Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Chief Planning Executive
Environment, Planning and Sustainable Development Directorate Customer Service
GPO Box 158
Canberra    ACT    2601


Dear Sir/Madam

William Hovell Drive duplication: Draft Environmental Impact Statement EIS202000014

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.

FOG made a submission about Referral 2020/8703 in July 2021 and is pleased to see that an EIS has been required to investigate many issues triggered by the proposed duplication of William Hovell Drive.

FOG is also pleased to find that many points which FOG made in its submission 13 months ago have been put forward for consideration, notably those to Avoid habitat loss, Avoid loss of mature Eucalypts, Offset Box Gum Woodland (BGW) loss, Reuse timber, Replanting, and Control of Weeds, especially African Lovegrass (ALG).

FOG was also pleased to find many other points being considered such as excessive habitat fragmentation, analysis of cumulative impacts by development across this northern side of the Molonglo River, and of all potential biodiversity risks.

However, FOG is deeply concerned that the EIS is not yet developed to a stage that can be used as an instrument to control the potential duplication project. Specifically, the issue of offsets is not taken far enough. Analysis clearly reveals impacts on several MNES and concedes that about 6.5 ha of Box-Gum Woodland of moderate quality will be directly impacted if this road is duplicated, even after redesigns have minimised impact. FOG presumes this concession means that impact cannot be avoided, so that must leave only the option of offsetting.

The scoping document (Appendix B) within section 8.12.3 explicitly requires that "If offsets are proposed to compensate for impacts on MNES, describe the proposed offsets and how they comply with the EPBC Act environmental offsets policy".

FOG does note that the draft EIS includes "The Project proposes to provide an offset against the loss of BGW TEC habitat by protection of land to the west of Kama NR…… " in sections 3.2.2,, and Table 5-14 also lists this offset as a Biodiversity Mitigation Measure, and that it will be required prior to construction with TCCS as the responsible agency.

FOG of course would be easily convinced that such an offset is great in principle, in fact we used this protection as an offset recommendation in our July 2020 submission. FOG is also convinced if the plan establishes such an offset prior to any construction commencement.

However, FOG calls for immediate analysis of offset-multiple factors and at least the skeleton of an offset management plan being released for public consultation before the proposition is considered further. Only in that way can the people of the region know whether or not the direct impact on BGW can be satisfactorily offset.

FOG submits that the EIS in such a draft form with next to no detail about offsetting and concludes it has been prematurely released.

FOG would like to make some other comments. The first is that the 13 Leucochrysum albicans var. tricolor plants that will be impacted by the project are almost certainly self sown out of a large revegetation program where the species was introduced abundantly into the Kama Nature Reserve. Also that a few new plants of this species are also now found in the nearby Pinnacle Reserve offset area.

Secondly, the Scoping document's Attachment B lists Entity Requirements by the ACT Conservator of Flora and Fauna. FOG agrees with the comprehensive list of issues, and notes that some suggestion for offsets was included. However, FOG wishes to highlight an issue of particular concern in weed control during construction and rehabilitation – William Hovell Drive is currently a weed bank, and the high risk that the infestation of African Lovegrass will be made worse by the project disturbance must be taken extremely seriously.

Lastly, in the mitigation measures in table 7-1 of the Biodiversity Impact Assessment and in Section 5.2.4 of the Draft Environmental Impact Statement the text is “Areas of re-vegetation should be maintained for a minimum of two years until plantings are established”. Plantings of trees and shrubs are unlikely to be completely established within two years. This would be better worded as “Areas of re-vegetation should be maintained until plantings are established”. If a period is mentioned, five years would be more realistic.

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

18 August 2021