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

 

Dear Sir/Madam

Wallaroo solar farm, NSW

Referral no: 2021/8994

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 and its members include professional scientists, landowners, land managers and interested members of the public.

FOG has major concerns about the assessment of the impacts on MNES as presented in this referral document – both in the assumptions that are made and in what is omitted from consideration.

Firstly, the Scoping Report claims that most of the site has been cleared of woody vegetation and modified by farming practices. In fact, it is very likely that there would have been areas of Natural Temperate Grassland, a critically endangered EPBC listed community, present on the site. Attachment A gives our rationale for this view. There is need for an appropriate and adequate assessment for the presence of this ecological community on the site.

Consideration of Striped Legless Lizard (Delma impar) is restricted to rocky habitat. However, the information available on this species indicates that it is a grassland species which overwinters in the base of grass tussocks and which is found even in degraded exotic pastures provided that habitat is not ploughed and was once or is within a few continuous kilometres of Natural Temperate Grassland. In our view, these conditions exist over much of the proposal area – see attachment B for more information.

Even though p33 of the Scoping Report states that the Golden Sun Moth (Synemon plana) has a high potential to occur on site, it has not been considered further. This is despite there being multiple records of this critically endangered moth within and adjacent to the development footprint, and an adjacent lot being set aside as an offset for this species. Attachment C contains details of the information FOG has available to it about the presence of the moth in the area. We believe that the proposal is likely to have a significant impact on this endangered moth since the development footprint includes known Golden Sun Moth habitat that is part of one of the most important remaining habitats for this species both in a regional and national context. It would also further compromise a key habitat connection point.

The referral documents also do not discuss the possible occurrence in the project area of other significant fauna for which there are nearby records, including the NSW endangered Key’s Matchstick Grasshopper (Keyacris scurra), the ACT vulnerable Perunga Grasshopper (Perunga Ochracea) and the rare and locally endemic Canberra Raspy Cricket (Cooraboorama canberrae). The first of these species has been nominated as threatened under the EPBC Act, with a decision due next year. Suitable habitat for all these species occurs with the development area – see attachment D.

As well, the proposal will have impacts on woodland birds (see attachment D). The development area is known foraging habitat of the Little Eagle. It is within a general identified breeding area of the nationally vulnerable Superb Parrot, for which the ACT and surrounding area is becoming increasingly important with climate change, shifting suitable breeding habitat eastwards.

FOG’s view is that the development will have significant impact on matters of MNES and also on State/Territory listed threatened species. The area is likely to contain Natural Temperate Grassland, is known to contain habitat of the Golden Sun Moth, is possible habitat of several other significant grassland species and is known habitat of several regionally threatened woodland birds. The proposal should be called in as a controlled action and subject to the consideration of an Environmental Impact Statement, with surveys for all potential threatened species and ecological communities undertaken in an appropriate season for each. After this, the principles of avoidance and mitigation can be applied to the design of the solar farm so that all the site’s biodiversity values are retained while still providing infrastructure for clean energy.

Yours sincerely

 

Naarilla Hirsch
Advocacy coordinator

7 August 2021

Attachment A

Attachment B

Attachment C

Attachment D

---

Attachment A: Natural Temperate Grassland

The vegetation survey was conducted at an unsuitable time when (as stated in the scoping report) 70‑95% of the property was bare due to drought. Thus, any conclusions regarding what parts of the property are dominated by exotic grasses and those parts dominated by native vegetation are at best guestimates. It is unclear why aerial photography, and vegetation mapping of neighbouring ACT and NSW lands were not utilised to help determine vegetation boundaries within the development proposal. Nor is it clear why the presence of Natural Temperate Grassland was not considered, when this is the vegetation mapped on neighbouring lands both within the ACT and NSW.

Comparison of the areas mapped as Natural Temperate Grassland and native grassland in adjacent areas of ACT, with the aerial photograph supplied in the referral documents, shows that there are patches within the proposed development area that have the same appearance form the air as both Natural Temperate Grassland and Native Grassland. For example, compare the signature either side of the border in the Jaramalee vicinity or compare the western Dunlop grasslands area with eastern sections of the development proposal.

