Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Applications Secretariat Section
Customer Services
ACT Planning and Land Authority
PO Box 365 Mitchell ACT 2911



Dear Sir/Madam


Clarrie Hermes Drive Extension EIS 3002194/Revision No. 2/29 July 2009


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 more than 200 members include professional scientists, landowners, land managers and interested members of the public.


FOG has a number of concerns about the proposed Clarrie Hermes Extension. Like many areas of Gungahlin, important biodiversity assets will be sacrificed because there have been inadequate attempts to integrate planning of biodiversity and other land uses. This is another example of the thousand cuts when a more broad landscape approach to planning should be undertaken. For example, the ACT government has long sat on its plans for the nearby proposed development at Kinleyside.


The main damage that the proposed road will do is to remove 5.2ha of the threatened ecological community, Yellow Box Red Gum Grassy Woodland (YBRGGW) (ACT threatened ecological community) or Box Woodland (Commonwealth threatened ecological community), and bisect the remaining woodland, thus reducing its value and hampering flow of flora and fauna. It will see the removal of significant habitat trees, which are obviously irreplaceable.


The Environmental Impact Statement (EIS) clearly recognises most of these losses. It notes that the Swift Parrot, Superb Parrot and Regent Honeyeater potentially could use the site and the foraging resources available (including nesting habitat), and FOG considers any such loss of habitat for these species detrimental.


FOG also has concerns about the movement of small fauna and the fragmentation of their habitat. It suggests that blue tongue lizards and olive legless lizards (both found in the accompanying EIS survey) are plentiful, but rarely are either animal observed in the wild, and there seems to be little research on their abundance or otherwise. FOG would like to be informed of any information on this point and on other reptile fauna that may be present.


Should the road proceed, the recommendations of the EIS to minimise the negative impact (set out on page 19 of the EIS statement) are supported. These include minimising clearing and educating those working on site, fencing of sensitive habitat areas, retention and reuse of top soil, rescuing of hollows from removed trees, and weed control.  In addition, the recommendation about mitigating and/or offsetting the direct loss of three potential nest trees for the superb parrot (page 29 of the EIS statement) is also supported


The EIS also recognises that certain biodiversity offsets and rehabilitation of nearly areas is called for. At the open night (1 September, Nicholls), there were some mention of what offsets were being discussed. The exact offsets should be clearly established before any work on the construction commences. To offset the destruction of biodiversity, offsets should be aimed at arresting the decline and fragmentation and securing and restoring of areas of Box Woodland. Offsets should also make provision for the ongoing maintenance of areas remaining along Clarrie Hermes Drive and other areas where offsets may be undertaken.


Sincerely yours




Geoff Robertson



8 September 2009