Submission guide - threatened species and urban sprawl
Please note, the submission period for this process ended on Tuesday 20 December 2011. Federal and state governments have been developing plans for new urban growth corridors in Melbourne's north, west, south-east, and Sunbury region. These plans could result in the destruction of thousands of hectares of habitat critical to the survival of threatened species such as the Growling Grass Frog, Golden Sun Moth and Southern Brown Bandicoot. Please help ensure Melbourne's urban growth does not come at the cost of these vulnerable species by making a submission on Melbourne's Growth Corridor Plans.
How to make a submission |
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It is almost two years since the last consultation period took place on Melbourne's 'Growth Corridor Plans'. Since then there has been a flurry of draft strategies and technical reports released by the Victorian Government. Some of these are very detailed and technical.
Key documents:
- Biodiversity Conservation Strategy: Aimed at ensuring the long-term protection of native plants and animals within growth areas. You can comment on the overall strategy or on individual species strategies - Growling Grass Frog, Southern Brown Bandicoot or Golden Sun Moth.
> You can download these documents from the Department of Sustainability and Environment website. - Draft Corridor Plans: These are also important and show how future growth corridors as a whole will be implemented.
> You can download these document from the Growth Areas Authority website. - Melbourne Strategic Assessment: Draft Growth Corridor Plans, Biodiversity Conservation Strategy and Sub-Regional Species Strategies. Published by the Environment Defenders Office.
> Download legal briefing note
Where to send your submission
Submissions on Melbourne's Growth Corridor Plans are due by 5pm on Tuesday 20 December, 2011. Please send them to:
Growth Corridor Plan Submissions, Growth Areas Authority
Email: gcpsubmissions@gaa.vic.gov.au
Post: Level 29, 35 Collins Street, Melbourne, VIC, 3000.
For other inquires call 1300 366 356.
Key points for your submission
- Conserving threatened species and natural areas is good for people as well as the environment.
- The proposed strategic assessment and growth corridor plans will essentially lock in proposed growth plans, without an further ecological assessment, for decades. This is a sweetheart deal for property developers.
- Many of the proposed reserve areas in the urban growth areas have multiple uses and benefits such as waterway management and recreation as well as conservation.
- The Melbourne area has a large number of threatened species, which need to be planned for as well as people.
- It is critical we get the planning right now.
- The Federal Government needs to ensure that regular (every 3- 5 years) reviews, evaluation and monitoring arrangements are put in place before the plans are approved.
- The Federal Government should appoint an independent monitor as soon as possible and undertake an independent peer review of the ecological assessments undertaken to inform the growth plans.
- There should be a vision to make key conservation areas, such as along Merri Creek, part of a formal government owned and managed urban park and conservation network.
- Conservation laws at a state level have not been considered, for example the Flora and Fauna Guarantee Act.
Grasslands & Grassy Woodlands
Grasslands are some of the most endangered habitat types in Australia, with as little as 1% in good condition left.
About 5000ha of Victoria's last remaining grassland habitats will be cleared in the growth corridors, approximately 2600ha of grassland will be retained in the urban growth areas, and the rest will be offset into two large 15,000ha grassland reserves outside the growth areas. Around 6000ha of a Rural Conservation Zone with planning controls inside new growth areas will be retained in private hands.
Key Submission Points:
- A clear, legally binding commitment from the Victorian and federal governments that they will complete the purchase of the 15,000ha of proposed Western Grassland Reserves by 2020.
- Grassland reserves should be progressively put in place before clearing commences.
- Applications from properties within the grassland reserves that they should be 'part developable' urban growth areas as part of the State Government's 'Logical inclusions' process be rejected.
- Only 20% of the proposed grassland reserves are of high conservation value and significant resources and a dedicated team and management plan should be put in place to restore the area over time.
- Identify and protect high conservation value and botanically rich remnants (including areas designated for further investigation) within the urban growth boundary as part of an urban conservation network, before the final plans.
- The Biodiversity Conservation Strategy must include a clear plan that indentifies and secures areas for proposed 1200+ hectares of grassy woodland reserves in the North Growth Corridor.
- Protect key sites for various grasslands that also contain threatened species inside the Melbourne growth area. These areas should be properly surveyed and identified as part of a formal reserve system before corridor plans are approved. These sites include:
- Clarkes Road grassland.
- Truganina Cemetery.
- Clyde Rail corridor.
Western Growth Corridor Urban Reserve Network
A number of smaller reserves are proposed as part of the Western Growth Corridor and these are supported by conservation groups. There areas include:
- Herb-rich grassland sites north of Kororoit Creek, near Taylors and Sinclair roads (Plumpton, immediately west of Caroline Springs).
- Herb-rich grassland sites immediately north of Ballarat Railway line at Ravenhall (one of the largest populations of nationally listed Large Fruit Groundsel).
- High quality grassland site between the northern edge of Western Grassland Reserves (Mt Cotterell section) and Greigs Road, with large populations of Spiny Rice-flower.
