IFFA UGB submission revised lo res.pdf - Indigenous Flora and ...

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Process IFFA is concerned that the process 1. has not included consideration of the alternatives to expanding the UGB, or if there has been consideration this has been behind closed doors, with no opportunity for the public to test the assumptions behind choices or to have input to these choices. 2. Much of the decision-making process seems to have been delegated to the Growth Areas Authority, which has no environmental expertise 4 3. Is unclear as to how the Victorian Government will implement its obligations under the Strategic Assessment. 4. Is unclear in terms of how the Victorian Government will fulfil its obligations under Victorian law. 5. The State Government has been unclear about what specific actions are to be covered by the strategic assessment and subsequent decisions by the Federal Minister Management and reserve sizes [IFFA is aware of projects successfully maintaining nationally significant species within grassland reserves in size down to 0.4 ha. On the other hand the draft prescriptions suggest that the minimum threshold of manageability is 150ha. This is not consistent with our experience 5 - it appears to reflect a selective and simplistic interpretation of conservation ecological theory. Whilst it would be preferable that remnants are larger and more connected, many vegetation types have been too heavily impacted by development for Comprehensive, Adequate and Representative reserve to be based solely on large reserves. The nationally agreed criteria CAR reserve system is based on three principles: • including the full range of vegetation communities (comprehensive) • ensuring the level of reservation is large enough to maintain species diversity, as well as community interaction and evolution (adequate), and • conserving the diversity within each vegetation community, including genetic diversity (representative) Parkland and habitat networks IFFA believes that a critical part of avoiding and minimising impacts is the explicit delineation at this stage of a parkland and habitat network which: • incorporates the bulk of extant remnant vegetation and indigenous fauna habitat areas • links these areas with generous habitat corridors, which where necessary can be revegetated 6 to create a habitat network. Habitat corridors should include waterways, but also nonwaterway links. • includes areas which until recent drainage were swamps and includes their restoration (given the parlous condition of the Plains Grassy Wetland ecological vegetation community (EVC) and of the fauna such as Latham’s Snipe that they support. • supplements recreational park facilities. 4 http://www.gaa.vic.gov.au/our_board/ viewed 7/7/09 stated "The Growth Areas Authority is overseen by a highly experienced board that brings a broad range of disciplines including planning, development, economics, financial management, local government and housing." 5 York park, in Barton in Canberra is a small (0.4 ha) park is surrounded by hotels, roads and office blocks. It retains a population of Golden Sun Moths, identified sometime prior to 1982. Bababi djinannang (Jukes Road Grassland), at 4 ha, contains a ‘large’ population of Dianella amoena, breeding ground-nesting birds etc. Evans Street Grassland (approx 3.5 ha), Central Creek Grassland (9 ha), etc. 6 Albeit not to the quality of the existing remnants. Indigenous Flora and Fauna Association Page 3
Resource use Given current trends for water availability in Melbourne, IFFA questions the wisdom of massively expanding the UGB with low density, water-hungry developments. IFFA also questions the wisdom of heavy investment in freeways given the looming problems of fuel availability and current problems with climate change. Precautionary principle This principle of ecologically sustainable development, is expressed in the Act as: "If there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation" Clearly there are threats of serious and irreversible environmental damage (urban development is as irreversible as it gets). The Strategic Impact Assessment Report is insufficient basis for determining whether matters of National Environmental Significance are absent from the investigation areas proposed for development. IFFA believes it is appropriate that the precautionary principle should be applied in this case to avoid inadvertent destruction of values of National Environmental Significance. Summary 1. IFFA opposes the expansion of the UGB and the construction of the proposed freeways because of the environmental impacts and calls for proper investigation of alternatives. 2. IFFA believes that remnant vegetation and indigenous fauna habitat should be protected in a parkland and habitat network which should be explicitly identified before urban expansion is considered. 3. IFFA supports protection of all significant areas of native vegetation, including but not limited to the proposed large reserves to the west of Melbourne 4. IFFA believes smaller reserves play a vital role in conservation and that the imperative for managing smaller reserves has been discounted in this report. 5. IFFA calls on the Commonwealth Minister to: • not approve the Strategic Assessment as it stands. • if he does approve the Strategic Assessment to ensure that beforehand adequate measures are included to ensure the protection of all areas of remnant vegetation and habitat. • to not exempt any actions relating to the proposed program because there is no way he could be confident that the objectives of the EPBC Act will be adequately met. 6. IFFA calls on the State Government to undertake an Environmental Effects Statement to be prepared considering the whole package of proposed measures, along with alternatives including the no-expansion alternative, prior to putting into place any expansion of the UGB. Indigenous Flora and Fauna Association Page 4
Page 1 and 2: Growth Areas Authority PO Box 1166
Page 3: Need IFFA is not convinced that the

IFFA UGB submission revised lo res.pdf - Indigenous Flora and ...

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