Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Referral Business Entry Point, EIA Policy Section (EPBC Act)
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
Canberra ACT 2601
Collector Wind Farm, NSW
Reference Number: 2011/5899
As FOG is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia, we have limited our comments on this development proposal to those aspects affecting natural temperate grassland and box gum grassy woodland. FOG is based in Canberra and is not specifically familiar with the area being impacted by this proposal. However, there are a few comments we would like to make on looking through the provided material.
First, we are not entirely clear on the specific area of EEC-affected habitat, nor of the larger TSC-affected habitat, as the numbers appear to be different in different places of the referral and the attached biodiversity assessment. As there will be an impact on EEC-defined habitat, we consider that the development should be a controlled action.
We note that the referral attempts to minimise locating infrastructure in areas identified as moderate to very high conservation value, and support the suggestion in the referral to seek input from an ecologist when the final infrastructure siting is decided. Something not clear to us from the referral information is any impact of the development on connectivity of the medium and high conservation areas, which should also be considered in the final siting.
We support the sourcing of local provenance native species in rehabilitation of areas disturbed by the works, and suggest that rehabilitation work be undertaken by experts in the bush regeneration field to ensure that rehabilitation is effective and appropriate. Any rehabilitation of either these disturbed areas or of any offset area should be monitored in the longer term, and continued until these areas are restored to a higher conservation value. In addition, monitoring should identify where weed control has not been adequate so that remedial action can be taken quickly, a particular concern given the presence of serrated tussock and other noxious weeds in adjoining areas.
We note reference in the document to an offset plan “to ensure a ‘maintain or improve’ biodiversity outcome. Large areas exist within the site boundary that if properly managed can assist with the recovery of this community”, with mention of improving connectivity of woodland. In principle, FOG’s view is that there should be no development that impacts on vulnerable or endangered species habitat or ecosystem communities, However, if the current proposal goes ahead, we think that offsets must be in place before construction commences. This would include any conservation covenants needed as part of the offset plan being in place, and rehabilitation of any offset area having commenced. While the project has a life of about 30 years, a conservation covenant in perpetuity would be part of a net gain for this endangered community.
John Fitz Gerald
11 April 2011