ACEPDcustomerservices@act.gov.au

Re. DA202342246, Drake Brockman Drive duplication development application

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 appreciates this opportunity to comment on plans advanced in DA202342246.

Summary of issues

1. As a group committed to conservation of grasslands and grassy woodlands, we are appealing to the developers to reconsider the environmental impact that the road duplication will create and the flow on effects for the local community. FOG urges a review of size and design details of DA202342246.
2. The clearing of the proposed high number of trees amounts to severe ecological loss and plans need to be reconsidered on the basis of existing ACT legislation (Nature Conservation Act 2014: Loss of Mature Native Trees: a key threatening process; and Urban Forest Act 2023).
3. Revegetation should aim to replant native species (trees, shrubs, grasses and flowering plants) that are characteristic of the local natural grassy woodland community that is being lost.

Rationalisation

Clearance of significant trees

FOG acknowledges, as laid out in document ENVIRONMENTALREPORT-202342246-01, that the developer years ago received strategic approval via SA.024 and has been granted exemption from EIS that allows 3.8 ha of EPBC Act Box-Gum Woodland to be cleared. Two conditions were attached in the Defined Process Strategy but neither require additional consideration. However, FOG challenges the developer to review the planning of extensive civil works so that some mitigation of environmental impacts is achieved.

Much has changed in environmental thinking since the Approval and EIS exemption were granted.  Climate change and extreme weather events are now a household consideration. The ACT has legislated far more considered Tree Protection. Heat island effects are core to tree preservation, and construction is now far more regulated around mature trees. Finally, the Yellow Box/Red Gum Grassy Woodland is now declared as Critically Endangered Ecological Community here in the ACT. These are all reasons that FOG has chosen to advance this challenge to promote the review of size and design details of DA202342246.

FOG was very disappointed to see the number of existing trees that will be cleared for construction. This is serious enough inside the existing road reserve, but is magnified greatly when the reservation will be significantly expanded with the result that the green belt at the northern edge of grazing paddocks will be substantially felled. Plantings planned will not replace the green belt for at least 50 years and in that time Holt and Higgins residents will suffer significant loss of amenity and possibly local heating from enlarged pavements. Another aspect of trees to be felled relates to loss of mature, potentially hollow bearing trees that are important habitat for many native creatures; their loss is identified as a key threatening process under the Nature Conservation Act 2014.

FOG has used the Urban Forest Act 2023 to run a ruler over the planned vegetation modification. In that legislation, all trees on public land are protected, trees with canopies larger than 8 m are protected on private lands. FOG has been generous in its analysis and used a canopy of 10 m as a gauge of habitat quality.  We have worked through drawings in the VERGE-202342246 series and compiled the table below which tallies large trees to be protected versus trees to be lost. Our view is that loss of 22 mature trees with canopies of at least 10 m, but protection of only 8, amounts to severe ecological loss. In addition, one more large tree (labelled 135 DEAD in drawing VERGE-…-08) is presently part of an Australia-wide mental health initiative of over 1100 such trees, and is just one of only 5 such trees in the ACT. This dead, but socially alive, blue-coloured tree will also be removed by Stage 2.

 

FOG appreciates that significant numbers of young trees, mainly natives, are to be retained along the north edge of Stage 2 works. This will be critical to the amenity of nearby residents, giving some filtering of noise, emissions and light from the ultimately large roadway. The young trees also represent useful environmental assets, giving some food and shelter for smaller birds, but nothing that in any way covers the loss of hollows and habitat from large trees expected to be removed. This downside will also be experienced by the many users of the road reserve for walking, cycling and recreation.

Revegetation of the construction zone and adjoining paddocks

FOG would also like to comment on details in the plans for revegetation of the construction zone and the adjoining paddocks where significant shelter will be removed. Firstly, the large areas of grass around new roads, tracks and trails will have to be mown regularly and therefore it makes sense that dryland grass be seeded. It is also apparent that the Drake Brockman Drive road reserve has lost almost all native quality that it once possessed. This is mainly due to roadside mowing having carried in and promoted the invasion of African Lovegrass. Every effort must be made to remove topsoil contaminated by seeds of this transformative species. Moreover, 20 years ago, the road reserve contained significant patches of native grasses and forbs, and FOG would very much like to see additions of some feature patches. The patches we have in mind, possibly up to 20 m diameter and containing attractive ACT grassland species, including herbaceous species as well as grasses, should be mown just once annually (with clean machinery), mown high and marked for mowers by log/rock barriers

Secondly, the Drake Brockman Drive road reserve was planted on its southern side with three species of small native trees: White Cedar, Black Sallee and Snow Gum. All of these are likely to be removed by roadworks. Eucalyptus pauciflora (Snow Gum) is included in the tree planting list (PLAN-202342246-GA-01), the other two are not. FOG suggests this be rectified. Of particular note, White Cedar is deciduous so could be used where this could be important for amenity.

Thirdly, some of the tree and shrub species seem quite peculiar. Chinese Elm (Ulmus parvifolia) in recent years has gained some status as being an environmental weed that should not be planted near natural areas. While it is deciduous (but could be substituted by White Cedar), it also has a reputation of releasing large airborne pollen loads at flowering time. That pollen is especially problematic for some allergy sufferers. Canberra is not a place where we need more pollen problems. The selected Acacia species also seem odd. A. howittii and A. iteaphylla are certainly not native to this area. That is no reason to avoid them, but the Acacia mix near Box-Gum woodlands should be dominantly from our indigenous species and hopefully include several bipinnate varieties which afford better shelter for small birds. Inspiration could be taken from the swale planting-list, which contains a good component of hardy local species.

We would be grateful for the opportunity to further discuss these concerns, with a view to reducing the damage caused by this proposal.

Yours sincerely

 

Professor Jamie Pittock
President, Friends of Grasslands

6 March 2024