Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Land, Planning and Building Services
Environment, Planning and Sustainable Development Directorate Customer Service
GPO Box 158
Canberra    ACT    2601


Dear Sir/Madam

William Hovell Drive duplication: Development Application DA202138722

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. FOG has submitted comments to parallel EIS202000014 that lay these out, and calls for public release of a preliminary offset management plan

Therefore FOG recommends that this DA 202138722 be set aside from decision until the EIS is released in final form for public consultation and approved.

FOG draws attention to the SMEC Biodiversity Assessment which in section 8.2.3 Impact Calculations has a Table 8-3 Impact Assessment which details: "When an Offset Strategy is completed, impact values should be assessed in parallel with a potential offset site to ensure a matching weighting can be used to compare site values. Table 8-3 outlines the ecological attributes that must be used to determine “Habitat Quality” for the EPBC offset calculation spreadsheet, for each of the communities and threatened species habitat to be offset." FOG cannot understand why the process has been suspended at this stage and calls for planning for offsets to be taken forward right now.

Apart from the offsets problem, FOG has been pleased to find in the DA documentation good recommendations in the reasonably environmentally-friendly plans and the SMEC Biodiversity Assessment Report. In particular, recognition of the high values in the road-reserve vegetation between Kama and Pinnacle Nature Reserves is greatly supported. The reduction of impacts here is welcomed.

FOG would like to draw attention to the SMEC section 6.3 Cumulative impacts from projects nearby such as Molonglo 3 transmission line where up to 5.9 more ha of BGW could be lost. FOG shares the SMEC conclusion "Most projects occurring in the region have some impact on the threatened White Box – Yellow Box – Blakely’s Red Gum Grassy Woodland and Derived Native Grasslands vegetation community and require the removal of habitat for threatened flora and fauna. Combined, these impacts are likely to contribute to the local extinction of these populations and communities." Everything possible needs to be done to prevent this.

FOG was less convinced by a few aspects of the SMEC report in the 10-page section 6 Impact Assessment. In particular, it was unsettling in Table 6-3 to find only "[tba]" entries in the column "Offset Required?". This reads to FOG as yet one more indication that the analysis process has a way to go. In contrast, Table 6-4 "Impacts of fragmentation on flora and fauna" reads as a very realistic analysis for a range of species groups. As a relevant issue, FOG has been made aware of an unusual number of wombats appearing as recent roadkill along Willaim Hovell alongside the disturbance, land clearing and pond creation in Whitlam development. Road duplication will presumably escalate this toll.

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

18 August 2021