General Manager
Queanbeyan-Palerang Regional Council
email: council@qprc.nsw.gov.au

 

Dear Sir/Madam

Draft Bungendore Structure Plan 2018-2048

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 has members in surrounding New South Wales. Its members include professional scientists, landowners, land managers and interested members of the public.

FOG recently visited Turallo Nature Reserve (NR) and Gidleigh Lane Travelling Stock Reserve (TSR). Our view is that both areas are excellent examples of native grasslands and need to be conserved and managed for their conservation values in perpetuity. We note that these areas are shown as temperate montane grassland in map 8, and their importance is discussed on page 21 of the Draft Structure Plan. We also note that the Turallo Nature Reserve Plan of Management states that "Turallo Nature Reserve protects one of the region’s best examples of Natural Temperate Grassland of the Southern Tablelands, an endangered ecological community listed under Commonwealth legislation. It has a particularly high native plant species richness, with around 100 species being recorded".

FOG welcomes the greater recognition of the environmental values in the Bungendore area in this updated draft of the Bungendore Structure Plan, including identification of areas which are constrained due to their environmental value. However, we do have a couple of concerns about the document.

The draft Plan shows one of the proposed bypass routes going through Gidleigh Lane TSR. This will impact negatively on the threatened grassland community in the TSR by destroying the vegetation along the proposed corridor. There will be even more impacts because of further fragmentation of the grassland area. We strongly urge that this possible bypass route be abandoned and only routes that don’t destroy connectivity between Turallo NR and the adjacent grassland and woodland in the TSR be considered.

It appears from the maps that a mineral resources future investigation area may overlap with Turallo NR. While we believe that all or part of the Nature Reserve would need to be degazetted by parliament before development could go ahead in the reserve, we would like to draw your attention to the need to provide for adequate buffers around the Nature Reserve and TSR to minimise impacts from any future adjacent potential industrial and residential developments. When adjacent to high conservation areas, such developments inevitably lead to long term impacts on the conservation areas due to fire management to protect the development area, invasion by weeds and garden escapees, illegal dumping, collection of timber for firewood, and so on.

FOG supports the further mapping of areas of grassy ecosystems in the Bungendore area mentioned on page 22. Our understanding is that, as the ecological communities Natural Temperate Grassland of the South Eastern Highlands and White Box-Yellow Box-Blakely's Red Gum Grassy Woodland and Derived Native Grassland are listed as critically endangered under the EPBC Act (see https://www.environment.gov.au/biodiversity/threatened/publications/natural-temperate-grassland-se-highlands-guide and https://www.environment.gov.au/epbc/publications/white-box-yellow-box-blakelys-red-gum-grassy-woodlands-and-derived-native-grasslands), any development impacting on Turallo NR and Gidleigh Lane TSR will need to be referred to the Commonwealth for consideration under the EPBC Act as well as going through the NSW approval processes.

Yours sincerely

 

Naarilla Hirsch
Advocacy coordinator

30 August 2019