DAVID HOGG PTY LTD

ABN 35 008 564 047 ACN 008 564 047

CONSULTANTS IN • ENVIRONMENTAL PLANNING AND ASSESSMENT

• RECREATION STUDIES
• SPORTS DEVELOPMENT

SUITE 3, BANK BUILDING, JAMISON CENTRE, MACQUARIE, ACT

POSTAL ADDRESS: PO BOX 213, JAMISON CENTRE, ACT 2614
TELEPHONE: (02) 6251 3885 FAX: (02) 6253 1574 E-mail: dhpl@bigpond.com

SANDFORD STREET EXTENSION TO THE FEDERAL HIGHWAY

SCOPING STUDY AND ASSESSMENT OF EIS REQUIREMENTS

David Hogg
8 July 2009
Report to Cardno Young Pty Ltd

1. Introduction

The following report has been prepared on behalf of Cardno Young Pty Ltd as a first
step in the systematic assessment of the environmental issues relevant to the
proposed extension of Sandford Street to the Federal Highway.

The main purpose of the scoping study is to identify environmental issues which may
need to be addressed in the design and construction of the road. In addition, it
provides information which may assist in determining whether an environmental
impact statement (EIS) is required under the Planning and Development Act 2007
(P&D Act) and, if so, would assist in the scoping of that EIS.

The scoping assessment has been prepared using a comprehensive scoping

framework which is currently being developed by the firm for specific application in
the Canberra area. It focuses particularly on those issues which are relevant to the
current stage of planning for the project. Some issues which may be important can
be addressed only in general terms at present, but would need to be pursued further
at a later stage of the planning and design process. Other issues relate to strategic
decisions which have already been undertaken. These distinctions are discussed in
Section 2 and are emphasised in the scoping assessment.

Section 3 of the paper provides a preliminary scoping assessment of all the

environmental issues potentially relevant to the project and comments briefly on how
these might be addressed most effectively in further environmental assessment and
in application to the design and construction process. This information would also be
useful in scoping the contents of an EIS, if it determined that an EIS is required.

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 2

This issue of whether an EIS would be warranted for the project is discussed in
Section 4, taking account of both the statutory requirements under the P&D Act, and
the pragmatic considerations of whether an EIS would lead to a better environmental
outcome or is desirable to address community concerns about the proposal.

2. The Decision-making Process

Scoping of environmental studies should be addressed in the context of the

sequential decision-making process that applies to a project (Ref. 1). In the context
of the Sandford Street extension, the key decisions are as follows:

Decision 1. Whether to extend Sandford Street to the Federal Highway. The

Sandford Street extension is part of the planned road network for Gungahlin (Ref. 2)
and, while that plan has been subject to some amendments, the road connection
remains as part of the Territory Plan. A suitable road connection to the Federal
Highway is essential for the future growth of Gungahlin, and the decision-making
process has moved past this point.

Decision 2. General location of the road. The general location of the road is
dictated by the existing locations of Sandford Street and the Antill Street roundabout,
and by land uses that have been established adjacent to the road. The road location
was determined in a previous engineering study for Sandford Street extension (Ref.
3) and does not need to be reviewed in the scoping study.

Decision 3. Detailed location of the road. The detailed location of the road within
the road reserve is addressed in the current design study. The scoping assessment
is focused largely on those issues which are relevant to the detailed road design.

Decision 4. Design of the road. This is also part of the current engineering study,
and may be influenced by environmental issues arising from the scoping
assessment. The design process may include the preparation of an environmental
management plan (EMP) for application during the construction process. This would
reflect environmental issues identified in the current scoping.

Decision 5. Construction of the road. Numerous other decisions on the

interpretation of the environmental protection measures embraced in the design will
be made once the construction starts. While these can be guided by the design
documentation and the EMP, it is not practicable for these to address every detail,
and further decisions will need to be made by the construction team.

In summary, the current scoping process is limited to identifying those environmental

issues which are relevant to the detailed location and design of the road, including
acknowledgement of issues that should be addressed in the EMP.

