Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Macquarie ACT 2614
National Capital Authority
GPO Box 373
Canberra, ACT 2601
Reference: Draft amendment 88: blocks 3 and 15, section 22, Barton
Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia, included related fauna species. 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 a long standing interest in the site concerning this amendment, i.e. York Park. We have, for instance, responded to several proposals concerning development impacts to the Park in the past, e.g. EPBC referrals 2010/5548 (5 July 2010) and 2012/6606 (19 November 2012 and 21 March 2013 – reconsideration request), and to the NCA’s development application concerning Block 14 Section 22 Barton - Redevelopment of 21 National Circuit - Stage 1 Works. FOG has visited the sites on multiple occasions, and undertook monitoring for the Golden Sun Moth (GSM) (Synemon plana) there in 2008-2009. In Jan 2013 FOG also wrote to the Department of Finance concerning deficiencies in management of the site, in particular weed control.
FOG is appalled by Draft Amendment 88 to the National Capital Plan and the accompanying EPBC referral, and is completely opposed to both proposals.
Under section 1.3, there is no mention of a third MNES involving York Park. A Striped Legless Lizard (Delmar impar) was recently captured on the site, and surveys are needed to understand the population and extent of area occupied by the Striped Legless Lizard at York Park and in adjacent areas.
FOG notes that the report “Proposed Amendment to the National Capital Plan: Block3 3 and 15, Section 22 Barton” (July 2017) briefly outlines, in section 7.4, the main thrust of the EPBC referral document. This section acknowledges the loss of Natural Temperate Grassland (NTG) and of GSM habitat, but does not mention the loss of an actual GSM population that has been reasonably stable and persistent over many years. FOG takes issue with the Umwelt conclusion cited on pages 26 and 30 of this report, that the GSM population is not viable in the long term. Evidence supporting this is not presented in the EPBC referral, and any recent decline in the population is most likely due to poor management of the site.
FOG also takes issue with the statement in the report (p30) that there is an appropriate offset available – in our view the offset is inadequate.
A summary of our reasons for opposing the EPBC referral, and hence this amendment is:
- The reduction in NTG and GSM habitat have come about because of inadequate management, despite earlier EPBC referrals approved with the condition that the block be managed for conservation
- The impact of removal of York Park on the newly-discovered Striped Legless Lizard population in the area has not been assessed
- The scientific values of York Park have not been considered
- The offset analysis significantly understates York Park’s values, so the offset proposal is not clear cut
- There is likely to be a net loss of GSM and NTG in the offset block over time based on past evidence that the Department of Finance lacks the processes to manage such an offset.
- There has been a lack of consideration of alternatives to the current proposal that might retain our biodiversity.
We can provide more information, or a copy of our submission concerning the EPBC referral, if needed.
In conclusion, FOG recommends that draft amendment 88:
- Not be approved as it stands since it supports a proposal that will totally destroy a place where matters of NES are well documented;
- Instead change the land use of York Park to “Nature Conservation Area” instead of “National Capital Use”; and
- Propose that York Park be directly and permanently added to the national conservation estate and managed by an area of government that has expertise in conservation, e.g. Department of the Environment or Parks Australia.
10 September 2017