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 Sustainability, Environment, Water, Population and Communities
GPO Box 787
Canberra ACT 2601
email: epbc.referrals@environment.gov.au

Dear Sir/Madam

Development of Symonston Stage 2, ACT

Reference number: 2012/6320

Friends of Grasslands (FOG) is a community group dedicated to the conservation of indigenous 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 members include professional scientists, landowners, land managers and interested members of the public.

While FOG would prefer no destruction of natural temperate grassland (NTG), it acknowledges that this referral attempts to preserve the larger patches of NTG in perpetuity.† In general, FOG supports the mitigation measures outlined in the referral but does have some concerns about them, as follows.

The first concern relates to the Public Land Management Strategy in the proposal, particularly the lack of identification of resources to implement the Strategy. FOG recommends that a condition of development include provision of resources to implement this Strategy and maintain it in the longer term.† In this context, the ACT Commissioner for Sustainability and the Environment recommended more resources for weed control at this site in her 2009 Report on ACT Lowland Native Grassland Investigation, but FOG is not aware of significant weed control activities occurring on the site.† In particular, grassy weeds such as Chilean Needle Grass, Serrated Tussock and African Love Grass need to be dealt with promptly before they impact further upon the remaining NTG areas. It also isnít clear to FOG if the Public Land Management Strategy will preserve the larger patches in perpetuity. Does this preclude a stage 3 which encompasses the rest of this area Ė after it has been allowed to degrade further so that it loses its ecological significance?

The second concern relates to the effectiveness of translocation of striped legless lizards. In their report, BIOSIS raised a number of questions concerning translocation of the lizard (see section 9.2 of attachment B). While noting that this Striped Legless Lizard tile program would be undertaken by, or under the supervision of, the ACT Government Conservation, Planning and Research Unit, with ethics approval being sought, FOG asks that these questions be taken into consideration to ensure the best outcome both from a long-term conservation perspective and for the individual animals concerned.

As always, FOG considers that these mitigation measures should be in place (or in the case of the Strategy at least have commenced) before development starts.† Improvement of the NTG areas being retained prior to translocation of striped legless lizards could only be beneficial in terms of the survival of translocated individuals.

FOG lives in hope that the quality of this severely stressed NTG area at Symonston will improve (particularly if some weed control is done) over the next few years if managed carefully. FOG's optimism comes from observing that some grassy ecosystem sites around the region have recovered given both more favourable seasons and reduction of grazing pressure.

In this part of the ACT, an important issue is establishing and maintaining a connectivity link between the Majura and Jerrabomberra valleys. Because of past urban development, this can only occur to the east of the airport, at Fyshwick and at this site, although being bounded by major roads detracts from the connectivity value of this site. From a conservation viewpoint, it is important for resources to be directed at connectivity between the Majura and Jerrabomberra valleys, which may or may not include rehabilitation of this particular site. If the development proceeds, perhaps this could be considered as part of the offset package.

Sincerely yours

John Fitz Gerald

President

2 April 2012