Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Campbell Section 5 Referral
Land Development Agency
GPO Box 158



Dear Sir/Madam


Campbell Section 5: Publication of Preliminary Documentation under the Commonwealth EPBC Act 1999


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.


Before commenting on the Preliminary Documentation itself, FOG was wondering why notification of it is still listed under “Previous consultations” rather than being moved to the “Current Consultations and Notifications” section of the LDA’s website. If it had not been listed under the “ACT Community Engagements” website, interested community members such as FOG might have missed notification of the opportunity to comment.


Need for offsets


FOG remains disappointed that any options for retaining the Natural Temperate Grassland (NTG) remnant and the golden sun moth (GSM) habitat were discarded early in the planning process for Campbell 5. As we submitted for EPBC 2012/6292 on 5 Mar, an opportunity to reserve a unique part of our natural heritage in the heart of Canberra has been brushed over. Retention of the NTG remnant, with appropriate signage and educational material about the significance of the area, would have made this site unique – as far as we know, a first in terms of the concept. Retention of the GSM population would be difficult alongside development. A relatively small amount of funding, for weed management in a retained NTG plot, would have been a good offset for the probable destruction of the Golden Sun Moth population in the northern part of the development site. FOG also protests that the NTG remnant was damaged by the excavation of nine test holes, with regeneration not implemented in these areas.


Therefore FOG's comments below on the offset proposal in the Preliminary Documentation papers are presented in an attempt to gain the best outcome for the environment in the face of a development decision that appears to have already been made.


Assessment of offset requirements


FOG notes that an offset assessment has been done by the consultant for the GSM but FOG could not find reference to any assessment for the destruction of the patch of NTG. The recent disturbance due to the current development proposal has impacted on this patch, despite due diligence by those undertaking the work. Prior to this, the Conservation Planning and Research Section of the ACT Environment and Sustainable Development Directorate (formerly known as the Research and Monitoring Unit) has described the area as robust, remaining in a stable condition for at least 15 years. The Commissioner for Sustainability and the Environment visited the site in 2008 and noted that it was approaching a critical condition but was still relatively free of weeds. FOG visited the site in 2009 and was of the view that, with appropriate management, the area could recover and be maintained in a stable condition. FOG considers that, at the very least, calculation of the offset requirements for Campbell 5 should include this patch as well as the GSM and its habitat, as the NTG patch was robust in quality prior to the disturbance that occurred as part of site testing for this development application.


Type of offset


Attachment I Campbell Section 5 Offsets Discussion Paper raises three options as potential offsets:


1.      Incorporation of an existing area of NTG/GSM habitat which is currently not conserved into a natural reserve or area of similar conservation status


FOG accepts the consultant’s view that this option does not appear to be available as an offset to Campbell Section 5 (see below).


2.      Improvement of management of an existing grassland habitat area to enhance its native quality and diversity as grassland or increase GSM numbers.


FOG’s view is that this is the best approach for offset requirements for Campbell 5, but has some concerns about the actual offset – further comments are provided below. FOG supports the offset being applied to NTG and not secondary grassland.


3.      Contribute financially to a research project which has reasonable potential to lead to improved conservation outcomes for NTG and/or the GSM.


As stated elsewhere, FOG has some concerns about this use of offset funding, the reasons being:

FOG also notes that SEWPaC has advised the LDA to develop a direct offsets package.


Possible offset sites


In Attachment I Campbell Section 5 Offsets Discussion Paper five possible sites were analysed in terms of potential to enhance their biodiversity as NTG and/or GSM habitat:


1.      Yarramundi Reach

Over recent years, FOG has put in hundreds of hours at working bees to improve the quality of this site. FOG supports Conservation Planning and Research Section’s suggestion for funding towards the management of this area of grassland with a view to improving its habitat quality and ultimately reintroducing the GSM and the striped legless lizard from captive populations.

However, the report states that this is unacceptable to the land manager, the NCA.


2.      CSIRO Headquarters, Campbell

In FOG’s view, the lack of security of long term conservation status of this site precludes it as an offset site. Conservation in perpetuity is a fundamental principle in offsets – otherwise there is definitely a net loss in our endangered NTG over time.

