Purdon Associates
Planning consultants for ACT NOWaste
email: purdons@purdon.com.au

 

Dear Sir/Madam

 

Mugga Lane landfill extension

 

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 members include professional scientists, landowners, land managers and interested members of the public.

 

FOG appreciates the opportunity that was provided to be a part of the group that toured the existing facility and the proposed offset site on 23 November. It was very valuable to gain better understanding of the landfill issues, and to be able to see first-hand the area proposed for development and offsetting.

 

Impact of development proposal

 

In principle, FOG is opposed to any development that impacts upon endangered Box-Gum Woodland. Within the 10 hectares of Critically Endangered White Box-Yellow Box-Blakely's Red Gum Grassy Woodland and Derived Native Grassland, the proposed extension will remove up to 100 mature trees, some of which are hollow-bearing and suitable nesting sites for woodland birds.

 

FOG recognizes that this development may be necessary, given that space at the existing landfill facility is expected to be full in a couple of years. Expansion of existing landfill facilities or development of new landfill sites will reduce natural heritage values, so FOG sees reduction of the volume of material going to landfill to be an important issue. In this context, it supports the ACT Waste Management Strategy 2011-2025, in particular implementation of strategies to reduce waste and recover resources. Even the proposed extension is a temporary solution, given that another solution will be needed in 20 years or so.

 

Proposed offset

 

FOG notes that a possible offset block has been identified, and is pleased to find that rehabilitation of this block has already commenced. FOG has argued in the past that offsets should be in place before construction work commences on developments that impact on endangered grassy ecosystem sites. In this context, the work on eradicating weeds on the proposed offset block is to be commended.

 

In relation to the proposed offset block, FOG notes that it

• Is low in the landscape, so will add to the ACT’s reserve system a particular ecosystem that is not well-represented;
• Is contiguous with Isaacs Ridge Nature Reserve and with good connectivity to Callum Brae Nature Reserve;
• Provides habitat for woodland birds;
• After rehabilitation and improvement in the quality, would be a gain in the protection of high quality box-gum woodland in the ACT and has the potential to offset the loss caused by the landfill extention.

One concern that came to the attention of FOG on the tour was the issue of the current requirement to dig pits for culled kangaroos in Box-Gum Woodland. One such pit, which we understand was not used, was within the vicinity of the offset area. We see it more appropriate that culled kangaroos be taken to the section of Mugga Land landfill that deals with deceased animals, to reduce impact on Box-Gum Woodland.

 

Conditions of development

 

FOG asks that the following be included as part of construction mitigation and the offset package:

• The mature trees in the construction area be removed during autumn or winter, to minimise the impact on any woodland birds or other fauna that might be using them for nesting;
• The wood produced be placed on the offset block to provide ground habitat for other fauna;
• The offset block be added to Isaacs Ridge Nature Reserve, to protect it in perpetuity;
• The quality of the offset block be improved by removal of weeds (particularly from the northern part of the block), for at least two years post-approval;
• Funds be set aside for management of the offset block in the long term (for example, a special-purpose Trust fund could be created, with the interest earned used for ongoing management).

In relation to the last point, secure and long term funding for this offset is essential. Neither the management for Canberra Nature Park nor the volunteer Parkcare groups have sufficient resources for the areas they are managing at present, and certainly would not be able to manage the additional area. Adding dollars to the general funding for Canberra Nature Park is not a secure solution, as future overall budget cuts or priority changes could see that funding disappear. Funding needs to be tied in ways that protect it from future government changes if the long-term goal of offsetting is to be achieved: no net loss across the landscape of endangered Box-Gum Woodland. One way of doing so might be to create the suggested Trust to support an expert bush management team to rehabilitate the site and maintain its values over time (see attached document for a proposal for such a team).

 

Sincerely yours

 

 

 

 

John Fitz Gerald

President

4 December 2012