Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614

email: advocacy@fog.org.au
web: www.fog.org.au

Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601
email: epbc.referrals@environment.gov.au

 

Dear Sir/Madam

Blocks 4 and 5, section 38, Campbell

Reference number: 2014/7372

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 is opposed to this development in its current form. While recognising the commercial and planning imperatives, we do not consider the development to be compatible with the future viability of the endangered species and communities on and adjacent to the site.

The development area is next to a significant population of the endangered Hoary Sunray (Leucochrysum albicans var. tricolor). While this population has persisted adjacent to a low density office and carpark, it is almost certainly going to be impacted, if not totally destroyed in the long term, by the proximity of high density residential and commercial developments. Although this population is not within the leased area, no allowance is made for the fact that it adjoins the area and, as a consequence, will be heavily impacted by the proposed development. This impact could be mitigated by fencing or other barriers but the concept plan does not provide for either.

The proposal will impact on an area of Natural Temperate Grassland (NTG) listed in Action Plan 281 as an area of conservation category 2. While the area may not seem large, it is significant for two reasons. Firstly, quite small areas of NTG can persist and remain viable in the long term if managed appropriately. Secondly, this area of NTG is in fact part of a larger area on the adjoining block. Destroying this NTG area will impact on the long term viability of the NTG patch on the adjoining block.

The referral acknowledges the possibility of the Golden Sun Moth (GSM) occurring on the site, but does not address the impact of the development may have on any GSM population within the whole area. In particular, issues such as the significant reduction in GSM habitat and impact of much higher density usage need to be considered.

The referral ignores the possibility of the vulnerable Perunga Grasshopper being on the site, even though it is discussed on pages 6 and 9 of Biosis’s Revised Ecological Due Diligence Assessment (Attachment C of the referral).

FOG’s view is that the entire site labelled CC01 in Action Plan 28 needs to be considered as a whole. A full ecological assessment of the entire site (not just the area of this referral) should be undertaken, before any further steps are taken or decisions made regarding the referral site. This assessment should include not just the condition of the entire site, but also an assessment of what would be needed to restore the entire area and protect the several matters of NES involved.

The Revised Ecological Due Diligence Assessment suggests (p10) that

the proponent is likely to seek an Environmental Significance Opinion (ESO) from the Conservator of Flora and Fauna for the current Master Plan which involves the removal of a portion of the western patch of Natural Temperate Grassland.

Should this occur FOG would like to see serious consideration given to ways to avoid or minimise the adverse environmental impacts of the development; for example, a reorienting and redesigning of the buildings on site to avoid any loss of NTG and any impact on the Hoary Sunray population adjacent to the site. A reworking of the masterplan should not only avoid or minimise adverse environmental impacts but also result in improved solar orientation of the buildings: a win-win for the environment and the development.  FOG does not consider an offset to be an option for this site.

 

Yours sincerely

 

 

 

Sarah Sharp
President

5 November 2014

 

1.              ACT Government (2005) ‘A Vision Splendid of the Grassy Plains Extended – ACT Lowland Native Grassland Conservation Strategy’. Action Plan 28. Environment ACT, Canberra