ACT Planning and Land Authority

ACEPDcustomerservices@act.gov.au

 

DA 202240416, Block 1 Section 65 Throsby, Proposal For Estate Development Plan - Throsby District Playing Fields

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 native 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 is deeply concerned that yet again there is to be a direct loss of another 2.47 ha and over 8 ha indirectly impacted Yellow Box – Blakely’s Red Gum Grassy Woodland and associated derived grassland, a critically endangered community (CEEC), as a result of damage caused by drainage works required to protect the playing fields. We are disappointed that additional habitat for threatened species, in particular Superb Parrot, is being lost in the Throsby development area. Additionally, some of the required works occur within the Nature Reserve, likely causing damage within this protected area. Changes to the drainage may also impact the wetland south-west of the playing fields, which provides habitat for a rare wetland species.

It is therefore probably, as stated in the Drainage Works ESO report by SMEC (2021), that the proposed works will have a likely impact under the Environment Protection and Biodiversity Conservation Act for the CEEC.

If this development is to proceed as stated we urge the highest level of protection be given to the remaining vegetation and habitat, as follows:

1. Consideration of whether this wide and intrusive drainage line is the only option to mitigate against flooding of the playing fields, given the degree of damage it is likely to cause directly to the woodland and indirectly within the reserve and to the south-west of the block.
2. The entire area that will not be developed or disturbed must be fenced off to prevent any off-site damage caused by vehicle movement, dumping of materials or equipment or inadvertent trampling to those areas.
3. Full consideration of any damage within Mulligans Flat to be planned for and avoided.
4. As identified in the ecological report, weed invasion will be a significant response to ground damage, , and will require significant on-going treatment. Many invasive weed species likely to become prevalent after soil disturbance, particularly African Lovegrass, Wild Oats and other annual grasses, are a significant fire fuel hazard, creating high levels of dry herbaceous biomass in summer, much greater than the biomass of native grasses. It is therefore prudent to retain as much native ground flora as possible to reduce the impact of weeds and resultant need to control these weeds into the medium to long term.
5. Replanting in the urban open space be only those species that are endemic to the community. Tree species should be a selection of those species surveyed on site: Yellow Box (Eucalyptus melliodora), Blakely’s Red Gum (E. blakelyi), Apple Box (E. bridgesiana) and Brittle Gum (E. mannifera), typical of the now critically endangered grassy woodland which was the naturally occurring vegetation community in this location. To maintain habitat for woodland species we urge that plantings only include endemic native species that occur within this location, using locally sourced parent material, as per the list of species identified in the surveys. FOG does not support planting native species that are not characteristic of this community, including Scribbly Gum (E. rossii) or River She-oak (Casuarina cunninghamiana), which is not a small tree. Where possible endemic shrubs particularly Silver Wattle (Acacia dealbata) should be planted to provide additional habitat for Superb Parrot, smaller birds and other fauna, thus retaining some potential for connectivity between remnants between Mulligans Flat and areas to the south, east and west of Throsby.

In conclusion, FOG draws attention to the statement in the Drainage Works ESO, that: ”Despite potential significant impacts to a CEEC and potentially to threatened fauna and flora species, the Project is seeking consideration of an ESO under this provision”, p. 29. FOG believes a full Environmental Impact Assessment under the EPBC Act is required on the basis that:

1. it will include significant destruction of 2.46 ha CEEC and habitat for species and likely impact on a further 8 ha;
2. the proposal will modify groundwater, surface water drainage patterns and soil nutrient levels, all of which may affect the CEEC on the project area and off site;
3. the project will incorporate drainage works within the nature reserve; and
4. there is no evidence that alternative options have been considered that will provide mitigation against flooding but reduce the impact on Mulligans Flat Nature Reserve, the CEEC within the block and downstream in the wetlands to the south-west.

Yours sincerely

Sarah Sharp

Vice President, Advocacy Coordinator

26 August 2022