Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Macquarie ACT 2614
Reply to applications for Duplication of William Hovell Drive:
Amended DA 202138722 and Revised EIS 202000014
To whom it may concern
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 native 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 is generally reassured by much in the amendments and revisions. FOG particularly appreciates the detail provided in Stakeholder Engagement Report, especially in its Submissions Response Table. This was most helpful in seeing how aspects have been changed to respond to all submissions.
The SMEC team who has produced the documents is clearly aware of the enormous complexities for biodiversity that the road project will generate. The revised plans appear to FOG to be sensible and wide in scope. However, the challenge will now be to have this documentation absorbed and understood by the responsible agencies and authorities. These bodies will develop procedures and protocols and these need to be clear and transparent to pass effectively through the chain of contractors and subcontractors who must implement them.
To borrow from an adage, this arterial road project cannot just be "paved with good intentions"; instead, they have to end up on the ground in line with the plans.
In particular, assuming the project gets the green light, the CEMP needs to be written, and FOG is particularly keen that the Flora and Fauna protection aspect is covered by practical checks and measures, including communication structures, needed to make that happen. FOG is pleased that management of weeds and pathogens is highlighted by the planning. Local landcarers have drawn to FOG's attention that environmental best-results are not always achieved in large infrastructure projects. Revegetation along the Whitlam Watermain is one where superficially good plans had not been realised by that project's end date. This must not happen at William Hovell Drive.
FOG in its submissions on the proposals called for the Offset Management Plan to come to fruition faster. FOG is therefore disappointed to find that information about the Offset Strategy and Plan is limited to one Table 5-18. The Offset Strategy creation is hopefully now well advanced and keeping to the forecast timeframe May-Sep 2022. FOG looks forward to release of developments soon, noting the need for offsets to be in place at the time project procurement will begin.
FOG was pleased to find the timeframe for vegetation maintenance was extended to "up to five years". Our submission was particularly about tree and shrub plantings, but we can safely predict that native ground layer consisting of diverse native grasses and forbs will also need maintenance going beyond 2 years to take it to a sustainable state. Weed management will be involved in this also.
FOG would like to make more detailed comment on 2 aspects:
- Page 135 of the EIS Rev D states, in relation to weeds and exotic flora, that "where reasonably possible, contractors tasked with revegetation activities will have demonstrated capability in successfully restoring native vegetation communities". FOG is surprised by the inclusion of "where reasonably possible". This is a major arterial road project, not a suburban back street. Surely experienced contractors will be tendering and given preference. If no experienced contractor can be hired, then measures must be put in place to oversee, monitor (by qualified ecologist) and assist any contractor who is conducting work beyond their demonstrated capability.
- Page 134 of the same document describes the plan for "dense Lomandra longifolia and native shrub plantings along the boundaries of Kama and Pinnacle Nature Reserves". FOG suggests dense planting needs careful planning and local species be mandated. Lomandra longifolia is a great tough native, common in areas like Black Mountain Nature Reserve, but out of place in the West Belconnen Hills. Dianella revoluta is however common through Kama and Pinnacle – this species would be optimal, being endemic and easy to establish and maintain. Shrub species should also be contained to locally endemic varieties, not confined to what is plentiful in the landscape suppliers’ catalogues.
Professor Jamie Pittock
1 August 2022