- High quality Stony Grassland Knolls and Golden Sun Moth habitat at Woods Road (northwest of Trug South precinct) - but only part of this proposed for protection.
- Grassland habitat link and Golden Sun Moth site on the southern slopes of Mt Atkinson, connecting Boral quarry grassland and Western Grassland Reserves - reserve for investigation.
- High quality grassland habitat link and Golden Sun Moth site along Middle Road - part protected, part to be investigated and part still in buffer/development zones.
Missing areas
- A key site missed is the rocky rise grassland between Ballan Road and the Werribee River at Wyndham Vale, which Biosis described as an excellent example of the Ecological Vegetation Community, and is full of Golden Sun Moth with connected habitat of over 100ha.
- There is a reserve to be investigated for a grassland adjacent to the headwaters of Skeleton Creek next to Boundary Road - this investigation area needs to be 4-5 times larger to include all of the potentially high quality grassland about the headwaters of Skeleton Ck - which has for a while been recognised as an important area for Striped Legless Lizard.
- Kororoit Ck reserve should be extended to include Rockbank radiostation Red-gum woodlands and Lignum Swamp (also called by locals - Beatty's Road Sth).
- The creek reserves in the west need widening in a number of places: the reserves along Skeleton and Dry creeks appear to be about 50-100m either side (nowhere near 200m), and should be extended in places to include adjacent grassland sites
Similarly the very narrow Growling Grass Frog reserve along Davis Creek should also be extended to include some small adjacent grasslands.
Download: detailed map of the Western Grassland Reserves
Golden Sun Moth
The Golden Sun Moth is a medium sized moth with wingspans of approximately 3.1 cm and 3.4 cm. Unusually for moths, the species is active during the day, favouring warm, sunny weather and calm wind conditions. The adults have no mouth and do not feed. They are thought to live for 2-3 years mostly underground and emerge 2- 5 days a year in spring and summer to breed.
For a more detailed description of the Golden Sun Moth visit our 'Get to know Melbourne's neighbours' web page.
The Golden Sun Moth was listed as 'Critically Endangered' under the EPBC Act in 2002 and is also listed as a 'Threatened' under the Victorian Flora and Fauna Guarantee Act 1988. It is restricted to Victoria, the ACT and southern NSW. The moth occurs in native and non-native grassland.
The Golden Sun Moth occurs in the West, Sunbury and Northern Growth Corridors. Approximately 11,000 ha of Golden Sun Moth habitat is proposed to be removed in the metropolitan area. Areas less than 100ha will be allowed to be cleared.
The Federal Government approved a rule that aimed to ensure an 80% protection goal of all 'high contribution' habitat across the region.
The proposed draft sub-regional species strategy proposes to meet this target by securing land proposed for the Western Grassland Reserves (to be completed by 2020) that will protect approximately 8100ha of confirmed high contribution Golden Sun Moth habitat (the same area is also being used to meet targets for grasslands).
In addition the new conservation reserves within the Urban Growth Boundary proposed in the Draft Biodiversity Conservation Strategy (DSE 2011) will protect approximately 300ha of confirmed high contribution habitat. These sites include areas yet to be surveyed in detail and boundaries identified at:
- Sinclair's and Taylors roads, Plumpton.
- Grieg's road, Mt Atkinson road, Middle Road Mount Cottrell.
- Woods road, Truganina.
- Manor Quarry.
- Kalkallo west.
- Mickleham road, Mickleham.
An additional, approximately 2360ha of confirmed, high contribution habitat would need to be permanently protected to achieve the 80% target, somewhere on the broader Volcanic Plain (e.g. between Melbourne and Portland).
A charge or levy is proposed for 'developable land' to provide 'compensatory habitat' to fund reserve acquisition and management.
Key Submission Points:
- A lot (over 11,000 ha) of habitat is being lost, and a large proportion of what is being retained has multiple uses such as grassland offsets.
- The 100ha threshold for retained habitat is too high and very little Golden Sun Moth habitat is being retained in the growth areas e.g. 300ha.
- Completion of survey and reserve area design of key golden sun moth conservation areas with the urban growth areas be confirmed before final corridor plans are approved.
- Additional Golden Sun Moth conservation reserves should be identified as part of an urban conservation network within the growth areas such as smaller areas in Sunbury and the Northern Growth Corridor.
- Golden Sun Moth reserves should be established before clearance or removal of habitat is allowed.
- A clear and explicit commitment for an additional 2360 hectares of Golden Sun Moth reserves in the Volcanic Plain should be 'protected' by inclusion in the formal public reserve system through purchase of private land by 2015.
Growling Grass Frog Sub Regional Strategy
The Growling Grass Frog is listed as 'Endangered' in Victoria and 'Vulnerable' under national environmental laws. Once widespread it is declining in the wild and needs corridors along waterways to survive.
The frog occurs in all the proposed growth corridors - West, Sunbury, North and South East.
For a more detailed description of the Growling Grass Frog visit our 'Get to know Melbourne's neighbours' web page.
