Throsby land in Gungahlin COG comments on EPBC Act referral

To: "Canberrabirds" <>
Subject: Throsby land in Gungahlin COG comments on EPBC Act referral
From: "Jenny Bounds" <>
Date: Wed, 29 Feb 2012 16:04:55 +1100
As COG members will have an interest in the future of this land which abuts Mulligans Flat and Goorooyarroo reserves, the ACT Government has now referred development plans to the Commonwealth environmental authorities, as the plans impact on Commonwealth listed threatened box/gum woodland and threatened species (Superb Parrot and Golden Sun Moth).  Comments are due in tomorrow, 1 March.  The COG comments are below for info with the link to the referral documents.  While the plans submitted propose reserving a large part of Throsby including the neck area and the Superb Parrot nesting trees on Throsby Ridge (a positive), essentially, COG is calling for a comprehensive, whole of landscape assessment for remaining developable lands in Gungahlin (not block by block, piecemeal), and for much greater protection for the Superb Parrot nesting colony on Throsby Ridge than the 100 metres buffer proposed.

" Mr Jonathan Teasdale

A/g Director

Commonwealth and Territories Section

Environment Assessment Branch

Dept of Sustainability, Environment, Water, Populations and Communities

GPO Box 787




Dear Mr Teasdale


RE 2012/6279; Development of the Future Areas of Kenny and Throsby


The Canberra Ornithologists Group wishes to provide comments on this referral by the ACT Government.  In summary our key recommendations are:

·         no development should be occurring at North Gungahlin without a whole of landscape environmental impact assessment with appropriate scope for public scrutiny and input

·         no development should be allowed in Throsby, as this provides the best protection for the important reserves, threatened species and communities and more broadly best protects the environmental values

·         the urban boundaries and buffer proposed by the ACT Government for Throsby are considered inadequate to ensure the long term survival of the Superb Parrot nesting colony at Throsby Ridge, and the precautionary principle must be applied

o   all potential Superb Parrot nesting trees in the southern portion of Throsby must be conserved (in addition to known nesting trees)

o   as a minimum, the urban boundary should be drawn back to protect all those potential nesting trees, more EPBC Act grassy woodland, and provide a greater buffer for the breeding colony from the urban edge and human related impacts.


COG is dedicated to the study and conservation of native birds and their habitats.  COG is essentially concerned with better protection for native vegetation which provides habitat for various species of birds, especially birds which are associated with grassy woodlands.  COG surveys and research show that woodland bird species continue to decline in abundance, including birds which are listed as threatened under Commonwealth and ACT legislation.  The primary cause is the overall loss of woodland habitat and fragmentation of habitat, overlaid by a variety of other pressures and threats including urban related pressures.




General Comments

COG has recently provided comments on another referral for a school site on the Throsby land (Gungahlin ACT/EPBC 2012/6251 Throsby Denominational School site).  Our general comments on that referral are also relevant to referral 2012/6279, in particular that this area has very high environmental values, that piecemeal planning is inappropriate and there must be a whole of landscape approach to planning with a comprehensive review of impacts across the landscape.


The proposed action must be considered a controlled action under the EPBC Act, given that North Gungahlin has significant patches of remaining endangered yellow-box red-gum woodlands, as well as habitat for a range of species of National Environmental Significance including the Superb Parrot. 


The proposed action is part of a ?larger action? and must be considered in the context of this, and the assessment of the action/proposal should be through an Environmental Impact Statement: 

·         there are two components to the larger action, the proposals for both the Throsby school and the Throsby Playing fields must be considered in the context of all development in Throsby and not independently

·         the current piecemeal approach to the EPBC referrals by the ACT Government fails to take into account whole of landscape ecological considerations

·         secondly, the ecological values of all of the remaining land in North Gungahlin must be considered

·         the whole of North Gungahlin should be subject to an Environmental Impact Assessment or a Strategic Environmental Assessment under the provisions of the Planning and Land Development Act 2007 (impact track) or the Strategic Environmental Assessment provisions of the EPBC Act

·         it is very concerning that the ACT Government is apparently considering an exemption for undertaking an EIS as a short cut.


The ACT Government has asserted in the referral that the proposal has been subject to extensive public consultation.  No public processes have considered the broader context of the ecological values of North Gungahlin, as overall planning for Throsby (indeed other areas of Gungahlin) has occurred largely behind closed doors, with individual developments referred piecemeal and little opportunity for the community to have their views taken into consideration:

·         no development should be occurring at North Gungahlin without a whole of landscape environmental impact assessment with appropriate scope for public scrutiny and input.


As COG commented in relation to the Throsby School site referral, it is inappropriate for the ACT Government to rely on an (out of date) EIS conducted in 1989:

·         this was prepared at a time when the grassy woodland community/box-gum woodlands, Superb Parrot, Golden Sun Moth and other species now listed as threatened, were not so listed; that 1989 policy plan did not envisage the contemporary biodiversity conservation issues we are now dealing with

o   additionally, the two nationally important grassy woodland nature reserves abutting Throsby (Mulligans Flat and Goorooyarroo) were not even designated as such when that assessment was prepared, nor had the ANU/ACT Government experimental research program into restoring woodlands been established there, all factors which much be seriously considered in terms of impacts from developments along the reserves borders

·         most significantly the referral relies on a draft report ?Environment Protection and Biodiversity Conservation in Gungahlin: strategic measures to avoid, mitigate and offset impacts of development? prepared by Umwelt and SMEC; this document has not been subject to any public consultation as far as we are aware and certainly not with COG

o   it is of great concern that environmental community groups such as COG are only finding out about this significant report through an EPBC referral notice; it is unacceptable that such a significant environmental assessment has been taking place behind closed doors and seemingly will be finalised without scope for public input and independent scientific scrutiny

·         this Strategic Review is apparently being developed through the Economic Development Directorate rather than by Ecologically Sustainable Development Directorate, with the inherent concern that the terms of reference and management of the assessment may not be adequately informed by environmental expertise

o   it is also unclear whether this report is different or the same as the Gunghalin Strategic Offsets Package, which again we have found out about through the Throsby school site EPBC referral, again attributed to Umwelt (December 2011); it is not appropriate to consider these referrals in the absence of an ACT offsets policy

o   it is worth noting that Umwelt were also responsible for preparing the referral information.


