2/9/2008
The Honorable Paul Holloway
Minister for Urban Development and Planning
South Australian Parliament
178 North Terrace
Adelaide 5000
Dear Minister Holloway,
The Grey Box Community is alarmed at your proposal for uniform development reforms allowing subdivision of smaller housing blocks & for buildings to cover up to 60% of the area of housing blocks.
The Grey Box Community is a community group whose purpose is to conserve & to improve the remnant, regenerated & 'urban forest' comprising the Grey Box (Eucalyptus microcarpa) Grassy Woodland vegetation community. This is an endangered vegetation community (listed under the Provisional List of Threatened Ecosystems in South Australia 2001).
Development of the original woodland area in the Mount Lofty Ranges has resulted in the loss of about 90% of the original 500,000 ha & the remnant woodland is significantly degraded & fragmented. This level of destruction is of great concern & has already resulted in numerous local mammalian & avian extinctions. It is believed that even without further degradation of these woodlands there is likely to be the extinction of a further 42 avian species because of an extinction debt incurred (Possingham & Field 2005). It is recognized that Birds of temperate woodlands are amongst the most threatened in the country & that one of the challenges in preserving these birds will be to limit small scale removal of vegetation (Olsen et al 2006). The biodiversity value of remnant vegetation in urban fringe areas is now regarded as highly significant with more than 50% of threatened
We assert that the large numbers of mature Grey Box Gums (together with other flora of the Grey Box Grassy Woodlands) that exist within the urban Mitcham Hills are highly significant in terms of biodiversity in the region because they comprise a significant proportion of the region's extant native flora & also because they link the highly fragmented remnant woodlands.
We also assert that the continued site-by-site degradation of this vegetation community will certainly result in a reduction in biodiversity & contribute to further local extinctions, particularly of native birds.
The application of small housing blocks with 60% building coverage will ensure the destruction of large numbers of mature Grey Box Gums throughout the Mitcham Hills to the permanent detriment of the remaining local biodiversity.
There is a need for systematic landscape planning that explicitly incorporates biodiversity values across all tenures, including private land & Government has explicit responsibilities to do so in order to preserve biodiversity; the international convention on Biological Biodiversity is a legally-binding instrument that Australia is signatory to (Buxton et al species nationally occurring in urban fringe areas; urbanization is considered one of the greatest current threats to biodiversity & there is an urgent need to improve conservation planning in cities. As there is incremental & cumulative removal of vegetation for development the accumulation of individual changes over time & within a region may constitute a major impact (Buxton et al 2006). It has been demonstrated that Avian species richness declines as the degree of urbanization (measured by roof-counts) increases (Yeoman & Nally 2004) & that a 10% change in the amount of tree cover results in a similar change in the native bird diversity (Freudenberger & Harvey 2003). 2006).
We further assert that there are explicit benefits of the Mitcham Hills urban forest for energy conservation, greenhouse gas sequestration, storm-water run-off, local character, local amenity & for the well-being of the residents.
Existing National, State & Local Government responsibilities & policies on biodiversity and zero species obviate the need for the Mitcham Hills to be granted an exemption from the proposed new Planning Regulations. Minimum block sizes must remain at current levels with no more than 40% coverage by built structures (house, garage, sheds and paving).
We further propose that the Mitcham Hills be proclaimed an area of special conservation significance with protection of all of the extant native vegetation, both within the remnant woodlands & within the urban Mitcham Hills, both on public & private land.
The Grey Box Community understands that the Native Vegetation Act applies to a large part of the Mitcham Hills & have expert advice to support this view from the Environmental Defenders Office. We urge the Government to legislate to include all of the Mitcham Hills to be covered by the Native Vegetation Act & also to amend the act to protect the vegetation community comprising flora of the Grey Box Grassy Woodlands.
We also urge the Government to ensure that the Native Vegetation Act is effectively applied & policed throughout the state, including the Mitcham Hills.
Yours Sincerely
Andrew Miller
for the Grey Box Community
13 Laffers Rd
Belair
SA 5052
phone 82780400
References (all available on the internet)
Change and continuity in Periurban AustraliaState of the Peri-Urban Regions: A Review of the Literature
Buxton et al 2006
Assessing the Benefits of Vegetation Enhancement for Biodiversity: A Draft Framework
CSIRO Sustainable Ecosystems
Freudenberger & Harvey 2003
Birds of Woodlands and Grasslands
Paper for the 2006 Australia State of the Environment Committee
Department of Environment and Heritage, Canberra
Olsen et al 2006
Regional Bird Extinctions and their implications for vegetation clearing policy
Possingham & Field 2005
The avifaunas of some fragmented, periurban, coastal woodlands in South-Eastern Australia
Yeoman & Nally 2004
