Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Mr. David Rhind
Commonwealth and Territories Section
Environment Assessment Branch
Department of the Environment, Water Heritage and the Arts
PO Box 787 Canberra ACT 2600
02 6274 2611
New Electricity Substation and Access Road, Williamsdale, Tuggeranong/ACT
Reference Number: 2009/4805
I am writing to provide comments by Friends of Grasslands (FoG) on this referral of a proposal to develop a new Electricity Substation and Access Road at Williamsdale, ACT. FoG understands that several sites were considered for the development, in particular sites “F”, “H” and “I” in the submission, and that TransGrid’s final proposal is to develop the substation on site “I”.
The preliminary flora and fauna assessment describes sites “I” and “F” as being located on a high quality remnant of Yellow Box/Blakely’s Red Gum Lowland Woodland (YBRGLW). The community retains a high diversity of native species and an appropriate tree cover, and contains at least one regionally threatened flora species, a number of regionally declining flora species and at least one vulnerable fauna species, with habitat available for other threatened species. On the other hand, site “H” (described as primarily native pasture) is more highly modified, with past and recent earthworks impacting on any natural values. The preliminary flora and fauna assessment considers site “H” to be the most environmentally sensitive choice for this development. The clearance of native vegetation at this site would be insignificant compared to the threatened species habitat which would be lost or otherwise damaged or disturbed on site “I” and “F”. The first recommendation of the flora and fauna assessment is that every consideration be given to the possibility and feasibility of moving the access route and substation site into the disturbed land immediately to the north (site “H”).
Page 4 of the submission mentions that the site (site “I”) was selected because it “best met all siting criteria including proximity to existing TransGrid 132KV transmission lines, gently sloping land and with no subsidence or high water table areas”. The earlier assessment referred to in the submission (at www.purdon.com.au) discusses selection of site “I”, but it was not clear to FoG from either the submission or this earlier assessment as to why site “I” might be preferred over site “H”.
As FoG was unable to determine the reasons for preferring site “I” over site “H”, and there are clear environmental reasons to prefer site “H”, FoG supports the recommendation of the flora and fauna assessment accompanying the submission and asks that the development be undertaken at site “H” rather than site “I”. Not only is YBRGLW regarded as an Endangered Ecological Community in the ACT and as Critically Endangered at the Commonwealth level, but the remaining remnants of this community are continually under pressure from the prolonged drought, management problems and developments due to urban expansion. Any loss of high quality YBRGLW is not acceptable to FoG when an alternative is available.
While offsets, if effective, are necessary in situations where there is no alternative, it should be recognised that 'reinstating' vegetation cannot replace the complexity of the ecosystem that is lost. If biodiversity conservation legislation to protect threatened species/ ecological communities is to be effective, some areas must be “no go”. The argument that the area being lost is small should not be used as an excuse to ignore the loss of the area under discussion since (a) much of the remaining high quality YBRGLW is small, and any further reduction of existing areas may have an impact on their long term conservation, and (b) further development is likely in this area (e.g. ActewAGL plans to build a 500-megawatt gas-fired power plant).
In addition, a priority task to improve conservation of YBRGLW in the ACT Lowland Woodland Conservation Strategy is to protect key habitat areas including off-reserve areas, with improved habitat connectivity another priority task. While the area under discussion is relatively small, its loss (particularly when another lower quality site is available nearby) appears to be contrary to the intent of the Strategy.
With the exception of the site selected, TransGrid have included most of the recommendations of the flora and fauna assessment in their submission. These are included as mitigation measures in the submission. FoG supports these measures, but also considers that:
- The proposed mitigation and techniques to be used should be spelled out specifically and unambiguously in contracts, as should the natural values being protected, and the need to avoid damage to them;
- If agreed mitigation measures in the contracts are breached, a significant financial disincentive should be used to remediate any damage caused. However, the emphasis should not move from prevention to simply monitoring and correction;
- Support site/works managers should understand the complexity of grassy ecosystem (especially grassland) management. All relevant personnel/contractors should be briefed on the values of the site and how to protect them before they go on-site, and reminded on-site (e.g. by use of appropriate signs);
temporary or permanent, the location of all proposed fencing should be
- mapped (identify boundaries of sites/areas to be protected with adequate buffers) and marked/laid out competently before construction;
- specified to be constructed from within the project site; and
- constructed prior to site works commencing;
- The submission states that the “area of site works will be maintained for a 6 month period after completion of the works while vegetation is re-established”. Given the drought and other factors, this should be amended to “maintained until the site has adequately revegetated”, since six months may not be long enough for revegetation to occur, particularly if the six month period falls over winter.
FoG notes that TransGrid is nominating a nearby 20HA area of YBRGLW as compensatory habitat but queries whether the compensation is of sufficient value for what is being lost. FoG understands that TransGrid has committed to a compensatory habitat planting scheme and has commenced discussions with Greening Australia to undertake this planting as part of a broader Memorandum of Understanding between TransGrid and Greening Australia. As the area being lost is quality YBRGLW, the compensatory habitat should also be similar. Any restoration, including use of seed mixes, should be consistent with the protection and long term management of the adjacent YBRGLW values and take into consideration source of seed (local), species selection and appropriate methods/timing of works.
The submission includes rehabilitation of all disturbed areas to be undertaken at the conclusion of the works. FoG suggests that this be assisted by minimising disturbance on site, e.g.
- wherever heavy machinery is proposed to be used, avoid soil compaction and disturbance by use of the smallest/lightest equipment, and with rubber tyres if possible;
- wherever excavation is required, its extent should be minimised;
- works structures (e.g. sheds) must be placed so as to not damage/degrade otherwise unaffected vegetation, including understorey plants; and
- avoiding sensitive times such as breeding periods or times of flowering/seed set.
If the final site selected is site “I”, FoG has particular concerns about accidental damage to conservation values of both the site and adjoining area during construction, particularly during the process of delivering the transformer. Careful management of this component of the site works is critical, and the employment of recognised (preferably accredited) ecologists to assist in minimising damage to native vegetation is recommended.
Again, if site “I” is selected, permanent fences and other measures should be taken to protect the surrounding YBRGLW, including the area of Swainsona sericea (listed as vulnerable in NSW) within the substation boundary. In addition, the offset area could be extended to the substation fence to include as much as possible of this species.
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 more than 200 members include professional scientists, landowners, land managers and interested members of the public.