Commonwealth and Territories Section
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
email: epbc.referrals@environment.gov.au

 

 

Dear Sir/Madam

 

South Jerrabomberra urban development project

Reference Number: 2010/5708

 

In FOG’s view, this proposal is unacceptable in terms of its impact on the endangered ecosystems Box-Gum Woodland and Derived Native Grassland.  The argument in the referral is that, even though the proposed action would remove both Box-Gum Woodland and Derived Native Grassland (approximately 28.6 ha), this would not constitute a loss since the “retention of 44.9ha (or 61%) of the community is proposed to be maintained in a managed open space network. The total extent of the community is likely to increase over time, through the retention of these areas within managed open spaces and changes to the current land management regimes of these areas”.

 

However, this is not a formal offset proposal and there is no guarantee that any increase in the extent of the community would increase over time.  There is no discussion of how the extent of the community might be increased, of what resources might be available to improve regeneration of the poorer quality areas, or of who might undertake this task.  Nor is there any commitment in the proposal to actually ensure that such regeneration might take place (“opportunities to rehabilitate” are not a commitment, particularly when it isn’t clear if this will rely in part on unskilled volunteers via a local Landcare group).  If offsets are to be offered for some of the very small patches that might disappear under urban development, on the basis that they are unlikely to be viable in the long term, these must be put in place before any development proceeds, i.e. regeneration of some of the poorer areas having commenced and shown to be at least partially successful.

 

The concept of connecting up some of the better quality remnant areas and avoiding further fragmentation in the proposal is acknowledged, but FOG does not consider that removing one third of the remaining quality areas and noting “opportunities to rehabilitate” to be anything other than a loss of these endangered ecosystems.

 

Lack of appropriate management of natural temperate grasslands and box-gum woodlands in this area is a major issue and has substantially contributed to deterioration of quality remnants and partial or complete loss of endangered species from the area. In this regard, FOG is aware that the Poplars is in much poorer condition than it was ten years ago. In the 1990s it was a major site for the golden sun moth (GSM), but now the moth appears to be absent from the area. This is an indictment on past management of the site, not a license to develop it. To now ask to develop areas that have deteriorated because of poor management is inappropriate – instead, efforts should be made to restore these areas to their previous condition, with urban development only being allowed in those areas that have been degraded for a long time.

 

Similar comments apply to the Pink-tailed Worm Lizard (PTWL) habitat , even though the loss is much smaller (approximately 3 ha).  From Figure 5, it appears that most of the proposed transport corridors avoid fragmenting further the remaining PTWL habitat. However, some fragmentation will occur, which in FOG’s view should be completely avoided.

 

FOG has some concerns about the accuracy of some of the maps in the proposal, since Figure 2 does not show the grassland and grassy woodland areas in the Poplars, although some are marked in Figure 5.

 

FOG notes that development of management plans is proposed for the protection of the remnant Box Gum Woodland and the habitat corridor, with provision of appropriate buffer zones; strategies to prevent the further spread of invasive weed (particularly during construction periods), appropriate stormwater management standards to minimise pollutants from developed urban areas entering the ecological communities; and strategies for the rehabilitation and enhancement of the remnant communities. In principle these sound fine, but there is little detail in the proposal. For example, it isn’t clear if the buffer zones will be taken out of the degraded areas (as should happen, since these buffer zones are generally managed for bushfire prevention and provision of utilities), or out of the conservation areas.

 

Another concern is the status of the higher quality conservation areas. Such areas should be either placed in a reserve or have a conservation covenant placed on them – generally designating them as urban open space leaves them available for future development.

 

Other issue that should be taken into consideration is the recent release of the ACT Government’s Eastern Broadacre Discussion Paper, which is also out for public comment at the moment. While this addresses areas under a different jurisdiction, the area of the current adjoins part of the area (in particular investigation area J) covered by the discussion paper. The ecological values of areas on either side of the NSW/ACT border should be considered together, not completely separately, to reduce loss of these endangered communities and take account of all connectivity issues.

 

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 more than 200 members include professional scientists, landowners, land managers and interested members of the public.

 

Sincerely yours

 

 

 

Geoff Robertson

President

 

9 November 2010