Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601


Dear Sir/Madam

Stage 1 Light Rail Service: Gungahlin to Civic, ACT

Reference Number: 2014/7379

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 members include professional scientists, landowners, land managers and interested members of the public.

FOG notes that a small area of the roadside easement on Wells Station Road was classified by the Commissioner for Sustainability and the Environment (CSE) in her 2009 Report on ACT Lowland Native Grassland Investigation (site GU07 in this report) as Natural Temperate Grassland (NTG). It appears from the maps in the referral that this NTG site will be destroyed as a result of the development, and is presumably the area identified in table 5.5 of the referral PEA as a “potential loss”. It also appears to FOG that the two small NTG sites in Mitchell, GU04 and GU05, could be affected by this proposal. The first of these in particular is of reasonable diversity and has in the past supported both the Golden Sun Moth and the Striped Legless Lizard. Even though the development may only affect one edge of this site, any action that decreases size of habitat has the potential to affect its long term viability, particularly with ongoing maintenance activities for the rail service.

The argument in the referral is that this proposal should not be a controlled action as it is “within the existing footprint of the current road corridor”. However, roadside easements (along with rail easements, cemeteries and travelling stock reserves) are important in conserving our native grasslands as these are some of the few places where these grasslands remain relatively intact. As the proposal potentially impacts on three sites identified by the CSE as NTG, as well as at least two threatened species, FOG’s view is that the referral must be a controlled action and that a detailed ecological assessment needs to be done of the affected areas, at an appropriate time of year to ensure that the information collected accurately reflects the status of each site.

FOG also notes that this is not the first development in this area to impact on the Striped Legless Lizard and Golden Sun Moth. Development of block 799 Gungahlin (EPBC referral 2010/5750) resulted in the loss of habitat for these species (although offsets were provided). This new proposal continues the trend of small, apparently minor losses that, in the long term, mount up to more significant loss across the landscape (particularly as the gains promised by the earlier offsets are yet to be fully proven).

In principle, FOG opposes any development that impacts on NTG and dependent threatened species. In particular we oppose any development that impacts on site GU04. While the referral acknowledges possible impacts on NTG sites, it lacks any mitigation strategy or offset proposals. As far as we are aware, no explanation is provided as to why a route that impacts on threatened species and communities is being proposed.

Yours sincerely


Sarah Sharp

10 December 2014