Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Macquarie ACT 2614
EPBC Act Public Portal
To whom it may concern
Campbell Park Car Park Consolidation Project
EPBC Number: 2022/09354
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 native 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.
The proposed development area is an integral part of one of the nation’s most important remnants of critically endangered vegetation and threatened species habitat. This location places major constraints on any development works and requires that such works be sensitive to the surrounding values, and well considered. This proposal more than doubles the car parking space and clears hundreds of trees, including 87 remnant and 23 hollow bearing trees and several hectares of threatened woodland bird and insect habitat. The scale of this proposal is neither sensitive or justified and will result in a significant environmental impact. It should be rejected, or at the very least subject to the production of an environmental impact statement. Ideally a proposal more in keeping with the values and location of the site and which avoids significant impact will be developed.
The wider context in which the development sits
The Campbell Park Offices sit inside the Mt Ainslie-Mt Majura Box Gum woodland-Natural Temperate Grassland complex that is of national conservation importance because:
- the complex contains some of the largest most diverse patches of critically endangered grassland and woodland in the country;
- wildlife connectivity to Mt Ainslie-Mt Majura and then onto Goorooyarroo, Mulligans Flat and the Majura Defence Training Area and from these areas to the western woodland flyway and the Great Eastern Ranges, make the Campbell Park area a part of one of the best connected box gum woodland patches anywhere;
- it is one of the nations’ largest, most diverse and high condition examples of the transition or ecotone between natural temperate grassland and Box-Gum woodland;
- it supports an extremely high abundance and diversity of threatened animals and plants; and
- it is a key woodland bird breeding habitat.
Lack of Justification for works
The proposal contains no justification why a more than doubling of the current car space is needed. Nor does it contain a rationale as to why the carpark footprint can’t retain major clusters of remnant and hollow bearing trees, and at least some of the planted foraging habitat. Currently there are few days when parking is not available on site either on tarmac or the designated overflow area. In five visits over the last few weeks at various times of the day there has always been many vacant parking spaces. Certainly current usage does not seem to justify the scale of works and environmental impact proposed.
Also it is unclear whether alternative such as introducing paid parking (to encourage public transport or carpooling) have been considered.
Missing and understated values of the proposed development area
Woodland bird habitat
The ecological assessment states that only 14 native birds were observed on site. This considerably understates the usage and value of the development site to woodland birds. One hundred and five native bird species have been recorded within the proposed development footprint via recordings on Canberra Nature Map. There are further native bird species recorded via ebird. These include the nationally endangered Gang-gang and nationally vulnerable Superb Parrot; the Scarlet Robin, Varied Sittella, White-winged Triller and Little Eagle that are all listed as vulnerable under ACT legislation and the Dusky Woodswallow, Speckled Warbler, Southern White-face, and Flame Robin which are listed as vulnerable in NSW. In addition the NSW listed Diamond Firetail and Barking Owl have been recorded in woodland immediately adjoining the site. Campbell Park is a known breeding habitat of most of the listed birds along with a suite of other woodland birds now uncommon in the ACT such as the Double-barred Finch and Jacky Winter. These birds will forage across the development footprint and, for some of the threatened and uncommon birds, at least parts of the proposal area will be within breeding territories. Rather than existing in isolation the development footprint is an integral part of the local woodland bird habitat. Some of the planted eucalypts such as Yellow Gum (Eucalyptus leucoxylon) and Mugga Ironbark (E. sideroxylon) provide a flowering resource not available elsewhere in Campbell Park. The loss of a few hundred remnant and planted trees would be a significant reduction in the local foraging resources.
It is also relevant that the development footprint could be managed much better than it currently is, with greater care provided to improve the health and vigour of the existing trees, and enhancement of bird habitat through additional plantings of small trees and shrubs. Thus the proposal would not only result in loss of important woodland habitat utilised by many woodland bird species but would remove the potential of the site to be enhanced.
Gang-gang breeding habitat has not been considered
The Gang-gang has been listed as nationally endangered since the completion of the ecological impact assessment and the potential impact of the proposal on this species is inadequately addressed. This is a significant omission. In the ACT, Gang-gangs have been known to nest in hollows that are between 3 and 12 m in height, have an entrance height of between 7 to 48 cm and an entrance width of 7 to 32 cm. There are tens of hollows within the development footprint that have these dimensions. A Gang-gang pair is currently breeding in a dead tree 122 m to the north of the development footprint. This photograph of the two newly hatched chicks and egg in the nest was taken earlier this week.
This nest is one of only about 70 known across the Gang-gangs entire range. About two-thirds of all the known nests are in nesting clusters and it is likely that other pairs are nesting within the Campbell Park area, including within the development footprint. Gang-gangs are quite tolerant to people and vehicles with several nests within 20 m of houses, or along busy walking and cycling tracks, next to tee-off areas on golf courses or adjacent to carparks.
Ecological assessment did not mention nearby Little Eagle nesting
The ecological assessment did not mention that in recent years a Little Eagle pair has nested either in trees on the north side of Fairburn Avenue or in a tree about 50 m south of Northcott drive close to the development footprint. A lot of heavy machinery noise and activity at the time when a nest site is being selected or used may be disruptive to their breeding.
