Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614

email: advocacy@fog.org.au
web: www.fog.org.au

Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601
email: epbc.referrals@environment.gov.au

Dear Sir/Madam

Ellerton Drive extension, East Queanbeyan, NSW

Reference number: 2014/7304

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, with many members in surrounding New South Wales. Its members include professional scientists, landowners, land managers and interested members of the public.

FOG has substantial concerns about this proposal. FOG believes the road extension will have a significant impact on Box-Gum Woodland and on a large population of the Hoary Sunray (Leucochrysum albicans var. tricolor), an impact on the connectivity between populations of this and other species, and also impact other natural vegetation communities. FOG’s views is that this proposal should be considered in conjunction with a more strategic approach both to conservation of high quality areas and to future developments such as changes to traffic arrangements in and around Queanbeyan. We believe that the offset proposals downplay the significance of this area. Further details are provided below.

In relation to the Box-Gum Woodland area being affected by this proposal, the argument is that the area is small and, while the impact is significant, it will not have a critical impact on the community’s long term survival. FOG opposes this view as a number of “small” impacts eventually add up to a large impact – death by a thousand cuts. In fact, as identified in the Queanbeyan Biodiversity Study (Bushfire and Environmental Services, Biodiversity Study Findings Report: Queanbeyan Local Government Area, 2008), this patch forms part of an important east-west biolink. In light of this and other factors such as previous developments affecting Box-Gum Woodland area and development pressures from the growing population of Queanbeyan, FOG suggests that a strategic approach to assessing developments would be of benefit to both developers and Council, and would also maximise conservation of both the endangered species and communities in the area, and the important vegetation corridors through the area. Such an assessment could build on the work already done in the Queanbeyan Biodiversity Study.

The argument with regard to Leucochrysum albicans var. tricolor (Hoary Sunray) is that, as there are over 200,000 individuals been surveyed in New South Wales and the ACT, the loss of 5,000 is not significant. FOG understands that this represents 2.5% of the NSW/ACT populations, a significant reduction for an endangered species – again death by a thousand cuts. As well, while there may also be significant populations in Victoria and Tasmania, there may be genetic differences between these populations (germination differences have been reported between the Tasmanian and Victorian populations), as is the case with another endangered daisy, Rutidosis leptorrhynchoides (Button Wrinklewort). FOG argues that our remaining Hoary Sunray populations, particularly one as large as this, should be preserved and managed to maintain their long term conservation values, and that the loss proposed due to this development will result in a definite net loss of an endangered species across the landscape.

Another concern is the impact of the road on adjoining high quality areas in the long term. Such roads open up opportunities for the spread of weeks – this is recognised in the referral, with Queanbeyan City Council’s routine weed control practices being sufficient to mitigate this impact. However, our advice from Queanbeyan Landcare is that, as is the case elsewhere, insufficient resources exist so that serious weeds continue to threaten nature reserves and other high conservation areas on public land in this local government area. In this regard, the SIS states that “Weeds (including noxious and highly invasive weeds) are common throughout the Box-Gum Woodland in the study area and are likely to contribute to further degradation without proper management.” If the area is not developed, clearly proper management, particularly of the weeds, is needed. While placing a new area of endangered Box-Gum Woodland into reserve represents one step to better manage that site, we wonder if in fact duty of care (particularly for public land) should of itself lead to management ensuring this endangered community is retained into the future.

FOG notes the proposal to attempt to confine all construction work in the Box-Gum Woodland area to the final road corridor without using the 5m buffer if possible.

While FOG opposes any destruction of an endangered species or community, we will comment on the offsets proposed. This should not be taken as support of the proposed offsets, but rather recognition that in the end such a compromise appears likely.

One concern is the dismissal of the need for offsets for the Hoary Sunray because it is “locally common in Queanbeyan area”. As already mentioned, FOG considers the loss unacceptable and, if the development does proceed, offsetting should be mandated. FOG does not agree with the argument that the disturbance of developing a road will open up opportunities for the Sunray to spread – disturbance is far more likely to spread weeds.

Another concern is that no information is provided in the referral about the offsets proposed. The SIS contains information about possible offset methodologies and offset ratios, but it is not clear if these are supported by the developer or whether a lesser offset will be sought.

The third concern is the timing of implementation of offsets. The SIS supporting the referral states that “Offsets would be finalised within 12 months of the start of construction” and that only the offset package needs to be in place when construction starts. FOG’s view is that all offsets should actually be in place before any development begins.

FOG notes that the highest possible offset ratio of 1:6 is proposed in the SIS for the Box-Gum Woodland area. FOG’s view is that the ratio is too low for a high quality environmental asset like this, particularly as higher ratios are being used for threatened species habitat elsewhere and as success of any long term weed control in the area cannot be guaranteed.

This proposal will result in net loss of both Box-Gum Woodland and Hoary Sunray. The offset arrangements are not clear for the Box-Gum Woodland area, and non-existent for the Hoary Sunray population. FOG thinks that more consideration needs to be given to the necessity for the development, to a more strategic approach to developments impacting on matters of NES in this area, and to offset packages if development does proceed.

Yours sincerely

Sarah Sharp
President
26 August 2014