As a general consideration in scoping the proposal, it is important to acknowledge

that the Sandford Street extension is just one development within a landscape that is
continually changing as the town of Gungahlin develops. In particular, the future
development of the adjacent suburb of Kenny will be more important than the road in
changing the local environment.

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 3

3. Preliminary Scoping Assessment

The following preliminary scoping assessment is based on a site inspection of the

road reserve as previously determined and adjacent land.

Ecological impacts – general. The area of greatest potential ecological value is

located towards the eastern end of the road where there is extensive eucalypt
regeneration of remnant trees and a predominantly native groundcover. While this
area has not been identified as being of particular ecological value in previous
studies (Refs. 4, 5), its condition has improved in recent years. It is desirable to
design and construct the road to retain mature trees and recent regeneration within
the road reserve where practicable, even though most of the adjoining land to the
north will ultimately be developed for urban use. This is a significant consideration in
the design of the road.

There are no significant ecological issues along the western part of the road
extension, where the environment is already substantially modified.

Threatened species and communities. The regenerating woodland towards the

eastern end of the road has features which may justify its consideration as the box –
gum woodland community listed as endangered under the ACT Nature Conservation
Act (NC Act) and/ or the Commonwealth Environment Protection and Biodiversity
Conservation Act (EPBC Act). This is an important issue which is addressed in the
current ecological assessment of the project (Ref. 6).

Other possible threatened species or communities which have previously been

associated with the area but are no longer considered significant concerns in this
context as a result of recent development are natural temperate grassland and the
striped legless lizard. The presence of threatened woodland birds is a potential
issue in any situation where remnant, hollow-bearing trees may be removed, but the
site is of minimal importance in this respect in a wider Gungahlin context.

Significant trees. Several mature trees of ecological and/ or landscape value are
likely to be removed as a result of road construction. It is desirable to retain as many
of these trees as possible in the design of the road, with priorities for retention being
set according to both ecological and landscape criteria. As stated above, retention
of regenerating trees within the road reserve is also desirable where this is
practicable.

Other habitat features. It is desirable to maintain Sullivans Creek as a potential

aquatic habitat corridor. This appears unlikely to be affected significantly by the road
extension. There are no other important habitat features that are likely to be
affected.

Ecological continuity. Apart from possibly Sullivans Creek, there are no areas
along the road extension which are likely to be important as wildlife movement
corridors. The main corridor for wildlife movement around Gungahlin is located
further to the east.

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 4

Exotic plants and animals. While much of the road corridor (particularly the
western end) is dominated by exotic groundcover, there are no major issues
associated with exotic plants or animals.

Modification of animal behaviour. Apart from the interaction between animals and
traffic (see below) the road extension is unlikely to have any significant impacts in
modifying animal behaviour.

Wildlife mortality. Particularly in the short term, some risk of wildlife mortality
(particularly kangaroos) can be expected along the road extension. This risk would
probably not be as high as on the parallel section of the Federal Highway, however.
In the longer term, urban development within North Watson and Kenny is likely to
reduce the extent of kangaroo movement across Sandford Street, with a consequent
reduction in wildlife mortality.

Potential for ecological enhancement. There is potential for enhancing the quality
of woodland within the edges of the road corridor. This could be achieved both by
facilitating natural regeneration and by planting appropriate species.

Landform modification. No significant landform modification appears likely to

result from the road construction.

Geotechnical assessment. Geotechnical assessment required for the road

construction has been carried out by Douglas and Partners in May 2009. Due to
presence of silty clay material it has been recommended that a 400mm excavation
from existing ground surface is completed and suitable fill compacted in layers up to
formation level of sub-base.

Soil management. Responsible soil management during and after construction will
be important. This would need to be addressed in the detailed design and the EMP,
and subsequently throughout the construction process. Subject to appropriate best
practice measures being implemented, this is unlikely to be a major issue.

Contaminated land. There is no apparent evidence of contaminated land along the

route of the Sandford Street extension. If so, it is expected that this would be
identified in the geotechnical assessment and addressed as part of the design/ EMP
process.

Climate and microclimate. There are no aspects of climate or microclimate that

are expected to influence the detailed design of the road.

