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



Dear David


Murrumbidgee to Googong water transfer development

Reference Number: 2009/5124


Recently (19 October 2009) Friends of Grasslands (FOG) made a submission on this project.  We understand that this development is a controlled action and that approval under the EPBC Act is needed before it can proceed.


Since sending its submission, FOG has been approached by one of the landholders along the Williamsdale Road who has box-gum woodland and an area of secondary themeda grassland on his block that will be affected by this project.  ACTEW have already dug three holes on the property as part of the preliminary project work, filled in these holes and rehabilitated them by seeding with some sort of grassy mix (the landholder was unaware of the species in this mix).


FOG notes that “The pipeline construction process would restore native topsoil so that following construction the site alignment can be rehabilitated, with the existing floristics restored to original condition” (Section 13.3.2 of part C of the EIA).  In inspecting the three rehabilitation areas, FOG noted the presence of rye grass (an exotic grass), which was evident no where else in the surrounding grassland and woodland.  As well, the restoration work was not of particularly good quality and raises concerns about the quality of future rehabilitation if the project goes ahead.  After six months growth it was difficult to tell what other grasses were present in the rehabilitation areas, and if all of these were already present on the property. 


FOG’s understanding is that one area of the proposed pipeline easement on this property was classified as non-native pasture.  However, FOG was unable to locate any specific area along the easement that was not predominately native vegetation, and in fact not box-gum woodland.  In total, FOG identified over 70 native species of native grasses, forbs, shrubs and trees along or near the proposed easement.  The vegetation structure was good; while a few woody and herbaceous weeds were present these could be easily managed.


Section 13.3.2 of part C of the EIA states that “Where the alignment passes through the few areas of good quality remnant vegetation the construction corridor would be reduced and the area of disturbance restricted to a narrow band.  Wherever possible the pipeline alignment would avoid mature trees”.  The landholder was not clear on the exact boundary of the construction easement.  In view of the quality of the native vegetation, FOG would like to see the working easement reduced to 15m if possible, and certainly less than the 40m advised to the landholder.  Issues such as the exact boundary of the working easement and the impact of the scour valve and air vent (also to be placed on the property) should be resolved with the landholder before he is expected to sign an agreement to ACTEW’s acquisition of the land.  As well, the landholder should be advised about the details of the proposed rehabilitation plan for the construction corridor, particularly in light of the introduction of an exotic grass to the property during the rehabilitation already undertaken.


FOG sees the Murrumbidgee to Googong water transfer development, if it goes ahead, as an opportunity for ACTEW to undertake mitigation activities appropriately and in a way that results in no degradation of good quality native grasslands and box-gum woodlands.  However, given what has happened in the above case, FOG has some concerns about the quality of rehabilitation of the working easement in these good quality areas and also about how restricted the working easement will actually be in such areas.  We would like the opportunity to come and talk to you about our concerns.  If this is possible, please contact Naarilla Hirsch (FOG advocacy coordinator) on 6288 2413 or email


If it would be useful for you to see the site, the landholder has indicated his willingness to another visit.  Let us know if you would like to do so, and Naarilla Hirsch will arrange for the visit.


Sincerely yours






Geoff Robertson



14 December 2009