Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601


Dear Sir/Madam

Referral no: 2018/8277 Federal Golf Club Retirement Village Project, ACT

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.

Under the Nature Conservation Act 2014, Loss of mature native trees (including hollow-bearing trees) and a lack of recruitment is now a listed threatening process in the ACT. This referral proposes the removal of 19 hollow bearing trees within the project area, with mitigation being relocation into the remaining area of box-gum woodland. FOG argues that, in the long term (i.e. when these structures deteriorate) the nesting habitat for the vulnerable superb parrot will be reduced since there will be a lack of recruitment over time. With the likely impact of climate change being a shift of the superb parrot into the southern part of its range, reducing rather than expanding possible nesting sites in this area will impact on the long term survival of the parrot. While recognising that this threatening process is not listed under the EPBC Act, FOG believes that it is a significant factor in the decline of the superb parrot (and other less threatened bird species) and should be taken into account.

In relation to this referral, FOG notes that the Red Hill Regenerators are of the view that the extent of box-gum woodland to be removed under this proposal has been underestimated. This needs to be resolved before further consideration of this proposal.

In fact, given that box-gum woodland is critically endangered, our view is that there should be no impact on remaining areas of this community, with the possible exception of essential infrastructure, something that is not the case in the current proposal. Chipping away at remaining quality sites, even though each individual impact may appear to be small, can only in the long term have a negative result. In the unfortunate situation that this development proceeds, there should be adequate offsets provided that are effective in the long term, so that the result is no net loss in the threatened species and communities being impacted.

Yours sincerely


Geoff Robertson

29 October 2018