Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Applications Secretariat Section
Customer Services
ACT Planning and Land Authority
PO Box 365 Mitchell ACT 2911



Dear Sir/Madam


Murrumbidgee to Googong Water Transfer: Environmental Assessment (NSW) and Draft Environmental Impact Statement (ACT), August 2009


Friends of Grasslands (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.


In considering this development proposal, FOG notes that a number of measures have been or are proposed to minimise the impact on environmentally sensitive areas (such as shifting the pipeline alignment to avoid impact on potential Swainsona recta habitat within railway land, and moving the mobile substation location to a highly degraded area). FOG supports reduction of construction and scour widths in areas that contain endangered ecological communities (EECs) and/or threatened species habitat, preferably to 15m if possible.


FOG supports the mitigation measures outlined in chapter 13, and asks that they be included in development contracts to ensure that they are implemented fully. A particular danger with a project such as this is the spread of weeds into areas that are currently relatively free of weed, especially given the presence of noxious weeds such as African love grass, serrated tussock and Chilean needle grass in some areas along the pipeline route. All of the measures suggested (e.g. development of a weed distribution map, undertaking a pre-construction weed control program in areas likely to pose potential weed dispersal problems, implementing strict vehicle hygiene controls, and identifying and fencing off “no-go” zones and sensitive areas adjacent to the construction corridor) should be adhered to. In addition, vehicles should remain solely within the construction easement and on roads, and works in weed-infested areas should be scheduled when weeds are not carrying seed. FOG urges commencement of pipeline construction to be within areas that contain low conservation value vegetation so that the time delay between vegetation removal and subsequent rehabilitation is minimized, especially within high conservation value communities in the ACT and Gibraltar “saddle” area.


Presumably the pipeline will require ongoing maintenance, necessitating a service track along its route. There needs to be commitment to cleaning of service vehicle and weed control in the long term, as well as during the construction phase. A program to eliminate all noxious weeds along the pipeline route before construction and to monitor and eliminate re‑infestations would assist in prevention of weed spread in the longer term.


The proposal mentions preparing a vegetation monitoring strategy to record the progress of the rehabilitation effort.  Such a strategy should include longer term monitoring to ensure that rehabilitation has been effective and that construction and ongoing maintenance activities do not lead to the long term spread of weeds within high quality grassland areas through which the pipeline passes. There are a number of examples of other such developments where rehabilitation was inadequate and the infrastructure corridor is marked by a swathe of weeds, e.g. the north-south gas pipeline, and eastern gas pipeline and water pipelines across Canberra Nature Park. Active weed control should continue for an extended period. One option is to require, under the contract, a 10 or 20 year bond, which could be used to cover government expenses in rectifying any weed problems that occur in high quality grassland and grassy woodland areas post-construction, or returned to the developer at the expiration of the bond period if rehabilitation is satisfactory.


FOG notes that the proposal states that offsets for the removal and/or modification of approximately 16.7 ha of native vegetation will be provided. In general, FOG supports the objectives of the Offset Plan as stated in the proposal, while noting that it is preferable that offsets not be needed at all. The principle that offsets and their actions must be enforceable through development consent conditions, license conditions, conservation agreements or a contract is one that FOG sees as important to ensure that proposed offsets do in fact deliver a net improvement in biodiversity over time, and should be part of this project.


Further information about the rehabilitation and offset plans was sought at the information session in Tuggeranong on 1 September, but has not been forthcoming. FOG notes that ACTEW intends to seek advice from all relevant regulators throughout the development of the offset plan. However, there is no mention of consultation with interested community groups such as FOG, or any provision for community groups to comment on the offset plan. The offset and rehabilitation plans should be agreed to by the community, then finalized, before any construction work commences on the project.


Given the number of development proposals happening in this area of the ACT, FOG is concerned about fragmentation of grassland and grassy woodland habitat. We also find it difficult to gain an overview of what is happening to the higher quality grassy ecosystems in the area when we are not advised as to the final location and status of offsets provided for previous developments. It would have assisted in our consideration of this proposal to have been provided with information about the final location of earlier developments and their agreed offsets (such as the Transgrid Transformer Electricity Substation and Subtransmission Line projects in the Williamsdale area, for which we understand a 20ha land parcel offset has been established). As other infrastructure developments will be proposed in this area of the ACT in the future (e.g. commercial solar power generation), an integrated approach to planning this infrastructure while maintaining biodiversity of the grassy ecosystems in the area is needed. FOG would be happy to provide comments on or be involved in any community consultation about such an integrated planning approach. Again, such an integrated approach should be developed and agreed to prior to construction work commencing on the Murrumbidgee to Googong Water Transfer project.


Sincerely yours





Geoff Robertson



15 September 2009