Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
GHD Pty Ltd
Canberra Technology City Submission
PO Box 36
BELCONNEN ACT 2616
Draft Environmental Impact Statement for Canberra Technology City (CTC)
I am writing to provide Friends of Grassland (FoG) comments on the draft EIS for a computer data centre campus and natural gas co-generation facility (CTC) at Tuggeranong.
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 the 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 notes that, although the site contains little remnant native vegetation, part of the route of the gas pipeline is adjacent to the Jerrabomberra Grassland Reserve protecting lowland native grassland (LNG, a threatened commununity listed under both Australian and ACT legislation) and a core conservation site in the ACT's relevant Action Plan 28 (conservation strategy for LNG). There is also some private land outside the reserve which includes LNG values.
While the report indicates that works associated with the gas pipeline and electricity line should be contained within the corridor indicated in the report, FoG is concerned that accidental damage may occur to remnant grassland during the construction phase, and potentially in the maintenance phase. FoG urges that this risk is noted, and that every effort is made to keep all construction/maintenance activity away from the remnants, e.g. outside the fence defining the boundary of the reserve. FoG suggests mitigation measures such as those in the attachment.
FoG also notes that both the gas pipeline and the electricity lines proposed will affect some mature native trees (e.g. Blakely’s red gum and yellow box ), and supports the consultant’s proposals concerning minimising removal of such trees. Many woodland bird species are in decline, and unnecessary removal of trees that provide habitat for these species may hinder their long term survival.
12 December 2008
FoG's suggested mitigation measures to protect grassland values
Proposed mitigation, and techniques to be used, should be spelled out specifically and unambiguously in contracts, and must be sufficient to protect/enhance all retained native vegetation along a works corridor and in adjacent sites. Inadequate mitigation measures can result in accidental damage to conservation values - on- and off-site - during and after construction.
Support works managers to understand the complexity of grassland management. Brief all relevant personnel/contractors before they go on-site, and remind them (e.g. use appropriate signs) on-site. Ensure they understand the relevant values and how to protect them.
Minimise the need for disturbance through appropriate location and good design.
Prevention or minimisation of damage to site and adjacent environments should be the emphasis, rather than measures/monitoring/correction. Minimise disturbance, e.g.
- if necessary, temporary fences should be erected to limit movement by vehicles
- wherever excavation is required, its extent should be minimised.
Avoid encroachment/intrusion, i.e. collateral damage to areas adjacent to the works site
- location of any works related proposed fencing should be
- mapped and marked/laid out competently before construction
- specified to be constructed from within the project site (i.e. outside reserve)
- constructed prior to site works commencing
- erected to prevent movement of vehicles and spillage of spoil
- vehicle access should not be through adjacent areas of high conservation value
- materials should not be stockpiled off-site (e.g. on adjacent reserve)
- no services (including temporary arrangements) should be routed through adjacent grassland
- no runoff or debris should be directed at areas of quality grassland.
Rehabilitate/revegetate disturbed areas sensitively and appropriately; using local species, and recognising the grassland values of adjacent areas. Any restoration, including use of seed mixes, should be consistent with the protection and long term management of local values - considering things like source of seed (local), species selection and appropriate methods/timing of works.
Prevent weeds. Avoid disturbance, and introduction of weeds (e.g. in landscaping material), and weed spread (e.g. through altered drainage resulting in increased water availability).
Make supervisors and contractors responsible. The natural values being protected adjacent to the corridor, and the need to avoid damage to them, should be recognised in contracts. Preferably, a site manager will be in charge and responsible at all times. If agreed mitigation measures in contracts are breached, use a significant financial disincentive to remediate any damage caused. However, the emphasis should not move from prevention to simply monitoring and correction; fixing a grassland site ripped up by machinery is too late.
Provide for low impact ongoing management (site use/maintenance) e.g.
- locate asset protection zones (for fire prevention) within the site
- manage linear structures as sensitively as possible - e.g. target problem (such as tall/woody) species rather than bulldoze lines.