ACEPDcustomerservices@act.gov.au

Re. DA 202342438: Proposal for telecommunications facility - construction of a new mobile telecommunications tower, landscaping and associated works

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 native 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.

On 12 April 2023, FOG wrote a submission addressed to Vanessa Wan at Indara opposing the proposal. Although parts of the site are disturbed and overplanted with exotic trees, the site retains a remnant of Natural Temperate Grassland, a critically endangered ecological community listed for protection under the ACT Nature Conservation Act 1980 and the Commonwealth EPBC Act 1999. As we stated in our previous submission, we do not concur with the proposal that the project is a low-impact facility under the federal Telecommunications (Low Impact Facilities) Determination 2018. Despite the efforts to minimise the impacts on the remnant Natural Temperate Grassland at this site, FOG still believes that this development is incompatible with the local environmental values, that include its contiguity with grassy woodland on the slopes, and is linked ecologically to grassy woodland, in Mt Ainslie Nature Reserve.

We are seriously concerned that construction works and on-going maintenance are likely to cause impacts beyond the construction zone, through weed invasion, soil disturbance, vehicle traffic and compaction. Through the development of the adjacent former CSIRO Headquarters site, there has already been significant loss of native vegetation into the remainder of the site. This is coupled with the loss of other Natural Temperate Grassland remnants in the area over the past decade, including on the corner of Constitution Avenue and Anzac Parade and at York Park in Barton. We believe it is possible and feasible to improve the ecological condition of one of the last remnants of critically endangered Natural Temperate Grassland in central Canberra. We are disappointed that there is no evidence that other areas of land north and east of the remnant grassland, that are not of environmental significance, have been considered as alternative locations.

While we recognise that the construction works are proposed to occur in the area dominated by exotics, not too many years ago this corner also contained native vegetation, and remnants of it are likely to still occur here.  A volunteer community group specifically dedicated to the restoration of the grassland has begun work, with the intention of returning the area dominated by exotics to Natural Temperate Grassland and improving the condition overall of the grassland and adjacent woodland. The formation of this group demonstrates the interest and dedication of community in taking active roles to improve the ecological condition of such remnants that are outside the reserve system. This proposal jeopardises those plans.

If we are not successful in changing the outcomes for this site, we urge the following conditions are met:

1. construction area will be fenced off, to restrict all access during and after construction to the rest of the site;
2. assurance that no vehicles will be driven onto the site nor that any materials will be placed temporarily or permanently outside the fenced areas;
3. the area within the fenced area will be landscaped using native grassland species and will be weeded regularly to ensure that no weeds or their seeds are spread outside the fenced area; and
4. resources for revegetation and rehabilitation work for the rest of the site will be provided to enable improvement of the habitat for the endangered Golden Sun Moth and natural diversity more generally.

Thank you for your consideration of the issues we raise.

Yours sincerely

 

Professor Jamie Pittock
President, Friends of Grasslands

19 February 2024