Ms Sylvana Maas
A/g Director
Commonwealth and Territories Section
Environment Assessment Branch
Department of the Environment, Water Heritage and the Arts
PO Box 787 Canberra ACT 2600
epbc.referrals@environment.gov.au

 

 

Dear Ms Maas

 

S78A reconsideration request: Bonner Stage 4, Site Servicing and Land Release Gungahlin, ACT

Reference Number: EPBC 2009/4816

 

Thank you for the opportunity to comment on the reconsideration of Bonner stage 4 land release. FOG continues to have concerns about this development. The new proposal merely excludes the sensitive area from current consideration but notes that a further proposal will be submitted for it in the future. Our understanding is that the excluded area was to contain dwellings that are part of the ACT Government’s low cost housing initiative. Accepting this modified proposal will place pressure on acceptance of further extensions to the suburb in the future, despite their conservation value. There are other examples where allowing the initial development has resulted in a continuous stream of losses to native grasslands and grassy woodlands and the endangered species inhabiting these areas: Canberra Airport is one where there is a continuous stream of development proposals that are slowly eating away at high quality natural temperate grasslands.

 

Our initial response supported the suggestion at the conclusion of the GSM report attached to the proposal: “In view of the more specific knowledge of GSM distribution within the site, it would be worth reviewing the urban boundary and the subdivision layout to determine whether an alternative design for this part of Bonner could be achieved which provided more effective conservation of the GSM while still providing an acceptable development solution.” We also proposed that ecological assessments in the entire area should be completed before any trade-offs in areas of endangered communities and species are made (particularly as a reduction in the total dwelling yield for Bonner will put pressure on future developments in areas of Jacka and Moncreiff where ecological assessments have not yet been completed). This does not appear to have been done, but in FOG’s view is necessary before any of these developments proceed.

 

Another concern is that there is no proposal to manage the paddock in the interim. Past experience indicates that rural lease holders have no incentive to manage temporary leases well, and that the areas with high conservation value may deteriorate under such management.

 

In our previous submission, we talked about educating future residents of Bonner about issues regarding the importance of maintaining biodiversity values in their neighbourhood, and about managing the grassland areas to maintain the golden sun moth population. Again, this does not seem to have been addressed in the new proposal.

 

Sincerely yours

 

 

 

 

Geoff Robertson

President

 

20 September 2009