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
draft.amendment@nca.gov.au
Re. Draft Amendment 96, Changes to the Monaro Highway Alignment
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.
In 2020 FOG submitted comments on the proposed changes to the road alignment (attached). FOG supported the alignment as long as mitigation recommendations were adhered to. The changes to the alignment outlined in Amendment 96 significantly increase the impact of the road and road works on natural values identified under the Environmental Protection and Biodiversity Conservation and Nature Conservation Acts.
FOG understands that realignment is recommended for safety reasons, but the draft amendment is inadequate as it does not address the known biodiversity and heritage matters, as follows:
- Loss of mature native trees in the horse paddocks and along the edges of the road (a key threatening process under the ACT’s Nature Conservation Act).
- Fragmentation (a key threatening process under the ACT’s Nature Conservation Act): the woodland is part of an important local wildlife connection linking the woodlands of the Red Kill/Mugga Mugga/Callum Brae/Wanniassa Hills/Farrer Ridge complex with woodland south of Tralee in NSW.
- Other areas of critically endangered White Box – Yellow Box – Blakely’s Red Gum woodland within the proposed alignment are not mentioned (see Figure 1, the map of woodland from ACTMapi, in which the darker green indicates higher value woodland).
- Potential threatened species habitat is not identified.
- It is not admissible to dismiss the nomination of the TSR (Hume Block 3 Section 8, opposite Mugga Lane) to the Heritage Act even though it is not yet assessed, given the backlog of matters to be addressed and the dissolution of the Heritage Council. This area is CEEC bgw. It is unclear/ambiguous as to whether this area will be impacted.
- In addition, the archaeological survey has identified areas of heritage significance that will be impacted.
We recommend, therefore, that the following mitigation actions are undertaken, according to best practice:
- The alignment should be reconsidered where possible to remove impacts to the six matters above.
- The realignment should be subject to an EIS and mitigation measures identified. This should include:
a) The works areas must be identified and be contained only within the areas that are to be destroyed for development.
b) Entry to the TSR must not be allowed for any construction work.
c) Compensatory management and revegetation for losses of other vegetation may be undertaken within the TSR and within other areas where feasible.
- A draft plan of the mitigation measures to be circulated for comment to key stakeholders, including the ACT Government, FOG and members of the heritage community.
Figure 1. Woodland within the Hume area including areas that will be impacted or destroyed by the road alignment.
FOG would be pleased to discuss this matter further.
Yours sincerely
Professor
Jamie Pittock
President,
Friends of Grasslands
8 December
2023