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

 

 

Dear Sir/Madam

 

Royalla PV Pty Ltd – Abengoa Solar Project, Belconnen, ACT

Reference Number: 2012/6469

 

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.

 

FOG could advocate that this referral of a proposal to clear up to 60 ha of native vegetation deserves to be unconditionally rejected.  However, FOG appreciates that the underlying objective of building an ACT facility for generation of 20 MW of clean, renewable, photovoltaic power for up to 25 years has genuine environmental positives.  Therefore, FOG would understand a compromise, with development of the facility if there would be no loss of native vegetation (trees or groundcover).

 

In the document “Abengoa Solar Farm Preliminary Environmental Proposal”, it is clearly assessed (section 6.1) that “large patches of EPBC Act listed Box-Gum Woodland (a matter of NES), ... will be directly impacted by the development of a Solar Farm at this site”.  In addition, the rest of the site is covered by native vegetation in the form of grassy woodlands.  FOG presumes that all trees and even grassy groundcover would be totally cleared to make way for dense solar panels if the proposal went ahead.  Even though the current condition of the vegetation is likely to be assessed as ranging from low to high if a full survey were to be conducted, the low level of weeds, the diversity of understorey vegetation and the presence of undisputed significant quality box-gum woodland suggests there would be a major environmental loss if the Solar Farm went ahead on this site.  In addition, FOG is aware from discussions with its sister organisation, the Canberra Ornithologists Group, that the habitat for birds would be extremely impacted; this is particularly concerning since several listed species inhabit the area of Registered Rural Block 1591.  FOG notes that this aspect has been very weakly handled by the preliminary assessment included in this Referral.

 

FOG points out several other major inadequacies with the Referral:

• There is no analysis of alternative sites in the Belconnen region where a solar farm could be built without destroying native vegetation and habitat for native fauna.
• The preliminary ecological assessment, Section 6.1, concedes that “a comprehensive Biodiversity Offset Strategy” needed to “be developed as part of the approvals process to compensate for residual or unavoidable impacts to Box-Gum Woodland and other Matters of NES”.  FOG found no trace of any such strategy in the Referral.
• The Referral is seriously deficient in
  • a)      not discussing issues of environmental connectivity with nearby areas of ACT Nature Reserves and with the West Belconnen Hills zone that is presently part of a major project for woodland regeneration, and
  • b)      not discussing the whole of landscape impact, especially considering that the location lies on the slopes of Central Molonglo (for which previous proposals for residential development were removed for ecological reasons).

 In summary, FOG recommends that, considering potentially huge environmental impacts, the outcome of this EPBC consideration be either total Refusal or possibly a ruling of Controlled Action, requiring preparation of a full EIS including consideration of alternative sites.  In short, FOG advocates that renewable energy installations must avoid conflicting with conservation of native vegetation and fauna.

 

Sincerely yours

 

 

 

 

John Fitz Gerald

President

 

30 July 2012