Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601
email: epbc.referrals@environment.gov.au

 

Dear Sir/Madam

Symonston Estate Stage 2, ACT
Reference number: 2014/7327

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.

FOG has had an interest in the Amtech site for some time. In responding to this referral, we draw attention to our response (dated 2 April 2012 and available on our website) to referral 2014/7327 concerning this site, as many of the issues remain the same.

While FOG would prefer no destruction of natural temperate grassland (NTG), we note that the design of the development footprint minimises loss of NTG on the site, and the proposed use of weed management measures during the development process. However, there are some issues that we feel are not adequately addressed.

The first is the proposed three or five metre wide management buffer along the edge road. It is not clear if the combined buffer and edge road are sufficient to meet bushfire Inner Asset Zone requirements. If not, then bushfire management of the remaining grassland area may not provide the best management from a conservation perspective, thus reducing the quality of the area further.

FOG supports the proposal to prepare and implement a Public Land Management Strategy to manage the areas of the site not developed as part of the proposed action. In our previous submission we drew attention to some of the grassy weeds occurring on the site. It is clear that little, if any, weed control activities have been undertaken since then. The current referral still does not identify the source of resources to implement the Strategy. Given that there are insufficient resources to manage significant weeds elsewhere in the ACT, including on grassland reserves and other areas of Canberra Nature Park, it would be inappropriate for some of these scarce resources to be diverted to this site – another source of funding to manage the site is needed. As we did in 2012, FOG recommends that a condition of development include provision of resources to implement this Strategy and maintain it in the longer term.

The Striped Legless Lizard Targeted Survey (attachment F) states that “From these results it can be concluded that D. impar occurs throughout substantially more of the study area than was previously thought. Moreover … the entire extent of [the study area] …. must be seen to constitute habitat for the species … we consider the population within the study area to be of significance given the considerable loss and fragmentation of habitat for the species within the locality…”. Despite this, the referral concludes that “the proposed development is considered unlikely to have a significant impact on the Striped Legless Lizard” and offers neither offsets nor any mitigation measures (such as rescue of individuals before clearing, as seen in the original proposal) if the development proceeds.

FOG is concerned about the neglect of the site which is contributing to its deterioration over time and the potential consequences of that neglect. Back in2009 the Commissioner for Sustainability and the Environment, her Report on ACT Lowland Native Grassland Investigation, the CSE indicated that “the action needed in the longer term is to allocate more resources to weed control at the site”. It is disappointing to find that noxious weeds (such as Chilean Needle Grass, Serrated Tussock and African Love Grass) on the site have not only not been removed but have, instead, been allowed to proliferate. It is also still not clear to FOG if the Public Land Management Strategy will preserve the remaining patches in perpetuity. Will we, in the future, see a later development proposal which encompasses the rest of this area – after it has been allowed to degrade further so that it loses its ecological significance?

Yours sincerely

 

Sarah Sharp

 

President

23 September 2014