From Figure 5. Natural Temperate Grassland distribution in Belconnen. P131 (ACT Government 2017)

From Aerial photograph showing proposal extent in referral documents

Similarly mapping of vegetation on the adjoining Wallaroo lot, maps about half of that alotment as native grassland with several patches of Natural Temperate Grassland.

From Figure 11 Grassland condition threshold zones (2017) – Lot 2 Wallaroo Road. (p41 ACT Government 2019)

 

---

Attachment B: Striped Legless Lizard (Delma impar)

There is the need for a credible assessment of the likelihood of this species occurring within the development area, one that considers the whole property and not just the restricted area of rocky habitat.

To quote the ACT Government (2017) p243.

The habitat of D. impar has been broadly described as naturally treeless grassland dominated by native, perennial, tussock-forming grass, particularly Kangaroo Grass (Themeda triandra), Wallaby Grasses (Austrodanthonia spp.) and Speargrasses (Austrostipa spp.) (Coulson 1990; Osborne et al. 1993; Hadden 1995). Although D. impar is largely restricted to areas that are (or were) lowland Natural Temperate Grassland, the species has also been found in grassland with scattered Eucalyptus trees (but not where canopy cover is high) and in grassland that has been derived from clearing of Eucalypts (‘secondary grasslands’) (Coulson 1990; Williams and Kukolic 1991; Osborne et al. 1993; Dorrough 1995; Hadden 1995; Howland et al. 2014). Records of D. impar in secondary grasslands are invariably from within two kilometres of the original boundary of the primary grasslands.

Delma impar has been recorded in degraded Natural Temperate Grasslands that are now dominated by exotic species such as Phalaris (Phalaris aquatica), Cocksfoot (Dactylis glomerata) and Serrated Tussock (Nassella trichotoma) (Coulson 1990; Williams and Kukolic 1991; Kukolic et al. 1994; Dorough 1995; Hadden 1995; Rauhala et al. 1995; Dunford et al. 2001; Biosis 2012; Howland et al. 2016). Degraded areas where the species has been recorded include a former quarry in Crace (Biosis 2012) that was converted to an asbestos dump and rehabilitated to grassland in the 1980s.

 

---

Attachment C: Synemon plana (Golden Sun Moth)

A major and crucial omission of the Wallaroo Solar Farm referral documents is that they do not mention the known multiple records of the Golden Sun Moth (Synemon plana), both from with the proposed solar farm footprint and from adjacent areas. This moth is currently listed as a critically endangered species. While there has been some consideration that the moth is less threatened than the current listing category suggests, it is still a threatened species and as detailed below the footprint is over an important habitat area. The presence of this moth and its omission from consideration within the referral documents is enough on its own to warrant the solar farm proposal being a controlled action and subject to further consideration under the EPBC Act.

Recorded Golden Sun Moth locations - source Canberra Nature Map

Within the actual solar farm footprint are two GSM records

·         A 11 December 1997 record, that is centred in the footprint and covers a 20ha area, in which tens of moths were observed; and

·         A 19 November 2019 record, where the recorder was standing on the ACT-NSW boundary and saw around 10 moths either side of the boundary.

Within the Wallaroo block but just outside the proposed footprint are two further records, near Gooromon Ponds Creek

·         A 20 Nov 2013 record within NSW Bionet of unspecified numbers; and

·         A 1 November 2009 record of a single moth from an impact assessment document prepared by Parsons Brinkenholf for a previous development proposal of the lot.

As indicated in the enclosed map there are numerous nearby records of many hundreds of moths from a mixture of native and exotic pasture, very similar to the habitat that occurs across the Solar Farm proposal.

A 2012 ACT Government report (Mulvaney 2012) noted that the Dunlop Grassland, adjoining NSW Wallaroo lands, Jaramalee and West Macgregor is best viewed as one cross-border continuous habitat and that it supports the second largest Golden Sun Moth population in the ACT region and one of the biggest habitat areas. Parts of the proposed development footprint occur within a key area of connectivity where habitat on the ACT side of the border is constrained by a large urban dam and a very moist habitat below the dam, which favours dense and high growth of exotic pasture species and is marginal or unsuitable Golden Sun Moth habitat.

In summary the solar farm footprint includes known Golden Sun Moth habitat that is part of one of the most important remaining habitats for this species both in a regional and national context, and would further compromise a key habitat connection point. The proposal is likely to have a significant impact on this endangered moth.

