Mr Ben Ponton
Chief Planning Executive
ACEPDCustomerServices@act.gov.au

Dear Mr Ponton

Re. Upper and Lower Tumut 330 kV Transmission Line Realignment (EIS202300023)

Friends of Grasslands (FOG) is a community group dedicated to the conservation of grassy ecosystems in south-eastern Australia - natural temperate grasslands and grassy woodlands. FOG advocates, educates and advises on matters to do with the conservation of these ecosystems, and carries out surveys and 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 monitoring closely the impact of developments in north-west ACT on both natural temperate grasslands (NTG) and box-gum woodlands (B-GW) and on habitat for threatened species such as the pink-tailed Worm Lizard (PTWL). On paper, the impact of this development is relatively low; our concerns remain however about the cumulative impacts of this and other current and planned infrastructure and residential development projects on threatened ecological communities and connectivity. The EIS acknowledges the cumulative impact of all these developments. 

The section of the EIS titled ‘Mitigation and Management Measures’ states in relation to biodiversity impacts that “Table 5.18 details the specific measures that will be implemented” (Section 5.6, p. 148). FOG did not find specifics offered for any measures and considers Table 5.18 sets out no more than a general framework for the activities envisaged. The EIS Scoping Document required specific measures to be presented for assessment. The proponent intends to include specific measures in a Construction Environment Management Plan and parallel documents which may not be developed until later and are not likely to be open to review by the public.

Absent specific measures, the effectiveness and adequacy of mitigation measures are, at present, impossible to assess.

We ask that you consider whether to require that the EIS be represented and republished so we can give consideration to specific measures for:

• appropriate site rehabilitation, including all tracks and trails;
• avoidance of sensitive ecological areas (BGW, NTG, PTWL habitat, mature hollow-bearing trees) wherever possible; and
• monitoring of rehabilitation efforts and effectiveness.

FOG submits that equivalent inadequacies exist in text about other mitigation “measures” such as for erosion and sediment control impacts.

FOG asks that efforts are also directed to meaningful rehabilitation efforts in Woodstock Nature Reserve after the towers are removed.  While not a grassy ecosystem, the reserve remains an important connectivity corridor for many species including some woodland birds.

If any clarification or additional information is needed, please contact Matt Whitting, FOG’s Advocacy Convenor, via matt.whitting@fog.org.au.

Yours sincerely

 

Professor Jamie Pittock

President, Friends of Grasslands

10 June 2025