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

 

Dear Sir/Madam

Urban Development of (Part) Block 5, Section 10 Greenway

Referral no: 2016/7781

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.

The ecological community Natural Temperate Grassland (NTG) of the South Eastern Highlands has recently had its listing upgraded under the EPBC Act from Endangered to Critically Endangered, a reflection of the dire straits this EEC is in. FOG is also aware that the condition of a number of the remaining areas of NTG in the ACT are not in good condition and some, in fact, are approaching a critical threshold (for example, see Dr Hodgkinson’s report to the Commissioner for Sustainability and the Environment in 2014, Condition of selected Natural Temperate Grassland sites in urban and peri-urban Canberra). For this reason, FOG regards all moderate and high quality patches of NTG to be significant and needing in depth assessment before any approvals are given for developments that might impact on them. While the Greenway patch is small, it has persisted in the midst of urban development and, given appropriate management, would have the potential to persist longer. It is also one of the only two remaining NTG patches in the Tuggeranong valley.

The area has not been accurately mapped for floristic values recently at the best time of year for such surveys. In this regard, the Umwelt report concludes that floristic values in the Deferred Area are best assessed in spring, from September to November, and recommends assessment of the area during this period, together with a survey for the Pink-tailed Worm Lizard in the area. FOG strongly supports this approach before any further consideration of approval for the proposed development occurs.

In the referral, FOG notes that there are three possible options to progress this development application:

1. Assessment under the ‘Impact Track’ process, requiring an Environmental Impact Statement (EIS);
2. Assessment under the ‘Impact Track’, with an exemption so that an EIS is not required; or
3. Assessment under the ‘Merit Track’ following granting of an Environmental Significance Opinion (ESO) by the Conservator of Flora and Fauna.

Given the critically endangered status of this EEC and the lack of data about the site’s condition that has been collected recently and in the right season, FOG’s view is that an EIS is needed for this referral and that the community should be consulted further in the referral process.

Yours sincerely

 

Naarilla Hirsch
Advocacy coordinator

11 October 2016