligation and as such should not be offered as an offset.


Proposal 6:


The protocol for minimising the impact of work zones needs to be monitored continuously once work commences to ensure that it is adequate and no breaches occur. FoG considers that there should be penalties for non-compliance, as accidental damage during construction has been an issue in the past. Independent monitoring of the construction zone and the use of penalties would be of value in ensuring adherence to the protocol and protect adjacent NTG. FoG notes that this proposal is in fact an existing obligation and as such should not be offered as an offset.


The net result of the offsets proposed is a considerable loss of NTG, and fragmentation of others, leading to an overall loss of biodiversity in the Airport area. The additional area offered as offset is relatively small, and specifics on how this might be restored to a reasonable conservation level are lacking. In the past, FoG has asked that developments at the Airport should comply with principles of no net-loss. While the proposed conservation area goes part way to meeting this principle, the proposed offsets do not fully compensate for the destruction of NTG at the airport that will occur with this development.


Yours sincerely





Geoff Robertson



5 March 2009