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.comments@environment.gov.au  

 

Dear Sir/Madam

Morisset Road Extension and Sullivans Creek Retardation Basin, ACT

Referral no: 2020/8822

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.

In responding to this referral, FOG notes that a detailed ecological impact assessment of the proposal is being prepared but is not yet available, and that the proponent proposes to make efforts to avoid MNES as far as possible in the road design.

A particular concern FOG has with this project is the fragmentation of the Striped Legless Lizard population. The referral notes that the project will result in the isolation of the approx. 10 – 30 ha of Striped Legless Lizard habitat that is considered likely to occur in blocks 799 and 800. FOG draws attention to a previous referral that impacted on the Striped Legless Lizard population in block 799 (referral 2010/5750). This earlier referral was approved with offset areas that have since been included in Gungaderra and Mulangarri Grassland Reserves. The ACT Government’s Offset Register reports that the offsets are compliant with the conditions of approval.

FOG has two concerns or questions about the ongoing impacts of developments on the Striped Legless Lizard in this area. The first relates to the cumulative impacts over time of different developments. We have argued before that successive impacts will eventually reduce a population of threatened fauna to the point where it is no longer viable, after which the argument is that the whole area can be developed. Referral 2010/5750 has already impacted on the Striped Legless Lizard population in blocks 799 and 800. This referral will have a further impact, so the question is whether the isolated population that will remain will be viable and what mitigation measures can be taken to ensure its survival? Should there be some assessment of these cumulative impacts?

The second concern relates to the offset for 2010/5750. While it is compliant with the conditions of approval, is there sufficient data available to indicate that this offset has resulted in no net loss of Striped Legless Lizard since prior to the approval being granted? If not, how can a group such as FOG be sure that any offsets offered for destruction of Striped Legless Lizard habitat and fragmentation of the remaining population be effective in delivering no net loss of the Lizard over time?

FOG is also concerned about the other impacts on MNES and is of the view that the environmental assessment data should be available before any decisions about this project are made.

The referral states that it has been lodged in the expectation that it will be determined a ‘controlled action’ to be assessed via preliminary documentation. The referral raises the possibility that it could receive an exemption from needing an EIS and hence be assessed in the Merit Track. In FOG’s view, the referral should be considered a controlled action and should not receive an exemption. The public should be given the opportunity to view the ecological assessment, together with proposed mitigation and offset actions, and to comment on these.

Yours sincerely

 

Geoff Robertson
President

14 November 2020