Referral Business Entry Point, EIA Policy Section (EPBC Act)
Approvals and Wildlife Division
Department of Sustainability, Environment, Water, Population and Communities
GPO Box 787
Canberra ACT 2601
email: epbc.referrals@environment.gov.au

 

 

Dear Sir/Madam

 

Development of the Future Urban Areas of Kenny and Throsby, ACT

Reference number: 2012/6279

 

Friends of Grasslands (FOG) is a community group dedicated to the conservation of indigenous 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 more than 200 members include professional scientists, landowners, land managers and interested members of the public.

 

FOG is concerned about the proposed development for Kenny and Throsby as it will impact on critically endangered White Box – Yellow Box – Blakely’s Red Gum Grassy Woodlands and Derived Native Grasslands, the critically endangered Golden Sun Moth Synemon Plana vulnerable Striped Legless Lizard Delma impar and Superb Parrot.  The population of Striped Legless Lizard in Kenny is of significant size, and thus of importance from a conservation perspective. In addition the old-growth Yellow Box, Apple Box and Candlebark trees in Kenny, which are a remnant of a highly cleared vegetation association that forms a component of the White Box – Yellow Box – Blakely’s Red Gum Grassy Woodlands on deep soils in valleys, need to be carefully considered.

 

The referral makes reference to avoidance and mitigation of environmental impacts as part of the “Environment Protection and Biodiversity Conservation in Gungahlin: strategic measures to avoid, mitigate and offset impacts of development” prepared for the ACT’s Economic Development Directorate by Umwelt & SMEC (2012). As this document is not available as part of the public consultation material, we cannot judge whether or not the proposal does “optimise long term conservation values and development potential through conservation reserve selection and design…” or that “ the significance of the impact is reduced from what may have been the case”. Nor do we have information about what the avoidance, mitigation and offset proposals are. We believe that such a document requires public consultation and scrutiny by the scientific community before being implemented. Consequently, we oppose assessment of this referral under the “Merit Track” and request that it be assessed under the “Impact Track” process, requiring an Environmental Impact Statement and full community consultation.

 

We believe that to consider this referral out of context with all other development of Gungahlin, relying on environmental information from the 1980s to identify suburb boundaries and then considering each one independently is ecologically, economically and socially unsound. We call on the ACT Government to prepare a study for all remaining land in Gungahlin, including Throsby, Kenny and Moncreiff to identify areas for development, for retention as core conservation areas and for broadacre land use. Such a study requires the incorporation of expertise from the broader scientific and conservation communities and should be fully open and accountable. The study should also consider the Throsby Denominational school site and the Throsby Playing Fields proposals.

 

We reiterate views expressed in our January submission on the Throsby Denominational School Site, Gungahlin (2012/6251) and other recent submissions in the Gungahlin area:

• This is yet another example of piecemeal development proposals that in the end have a negative impact on grassland and box-gum grassy woodland biodiversity without adequate consideration of alternatives;
• A strategic approach needs to be taken to developments in the Gungahlin area; and
• The ACT Government’s offset policy and Gungahlin Strategic Offsets Package need to be made available for public scrutiny to ensure there is full understanding of the process for establishing and funding offsets. 

In conclusion, FOG asks that:

• There be no further development in Gungahlin until a strategic approach to grassland and box-gum grassy woodland conservation in Gungahlin is identified that has included input by the scientific and conservation community;
• An environmental impact statement be required for any development in areas of higher conservation value in Gungahlin, including Throsby and Kenny, and also Moncrieff.

Sincerely yours

 

 

 

John Fitz Gerald

President

 

29 February 2012