Almost 8,000ha of frog habitat is to be removed. In the proposed corridor plans just 11% of Growling Grass Frog habitat (650ha) in the growth zones is to be retained and only 44% of its habitat is to be retained across the whole metro area, including green wedges.
Frogs need access to water and populations move over fairly large areas, depending on annual climatic conditions. Protecting zones along waterways and creeks is not only good for frogs, but also helps ensure clean water, act as flood protection and can be used as open space for people.
The draft strategy proposed that waterways have a buffer of 50m to 200m on each side of waterways (i.e. a habitat corridor of up to 400m wide along waterways). However, there are plans to reduce this in commercial areas. For example, the Biodiversity Conservation Strategy has identified approximately 54 hectares of land to be removed from Growling Grass Frog corridors on the Merri Creek and Werribee River to provide room for proposed town centres at Donnybrook and Tarneit West.
Four hundred artificial frog ponds are proposed to be developed as part of the draft strategy. A small number of links to other water bodies are also identified but without any detailed plans
A levy of between $6000 and $8000 per hectare of per developable hectare is proposed as provision for 'compensatory habitat'. This will include payment funding for restoration and management of the proposed areas (total cost $55 million). The waterways would generally be managed by Melbourne Water.
Key Submission Points:
- Maximum buffer zones for creeks and waterways of 200 metres each side should be consistently maintained throughout the growth areas, with no exclusions.
- The waterways should be in public ownership and managed in an integrated way for water quality, flood mitigation, biodiversity and recreation.
- The compensation levy of between $6000 and $8000 is likely too low and should be increased to ensure habitat restoration.
- A detailed evaluation and monitoring framework should be developed and released for public comment before the final plans are signed off by the Federal Government.
Southern Brown Bandicoot Sub Regional Strategy
In the 19th century bandicoots were described as being one of the 'very commonest' mammals in south-east Australia. But recent records, including survey work in East Gippsland, the southwest, around Wonthaggi and Wilsons Promontory, and southeast of Melbourne suggest their numbers are now low in many parts of Victoria.
There have been local extinctions at many previously occupied sites, leaving the species with a substantially reduced range. Small populations southeast of Melbourne are under increasing pressure from a range of threats closely associated with urbanisation.
The Southern Brown Bandicoot is listed as 'endangered' under the Federal Government's Environment Protection and Biodiversity Conservation (EPBC) Act 1999. In Victoria, Southern Brown Bandicoots are listed as 'threatened' under the Flora and Fauna Guarantee Act.
The Southern Brown Bandicoot is known to occur within the Royal Botanic Gardens Cranbourne and elsewhere in the southeastern growth area. It also occurs at several sites to the south and east of the expanded 2010 Urban Growth Boundary, and may be persisting in low numbers at the Pines Flora and Fauna Reserve to the west of the growth area.
The 'Sub-regional Species Strategy for the Southern Brown Bandicoot, a draft for public consultation, says that "it is important that Southern Brown Bandicoot populations and habitat are protected and managed on a landscape level".
The proposed habitat network for the Southern Brown Bandicoot has three main components:
- The retention, securing, and enhancement of existing habitat.
- The creation of additional habitat patches for the species.
- The provision of corridors linking populations and habitat patches.
The Sub Regional Species Strategy proposes two corridors:
1) The creation of a north-south corridor extending south from the Royal Botanic Gardens Cranbourne through a small area of the proposed Botanic Ridge precinct more or less due south to Quail Island (Westernport) through generally large rural properties. This will require creation of a secure habitat node to the south of the expanded 2010 Urban Growth Boundary, 50m to 80m wide. South of the Urban Growth Boundary a Continuous Habitat Corridor is proposed (160m to 200m wide).
2) The creation of an east-west corridor extending east from the Royal Botanic Gardens Cranbourne to Devon Meadows, then continuing to the South Gippsland Railway Line intersection with Manks Road. This will require securing and enhancing an additional approximately 50 hectares of land to create a habitat node at Devon Meadows within the expanded 2010 Urban Growth Boundary, and potentially utilising a portion of the proposed Melbourne Water retarding basin to also create a habitat node.
A third option for a link down the power line was also investigated, but rejected due to impacting on larger numbers of private landholders and difficulties with reconciling competing management objectives along the power line e.g mowing by power transmission companies.
Key Submission Points:
- These corridors will take up approximately 2%-3% of land proposed for urban development and are a bear minimum for Southern Brown Bandicoot conservation.
- The property development industry is getting a very good deal.
- Environment groups support the two proposed bandicoot corridors, they should however be 100-200m wide at all points, not reduced in size in urban areas.
- Many of the background technical documents (Practical Ecology 2011 a) identified a western link from the Royal Botanic Gardens Cranbourne to the Pines Flora and Fauna Reserve and Langwarrin Flora and Fauna Reserve, this link is now missing. An East West habitat link should be re-instated and developed.
Download the Sub-regional Species Strategy for the Southern Brown Bandicoot