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

Snowy 2.0 main works, New South Wales

Referral no: 2018/8322

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.

In principle FOG believes that no developments should impact upon endangered and critically endangered species and ecological communities. In the case of Snowy 2.0, FOG acknowledges that it has been declared Critical State Significant Infrastructure by the New South Wales government. However, its situation within Kosciusko National Park means that it is inevitable that such a massive engineering project will have localised, negative environmental impacts that would not normally be permitted in this environmentally sensitive area.

FOG has a particular interest in the Alpine Sphagnum Bogs and Associated Fens ecological community as well as the grassy ecosystems in the project area Grey Box Grassy Woodlands, Natural Temperate Grasslands and Box- Gum Grassy Woodlands. We are aware of significant threats already impacting upon these communities, such as weed invasion, wild horses and feral animals. Any additional impacts from Snowy 2.0 will further erode the capacity of these communities to survive in the long term.

The negative impacts from Snowy 2.0 on these threatened communities, and also the threatened species that occur within them (e.g. Rutidosis leiolepis, Calotis glandulosa, Prasophyllum bagoense and Prasophyllum innubum) needs to be quantified and, as far as is possible, avoided from the beginning of this project. In this regard, FOG notes that environmental studies have not yet been completed. We ask that they be completed before the project proceeds any further. Following that, the environmental impacts of the project, together with alternatives for avoidance and (if necessary) mitigation of these impacts be assessed by an independent scientific committee and that the recommendations of such a committee be accepted.

If impacts are unavoidable, then adequate offsets must be provided. Such offsets must be like-for-like and should be in place before any construction work begins. We suggest that, given the ongoing impacts of the original Snowy scheme, offsets such as improved control of weeds, brumbies and feral animals, together with more resources for management, could see improvement in the grassland and grassy woodland areas of Kosciusko National Park.

Noting the ongoing impacts of the original Snowy scheme, it is important that offset calculations include the impacts of ongoing maintenance of Snowy 2.0 as well as the construction phase.

In view of the fragile nature of our alpine and sub-alpine environments, and the threatened status of the alpine sphagnum bogs, natural temperate grassland and grassy woodland communities, FOG is of the view that all possible efforts should be made to avoid impacts upon these communities, and that mitigation and, as a last resort, offsets only be applied if there is truly no alternative.

Yours sincerely

 

Geoff Robertson
President

12 November 2018