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

Belconnen Trunk Sewer Project, ACT

Referral no: 2018/8256

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 sees that ICON Water openly accepts that specific parts of the work proposed trigger an EIS process.  FOG therefore recommends that the Commonwealth control the action and require this EIS to be prepared and communicated.

FOG takes this opportunity to make a set of points in response to material that ICON has submitted in this referral:

1.  While the areas of Natural Temperate Grassland (NTG) the proposed trunk sewer will pass through are small and fragmented, FOG considers it essential that targeted surveys for species such as the Ginninderra peppercress be undertaken and the actual quality of any NTG patches be assessed before a decision is made about the route for the trunk sewer and possible mitigation and offset measures. As this is an infrastructure project, we do not oppose the development, but do think that the option chosen for the sewer route should be the one that minimises the impact on threatened grassland species and communities. In particular, if the Ginninderra peppercress is present, it must be avoided and steps taken to protect it. We also think that suitable offsets should be offered for any other impact on MNES, but are unable to comment further given the lack of detail in the Referral about the occurrence of these in the project area.

2.  It is overdue that local residents as well as community groups like Ginninderra Catchment Group and Belconnen Community Council be included in the planning process for the infrastructure.

3.  No background is given to inform everyone about reasons for the augmentation.  Has there been upgrade to waste treatment standards, increase in forecast peak-level rainfalls, increased volume due to construction of new suburbs, etc.?

4.  The Referral structure required FOG to put in significant time and effort to sift through documents prepared over some years and essentially lumped together as a Referral.  It was vital to have the Consolidated Referral document to make even initial sense of the suite of reports.

5.  FOG is concerned by Fig 1.4 in the consolidated referral, primarily about the location indicated for a future Odour Control Unit.  The western red circle close to Southern Cross Drive in Latham sits right over an area of iconic and high-quality NTG, known widely as the Blue Devil Grassland.  That OCU will have to be re-sited into poor quality grassed areas close to Southern Cross Drive.  Adding to this, lines indicated for alternative and future sewer routes within Umbagong District Park raise concerns for FOG.

6.  Figs 1.1 and 4.1 in the consolidated referral clearly show a length of "trenchless construction" and an area of "ecological protection zone" one hundred metres east of Kingsford Smith Drive.  FOG did not find mention of these important features elsewhere in the referral.  Further, they are not acknowledged, even potentially, as measures of mitigation in the assessments for the two reptile species listed.  At best this is totally confusing.

7.  The analysis of Golden Sun Moth nowhere acknowledges that this insect is well known to thrive in areas of dense Chilean Needle Grass, sometimes regularly mown.  Unmown CNG in Jaramlee Offset represents one nearby example.  Some of the route proposed here along Ginninderra Creek by ICON surely fits this description, yet is not included in assessment of threats to GSM.

8.  The Ginninderra Creek Corridor is part of the home range of listed birds particularly the Scarlet Robin and the Superb Parrot.  While such birds almost certainly do not nest here, they will be impacted.

9.  In open grassy spaces in urban Canberra, decades of unsatisfactory and uninformed management have resulted in steady invasion by exotic species such as the Weeds of National Significance noted in the Referral, plus the newer but serious threat African Lovegrass (which is not WONS listed).  The Referral does mention weed management is required.  However, this misses a fine opportunity for rehabilitation along the whole 2.4 km route, plus extra length from local street access that will clearly be required.  FOG recommends that an opportunity be taken for wide scale rehabilitation of all disturbance by seeding and planting of native grasses, forbs and sub-shrubs (not necessarily targeting an NTG quality), followed by long-term weed control.  This could be the beginnings of clawing back to halt weed invasion into ground-layer vegetation in the Creek Corridor.

Yours sincerely


Geoff Robertson

21 August 2018