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

Adaminaby sewage treatment plant upgrade, NSW

Referral no: 2020/8815

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 has many members from neighbouring areas of New South Wales. Its members include professional scientists, landowners, land managers and interested members of the public.

Earlier this month FOG visited a number of Natural Temperate Grassland sites on the Monaro, including the area subject to this referral. FOG was impressed by the condition of the site and considers it to be a high quality Natural Temperate Grassland area with significant conservation values, enhanced by the presence of individual threatened species. Specific rare and threatened species FOG observed at the site were the Hoary Sunray (Leucochrysum albicans subsp. Tricolor), Monaro Golden Daisy (Rutidosis leiolepis), Mauve Burr Daisy (Calotis glandulosa) and Hairy Anchor Plant (Discaria pubescens).

Site nomenclature

In the referral the site is called a Travelling Stock Reserve (TSR) at lot 292 DP 729876. FOG’s understanding is that it is known locally as a town common and is crown land with a different designation than ‘TSR’.

Hoary Sunray

The referral estimates that the upgrade to the access road will directly impact 9% of the endangered Hoary Sunray (Leucochrysum albicans subsp. Tricolor) population on the site, and indirectly impact a further 21% of the population. It also suggests that the impact will be less if there are more Hoary Sunray individuals present in the general area on private properties and further along local roadsides. However, it isn’t apparent from the documentation that this is indeed the case. Even if it were, the nature of such refuge patches should be taken into account. In the long term, edge effects are a bigger threat to populations in long narrow areas such as roadside verges than in an area such as a paddock or TSR, particularly given the possibility of future road improvements.

Monaro Golden Daisy

The Monaro Golden Daisy (Rutidosis leiolepis) is listed as vulnerable under the EPBC Act in New South Wales. The targeted flora surveys undertaken in 2017 by the environmental consultant do not appear to have found any Monaro Golden Daisy (MGD). However, on its recent visit FOG members with considerable expertise in plant identification located at least three MGD plants likely to be directly impacted by the upgrade of the access road. They also found several other plants immediately east of the gate into the site. These too will be very vulnerable to being damaged by the works, by being either driven or parked over, or otherwise destroyed during the construction period. Other MGD plants were identified within the NTG area. Some information about FOG’s MGD observations is included in the attachment.

While the biodiversity assessment report flags the possibility that species may be missed due to the limited survey effort and timing (i.e. two days / evenings in summer during optimum survey season), that one threatened plant species was completely missed is of great concern, particularly as the MGD is a long lived perennial that will persist in these locations from year to year. The site needs to be re-surveyed to ensure that all threatened species on the site are located, including the population of MGD on the site. Then the environmental assessment needs to be updated to include the impact on this threatened species before the project proceeds any further.

Ecological Mitigation Management Plan

The Ecological Mitigation Management Plan proposes some sound construction mitigation activities such as temporary exclusion fencing, weed control and use of local provenance for revegetation. In particular, the whole area of NTG should be monitored to ensure that any inadvertent introduction of weed species is identified and eliminated early.

However, FOG has significant concerns with some aspects of the Plan. The biodiversity mitigation hierarchy is ‘Avoid, Minimise, Offset’, but we question whether ‘avoid’ has been fully canvassed and do not think that the proposed ‘minimise’ activity of translocation will be effective.

Road alignment

The Plan does avoid impacts to some extent by restricting the disturbance area footprint associated with the access road. We note that Council investigated alternatives to the proposed access road upgrade, but that these could not be progressed due to land ownership, existing Land Claims and intended use of the sites. From a visual inspection on our short visit, the grassland appears to be of much lower quality downhill, though that too needs to be assessed more formally, so that shifting both the gate and the road downhill would result in a better environmental outcome. Some more information on why this is not possible would be helpful. In particular, it’s not clear if it would be possible to make a small shift in the gate and the alignment of the access road that would reduce the potential impact of the project on the Hoary Sunray. As well, since the MGD was not considered in the assessment , any possible changes to the road alignment that might reduce the impact on this species have not been considered.

Proposed translocation

FOG is not aware of any cases where translocation of NTG flora species has been totally successful. FOG members have attempted to translocate the Hoary Sunray but been unsuccessful, despite their care an site preparation work. Hoary Sunray plants are short-lived perennials and do not transplant, especially over summer. The proposed mitigation strategy of translocating MGD plants directly impacted by the road upgrade will lead to a loss of these plants.

As with the Hoary Sunray, translocation of the MGD on the site is also not feasible because they are growing in severe conditions and are likely to have a big taproot. Again, attempting to translocate the MGD directly impacted by the current proposal will lead to a loss of these plants.


The Ecological Mitigation Management Plan needs to be updated to include impacts on the threatened MGD. Further work on possible alternative road alignments to avoid more or all of the threatened species (especially the MGD) is needed, with an explanation of why some have been rejected. As well, if impacts are unavoidable, a viable and effective offset strategy that results in no net loss to both Hoary Sunray and Monaro Golden Daisy across the landscape.


FOG is of the view that the site needs to be resurveyed to ensure that all of the threatened species that will be impacted by the project have been identified, and that work is needed on further avoidance and mitigation strategies. If these unfortunately prove impossible to action, we recognise that this project concerns essential infrastructure and ask that there be an offset plan that will deliver no net loss of any of the threatened species or NTG on the site.

Yours sincerely


Geoff Robertson

25 November 2020

Attachment: MGD information

[Attachment showing precise locations of endangered species is not published on line]