Altered hydrological regime. The main issues associated with hydrology are
maintaining the flow in Sullivans Creek and avoiding any works which would affect
soil moisture levels in the vicinity of the 2CA transmitter at the western end of the
road. It is expected that these issues would be addressed in the design process.
There is also an extensive pedoderm north of the western end of the road which
traps and temporarily stores groundwater following heavy rain. A trench beside the
road would be designed to intercept this groundwater and use it to recharge
Flemington Road Pond P2. There may be changes to the hydrological regime of the
minor watercourse near the eastern part of the road.

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 5

Drainage changes. No significant drainage changes are anticipated as a result of

the road construction, although there may be some modification to the minor
watercourse near the eastern part of the road.

Flood risks. It is assumed that flood risks, particularly those associated with
Sullivans Creek, would be taken into account in the engineering design of the road,
and would not be significant.

Water quality. No significant water quality issues are expected to arise as a result
of the road. The risk of turbidity and sedimentation resulting from runoff during
construction is discussed under Construction impacts.

Traffic impacts. There would be some significant changes to traffic patterns,

particularly between Mitchell and the Federal Highway as a result of extending
Sandford Street. This is the main purpose of the proposal. In the longer term, traffic
would be generated on the road as result of development in the suburb of Kenny.

Traffic impacts during construction are discussed under Construction impacts.

Air quality. The increased volume of traffic on Sandford Street and connecting
roads is not likely to lead to any significant air quality impacts on nearby land uses.
The impacts on air quality at the metropolitan scale would be negligible.

Dust generation during construction is discussed under Construction impacts.

Noise and vibration. Traffic noise is an issue which needs to be addressed in the
design of both the road and adjoining land uses. The only existing land use in the
vicinity of the road which is likely to be noise-sensitive is a rural residence near the
Antill Street roundabout. No major vibration issues associated with the road appear
likely.

Construction noise is discussed under Construction impacts.

Visual impacts. The visual impacts resulting from the road would be of a local
nature only. In the longer term, the road would appear as an edge road to the
suburb of Kenny, and would be viewed as part of that suburb.

Views from the road. The nature of the road is such that views from the road are
unlikely to be a significant factor influencing its design.

Cultural heritage impacts. Previous archaeological surveys of the area containing

the road extension have not found any Aboriginal artefacts (Refs. 7, 8). Should any
such artefacts be found along the road, it is assumed that these would be managed
appropriately prior to or during the construction process.

There do not appear to be any features of European cultural heritage significance

that would be affected.

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 6

Geological heritage. There are unlikely to be any geological heritage issues

associated with the proposed road.

Land use impacts – general. The road would impact on the property fronting the
Federal Highway at the Antill Street roundabout as well as on grazing land to the
north of the equestrian trail. The latter area would eventually be withdrawn from
rural use when Kenny is developed. There would be no impact on the Bimberi Youth
Justice Centre.

Effects on nearby communities. There are no existing residential neighbourhoods

or other communities in proximity to the road. In the longer term, the road would
benefit residents of Kenny.

Effect on recreational uses. The road would intersect the equestrian trail north of
Antill Street roundabout, requiring a safe crossing for horse riders, but would
otherwise not affect that trail. No other recreational uses are likely to be affected.

Effects on educational and scientific uses. No adverse impacts on existing

educational or scientific uses appear likely.

Access/ accessibility. The primary purpose of the road is to improve accessibility

to Mitchell and, in the future, to Kenny. There would be no adverse impacts on
access or accessibility.

Property values. Construction of the road is not expected to have any significant
impacts on the value of existing properties.

Other economic effects. There are economic benefits from a broad planning
perspective, but this is not relevant in the design context.

Waste management. There are no significant waste management implications

associated with use of the road. Waste management during construction is
discussed under Construction impacts.

Resource demand. Due to the recommended removal of 400mm depth of

unsuitable silty clay material and in order to bring the finished road surface up to
ground level or higher, there is expected to be net imported fill requirement for the
road. Cut and fill quantities will be determined during design.

