Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
Canberra ACT 2601
email: epbc.referrals@environment.gov.au

 

 

Dear Sir/Madam

 

Bango Wind Farm, NSW

Reference number: 2013/6810

 

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 but has many members from surrounding areas of New South Wales. Its members include professional scientists, landowners, land managers and interested members of the public.

 

FOG notes that, through the process of developing this proposal, turbines and access tracks have, where possible, been located away from threatened Box-Gum Woodland and other areas of conservation significance.

 

FOG supports the proposed mitigation measures, including weed control and revegetation with local native species. However, there is no timeframe mentioned over which the revegetation is to occur. FOG’s view is that such weed control and revegetation activities need to continue until independent ecological monitoring has ascertained that any areas containing remnant native vegetation or habitat in which degradation caused by construction activities has occurred have been restored to a defined level of ecological integrity. From other projects it has become clear that such restoration activities need to be done well and continue for some time if they are to be successful. Ongoing measures to prevent the spread of weeds into high quality areas traversed by the access tracks are also necessary if these areas are to maintain their value. Prevention is likely to be much more cost effective than restoration.

 

In relation to the significant impact on the Golden Sun Moth (GSM), FOG’s view is that no development should proceed if it has such an impact on an endangered species. In the event that the proposal does go ahead, FOG makes the following comments concerning the GSM and offsets. FOG could not, from the information provided, determine which of the GSM sightings in Figure 3a have the higher density moth populations. The way the GSM sightings are clustered raises the question of whether, by relocation or removal of a couple of turbines, the impact on known GSM populations of higher density could be further reduced.

 

On the offset strategy itself, FOG notes that it is still to be developed and will meet both NSW and Commonwealth requirements. In FOG’s view, offsets should always be in place prior to construction commencing.

 

Yours sincerely

 

 

 

 

Sarah Sharp

President

 

10 April 2013