Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Canberra International Airport
1/2 Brindabella Circuit
CANBERRA AIRPORT ACT 2609
Dear Ms Howship
Canberra International Airport preliminary Draft Master Plan 2008
Friends of Grasslands (FoG) is writing to provide comment on the above DMP. 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 conservation of grassy ecosystems, and carries out surveys and other on-ground work. FoG is based in Canberra and its more than 200 members include professional scientists, landowners, land managers and interested members of the public.
While FoG recognises CIA's emphasis on environmental management - especially its green building design and waste/water management - FoG and informed others have ongoing concerns about biodiversity management, specifically the conservation of natural temperate grassland (NTG) and associated threatened species, particularly the grassland earless dragon (GED), at the airport. FoG notes that these issues are mentioned in the DMP, and that references are made to related documents (the CIA Environment Strategy and Grassland Management Plan).
FoG is aware that airport land is leased under the Airport Act, and that ACT legislation does not apply strictly. However, the Environment Protection and Biodiversity Conservation Act 1999 (EPBC ) does apply and the protection provided for NTG and GED and other relevant threatened species under that legislation is consistent with ACT protection. FoG's view is that conservation strategies in place in the ACT are relevant, especially given processes such as recovery planning (across jurisdictions) under EPBC. FoG made a submission on the proposed transfer of Defence land for a proposed road (see below, EPBC ref 2007/3756) and has also written former/current Commonwealth Ministers for Environment about that proposal as an example of concerns about administration of the EPBC Act.
FoG has particular concerns about the following.
Conservation of NTG. Two NTG remnants - at the airport site and adjacent Majura Training Area - are the highest quality remnants of that type in the Majura Valley, and two of the largest in the ACT. The airport site is a category 1 or 'core conservation site', warranting the highest level of protection. Taken together, the greater remnant, at its eastern edge, adjoins another threatened ecological community (yellow box-red gum grassy woodland) in one of the few remaining examples of this natural concurrence in the ACT. FoG's view is that these remnants should be conserved intact, and managed primarily for conservation in the long term.
The proposed major road on the northern edge of the airport site [not yet approved] will fragment the remnant in a way that the existing narrow gravel track, now infrequently used, does not: the stated intention of seeking to minimise likely impact by 'position[ing] where possible on existing roads' is not honest. Apart from the scale of likely roadworks and ongoing use/maintenance, further fragmentation of the NTG remnants will increases the pressure on the both the community and its threatened species.
The proposed runway extension [apparently already approved] is also likely to cause significant impacts on NTG, and potentially on GED habitat. The lack of observations of GED in this area in recent years does not mean that the species is not still present; the site conditions have been very poor because of drought.
While FoG notes that CIA has employed recognised grassland ecologists, it is unclear in the DMP how use of 'more precise' mapping of 'different [grass] qualities' will help with conservation of NTG. Such mapping appears of little use, given the CIA's clear intentions to deal with inconveniently located remnants by destroying or moving or reinstating them to areas of lesser quality. The potential of securing local offsets, in the case of proposed further loss/degradation is not even mentioned.
FOG also has reservations about the mowing regime at the airport which, as far as we are aware, makes it hard for plants in grassland areas to seed and regenerate.
The conservation management of NTG should be part of a wider management plan for the entire Valley, including formally reserved areas and areas such as at the airport, managed through effective planning and implementation of agreed actions. Effective planning would adopt an adaptive approach - based on good science and monitoring.
Retention of threatened species. CIA should be managed to conserve the habitat and the occurrences of all threatened species on site. Action Plan 28 identifies NTG at the airport site as including three threatened species - GED (key habitat), the Perunga grasshopper and the golden sun moth. FoG has concerns about the adequacy of the 'updated protocol' for the management of GED as it appears to be about 'rescuing' by relocating unfortunate individuals (which may simply die in captivity) - not a preferred conservation option.
Continuing development. FoG notes that Action Plan 28 stated that development at the airport had already reduced the area of grassland (since an earlier related Action Plan); under CIA management, the numbers of GED have declined, and the habitat for other threatened fauna species has also been reduced. Action Plan 28 also identified an issue at the airport of resolving planning and development proposals, and the need to identify boundaries of areas to be protected for nature conservation or managed with nature conservation as the primary objective (section 3.6.1). FoG is concerned at the apparent continued expectation that the airport and its infrastructure will continue to expand at the cost of the NTG. 'Salvage' of threatened individuals, or moving/reinstating other elements of NTG (however that is expected to occur), as provided for in the DMP and related documents, are not the answer. There must be firm boundaries placed on 'no go' areas to conserve NTG and associated threatened species in the Majura Valley, including parts of the airport site. And all remnant sites in the Valley - whoever is responsible for them - must be managed consistently.
Finally, FoG continues to be concerned that suggestions it has made to CIA over many years have been largely ignored, including to:
- avoid development that destroys NTG, threatened species habitat, or areas that connect them
- enter into genuine dialogue with the ACT and Commonwealth governments about good management practices, such as through an MoU
- publicise areas of NTG and GED habitat at the airport, and develop displays to raise public awareness
- develop gardens, and carry out landscape restoration, focussing on NTG plant species, e.g. a low water garden consistent the original vegetation - FoG emphasises again that tree/shrub planting of areas of NTG (of which CIA is so proud) is inappropriate
- recognise that developments at the airport should comply with principles of no‑net-loss, which would mean finding offsets (e.g. securing others areas of NTG and fauna habitat) to compensate for destruction of these natural assets at the airport, and
- contribute to research aimed at securing the recovery of NTG and threatened grassland fauna.
FoG is keen to understand how documents like any existing Master Plan, Environment Strategy and Grassland Management Plan, are working to conserve NTG and threatened species such as GED. FoG suggests that reporting on the effectiveness of strategies/actions contained within such documents is made public so that the DMP is provided in context of reality.
FoG participated recently in the ACT Commissioner for Sustainability and the Environment's inquiry into ACT grasslands. FoG's view is that formal processes - such as finalisation of this DMP - should wait until the Commissioner has reported, so that recommendations can be considered and followed up as appropriate.
27 February 2008
cc Cth Minister for the Environment
ACT Chief Minister
Deb Fosky, ACT MLA
Mick Gentleman, ACT MLA
ACT Conservator of Flora and Fauna
ACT Commissioner for Sustainability and the Environment
Limestone Plains Group
 A vision splendid of the grassy plains extended: ACT lowland native grassland conservation strategy: Action Plan No 28 [Action Plan 28] (ACT Government), sections 3.4.6 and 3.5.1
 Action Plan 28, section 3.5.1: sites of high botanical significance, containing key threatened species habitat and being large sites
 Action Plan 28 at section 3.6.1