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.comments@environment.gov.au
Dear Sir/Madam
William Hovell Drive duplication
Referral no: 2020/8703
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 members include professional scientists, landowners, land managers and interested members of the public.
This area lies within the West Belconnen Hills zone that has been one focus for Woodland Restoration work pursued by ACT Government since 2011 (see Woodlands for Wildlife, Progress Report 2018, ACT Government). It is therefore undesirable that any woodland vegetation in the road reserve is impacted by this project. As well as its conservation status under Matters of National Environmental Significance (MNES), the vegetation is a valuable stepping stone for small birds that cross the area, such as the Scarlet Robin (listed as vulnerable in New South Wales and the ACT).
Specific MNES that occur within the road reserve are:
- Golden Sun Moth (GSM) (Synemon plana) habitat: 0.6 ha in total
- Pink Tailed Worm Lizard (PTWL) (Aprasia parapulchella) habitat: 0.23 ha in total
- Box Gum Woodland (BGW): 13.75 ha, 25% of the area, mainly located adjacent to Kama Nature Reserve (NR) and The Pinnacle NR and to the north including 0.7 ha of native grassland, likely secondary.
- Approximately 20 hollow bearing trees (omits reference to the threatening process: clearance of mature trees)
- Superb Parrot (Polytelis swainsonii): the Likelihood of Occurrence Assessment (Appendix B) for this vulnerable species notes 8 ACTmapi records within 10 km. However, the Canberra Ornithologists Group regularly records its presence nearby. For example, Davey (2013) published observations of breeding behaviour from a paddocks area 0.5 to 1 km west of the road reserve. Another technical report to the ACT Government identifies a further breeding colony less than 5 km from this roadway (Rayner et al. 2016). Potential impacts on this species require consideration of all available data sources, not just ACTmapi.
In addition, we note that there has been no consideration of the key threatening process, Loss of Mature Native Trees and Lack of Recruitment, listed under the ACT Nature Conservation Act 2014. While we aware that this is not an MNES, nevertheless it is a significant issue. This listing includes any mature native trees with a diameter of 50 cm or more and does not require the tree to contain hollows. Our own inspection of the site identified about 40 trees that meet these criteria, including one Yellow Box, 1 m dbh, that is 5 m away from the top of the cutting on the western side about 5 m inside the road reserve, 120 m south of the southern fence of Weetangera Cemetery. Such trees contain important habitat for a range of species, including species that are MNES.
Our conclusion is that there ARE significant impacts on threatened ecological communities and species. There is no guarantee that they will not be impacted directly or indirectly. However, we recognise that complete avoidance is not feasible. We provide the following recommendations to mitigate impacts and to offset against impacts:
- Avoid where possible loss of BGW habitat, GSM habitat and PTWL habitat
- Avoid loss of mature eucalypt trees over 50 cm in diameter, including all mature trees with hollows
- Provide an offset against the loss of BGW habitat by protection of land to the west of Kama NR which will preserve nesting habitat for Superb Parrot and retain old growth trees and native grassland understorey, as well as provide a wildfire and invasive species buffer to the west of Kama NR
- Ensure better integration with surrounding Woodland Restoration initiatives at the landscape scale. For example, one of the aims of this project has been to return some coarse woody debris to the open paddocks in West Belconnen Hills. Any large timber that does result from road widening should be used in this way
- New planting programmes in the edges of adjoining paddocks to close any vegetation gaps due to construction. The Preliminary Assessment proposes that the Weetangera Cemetery deserves some new edge plantings to screen it. This principle should extend to all currently treed areas, ensuring that such plantings enhance native species habitat values in the landscape
- Weed invasion is noted (6.3.2) as an effect that has to be managed. This objective is particularly important at interfaces with conservation-reserve lands and habitat patches, especially since African Lovegrass, a highly invasive exotic and serious pest plant, is currently well established right along William Hovell Drive edges.
Yours sincerely
Geoff Robertson
President
14 July 2020
References:
ACT Government: Woodlands for wildlife: ACT lowlands woodland conservation strategy, progress report 2018
Davey C: Distribution, abundance and breeding status of the superb parrot (Polytelis Swainsonii) during the 2011-12 breeding season, central and lower Molonglo valley, ACT, Canberra Bird Notes 38 (2), 134-154, 2013
Rayner L, Stojanovic D, Heinsohn R and Manning A: Breeding ecology of the Superb parrot (Polytelis swainsonii) in northern Canberra, Technical report to the ACT Government, 2016.