Referral Entry Business Point
Environment Assessment Branch
Department of Sustainability, Environment, Water, Population and Communities
GPO Box 787
CANBERRA   ACT   2601
email: epbc.referrals@environment.gov.au

 

 

Dear Sir/Madam

 

Mugga Lane Solar Development, ACT

Reference number: 2012/6670

 

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.

 

While FOG is sympathetic to the objective of building an ACT facility for generation of 2.2 MW of clean, renewable, photovoltaic power, it is concerned about the potential environmental impacts of the proposal for the following reasons:

• FOG is aware that there is a predominantly exotic understorey in some of the land surrounding Mugga Land resource centre. However, the detailed field survey in the Biodiversity Review was undertaken in May. Late autumn is not a good time to be surveying for grassland plants or for the threatened birds that potentially could occur in the area (identified in the submission as Swift Parrot, Superb Parrot and Painted Honeyeater). Such surveys should be undertaken at appropriate times of year (in Spring in the case of understorey species) to make a true assessment of whether or not this segment meets the EPBC criteria for Box-Gum Woodland or for dependent threatened species.
• FOG’s view is that the proposal area should be considered as part of the wider Box-Gum Woodland of which it is part, rather than as an isolated segment. The current proposal takes little account of connectivity other than a brief mention of the eucalypts on the site possibly being used by woodland bird species moving through. However, the width of the corridor to be removed is not small, and may impact on connectivity between Callum Brae Nature Reserve and areas to the west. This habitat connectivity was identified in the ACT Government’s Southern Broadacre Planning Study Final Report (February 2005).
• In responding to this development proposal, FOG notes that it is the second development proposal in the Mugga Lane area within a month, the other being a proposal for extending Mugga Lane landfill put forward on behalf of the ACT Government. The impact of these two proposals together in terms of loss of Box-Gum Woodland and mature trees providing habitat for a range of species and connectivity across the landscape is more significant than is discussed in the current proposal. FOG’s view is that a strategic approach to developments in the Mugga Lane area/Jerrabomberra Valley needs to be taken, rather than a series of piecemeal developments with cumulative effects.

For these reasons, FOG’s view is that this development should be a controlled action.

 

Sincerely yours

 

 

 

John Fitz Gerald

President

 

18 December 2012