Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601
email: epbc.referrals@environment.gov.au

 

Dear Sir/Madam

Snowy 2.0 Transmission Connection, Kosciuszko National Park and Bago State Forest

Referral no: 2018/8363

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 has a particular interest in the Alpine Sphagnum Bogs and Associated Fens ecological community as well as the grassy ecosystems in the project area – Grey Box Grassy Woodlands, Natural Temperate Grasslands and Box- Gum Grassy Woodlands.

FOG has already responded to referral 2018/8322 Snowy 2.0 main works in relation to this project (letter dated 12 November 2018), and many of our comments remain the same for the current referral. These include an in principle objection to developments impacting upon endangered and critically endangered species and ecological communities and concerns about the current significant threats already impacting upon the three TECs communities (e.g. weed invasion, wild horses and feral animals) worsening due to additional impacts from Snowy 2.0.

In the referral there is mention of a discussion with NPWS concerning placement of new transmission lines overhead versus underground. We think it essential that the advantages and disadvantages of both options be clearly understood, and that the option with the least long term environmental impact be selected.

FOG also notes that “Bago State Forest is managed with a mix of plantation areas and native forest areas. FCNSW identified that it would be preferable for the native forest managed areas to be impacted, rather than the plantation areas.” We are opposed to this as our understanding is that, at least in the past, there were at least twelve peatlands and swamps with environmental values in the State Forest. In a letter (dated 13 August 2007) to the then NSW Minister for Climate Change, Environment and Water we drew attention to the various forms of degradation that was occurring at these sites and asked the Minister to ensure that appropriate management plans for these native vegetation areas were drawn up and implemented. Before any part of the Snowy 2.0 project impacts on these areas, the environmental values of these areas and the possibility of improving their values needs to be assessed.

Where biodiversity impacts cannot be avoided, the referral proposes offsets in perpetuity, with a Biodiversity Offsets Strategy to be prepared. This should be made available for public comment alongside the EIS, rather than being agreed upon at a later date behind closed doors. As well, information about ongoing management of offsets should be made available to the public until it is clear that the offsets have achieved their stated aims and resulted in no net loss of the TECs and species impacted by the project.

As well, where offsets are necessary, they must be adequate for the size of the impact upon MNES, like-for-like and put in place before any construction work begins. We suggest that, given the ongoing impacts of the original Snowy scheme, offsets such as improved control of weeds, brumbies and feral animals, together with more resources for management, could see improvement in the grassland and grassy woodland areas of Kosciusko National Park.

Noting the ongoing impacts of the original Snowy scheme, it is important that offset calculations include the impacts of ongoing maintenance of Snowy 2.0 as well as the construction phase.

FOG is of the view that the EIS should not only recommend mitigation and management measures to reduce the biodiversity impacts of the construction phase as much as possible, but also make recommendations about long term operation mitigation measures.

We note that community engagement is to be part of the EIS and ask that we be advised of these via advocacy@fog.org.au. In particular, we would like the opportunity to input into any potential impacts on the three TECs in the study area.

Yours sincerely

 

Geoff Robertson
President

11 March 2019