Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
ACT Planning Authority
PO Box 365
MITCHELL ACT 2911
Preliminary Assessment for upgrading of the ACT portion of the Kings Highway
I am writing to provide Friends of Grasslands (FoG) comments on the above PA. FoG is a community group dedicated to the conservation of natural temperate grassy ecosystems in south eastern Australia. FoG advocates, educates and advises on matters to do with conservation of grassy ecosystems, and carries out surveys and other on-ground work. FoG is based in Canberra and its more than 200 members include professional scientists, landowners, land managers and interested members of the public.
FoG was unaware of the community workshop held in December 2005; ideally, given the scale of this project, dedicated groups such as FoG would have been invited to attend. FoG would be interested to know who did attend and, therefore, how comprehensive were the views provided. FoG also notes that, while matters of potential impact under the EPBC Act are raised, there is no mention of how this process meets the requirements of that Act, or whether there will be a separate process.
FoG members have visited remnant vegetation sites mentioned in the PA, and regard them as being of high quality. The PA's description of native vegetation (type and quality - particulary of non-tree species) is inadequate, and it does not quantify the potential loss across the proposed works, and adjacent areas, adequately. Similarly, the description and assessment of fauna, and potential impacts, seems inadequate: while the techniques noted at 2.2.2 seem appropriate, the information gathered is not particularly convincing.
FoG is most concerned with that part of the upgrade that takes the existing highway away from its current route and comments follow.
Throughout the PA there is an overemphasis on trees, compared with the diversity of native vegetation present, in considering impacts on native vegetation, for example:
- reference at 2.1 under 'Vegetation Survey' to the ecological assessment 'highlight(ing) potential tree removal' and outlining the very specific tree recording/detailing (FoG noted nothing about understorey survey)
- reference under 'Effects on Canopy' (at 220.127.116.11, p40) to 'most obvious ecological impact ... the potential loss of trees'; while this may be the most visible loss, and is certainly of ecological concern, the potential impacts are far greater than this
- references at 'Effects on Understorey and Groundcover' (18.104.22.168, from p42) to grassy and shrub species; overall, vegetation type is undefined, quality is downplayed, and a general statement that the 'amount ... to be cleared ... is low' is confusing and lacking evidence
- in the ecological assessment it is clear that the 'vegetation survey' was a 'tree survey' (EA 3.3).
- Where 'grassland' is mentioned, references are not specific enough to enable understanding of type or quality, for example:
- 'rural grasslands' (at 2.1 and elsewhere), meaning what - derived grassland (from previous woodland)? 'improved' pasture?
- 'Felled Timbers grasslands' (at 2.1) - meaning what?
- 'open grassland' (at 2.2.1 and elsewhere), meaning what?
- at Table 4, there is no mention of grassland derived from the Yellow Box - Red Gum Grassy Woodland (YB-RG GW), and given that the Table also specifies that Natural Temperate Grasslands of Southern Tablelands NSW and ACT was not found in the vicinity of the works, any quality grassland is probably derived from YB-RG GW; could it be defined thus, and have endangered ecological community coverage?
- references at 'Effects on Understorey and Groundcover' (22.214.171.124, from p42).
The PA is inconsistent in references to potential impact on the YB-RG GW, for example,
- while at Table 4 there is reference to the proposed new alignment having 'minor impacts on the small northern portion', 'Section 4' which is apparently over 2km in length (2.2.2 Fauna p.28) has 'moderate to high' 'open grassland and/or open grassy woodland' habitat values
- there is proposed 'removal of several hundred mature trees' because the new alignment 'traverses an area of intact woodland, the Kowen [TSR]', with no mention of the understorey values to be lost as well (at 126.96.36.199, p40)
- also reference to removal of around 30% of 'trees mapped ... varying age and size classes' in Section 4 (at 188.8.131.52, p40).
