Lawson EPBC Referral
Land Development Agency
GPO Box 158
Canberra City ACT 2601
email: LDACommunity@act.gov.au

 

 

Dear Sir/Madam

 

Re: Lawson South Residential Development

Invitation to comment on the Referral and Preliminary Documentation

 

FOG welcomes this invitation and wishes to follow up on comments it has made in a series of earlier submissions from 2009 to 2011 about development proposals and land-use planning for Lawson.

 

Page 14 of the Referral shows three categories of sensible measures proposed to mitigate some impacts of planned development.  FOG repeats its support for the 30 metre wide ecological buffer zone and for cat containment.  It is also completely in agreement with the strategies suggested for planting of native species and regeneration of grassland using locally sourced seed.  FOG was similarly reassured to see the commitment on Referral page 10 to preventing weed invasion (garden escapes) into the adjoining high-quality Natural Temperate Grassland (NTG) on Commonwealth land.

 

The LDA in its Referral clearly states that development will negatively impact upon environmental values of Lawson South.  FOG cannot accept the several assertions made in the Referral that such impacts are either minor or not significant because an expanse of NTG exists in adjoining Lawson North, principally as (a) the future of that land has not been finalized and (b) that land is controlled by the Commonwealth and not the ACT Government.

 

FOG is much better aligned to the sound assessments in the Preliminary Documentation (PD) dated Nov 2011, prepared by David Hogg Pty. Ltd and informed by advice to LDA from, among others, the SMEC and Umwelt groups and especially that presented as Appendix C in the Preliminary Documentation package.  As carefully explained in Chapter 8 of the PD, a major offsets program is an excellent way to satisfy at the same time the requirements of the Commonwealth EBPC Act and the objectives of the ACT Government to ensure conservation gains.  FOG is convinced that a carefully crafted offsets package like that laid out in Appendix C has guaranteed and major benefits.

 

At this point FOG would like to point out that a major difficulty facing us when analysing material posted on the LDA website.  This difficulty was due to two questions remaining open– what is the LDA’s assessment of the PD and how far does it intend to implement the PD strategy?  In the absence of information to the contrary, FOG has to infer that the LDA accepts the propositions detailed in the PD and is prepared to proceed with the strategy to the maximum extent.  FOG bases this inference on two statements in chapter 8 of the PD, that “the offsets package has been developed on behalf of the LDA” and that it “has been endorsed by the ACT Government”.

 

FOG is highly encouraged by many different facets of the approach to natural asset analysis in the PD, particularly the offsets package, which appears to represent best practice in many regards, including:

• Identification of a suitable direct offset area of like-for-like habitat in the Belconnen sub-region, of a size and location that will improve continuity of grassy habitat adjacent to part of the ACT’s NW boundary;
• Confirmation that such offset land is to be added to the ACT Reserve system, initially as a Conservation Reserve.  In this way, such offset action can benefit the region’s biodiversity in perpetuity;
• Earmarking an investment to enhance habitat in the offset area, money which is “supplementary to funding that would be provided for ongoing maintenance as determined by the ACT Government”;
• Careful management planning including monitoring and long-term auditing programs;
• Acceptance that perpetual environmental management plans have to be established to preserve the open spaces between Lawson South residential zones, and initiated through declaration of these open spaces as avoidance areas during construction; and
• Timescales (SMEC Strategy, section 4.6) set so that the offset strategies including management plans be in place prior to the commencement of any development.

Overall, this sensible approach should greatly improve the chances of survival of a number of the rare or threatened species and ecosystems on lands, both near to the Lawson South development and in the direct offset area, which would be to FOG’s great satisfaction.

 

To conclude, FOG notes how refreshingly positive the Preliminary Documentation appears in comparison to the older EPBC Referral 2010/5549.  FOG looks forward to learning the detailed outcome of the EPBC decision and hopes that the full package can be carried through to reality.  FOG would be delighted if this level of approach to conservation were to become standard for land developments in the ACT.

 

Sincerely yours

 

 

 

 

John Fitz Gerald

President

 

20 March 2012