Friends of Grasslands

supporting native grassy ecosystems

PO Box 987

Civic Square ACT 2608

Mick Welsh
Commonwealth and Territories Section
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
Ph: 02 6274 1692
michael.welsh@environment.gov.au

Dear Mick

Kings Highway Deviation, ACT

Reference Number: 2010/5501

Friends of Grasslands (FOG) notes that this southern alignment of the Kings Highway upgrade is being proposed after the northern deviation was rejected by TaMS in 2008 due to the impacts on the Kowen Traveling Stock Reserve (TSR), and that the new alignment has been specifically designed to avoid the removal and fragmentation of a large number of eucalypts.

However, as noted in the proposal, a small section (2.6ha) of the threatened ecological community, Box-Gum Woodland will be directly impacted by road construction at the western end of the project. As well, the box-gum woodland will be fragmented into one large and one small remnant, which may threaten the viability of the smaller remnant in particular. Even though the area being lost is small, all losses of threatened ecosystems are significant. For this reason, FOG would like to see a formal offset offered for both the area being lost and fragmentation of the area, and recommends that the rehabilitation proposed in the EIS be included as this offset. The rehabilitation we refer to is the proposed rehabilitation of the road works with locally occurring native species, the removal and rehabilitation of a component of the existing Kings Highway alignment to try to re-establish connectivity between the two halves of the Traveling Stock Reserve, and the revegetation of the pockets of pine trees to the north of the Kings Highway Southern Deviation (that will be isolated from the plantation by the road construction) with local provenance native species to attempt to improve connectivity between the existing Yellow Box Red Gum remnants. FOG would like to see the use of forbs as well as grasses in such rehabilitation activities, and be assured that sufficient resources will be provided to result in a reasonable quality connection between the Box-Gum Woodland remnants and maintenance of the rehabilitated areas over the long term. Inclusion of these rehabilitation activities as a formal offset for both the area being lost and fragmentation of the area left will result, over the long term, in a net gain and improved connectivity between the larger remnants of Box-Gum Woodland.

FOG supports a number of the recommendations of the proposal and the attached EIS relating to prevention and mitigation of impacts from construction activities, such as the narrowness of the construction footprint in sensitive areas, weed control, fencing sensitive areas prior to construction, minimizing tree clearing, minimization of importation of fill material into the area of works, and development of a Construction Environment Management Plan to be included in the Request For Tender (RFT). FOG is pleased by the recommendations for fencing and protection of the Snow Gum remnant and the Hoary Sunray patch, and suggests that the final construction plan includes details for monitoring for weeds during construction. An induction for workers that helps them understand the values of the conservation areas and how to protect them would also be useful in prevention of accidental damage and spread of weeds.

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.

Sincerely yours

Geoff Robertson

President

24 May 2010