THE PROPOSED URBAN GROWTH BOUNDARY AND EPBC STRATEGIC ASSESSMENT REPORT KEY POINTS IN RESPONSE Urban growth boundary expansion is unsustainable and unnecessary The proposed large-scale expansion of the urban growth boundary will accelerate Melbourne's car dependent urban sprawl, resulting in loss of nearby green wedges and threatened habitats and a less liveable city. The proposed UGB expansion is unnecessary to provide for housing and industrial sites, as if Government implements its own housing density target of 15 lots / ha (of gross developable land) there is enough land in existing growth corridors to last for 19 years, or 20 years if a modest target of 20 lots / ha (gross) was implemented1. Urban infill development and higher density redevelopment along train lines is much cheaper, and results in much less greenhouse pollution than outer-suburban sprawl2. New grassland reserves are welcome, but effective implementation measures needed and Red-gum woodland reserve The proposed reserves will be an important step forward for grassland conservation, but there are many doubts about how they will be secured, funded and managed. State and Federal Governments should make a clear commitment to do the following: secure the reserves in the short-term (e.g. over a 5 year period), through public acquistion and permanent conservation agreement on private land, before any clearing for urban expansion occurs; Provide adequate public funding (e.g. $ 50 million) to establish and manage the reserves, and pursue a developer biodiversity levy for this purpose, instead of relying on offsets from large-scale clearing; Support private landholders to protect and manage grasslands in the interim before the reserves are established, and enforce clearing controls as required; Establish accountable management and monitoring processes and a skilled workforce to ensure the reserves are effectively managed and restored; Secure a viable biolink along the Werribee River corridor connecting the Werribee Plains and Mt Cotterell area reserves 1 From analysis by Green Wedges Coalition Researchers at Curtin University, WA, have reported that up-front infrastructure costs were $50.5 million for inner city redevelopment versus $136.00 million for new outer-suburbs, whilst the net present value of on-going transport costs over a 50 year time period, was $256.8 million for inner city redevelopment versus $507.1 million for outer-suburbs. (“Assessing the Costs of Alternative Development Pathways in Australian Cities”, Romon Trubka et al 2008 , Curtin University Sustainability Policy Institute, Fremantle.) 2 Fund and secure a substantial new reserve for Plains Grassy Woodland (Red-gum woodland) across the core area of woodland in the Whittlesea green wedge. Spring ecological surveys and further public consultation needed before any decision made about UGB Detailed on-site native vegetation quality mapping, and flora and fauna surveys are required this spring across the urban investigation areas, together with further public consultation, before any decision is made about urban expansion and new freeways. The urban growth boundary review and EPBC strategic assessment are being pushed through in a very short time frame, without time for adequate ecological assessment or community consultation. Only a minor proportion of affected remnant vegetation has been mapped on-site (mostly on the Werribee Plains), and instead most has been subject to a desktop assessment, which has often been inaccurate especially in Melbourne’s north. There has been very little analysis of impacts on threatened species or the significance of different sites for species conservation. Whilst we know the environmental impacts will be large, we don’t know the full significance of what we’ll be losing. Ecologically significant sites close to Melbourne must be protected, not traded-off for proposed grassland reserves. High quality, diverse grassland and other threatened ecosystems close to Melbourne are an important part of the biodiversity of the region, often with unique ecological values and species composition. They include grassland types such as Heavier Soils Plains Grassland and Themeda dominated grassland, which are not well represented by the proposed reserves. These habitats are integral to the liveability of our city. Whilst the planned UGB expansion, proposes to retain some important remnant vegetation within mapped exclusion areas (e.g. for conservation purposes, waterways and floodways, quarry buffers) up to 6900 ha of Plains Grassland, and 900 ha of Plains Grassy Woodland are proposed to be cleared. The proposed environmental prescriptions for urban precinct plans may help to retain some additional remnant vegetation, especially Plains Grassy Woodland and key sites for nationally listed species, but they tend to support clearing in exchange for off-site offsets – especially in the proposed grassland reserves. Yet the ecological values in the latter differ from those around the edge of Melbourne, and State Government has acknowledged it will breach the offset requirements of the Native Vegetation Framework. State Government has the opportunity now to establish a world-class reserve and protected area network around the fringe of Melbourne, to secure the diversity of threatened ecosystems and species on our doorstep. As part of this the following is needed: 3 all sites of regional ecological significance and higher, with effective habitat links along waterways and elsewhere, should be identified as part of the ecological assessment of the UGB review, and secured as part of a strategic urban-fringe conservation network3; urban precinct plans should implement a strategic urban-fringe conservation network, and be guided by clear prescriptions to protect sites of ecological significance and effective habitat links within the precinct; management and funding arrangements should be set out to secure and manage high conservation value sites which are proposed to be excluded from urban development within the expanded UGB; State Government should commit substantial new public funding for urban-fringe biodiversity conservation and pursue a developer environmental levy for this purpose; offsets for clearing within one growth corridor, should stay within that corridor or the nearby green wedge; sites of ecological significance and habitat links should be identified for retention at the outset across each urban investigation area, to set the framework for the subsequent urban precinct planning process. This will help provide certainty for developers