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
ACEPDcustomerservices@act.gov.au
Re. 315 Stockdill Drive, Belconnen (DA 202342503)
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.
Back in 2021, FOG responded expressing concern to the Federal Regulator (DCCEEW) about the proposed installation of this Big Battery.[1] We are heartened to see problems we identified then have been addressed. In short, the new offset proposal is better aligned with offsetting principles, i.e., the proposed offset site is in the ACT, is generally like-for-like Box Gum Woodland (BGW), and the offset acquisition and mitigation is planned to begin when the impacts will begin (if the DA is approved).
What will be lost forever – it is significant?
FOG remains concerned about the proposed loss of up to 6.19 ha of the derived native grassland form of EPBC listed BGW from West Belconnen, even if it has been somewhat degraded by decades of farming. The loss of mature habitat trees in the Battery footprint is also a serious problem. The proponent argues these impacts cannot be avoided, so proposes a necessarily thorough analysis of an offset package south of Tharwa.
FOG is very concerned about mature tree loss. The EIS and Tree Survey Report indicate Tree 7 Eme H is to be felled at the Battery site despite the tree's remnant-tree status and its pre-eminence as habitat in the construction proposal area for the Battery. (Tree 7 is a huge hollow-bearing mature Yellow Box (canopy 20m, height 23.4m, trunk 3.4m circumference. This leaves only 5 other trees similar in stature:- 1 Ebl H, 44 Eme M, 64 Eme M, 209 Ebl M and 367 Ebl M of height >11.7m, tree 1 is the only other that is hollow-bearing). FOG notes that this giant tree is several hundred years old. It is just one of many that are toppled by developments in West Belconnen and beyond every year now, despite the fact the ACT now has complex tree-protection legislation.
What will be lost temporarily – really? will it recover?
FOG notes there will be a 'temporary' impact on 1.5 ha for a construction laydown area. That impact will supposedly cease when the construction phase ends, at which time the proponent will commence rehabilitation. This is noted in a general way in several places in the DA package, but the details will be deferred to the development's Environmental Management Plan needed if the construction proceeds.
If this DA is approved, ACT authorities will need to monitor this process to ensure the best possible outcomes are produced; in short, our concern is temporary impacts will become permanent.
FOG notes the commitment in EIS table 5.12 that “Any biodiversity rehabilitation work will be undertaken by a suitably qualified and experienced professional.” FOG's recent experience with rehabilitation works on major infrastructure projects suggests from frequent underperformance that very few companies have the necessary experience to revegetate to a quality consistent with native grasslands and grassy woodlands of the ACT region. FOG again urges careful monitoring of this stage by authorities. FOG however does see value in Neoen's suggestion (EIS Table 5.11) of some woodland replanting at the edge of the 'temporary' impact zone to restore connectivity.
Offsets
Biodiversity Offset Strategy. The EIS section 5.7 contains an 8-page summary of the 63-page Specialist Report Appendix F. In our view the Strategy has significant value. FOG is impressed that the location proposed "shares three boundaries with the Rob Roy and Gigerline Nature Reserves and the Murrumbidgee River Corridor".
The offset proposed, if properly created, managed and protected, offers positives for conservation of habitat. FOG is pleased to see explicit acceptance that "“The benefit of an offset should last for the duration of an impact. As the loss of BGW resulting from the Proposal would be ‘permanent’ (lasting for at least 20 years), the proposed offset area would require protection in perpetuity. Land use in the ACT is governed by the Territory Plan, which defines zoning and allowable uses. The legal mechanism to ensure the protection of the proposed offset area in perpetuity will be a land use zoning variation through the Territory Plan.” We would prefer a nature reserve overlay as well.
FOG is also pleased to see an important commitment to ‘purchase [of the 102.26 ha offset]… would be undertaken immediately following the DA approval’.
FOG draws attention to “The Offset Area ……. will require stock access and grazing for biomass management. It will therefore remain subject to a Land Management Agreement (LMA)". That LMA will need to be tailored to the ecological condition and value of the area since the objective is to improve conservation value in the long term, not just keep fuel load within criteria.
Administration
FOG must express concern once again that the DA package was not well organised so that it could be easily navigated or quickly and efficiently analysed by our members who give most generously of their volunteering time.
This EIS document is a monster. It all looks okay at the outset when the table-of-contents show about 400 pages to be negotiated; however, this was not the case. The full package was actually 1126 pages. The EIS table-of-contents appears to indicate 48 pages of documents in appendices; the real story is 749. Worse, the table-of-contents was not helpful for navigating the appendices. FOG created its own table-of-ACTUAL-contents to usefully navigate the package. This falls far short of EPSDD's stated policy to make DAs open to, and readily accessible by, the community.
Yours sincerely
Professor Jamie Pittock
President,
Friends of Grasslands
15
November 2024