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

Reference: 2018/8151 Mugga Quarry overburden expansion project, ACT

Friends of Grasslands (FOG) commented on the original referral for this project. In those comments we stated our in principle opposition to any development proposal that impacts on our native grassy ecosystems and hollow bearing trees. We also put the view that, if the project is allowed to go ahead, it should be a controlled action with appropriate offsets, so we are pleased to note that it considered a controlled action.

FOG supports the proposed additions to Boral’s EMP. Given the uncertainty about future seasons, particularly in relation to climate change, FOG would like to reiterate it’s statement from our original submission: the proposed planting needs to have some commitment to long term care to ensure its survival if it is to be of any benefit. We note that the EMP changes include “the scale of planting more than matches the loss of saplings and shrubs”, but we still think that the conditions of approval should include a requirement that the successful planting does actually, in the long term, exceed the loss of saplings and shrubs. This will take account of losses – as we know a large percentage of plantings can fail in dry conditions.

While noting that the proposed offset site “has been endorsed by the ACT Conservator of Flora and Fauna”, it is not clear to FOG why a site outside the ACT is being considered, nor whether alternatives inside the ACT were considered. For example, was any consideration given to expanding the size of Kama Nature Reserve?

There is a paucity of information about the proposed offset site. Is it part of a much larger protected grassy woodland area? What are its ecological values? What improvements will be made as part of the offset package to ensure no net loss across the landscape? Where exactly is the offset site? What are its current ownership arrangements and what long term protection will be provided? What compensation is being offered for the loss of ten hollow-bearing trees?

As stated in our original submission, FOG is concerned about the cumulative impacts of such developments in the Mugga Lane area. It is not the first project to impact on the box gum grassy woodland and, in particular, the large hollow bearing native trees along Mugga Lane. While we accept that essential infrastructure may have impacts on our endangered species and ecosystems at times, and that at least some of the quarry outputs may fall into that category, but remain concerned about the cumulative impacts of “essential” developments in this area over the long term and would like to see some consideration of the area from a long term strategic perspective.

Yours sincerely

 

Geoff Robertson
President

4 March 2019