Rehabilitating the CSIRO site now does not safeguard development here in the future: Campbell Block 5 illustrates this to be a real concern. FOG also notes that the NCA does not favour such an offset. However, if long term funding and management were accompanied by conservation status for the site, FOG submits it could become suitable.


3.      St John’s Church, Reid

Work on the NTG at St John’s Church is already a condition for EPBC referral 2011/5803. Since offsets cannot be used twice, FOG rejects this option.


4.      Yarralumla Open Space and Road Verges

A possible offset noted in the report would be to increase the botanical quality of some of these areas which are not identified for future development and where there is a strong possibility of recolonisation or population increases by the existing local populations of the GSM. The report notes that NCA agreement would be required.

FOG needs further detail to assess this, in particular information about the actual sites proposed, their conservation status, and their condition. Any site that is not already reserved for conservation (or reservation is not proposed as part of the offset) would not be acceptable for the reasons similar to those outlined in 2. above. On the other hand, rehabilitation of these other sites and addition of reservation status could be acceptable.


5.      Glenloch Interchange/Old Caswell Drive

The report notes that Friends of Aranda Bushland have been active here. FOG needs further information to assess whether this is a suitable offset, in particular information about the condition of the site (currently invaded by St Johns Wort, but still has significant natural and heritage values) plus lists of new activities proposed to be used as offset.


In summary, FOG’s view is that options 4 and 5 might be reasonable but more information is needed before either is deemed be suitable. In either case, offsets need to have been secured by the date of any construction commencing at Campbell and creating loss of environmental value.


Size of offset resourcing


The consultant’s report suggests an amount of $100,000 as sufficient offset funding, based solely on the precedent of Forde North from two years ago. FOG considers this a poor reason to set this amount.


Firstly the offset for Forde North was a research project, not a direct offset. There is no indication in the material available to FOG to show how this amount was calculated, or if it would meet the Commonwealth’s current requirements for an offset. At this stage it is also not clear if the offset funding has in fact prevented a net loss of conservation values.


Secondly, offsets are meant to result in no net loss to the environment. There is little point in using the offset calculator with assumptions of restoration of an area of NTG to a quality score of, say, 5, then allocating a fixed amount of funding to it that is insufficient to achieve rehabilitation of the designated area to that level. FOG argues that the offset amount should be based solely on the level of funds needed to achieve the offset requirements. Rehabilitation is more than just removal of a few weeds – it is a more complex management task that may include replanting and feral animal control as well as weed control. The experience at Canberra Airport suggests that $100,000 is likely to be insufficient for Campbell 5.


FOG proposes substantial sums be placed in a special-purpose trust fund to undertake rehabilitation and monitor its effectiveness. At the end of a 3-5 year agreed period if objectives are met yet funds remain, these can be recovered by the developer. Rehabilitation of grassy ecosystems is in its infancy in terms of proved results, and risks need to be borne by the developer, not the environment.


FOG also recommends that rehabilitation work be undertaken by organisations with demonstrated expertise, such as Greening Australia who is already experienced with NTG rehabilitation, maybe even a bush regeneration team as FOG has proposed elsewhere.


In this light, selection of appropriate confidence levels to input into the Commonwealth’s offset calculator is important. Confidence levels are dependent in part on both the amount of funding allocated for rehabilitation work and the quality of the work that is done. The confidence level of 80% used by the consultant in the Preliminary Documentation seems high to FOG. The only precedent mentioned is that of York Park, but in fact grassland rehabilitation is being attempted elsewhere in the ACT. The confidence level cannot be estimated with any certainty until the offset site is decided on and its condition is known. Without that information, FOG considers that a confidence level no higher than 50% is more realistic.




FOG opposes destruction of the Campbell 5 NTG and GSM sites as part of this development proposal; offset-requirement calculations must include the NTG patch as well as the GSM and its habitat. Further work is needed on offset options to determine which, if any, is suitable. Offsets should be secured before any development commences. The offset amount seems to be insufficient to prevent net loss occurring.


Sincerely yours




John Fitz Gerald



12 December 2012