Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608


ACTEW Water Security Projects
GPO Box 366
Canberra City 2601



Dear Sir/Madam


Murrumbidgee to Googong water transfer: draft public environment report

Reference Number: 2009/5124


In considering this public environment report (PER), FOG supports the measures proposed to minimise the impact on the threatened small purple pea (Swainsona recta) habitat, such as avoiding the identified populations during construction and alignment refinements to minimise impacts on any populations during the pre-construction surveying. FOG also supports the mitigation measures proposed to minimise impact on the pink-tailed worm lizard (Aprasia parapulchella), while noting that it would be better if all pink-tailed worm lizard habitat could be avoided given the status of this reptile as threatened. We are uncertain as to the likely success of the proposed relocation into the offset area of any pink-tailed worm lizards found during pre-clearance surveys. Any lizards that are removed from the wild should be used for captive breeding purposes and/or for successful translocation. If such translocation is attempted, it should be done only after careful consultation with expert advice, and it would be valuable to tag individuals and monitor their long term survival. FOG would prefer that no lizards are removed from the wild, would like more detail on what is proposed for any such translocation efforts, and also requests to be advised about monitoring results in the unfortunate circumstance of translocation being needed.


FOG notes from the report that “ACTEW is committed to successful rehabilitation of the construction easement”. However, as expressed in our letter of 14 December 2009, FOG has some concerns about the rehabilitation work done to date for this project. As stated in that letter, FOG inspected the three rehabilitation areas on a property along the Williamsdale Road and noted the presence of rye grass (an exotic grass), which was evident no where else in the surrounding grassland and woodland. In FOG’s view this restoration work was not of particularly good quality. We recommend the use of experts in bush regeneration to ensure that all rehabilitation efforts are of the highest quality and likely to succeed, both in the construction corridor and in the offset area. Given past problems in this area, FOG would like information about what regeneration is planned and who would be undertaking it. We also recommend the development of performance measures for the rehabilitation work, and monitoring to ensure that these measures are met. This is an approach that FOG is currently advocating, and we would like to be advised about these activities and have the opportunity to discuss the detailed approach to be used.


In this context, the proposed two year period for rehabilitation and weed management definitely needs to be regarded as a minimum only, and if unfavourable conditions (such as drought) result in a poor rehabilitation outcome, the rehabilitation and weed management period should be extended until a good outcome is achieved. Given previous examples of similar developments where rehabilitation was inadequate and the infrastructure corridor is marked by a swathe of weeds, active weed control and monitoring of the success of rehabilitation should continue for an extended period. As mentioned in our previous submission, 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. Since the impact of the development is ongoing, FOG would like to see commitment to monitoring rehabilitation success (and further work if rehabilitation is not successful) for five years at the very least.


FOG notes in the information about management plans that the roles and responsibilities of all personnel and contractors will be identified, and that there will be ongoing communication with the community.  FOG supports the proposed mitigation measures, and recommends that all mitigation measures be specified in development contracts to ensure that they are implemented fully, with penalties for any environmental damage that occurs. FOG would like to be kept informed about the progress of rehabilitation and mitigation efforts and the implementation and maintenance of offsets.


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 should be adhered to, and in addition, vehicles should remain solely within the construction easement and on roads, with works in weed-infested areas scheduled only during months when weeds are not carrying seed. Noting that a corridor along the pipeline route will be needed for ongoing access, commitment to cleaning service vehicles and weed control is essential in the long term, as well as during the construction phase. A program to eliminate all noxious weeds along the entire pipeline route (not just the areas containing natural temperate grassland and box-gum woodland) before construction and to monitor and eliminate re-infestations would assist in prevention of weed spread in the longer term.


The map of the vegetation communities (Figure 4.28) appears identical to that presented in the Draft Environmental Impact Statement presented in August 2009. From this it appears that one area of the proposed pipeline easement on the property that FOG visited late last year was classified as non-native pasture. However, as noted in our letter of 14 December 2009, we were unable to locate any specific area along the easement that was not predominately native vegetation, and in fact not box-gum woodland. FOG asked that the working easement on this property be reduced to 15m if possible, and certainly less than the 40m advised to the landholder. While this level of detail is not contained within the PER, we would like to be made aware of what is now planned in this case.


FOG would prefer that there were no need for offsets due to no impact on threatened or endangered species or ecosystems, but acknowledges that at times they may be necessary. To be effective, offsets should be of similar quality to the areas being lost, be maintained in perpetuity, and be in place before construction activities commence. If offset areas are of a lower quality than the areas being lost, rehabilitation activities need to continue until such time as the offset area reaches the same quality. While the offset ratios proposed in the report seem reasonable, details of the relative qualities of the sites being lost and the offset sites is not clear from the PER, which makes further comment difficult. Long term protection and resourcing for their ongoing maintenance is essential for any offset site, as is a management plan. FOG’s view is that the Offset Plan must be finalized and the offsets actually achieved before construction activity through natural temperate grassland or box-gum woodland areas commences. We would like to be advised of the final Offset Plan, particularly in view of the lack of a public ACT Government stand on offsets at present. FOG is currently reviewing its offset policy, and in general terms the proposed offsets seem reasonable. However, without more detail it is not possible for FOG to make a judgement about the acceptability or not of this offset proposal. If there is a definite proposal on the table, then FOG would like the opportunity to consider this and provide feedback.


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.


Sincerely yours





Geoff Robertson



24 May 2010