Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601


Dear Sir/Madam

Beatty Hill, Royalla - 5 Lot Residential Subdivision

Referral no: 2021/8974

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

FOG is aware that another development (a quarry) is proposed for an area adjoining the development area for this referral, and that the second referral will be referred to the Commonwealth for consideration under the EPBC Act. As we have argued on numerous occasions in the past, it is essential that development proposals impacting on MNES within the same general area be considered together rather than piecemeal. The latter approach results in a succession of proposals that are individually not deemed to have a significant impact but, if considered together, the impact can in fact be substantial. For this reason, we strongly urge that this referral and the Royalla quarry referral be considered together. The cumulative impact of both proposals needs to be considered to truly gauge the effect on MNES, and the public should be given the opportunity to comment on such cumulative impacts.

The referral states that, of the 120.65 ha of EPBC Act Box-Gum Woodland, 86.93 ha (72%) will be conserved in the Biodiversity Stewardship Site, and a further 30.13 ha (25%) will be retained and protected within the proposed residential lots, leaving just 3.56 ha (3%) of EPBC Act listed Box-Gum Woodland to be impacted by the proposed action. FOG supports establishment of the Biodiversity Stewardship Site. However, we are concerned about both the level of protection and fragmentation of the Box Gum Woodland areas that will be impacted.

While noting that the proposed BC Act Conservation Agreements should protect the remaining Box-Gum Woodland on the residential lots, we are uncertain as to whether in fact their biodiversity values will be retained in the long term. What assurance is there that owners of private lots will in fact undertake the required conservation-focused management measures? How will this be monitored and what will the consequences be if owners do not undertake these actions? If there are such agreements in place on existing residential lots in Royalla, have owners managed the biodiversity values as specified? Has there been any monitoring or assessment to determine if such blocks have maintained their values? Until these questions are answered in a way that demonstrates no loss in biodiversity over time, the areas of Box-Gum Woodland in the residential blocks should be regarded as a loss.

Assuming that the biodiversity values of the proposed residential lots are retained, another impact of the proposed subdivision will be to fragment the areas of Box-Gum Woodland. From the information available as part of the referral, the Box-Gum Woodland patch to the south-east will be split into two by the building envelopes and access roads. Similarly, the Box-Gum Woodland patch in the south of lots 3 to 5 will be largely separated from the Box-Gum Woodland to the north of these lots. Such fragmentation will impact on the long term viability of the Box-Gum Woodland retained on the residential blocks.

While the impact on the Pink-tailed Worm-lizard (PTWL) habitat is smaller, similar comments apply to this threatened species.

In conclusion, while noting that the proposed development has been located in areas where the native vegetation and threatened species habitat is in the poorest condition, FOG is opposed to any non-essential development, such as Beatty Hill, that impacts on our remaining critically endangered Box-Gum Woodland. FOG also thinks that this referral should be considered in conjunction with the referral for a quarry at Royalla, which we understand to be in the pipeline, so that the overall impact of the two developments on all threatened species and ecological communities can be considered.

Yours sincerely

Naarilla Hirsch
Advocacy coordinator

26 July 2021