The failure to identify native vegetation impacts comprehensively - both in the works corridor and on adjacent land that is also vulnerable to works impacts - means that mitigation measures, to the extent that they are mentioned, are inadequate.
The needs analysis (184.108.40.206) seems to be limited, and reporting of it unsatisfactory. The reference to 'consideration of other qualitative factors' being taken into account (only) after such analysis indicates that a 'project should not proceed in financial terms' is odd. There is no evidence here that ecological factors were considered at all in this analysis.
References throughout to the likely benefits of 'rehabilitation of the existing road alignment' and reconnection of sections of the TSR are not convincing given the lack of detail about how this will occur. If rehabilitation (not specified adequately) happens, there is a need to protect the values retained/enhanced in the long term, such as through reservation for nature conservation. This would address the second, critical recommendation from the ecological assessment (which FoG did not see reference to in the PA) to 'meet the criteria for improving or maintaining the ecology of the areas (a standard recognized by state and federal environment agencies)', i.e. the no net loss standard. Such reservation would protect retained/rehabilitated areas from the risk of 'overzealous tree mgmt' noted at 2.2.2 and elsewhere, as even TSRs are vulnerable to overgrazing (when feed is poor and stock needs to travel) and also neglect because of lack of resources for management. The ecological assessment's recommendation continues that 'Compensatory habitat should be considered if the project does not meet [the improve/maintain] test', i.e. the developer would need to find/fund offsets.
FoG is very interested that the developer will pay a commercial value for loss of pine trees (see 4 Summary and Conclusions p51), but not commit to offsetting the loss of native vegetation which, although intrinsically priceless, can be 'valued' to some extent for the purpose of compensatory native vegetation protection, which should be required for such extensive works as it is in other jurisdictions. FoG is also interested to see that although the engineering works are planned to be 'seamless' for the road user (see 1.5.4), the results from planning approval requirements in ACT compared with NSW - under the latter's assessment methodology required by native vegetation protection legislation - are likely to be quite different; with the ACT approach most likely leading to avoidable 'net loss'.
Proposed mitigation, and techniques to be used, should be spelled out specifically and unambiguously, and must be sufficient to protect/enhance all retained native vegetation along the works corridor and adjacent sites. For example,
- reference to the species to be selected and source of material - included under 'Visual impacts' (at 3.2.5, e.g. 'plant materials to be used in landscape redevelopment works will be propagated from locally collected seeds') but not otherwise detailed
- reference to use of 'non-invasive dryland grass', if to some sort of commercial seed mix, is not consistent with the above point; depending on timing of works, consideration should be given to using seed material from, or as close to that from the local area as possible, for the non-woody species as well
- almost no addressing of potential for increased weediness, e.g. potential for weed introduction in landscaping materials, and weeds being carried by drainage around the sites (and off-site).
The 'Effects on Fauna' (at 3.3.2, p44) does not make sense as there seems to be text missing. This does not provide any confidence in understanding of potential impacts. The glancing reference to assumed sympathetic neighbour behaviour in managing wildlife (signs on a fence, see 3.3.3 p45) does not improve confidence, nor does the text re possum/glider movements on p46. Essentially the effects of the mitigation hinted at is unknown; far too many 'may' statements.
Where alternatives are mentioned in the PA, e.g. at 2.2.1 'southern deviation alignment', the relative potential impacts are not clear. FoG suggests that the proposal be put on hold pending better information being provided on grassy ecosystem values present and at risk, and clear identification of less destructive alternatives.
Finally, the PA (p29) recognises 'the landscape mosaic ... role in the identification of Canberra as the "Bush Capital" ... its cultural and historical landscape setting' and 'landscape components ... symbolic of much of the landscape of rural south eastern Australia' but fails to recognise the irony in the progressive destrucion of elements of this landscape - especially vulnerable remnants of its former grassy woodlands - such as through these roadworks.
9 May 2008
cc ACT Commissioner for Sustainability and the Environment
ACT Conservator of Flora and Fauna
Limestone Plains Group