Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....




Referral Business Entry Point

EIA Policy Section (EPBC Act)

Approvals and Wildlife Division

Department of the Environment, Water, Heritage and the Arts

GPO Box 787



Dear Madam/Sir


ActewAGL sub-transmission line, Williamsdale to Theodore


Friends of Grasslands (FoG) provides the following comments on EPBC referral 2008/4621, a proposal to build a 132kV sub-transmission line.


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 the proposed route goes through the middle of Box Gum Grassy Woodland, a threatened ecological community, in Rob Roy Reserve (part of Canberra Nature Park), and makes the following comments.


Location. FoG continues to be concerned that public utilities are routed through conservation reserves such as Canberra Nature Park as an apparent convenience - continuing to use the sites as 'land bank' - rather than in areas of less value e.g. along roads or property boundaries. Are there other alternatives for the alignment that could largely or completely avoid the reserve?


Mitigation. FoG is not only concerned about loss of woodland within the reserve along the transmission line route, but that accidental damage may occur still within the reserve outside the alignment, during both the construction and maintenance phases. FoG urges that every effort be made to minimise the area so affected. In particular, as the transmission line goes through threatened woodland, disturbance between each pole site should be keep to a minimum. FoG is alarmed to find that there is no agreement between the ACT Government and ActewAGL, as a major utility provider, about standard operating procedures for line management in reserves. I have attached some mitigation suggestions.


Offset. FoG notes that the referral includes proposed 'compensatory habitat' on the southern ACT border with NSW, and states that this is in better condition than the habitat along the transmission line route (some of which is degraded from previous rural activities). FoG remains concerned that there is no agreed basis for estimating habitat values in the ACT, including as a basis for proposing offsets such as the one proposed. On what objective basis is adequacy of the compensatory habitat (to ensure 'net gain preferably, or at least 'no net loss') determined (by the proponent) or evaluated (by us)? Methods for valuing and offset estimation exist in at least NSW and Victoria[1], and FoG suggests that the NSW methodology is relevant, as the border is very close to Rob Roy. FoG notes that under the NSW system the proposal would not be approved as it includes the clearing of 150 trees in an endangered ecological community. FoG's view, obvious in other state approaches, is that as there is so little grassy woodland left, some remnants are too important to be destroyed; and how do we know what is proposed to be lost without proper evaluation of its value? In principle, FoG supports the concept of offsetting as a last resort - i.e. if there is no alternative (as in other states). If the compensatory habitat approach is used here, FoG notes that the proposed area provides a direct link to the Murrumbidgee River Corridor. FoG suggests that either gifting the land to the Territory or covering it under a permanent conservation agreement, would be appropriate to ensure that conservation values are retained and enhanced.


Yours faithfully




Geoff Robertson


15 December 2008


Copied to:

ACT Chief Minister

ACT Environment Minister

ACT Senators

ACT Greens environment spokesperson

ACT Commissioner for Sustainability and the Environment

ACT Conservator of Flora and Fauna

Limestone Plains Group




FoG's suggestions for mitigation


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. Careful management of site works and mitigation is critical. Inadequate mitigation measures can result in accidental damage to conservation values - on- and off-site - during and after construction.


Support site/works managers to understand the complexity of grassy ecosystem (especially grassland) management. Brief all relevant personnel/contractors before they go on-site, and remind them (e.g. use appropriate signs) on-site. Inform/train them to understand the values of the site 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 monitoring/correction. Minimise disturbance on site, e.g.


Avoid encroachment/intrusion, i.e. collateral damage to areas adjacent to the works site

Rehabilitate/revegetate disturbed areas within the works site sensitively and appropriately; using local species, and recognising the woodland/grassland values of the site and any adjacent areas. Any restoration, including use of seed mixes, should be consistent with the protection and long term management of site 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). All machinery going on site needs to be clean of weed seeds; a 'brush down' may not be sufficient.


Make supervisors and contractors responsible. The natural values being protected, and the need to avoid damage to them, should be recognised in contracts. Preferably, a site manager will be in charge at the site 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 habitat site ripped up by machinery is too late.


Provide for low impact ongoing management (site use/maintenance) e.g.

[1] FoG is advocating for a similar approach in a revised Nature Conservation Act. 'Under such systems clearing of native vegetation is allowed only as a last resort, after all feasible mitigation measures have been taken, and after it has been shown that the biodiversity loss resulting from clearance can be offset. Offsets do not replace cleared vegetation, rather clearing is only allowed if offsets enhance remnants to an extent that is expected to at least match the biodiversity loss caused by clearance.' [Proposed Molonglo urban developments and their significant impact on endangered woodlands, a report prepared by the Conservation Council ACT Region in June 2008]