At a minimum solar panel location should avoid known and potential habitat, while the project should seek to enhance rather than degrade habitat connectivity for the moth.

 

---

Attachment D: Other significant species not considered within the proposal

Key’s matchstick Grasshopper (Keyacris scurra) – This species is listed as endangered in NSW and has been nominated as threatened under the EPBC Act, for which a decision is due on 30 April 2022. 20-30 grasshoppers were seen at the nearby Hall Cemetery in September 2020 and the species was again observed at this location in April 2021.  At the Cemetery the grasshoppers were found in patches of Kangaroo Grass (Themeda triandra) which is the most usual habitat in the ACT region. Such patches exist within the proposed Development area.

Recorded Location of NSW endangered Matchstick Grasshopper

 

Perunga Grasshopper (Perunga Ochracea) – This species is listed as vulnerable in the ACT and has a restricted distribution within the Southern Tablelands.  There is a 22 December 2017 record from within Lot 1 Wallaroo rd. and four records from the nearby Dunlop Grassland Reserves from October or November in 2019 or 2020. Similar and what appears to be suitable habitat for this species occurs within the Development footprint.

Recorded locations of the ACT vulnerable Perunga Grasshopper

 

Canberra Raspy Cricket (Cooraboorama canberrae) is the only species of its genus and is restricted to the ACT and nearby areas of NSW. The ACT Government has had prepared a nomination for this species to be considered as threatened under the EPBC Act (Vertucci and Speirs 2014). There is an 11 Dec 2015 record from the adjacent Jarramalee property and 10 February 2015 record from nearby Dunlop Grassland Reserves. Again suitable habitat for this species appears to occur with the footprint of the proposed development.

Recorded location of rare and endemic Canberra Raspy Cricket

 

Woodland birds

Davey (1997) provides an overview of Superb Parrot observations up until that time in the ACT region. Observations including notes on nesting were centred in the area just to the north-west of the ACT, in which the development proposal sits. As stated in the ACT Government Superb Parrot Action Plan p 117, it is predicted that climate change will result in the core range of the Superb Parrot shifting south-eastward, concentrating the population over the ACT and areas to the immediate north. Thus the vicinity of the proposal is a known Superb Parrot nesting area that is likely to become increasing important for the species future survival. An assessment of the location of potentially suitable nest trees and a nesting time (October –January) survey seem warranted.

Since 2017, an informal collaborative Little Eagle Research Group has studied the number, breeding success and movement in the ACT – neighbouring NSW region. Publications and reports that the group has produced are available at https://littleeagleresearch.blogspot.com/?fbclid=IwAR2YSpgdg9vtu2tz9_Kt42QOG3_tYa7Tw7-ZFFTc9S1V-Ij2AxgQ0qSEWgI. From their work it is known that several Little Eagles occasionally forage, mainly for rabbits, over the development proposal area.

The report notes other NSW and or ACT listed threatened birds that have been reported in the area. Large expanses of natural or secondary grassland (particularly when grass growth is short) will constrain the landscape movement of these birds. In the context of the development proposal natural shrubs, trees and plantings (particularly along Gooromon Pond and Ginninderra Creeks) are important for the movement of birds from and into woodland around Hall and the northern ACT and down to the wooded corridor of the Murrumbidgee River. An impact assessment of the proposal needs to consider how it may affect the movement of woodland birds across the area.

 

---

References

ACT Government 2017. ACT native grassland conservation strategy and action plans. Environment, Planning and Sustainable Development, Canberra.

ACT Government 2019. Gooroman Grasslands Offset Management Plan. Environment, Planning and Sustainable Development, Canberra)

Davey C 1997. Observations of the Superb Parrot within the Canberra District. Canberra Bird Notes. 22(1) 1-14.

Mulvaney M 2012. Golden Sun Moth (GSM) Draft Interim ACT Strategic Conservation Plan. Report for the Flora and Fauna Committee. Conservation Planning and Research, ACT Government, Canberra

Vertucci S and Speirs R 2014. Canberra Raspy Cricket Ecological Study Preliminary Draft Report. Unpublished report to Environment and Sustainable Development Directorate, ACT Government (Biosis, Canberra)