COG remains concerned about the piecemeal environmental approvals for North Gungahlin, as well as the ongoing trend for offsetting of endangered habitat and the lack of any mechanisms to ensure ?offset? areas actually result in additionality, that is ?net gain?, through appropriate management, regular scientific monitoring, with outcomes publicly reported.  The lack of an ACT offsets policy is also concerning and COG supports the establishment of an offset register which lists all offset areas, conditions placed on the offset site, management arrangements and annual public reporting of biodiversity outcomes subject to regular independent review by the Commissioner for Sustainability and the Environment.


Throsby & Superb Parrot Issues

COG is pleased to see that the referral proposes a revised urban boundary line which would retain known Superb Parrot nesting trees with a 100 metres buffer (presumably this buffer will absorb all bushfire mitigation measures).  Nonetheless, we still have strong concerns about the future of the Superb Parrot breeding colony at Throsby Ridge which would be very close to urban development and associated threatening processes.  COG does not agree with this line and believes a much larger buffer is required to ensure the long-term survival of that Superb Parrot breeding colony. We strongly believe that the precautionary approach must be applied here and recommend for a number of reasons, that approx the southern third of the proposed development area block 733 in Throsby not be approved for development:

·         there are a number of potential Superb Parrot nesting trees (hollows) within the development area of block 733 near Throsby Ridge (identified in the referral) which could be used by Superb Parrots in the future, particularly if that colony expands or existing nesting trees are lost; they should be included in the conservation zone, as it is possible Superb Parrots could use those trees in the future; these kinds of hollows are very scarce in the landscape

o   this is a very strong reason to retain those potential nesting hollow trees and re-draw the development boundary

·         there is also an important issue of what kind of development, if any, might occur adjacent to the Throsby Ridge parrot nesting site; COG has concerns if housing, particularly higher density housing, were to be developed close by and possible impacts on the Superb Parrot nesting colony due to close urban presence, potential for human disturbance, dogs allowed to roam etc (at present this area is effectively closed to the public due to its leasehold status)

o   further, there is likely to be an increase in the introduced Common Myna penetrating into woodland from a closer urban area/edge, an aggressive resident species of bird, (in high numbers in Gungahlin), which competes with native species for nesting hollows; this is a likely threatening process for the Throsby parrot nesting colony

·         a greater area of EPBC Act woodland must be protected in this general area, to minimize the loss of this vegetation community to the Superb Parrot (and other species)

·         consideration should be given to a ?no housing? option east of Horse Park Drive and possible alternative land uses if any development is approved there:

o   COG has consistently put the position that there should be no development at all allowed in Throsby due to its high environmental values and proximity to the important woodland reserves, to manage this land for conservation as the best chance to ensure the long term survival of the Superb Parrot breeding areas, particularly the colony on Throsby Ridge

o   should agreement be given to development on block 733, a suitable low impact, broadacre use (not housing) must be considered for the land in close proximity to the parrot breeding colony.


Again, all these factors are strong reasons for a comprehensive, landscape scale impact assessment, such as an EIS, to be undertaken for the remaining potentially developable lands in Gungahlin.  This would ensure that threatened species/communities, wildlife corridors, and environmental values are examined in a broad context.  Additionally, the important environmental areas are not compromised by inappropriate development, inadequate buffers, and urban boundaries too close to high conservation areas where ACT Government asset protection zones (for prescribed burning, slashing etc) have been allowed to intrude into conservation areas/reserves (eg Crace, Forde, Bonner).


Block 742

COG notes that block 742 is marked on maps in the referral, but is not part of this referral.  We understand this block was re-zoned as broadacre after an ACT Territory Plan change several years ago.  COG believes this block should go into the adjacent Goorooyarroo nature reserve, given it contains significant patches of EPBC Act woodland, is potentially Striped Legless lizard habitat, and has suitable habitat for threatened and declining woodland birds.  The future of that block should be considered as part of a wider assessment.



As we understand, the proposal by the ACT Government is to clear Kenny for urban development.  A critical issue in relation to Kenny is the potential loss of a large number of mature eucalypts in the order of several hundred years old, for example Yellow Box (Eucalyptus melliodora).  The impact of this loss across the landscape has not been properly assessed.  Large paddock trees are very important as food resources for species like the endangered Regent Honeyeater, as hollows for nesting species, and as stepping stones and corridors across the landscape, for example for Superb Parrots.  COG recommends that these issues are more fully addressed through a whole of landscape assessment, given the proximity of the major Superb Parrot breeding site in Throsby and the birds movements from there across Kenny and Harrison and along the Gungaderra Creek corridor to feeding sites.


We note that when the suburb of Crace in Gungahlin was developed, there was a similar situation with a large number (in the order of 100 ) mature eucalypts scattered across the blocks proposed for development.  The initial development applications and process for Crace maintained that most of these trees would be retained, however, at the last minute planning authorities ruled that most of the trees would have to go to allow better solar orientation of houses.  These trees historically had been used by Superb Parrots."

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