Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Mr David Rhind
Commonwealth and Territories Section
Environment Assessment Branch
Department of the Environment, Water Heritage and the Arts
PO Box 787 Canberra ACT 2600
02 6274 2611



Dear David


Clarrie Hermes Drive Extension development 

Reference Number: 2009/5156


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.


FOG has a number of concerns about the proposed Clarrie Hermes Extension. Like many areas of Gungahlin, important biodiversity assets will be sacrificed because there have been inadequate attempts to integrate planning of biodiversity and other land uses. This is another example of the thousand cuts when a more broad landscape approach to planning should be undertaken. FOG considers that an integrated long term approach to planning in this area (including future developments such as at Kinleyside) should be adopted.


The main damage that the proposed road will do is to remove 5.2ha of the threatened ecological community, Yellow Box Red Gum Grassy Woodland (YBRGGW) (ACT threatened ecological community) or Box Woodland (Commonwealth threatened ecological community), and bisect the remaining woodland, thus reducing its value and hampering flow of flora and fauna. It will see the removal of significant habitat trees, which are obviously irreplaceable.


The development proposal clearly recognises most of these losses. It notes that the Swift Parrot, Superb Parrot and Regent Honeyeater potentially could use the site and the foraging resources available (including nesting habitat), and FOG considers any such loss of habitat for these species detrimental.


FOG also has concerns about the movement of small fauna and the fragmentation of their habitat. It suggests that blue tongue lizards and olive legless lizards (both found in the accompanying EIS survey) are plentiful, but rarely are either animal observed in the wild, and there seems to be little research on their abundance or otherwise. FOG would like to be informed of any information on this point and on other reptile fauna that may be present.


Should the road proceed, the recommendations to minimise the negative impact (set out in section 4) are supported. These include minimising clearing and educating those working on site, fencing of sensitive habitat areas, retention and reuse of top soil, rescuing of hollows from removed trees, and weed control.  In addition, the recommendation about mitigating and/or offsetting the direct loss of potential nest trees for the superb parrot is also supported


FOG notes that since ACTPLA released the Environmental Impact Statement (EIS), details of the proposed biodiversity offsets have been provided. These appear to be tree planting and subsequent watering in a degraded area (with an offset ratio of 1 to 3) for a couple of years. Unfortunately, this is a little premature, as we understand that the ACT Government is still determining its position on offsets – perhaps finalisation of offsets for this project should wait until the Government’s policy is clear.  An offset ratio of 1 to 3 seems low, and, in FOG’s view, offsets should replace like with like, i.e. result in no net loss. While FOG supports tree planting and maintenance, such activities in themselves may not be considered an offset unless understorey is also replaced and the area returned to a level of biodiversity comparable to what is being lost. Rather than tree planting alone, a better option would be a significant contribution to a fund to be used to facilitate something like a bush regeneration team to plan and oversight the restoration and maintenance of the site. FOG also notes that there should be provision for ongoing maintenance of high quality areas remaining along Clarrie Hermes Drive and in the Harcourt Hill area where restoration activities are undertaken.


Sincerely yours





Geoff Robertson



4 November 2009