Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Referral Business Entry Point, EIA Policy Section (EPBC Act)
Approvals and Wildlife Division
Department of Sustainability, Environment, Water, Population and Communities
GPO Box 787
Canberra ACT 2601
Development of future urban areas Jacka (North), Taylor and Kinlyside
Reference no: 2012/6350
Friends of Grasslands (FOG) is a community group dedicated to the conservation of indigenous 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.
FOG is concerned about the proposed development as it will impact on critically endangered White Box – Yellow Box – Blakely’s Red Gum Grassy Woodlands and Derived Native Grasslands and on the critically endangered Golden Sun Moth Synemon plana. In considering this referral, FOG appreciates that the potential impact of the proposed development has been reduced by exclusion of Kinlyside and parts of the northern areas of Jacka and Taylor from development. However, we note that no indication of their proposed long term status has been provided and thus their conservation status remains uncertain. As well as areas of higher value Box-Gum Grassy Woodland and Golden Sun Moth habitat that will be destroyed as a result of the proposed development, other areas of perhaps lower conservation status but of value in providing connectivity will be destroyed. The result will be a net loss of the endangered box-gum grassy woodland community.
This referral (like other recent Gungahlin referrals) makes reference to avoidance and mitigation of environmental impacts as part of the “Environment Protection and Biodiversity Conservation in Gungahlin: strategic measures to avoid, mitigate and offset impacts of development” prepared for the ACT’s Economic Development Directorate by Umwelt & SMEC (2012). As this document is still not available as part of the public consultation material, we do not have detailed information about what the avoidance, mitigation and offset proposals in it are. We believe that such a document requires public consultation and scrutiny by the scientific community before being implemented.
We reiterate views expressed in our February submission on the Development of the Future Urban Areas of Kenny and Throsby, Gungahlin (2012/6279) and other recent submissions in the Gungahlin area:
- This is yet another example of piecemeal development proposals that in the end have a negative impact on box-gum grassy woodland biodiversity and connectivity without adequate consideration of alternatives;
- A strategic approach needs to be taken to developments in the Gungahlin area; and
- The ACT Government’s offset policy and Gungahlin Strategic Offsets Package need to be made available for public scrutiny to ensure there is full understanding of the process for establishing and funding offsets.
In this context, the Conservation Council (with the help of member groups such as FOG) is working to identify the areas we consider most important to conserve, from the point of view of both conservation status and connectivity of high value areas across the landscape. Our view is that consideration of any future development in Gungahlin is premature until this process is completed.
In conclusion, FOG again asks that:
- There be no further development in Gungahlin until a strategic approach to grassland and box-gum grassy woodland conservation in Gungahlin is identified that has included input by the scientific and conservation community;
- An environmental impact statement be required for any development in areas of higher conservation value in Gungahlin, including Jacka and Taylor.
John Fitz Gerald
29 April 2012