"
Mr Jonathan Teasdale
A/g
Director
Commonwealth
and Territories Section
Environment
Assessment Branch
Dept
of Sustainability, Environment, Water, Populations and
Communities
GPO
Box 787
CANBERRA
ACT 2601
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.
Kenny
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."