Underestimate of the extent of Golden Sun Moth habitat within development footprint
It would appear that no Golden Sun Moth survey occurred across the proposed development area and an assumption was made that the moth would only be found in that part of the site that remains or once was Natural Temperate Grassland. Until quite recently it was thought that the moth was confined to grassland but in recent years many surveys and sightings have found the moth in open woodland, including on the nearby lower slopes of Mt Majura. The moth has also been found to be widespread across the Goorooyarroo and Mulligans Flat reserves in woodland with a similar canopy cover as found across the un-developed parts of the proposed development footprint. Most of the area mapped as Box Gum woodland in Figure 8 has an understorey dominated by either Wallaby or Corkscrew grass, both known food plants of the Golden Sun Moth. Patches of Chilean Needlegrass, another known food plant, occur elsewhere. Thus until surveys can prove otherwise it should be assumed that the development footprint contains at least 3.38 ha of habitat of the vulnerable Golden Sun Moth and not the 0.38 ha mentioned in the report.
Understates the importance of the presence of the Coconut Ant
As described in the Ecological Impact Assessment the footprint contains at least two colonies of Coconut Ant (Papyrius sp,). The EIA also notes that the Small Ant Blue Butterfly (recorded on Mt Ainslie) is an obligate breeder, in that its eggs and caterpillars can only survive within an ant colony. Less than ten breeding locations are currently known for the Small Ant Blue anywhere and all but one of the locations are in the ACT. There are at least two species of Coconut Ant in the ACT and both seem to be utilised by the Small Ant Blue. Coconut Ants have a distinctive nest and have been comprehensively surveyed for across the Mt Ainslie-Mt Majura complex. Only 11 other colonies were recorded in addition to the two in the development footprint.
Within the ACT, Mt Ainslie is also one of just two recorded locations of the Bronze Ant-blue (Acrodipas brisbanensis). It is also thought that the caterpillars of this species also eat Coconut Ant larvae and require the ant for its survival (see Suzi Bond - Field Guide to the Butterflies of the ACT).
Significant Direct Impacts of the Proposal
The direct impacts of the proposal include:
- Clearance of nearly 3 ha of Box Gum woodland, 2 ha of which meets the criteria of being part of the national critically endangered community and the last hectare could be managed in a way that it could meet the criteria in a few years, as has been the experience for hundreds of hectares elsewhere in the ACT of what was recently similar condition woodland;
- Clearance of 3.38 ha of potential Golden Sun Moth habitat, a nationally vulnerable species;
- The loss of 23 hollow bearing trees in which woodland species currently nest, shelter and drink from. Nationally endangered Gangs-gangs are currently known to nest just outside the development footprint and may utilise trees hollows within the development footprint;
- The loss of 87 remnant trees and an unspecified (but well over a hundred) number of planted trees that are a foraging resource utilised by at least ten species of threatened woodland birds. For some of the species, such as the Gang-gang and Dusky Woodswallow, this usage will be both regular and prolonged;
- The loss of a significant proportion of the potential breeding habitat of the Small Ant-blue and Bronze Ant-blue on Mt Ainslie; and
- The loss of 0.38 ha of habitat of vulnerable Striped legless lizard and Perunga grasshopper.
Significant Indirect Impacts
The scale of likely indirect impacts is difficult to determine because of the lack of detail in the proposal documents. However they are likely to be significant and include:
- Runoff of sediment, nutrient (tarmac has a high nutrient content) and pollutant (oil etc) rich water will increase from the footprint area both during and after construction. The location, possible channelling and extent of this runoff is unknown but the catchment area is large. Areas subject to runoff are likely to be prone to weed invasion, while the altered hydrology is likely to affect the native species growing in these areas;
- The expanded tarmac will also reduce the water available to trees growing immediately adjacent to the new carpark and may place some of these adjoining trees (and the habitat they provide) under stress and could lead to their death, as is evident by the number of dead trees next to the existing car-park footprint;
- A large expanse of tarmac is also likely to increase reflected heat and raise the temperature of the local micro-climate, which may further stress the adjoining trees and vegetation;
- It is unclear whether the increased carpark footprint will require changes to fuel load and bushfire management activity in surrounding high quality woodland and grassland, but this alone could be a significant impact;
- The noise and construction traffic during construction may interfere in the nest selection and breeding of a pair of Little Eagles that nest locally, while it is not known how they may react to having a much increased expanse of tarmac within their breeding territory; and
- It is unclear whether the new carpark will involve increased lighting and how this light spill may affect usage of the surrounding area by wildlife.
As detailed above the combined direct and indirect impacts of the proposal will have a significant impact, while several natural values and potential impacts have been inadequately addressed. It is also relevant that the footprint sits within and is an integral part of one of the most important woodland and grassland habitats in the country. The scale of the project is inappropriate to the location and values present on the site and is unjustified. The proposal should be rejected, or at the very least subject to an EIS assessment.
Ideally a revised car park proposal that is of an appropriate scale and cognisant to the conservation values present will be prepared. Features of such a proposal would include:
- Retention of all remnant and hollow bearing trees;
- Retention of the majority of planted trees particularly those of good health and size or which provide particularly good foraging (such as the planted Yellow Gums and Iron Barks;
- Use of the trunks and major limbs of any felled trees as “fallen timber” habitat features within retain vegetation within and next to the carpark;
- Retention of the Coconut Ant colonies, and possible enhancement through use of fallen timber;
- Planting of small trees and shrubs to add to the habitat diversity within the Campbell Park office area, while taking into account retention of the key Golden Sun Moth habitat areas;
- Management of retained native vegetation to improve the quality and diversity of the native understorey;
- Design features so that there is no runoff into surrounding vegetation; and
- Design so that no additional bushfire management activities are required in surrounding areas.
Professor Jamie Pittock
8 December 2022