Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Macquarie ACT 2614
Environment, Planning and
Sustainable Development Directorate Customer Service
GPO Box 158
Canberra ACT 2601
EIS exemption 201800010: Ginninderry, Stage 2 and all subsequent stages in the ACT
Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia, included related fauna species. 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 also has members in surrounding New South Wales.
FOG recommends to the Minister that this approval for exemption from EIS not be granted.
FOG has engaged with matters in the Ginninderry development since they have been in the public domain. It has appreciated the privilege of a seat on the Bush on the Boundary consultation group convened through the Conservation Council (ACT) and has actively participated in considerations of that group.
FOG is well aware of the huge amount of environmental assessment, analysis, publication and consultation that has been undertaken by the Development Joint Venture. This urban development planning aspect is far ahead of any other in the region when it comes to environmental values, and the developers deserve community congratulations about the quality and convictions of intentions and objectives stated in their plans. However, the Suburban Land Agency and Riverview Developments are primarily concerned with developing and selling residential blocks, and much of the associated environmental intention still remains to be implemented.
Our understanding is that an EIS exemption can be granted if “recent studies have adequately addressed the expected environmental impacts of the proposal”. FOG’s view is that, to be adequate, the application needs to build on the studies by releasing, and having at least started to implement, plans for management of reserves and offset areas. Offering general statements about intention for the future of these matters is not sufficient - without details of plans, it is impossible for the Minister to determine the full environmental impacts of the Ginninderry development in the ACT or whether offsets in or out of the ACT are likely to be effective.
FOG also submits that the conditions of EPBC Approval for Ginninderry Stage1 issued by the Commonwealth Department of Environment 1-9-2017, and in force until 2067, must surely be the overriding instruction. That EPBC Approval required many actions to occur before any construction was to proceed on Ginninderry Stage 2 and beyond. From FOG's perspective of the set of conditions, the most important action required to occur is the establishment of the West Belconnen Conservation Corridor (WBCC) and particularly of its Management Plan and oversighting Trust.
Only once the WBCC has been planned, endorsed and approved with the range of authorities involved, and is actually operational, can the possible environmental impacts be known in detail. FOG argues that, at least until the WBCC is operational, each of the 18 or so development stages envisaged in the ACT needs to be assessed via EIS.
FOG is particularly concerned about the following issues that are environmentally significant and need to be addressed with agreed and detailed plans as soon as possible:
- Bushfire management for the WBCC - this has obvious importance for the safety of the future residents of Ginninderry as well as environmental quality in the WBCC.
- Offset management for Golden Sun Moth Conservation Reserves. This must include writing, in conjunction with ACT authorities, a new operational plan to deal with dissection of Jaramlee and West Belconnen Reserves. With NSW Authorities, plans must be written for the proposed Wallaroo Road Reserve.
- The developers acknowledge that Native Grassland areas will be impacted by urban development in the ACT stages of Ginninderry, including some areas assessed to be protected Natural Temperate Grassland. Proposals to deal with these exist in scenario form only (Umwelt 2017, Strategic Assessment Report, section 4.7) for Defined Process Strategies. This a good first step, but clearly remains a MNES and so cannot be EIS exempt. Additionally, FOG's first hand experience is that even small moderate-to-high quality native grasslands can be quite resilient in an urban setting providing they are given a reasonable chance by sensitive management (e.g. mowing regimes) and urban design. In other words, offsetting should be a last resort.
- Similar comments apply to the Pink Tail Worm Lizard. In addition, for this species, the impact of road, track, and sewer building and of bushfire and weed management in the WBCC all need to be prescribed in specific plans before the full impact is known.
- Threats from loss of Hollow-Bearing Trees. The developer was very committed to mitigating this environmental threat in planning Stage 1, even though the nomination of the threat has not yet proceeded to be finally implemented in ACT legislation. For Stage 1, details were released and active community consultation undertaken. FOG hopes that this will continue stage by stage.
- The developer has consistently argued that the long life of the project meant that detailed design of management would be ongoing (e.g. Umwelt 2017, section 2.6.2 that extols virtues of adaptive management). Consequently, future developments in environmental best practice can be taken into consideration.
To summarise, FOG is does not agree that EIS exemption is the way forward. There are extensive issues that require wide participation by not only government and other authorities but also by groups like FOG and individuals with ecological expertise. We cannot say that a merit-track approach to subsequent development stages will necessarily be to the detriment of the environment. However we can advocate that open and transparent planning is likely to give the best result, as onerous as that might be for the Joint Venture. Open process is also consistent with the aspirations of the developer and of government at all levels – consult and engage the community to the maximum extent.
29 April 2018