Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Jamison Centre
Macquarie ACT 2614
email: advocacy@fog.org.au
web: www.fog.org.au
Re. Request for reconsideration of decision under section 78 of the Environment Protection and Biodiversity Conservation Act 1999: South Canberra Memorial Park (EPBC 2019/8595)
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.
Friends of Grasslands is gratified that the Environment Minister has determined that the development of a private crematorium adjacent to and linking with Callum Brae Nature Reserve, on Block 1 Section 3 Symonston be reconsidered as a controlled action.
It is our understanding that the environmental impacts of these works are substantially greater than were originally described by the proponents due to amendments to the development application, and as such, warrant reconsideration of the referral decision. We refer in particular to the reasoning provided in the Reconsideration Requests submitted by the Friends of Callum Brae Nature Reserve and Margaret Roberts and in summary identify the following concerns:
1. Natural values of the area have been understated and misrepresented
- The previous use of this area has resulted in substantial changes to the understorey, but many very old hollow bearing trees remain on site, providing important habitat for a range of native species, including the critically endangered Superb Parrot and endangered Gang-gang Cockatoo, which are known to inhabit the site. It is not unlikely that other rare species also utilise the woodland.
- The woodland is a key component of landscape connectivity between critically endangered Natural Temperate Grassland in the valley, to critically endangered White Box - Yellow Box – Blakely’s Red Gum through to open forest on higher slopes. As such, many species including invertebrates, reptiles, macropods and birds have the opportunity to range across large areas. Such landscape- scale natural ecosystems are now poorly represented in ACT and the region.
2. Substantially more activity is proposed than stated in the original Development proposal
- It is understood that the frequency of operation and expected noise and other outputs is significantly greater than was first described. In addition to impacts on human health, it is likely to impact the quality of habitat for native fauna.
3. Alternative uses are possible to meet legislative requirements for recovery of threatened matters
- With increasing importance to provide protection of threatened matters under the EPBC Act there are opportunities to substantially enhance the ecological condition of this site to increase the quality and extent of the critically endangered Box-Gum Woodland and of habitat for critically endangered and endangered species. This area could be used as a woodland park, with paths and information provided to users, while retaining its substantial conservation values.
We urge, on the basis of environmental considerations that were not provided in the original application, that development of a private crematorium complex on Block 1 Section 3 Symonston should be considered a controlled action.
Yours sincerely
Professor Jamie Pittock
President, Friends of Grasslands
18/8/2024