Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Ms Gordana Josipovic
2 Brindabella Circuit
Brindabella Business Park ACT 2609
02 6275 2222
Dear Ms Josipovic
Canberra Airport Environmental Strategy
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 had a long-standing interest in the natural temperate grassland (NTG) and threatened species on the Airport, with the most recent submission being in response to an EPBC referral in March 2009. It acknowledges that the Canberra Airport is managing the NTG and listed threatened species on the Airport in accordance with the Airport’s 2004 Grassland Management Plan, and that the ACT Commissioner for Environment has acknowledged (2009) that the grassland is well managed and is in good condition. However, FOG has not been able to confirm this to its own satisfaction due to lack of access to the area. FOG is also aware that the Canberra Airport is involved with ongoing monitoring and joint venture studies with the University of Canberra concerning the Grassland Earless Dragon and Golden Sun Moth.
FOG remains concerned about the continuing fragmentation and loss of NTG on the Airport. Each new development involves further loss of this endangered ecosystem and of the endangered species that occur in it. The latest development approval requires offsets of 1:3 if the area to be cleared is less than 15 hectares, and 1:5 if the area to be cleared is larger. FOG views these offset ratios as minimal, given the earlier losses of NTG on the Airport for which no offsets were required.
FOG is opposed to the development of the proposed northern road if it involves the loss or destruction of any habitat or results in any fragmentation of the airport grassland from surrounding habitat. The need for the Northern Road as proposed is not clear to FOG, particularly in view of advice from the ACT Minister for the Environment, Climate Change and Water that the ACT Government does not need the road in this form, and from DEWHA that conditions must be meet (including no net loss or fragmentation of Grassland Earless Dragon (GED) habitat). FOG has difficulty in reconciling the proposal to build this road with the “environmentally sensitive manner” of undertaking developments and “ensuring the impact on the environment is minimized” as stated in the draft 2009 Canberra Airport Environment Strategy.
FOG notes and supports the management actions for NTG and endangered species in the draft Strategy, such as weed management, grassland, GED and Golden Sun Moth (GSM) surveys, development of a threatened species management plan and rehabilitation and remedial works. Given the continuing stream of developments occurring at the Airport, each of which both reduces and fragments the remaining NTG, FOG’s view is that 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 Strategy (north of the Runway 17/35 undershoot road) is a first step in this direction, and FOG supports the proposal to place this area under conservation agreement, as long as this provides guaranteed protection from disturbance (a “no go” zone). However, the size of the area concerned is relatively small, and FOG would like to see further commitments to long term conservation in the 2009 Canberra Airport Environment Strategy.
On the issue of remedial works, FOG considers that prevention is a much better outcome for the environment (and ultimately less expensive option for the land manager) than post-damage remedial work. The Strategy could outline the Airport’s strategy to prevent and minimise damage to NTG when developments are being undertaken adjacent to high quality NTG areas. FOG notes that the Management Plan includes a protocol for the retrieval of GEDs from works areas, but is aware that translocation at the moment is not effective and thus any GEDs retrieved from works areas represent a net loss to the ongoing population.
14 December 2009