Friends of Grasslands

supporting native grassy ecosystems

 

PO Box 987

Civic Square ACT 2608

 

 

Alan Boreland
ACPLA
PO Box 1654 Fyshwick 2609
Ph: 6126 1927
clarrie.hermes@portal.smecnet.com

 

 

Dear Alan

 

Clarrie Hermes Drive Extension Preliminary Documentation

 

As stated in earlier submissions on this development, FOG has a number of concerns about the proposed Clarrie Hermes Extension. FOG’s concerns relate to removal of the threatened ecological community, Yellow Box Red Gum Grassy Woodland (YBRGGW) (ACT threatened ecological community) or Box Woodland (Commonwealth threatened ecological community) and bisection of the remaining woodland, with potential impacts on birds such as the Swift Parrot, Superb Parrot and Regent Honeyeater, and the movement of small fauna (such as the skinks observed in the recent surveys) and the fragmentation of their habitat.

 

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 has been calling for an integrated long term approach to planning in this area (including future developments such as at Kinlyside). The Preliminary Document advises that there is a “proposed Kinlyside Nature Reserve, with boundaries … subject to ongoing discussions between the ACT and Commonwealth governments in relation to an offset strategy for the northern ACT. It is anticipated that any future broad scale development in these parts of the ACT would be subject to the strategy presently under development”.  It would be better if this strategy were completed and subject to public scrutiny before proceeding with developments such as the current one, since once again the community is being asked to comment without sufficient information about the Government’s plans.

 

In considering the Clarrie Hermes Drive Extension Preliminary Documentation, FOG notes the revision of the alignment that has the magnitude of the impact on some of the higher quality vegetation in the area.  However, the Document states that there will still be a loss of approximately 1.77 hectares of EPBC listed Box-Gum Woodland, together with loss of an additional 7.44 hectares of Non-EPBC woodlands and native pasture.

 

FOG has considered the proposed offset package and, while acknowledging it is a significant improvement on what was originally proposed for this development and that it has been developed with a view to maintenance or enhancement of box-gum woodlands in the ACT, has a number of concerns.  Firstly, FOG does not consider money alone to be an acceptable offset.  As a general principle, an offset package should include land (e.g. purchase of land or a legal commitment to conserve land into perpetuity) and conservation management of that land as well as money to support that management.  While the information being sought by the proposed research is much needed, there is no guarantee of any outcome of the research, nor of any commitment to apply it to grassy woodland sites within the ACT.  Any research offered as part of an offset package needs to be well directed and to provide results that can be and are used in the field.  It is not clear from the offset proposal as to whether the funding on rehabilitation in Kama Nature Reserve will be used before or after the outcomes of the research proposals are known.  Nor is it clear what the exact research topic will be or over what timeframe the research will occur.  Finally, while two rehabilitation areas are nominated on the Kama footprint, there is a complete lack of any other key details about how and when any restorative actions will be undertaken.

 

FOG is also concerned that offset money may be seen as a partial or total replacement of ongoing government funding for the operation of Kama Nature Reserve.  The proposed $50,000 to be spent on enhancement of disturbed woodlands in Kama Nature Reserve needs to be in addition to normal government funding for this reserve. 

 

FOG also thinks that offsets should be in place before the development commences.  In this case, the research proposals and rehabilitation in Kama Nature Reserve should be clearly defined, if not in place, prior to the development commencing.  There needs to be a process by which the offset is monitored, with penalties for non-compliance or for delays in completing the research projects.  If necessary, the cost of compliance with the offset package should be added to that package.

 

In calculation of the offset ratio, FOG notes that the lowest offset ratio was used due to the poor quality of much of the woodland. However, there appears to be no allowance in this calculation for the fragmentation that the road will create.

 

In conclusion FOG asks, now that the ACT Government’s draft offset policy is being used to assess and manage environmental impacts from developments, that the complete draft be formally released for public comment. It is frustrating to be expected to comment on development proposals that contain snippets of information about this draft policy, but not the full methodology underlying the offset proposals presented.

 

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

 

5 July 2010