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

 

Dear Sir/Madam

Commercial development, the Poplars, Jerrabomberra, NSW

Referral no: 2020/8801

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.

Since its inception, FOG has had an interest in the conservation values of the Poplars and made submission to Queanbeyan City Council concerning the rezoning of the Poplars in 1995. Since that time the adjoining high conservation areas in the ACT have been gazetted as nature reserve. The continuous stretch of Natural Temperate Grassland of the South Eastern Highlands (NTG-SEH) formed by Jerrabomberra East Nature Reserve (NR), Jerrabomberra West NR and the Poplars North and South BioBanking Sites are an extremely important remnant of this critically endangered ecological community and provide essential habitat for several endangered grassland fauna species.

FOG notes that, while over 90% of NTG-SEH at the Poplars is included in the two Poplars BioBanking sites, some of moderate to high diversity remains outside the BioBanking sites and is included in this referral as potentially impacted by future development at the Poplars. This ecological community is now considered critically endangered at the national level – there is so little left that all remnants should be protected, particularly one like this that is part of a larger reserved area of this ecological community. For this reason, FOG is strongly of the view that the NTG-SEH in the south west corner (PCT320 zone 1) should be excluded from future development and should be managed for its conservation values, with the long term aim of improving its condition and including it in the Poplars South BioBanking Site. FOG does not accept that the loss of this area of NTG-SEH can be adequately offset in any way.

This area is also habitat for three threatened grassland species, the critically endangered Golden Sun Moth Synemon Plana, the endangered Grassland Earless Dragon Tympanocryptis pinguicolla and the vulnerable Pink-tailed Worm-lizard Aprasia parapulchella. Again, the presence of habitat for these species that is contiguous with the Poplars South BioBanking Site is an indication of the biodiversity values of the area and FOG believes support the case for managing the area for its conservation values and adding it to the BioBanking Site.

Similarly, FOG notes that, while over 90% of White Box Yellow Box Blakely's Red Gum Woodland and Derived Native Grassland (Box-Gum Woodland) at the Poplars is included in the two Poplars BioBanking sites, some moderate to high diversity remains outside the BioBanking sites and is included in this referral as potentially impacted by future development at the Poplars. Again, this ecological community is now considered critically endangered at the national level, so FOG is strongly of the view that the remnant of Box Gum Woodland in the north east corner (PCT 1334 zone 1) should be excluded from future development and should be managed for its conservation values, with the long term aim of improving its condition and including it in the Poplars North BioBanking Site. FOG does not accept that the loss of this area of Box Gum Woodland can be adequately offset in any way.

The critically endangered Golden Sun Moth Synemon Plana occurs throughout the area, with 16.28 ha impacted by the proposed action as well as the already mentioned areas potentially impacted in the south west corner. The proposed development will result in the clearance of some Golden Sun Moth habitat. While FOG’s view is that there should be no clearance of habitat for threatened species, if it is decided to go ahead with this clearance, perhaps consideration could be given to including PCT320 zone 1 and PCT1334 zone 1 in the Poplars BioBanking Site. There is also the possibility of reducing the corner jutting into the north east side of the Poplars South BioBanking Site, which would reduce boundary effects on the east of this site – more of a concern going into the future with the proposed development abutting the BioBanking Site than it has been in the past.

The proposed development goes right up to the boundary of the BioBanking Site, so the impact of edge effects on the BioBanking Site needs to be considered. Urban development adjacent to conservation reserves introduces risks that are well documented risks, including an increased likelihood of impacts such as nutrient and sediment run off into the adjacent conservation area, spread of weeds and urban planting escapees, an increase in pest birds and mammals with resultant predation on wildlife, accidental damage during construction, and increased use by people. The Biodiversity Development Assessment Report makes mention of provision for the demarcation, ecological restoration, rehabilitation, and/or ongoing maintenance of retained native vegetation and habitat, and of minimising and mitigating construction impacts by measures such as control of potential sedimentation of receiving waterways, of weed introduction and/or spread, of incidental damage to retained native vegetation and habitat, and of pest animal populations. Any conditions of approval should include provisions to ensure that this happens in the long term during occupation as well as part of construction mitigation.

It is essential that any bushfire management zones be included in the development footprint and not in the BioBanking Site, since biodiversity management and bushfire management of an area often differ.

The construction of any development needs to ensure that seed from the serrated tussock infestation isn’t spread more widely, in particular in the vicinity of the BioBanking Sites.

Vegetation plantings in the development area should exclude species that have the potential to spread into the conservation areas.

Yours sincerely

 

Geoff Robertson
President

16 October 2020