Existing services and infrastructure. Where the road crosses any existing
infrastructure, such effects would be routinely addressed in the design of the road.
Most of the route does not appear to be subject to such constraints. The proposed
road alignment crosses under an existing ActewAGL overhead electrical power line.
This line will be raised or diverted underground.

Safety issues. Road safety is an integral component of the road design.

Bushfire risk. With future urban development proposed to the north of the road and
south of the Federal Highway, the risk of bushfires spreading across the road
corridor would be low. In the short term, the road could be exposed to grass fires

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 7

approaching from the north, but this is unlikely to be of serious concern in the context
of the wider road network. The road itself would not increase bushfire risk.

Energy implications. The road would have a marginal energy benefit in reducing
travel distance and hence fuel consumption between Mitchell and the Federal
Highway.

Construction impacts. The typical construction impacts that can be expected

include noise, vibration, traffic movement, dust, sediment and erosion control,
restriction of public access, waste disposal and establishment of works areas.
These should all be addressed through the EMP and, in some cases, as part of the
project design. The management of these impacts will involve many decisions
throughout the construction stage.

Sustainability. There does not appear to be any opportunity to address the issue of
sustainability in a meaningful way at the design level in the current project.

Climate change implications. The proposed road does not appear to raise any
significant issues in the context of climate change.

4. EIS Requirement

The possible requirements for an EIS is considered from two perspectives. One
perspective relates to the statutory requirements under the P&D Act. The other is in
terms of whether preparing an EIS would determine any real benefits in terms of
achieving a better environmental outcome or in addressing community concerns
about the proposal.

4.1 Statutory requirements

Schedule 4 of the P&D Act sets out conditions for which a development proposal
requires an EIS. Those conditions possibly relevant to the current proposal are as
follows:

• In Part 4.2, Item 1:

proposal for a linear transport system corridor (for example, construction of

new corridor or realignment outside existing corridor) intended to result in a
major road, bus way, railway, light rail or tramway, and that is likely to have a
significant impact on air quality or ambient noise or cause a significant level of
vibration, significant visual intrusion or significant impact on a residential area.

• In Part 4.3, Item 1:

proposal that is likely to adversely impact on the conservation status of –

(a) a species or ecological community that is endangered; ...

• In Part 4.3, Item 3:

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 8

proposal involving –

(a) the clearing of more than 0.5ha of native vegetation; ...

These conditions are discussed in turn as follows:

With regard to Part 4.2, Item 1, ‘major road’ is defined in the P&D Act as meaning ‘a
road with physically separated carriageways, which has at least 4 lanes (in either
direction) and is at least 1 km long’. While the current construction project is for a
single carriageway only, the full potential development should be considered in the
environmental assessment.

There are no residential areas, however, that would be affected by the initial
construction of the road and, with appropriate design of the road adjacent to
subdivisions, it should be possible to avoid any significant impacts with respect to air
quality, ambient noise, vibration or visual intrusion. It is therefore considered that
this provision would not justify the preparation of an EIS.

With regard to Part 4.3, Item 1, there is the possibility that the regenerating woodland
towards the eastern end of the road may be considered as part of the endangered
ecological community, yellow box – red gum grassy woodland, as a result of recent
regeneration of eucalypts and native groundcover. While it is not shown as such in
Action Plan No. 27 (Ref. 4), the information in the Action Plan is several years old
and it is apparent that the condition of the woodland, at least in the vicinity of the
road, has improved since that information was compiled.

If this regenerating woodland is considered to be part of the endangered community,

it is still uncertain whether the road would be considered to adversely affect its
conservation status, when viewed in the wider planning context of Gungahlin. A
commonsense approach suggests that it would not.

With regard to Part 4.3, Item 3, it appears that the roadworks would involve the
clearing of more than 0.5 ha of the regenerating woodland and that the woodland
would be considered to be native vegetation, even though its forb diversity is lower
than in a natural situation. While the definition of native vegetation under the P&D
Act and the Nature Conservation Act is unclear, it is considered that this impact
would trigger the preparation of an EIS based on a strict interpretation of Schedule 4.

4.2 Potential Benefits of an EIS

The main distinguishing feature between an EIS and other forms of environmental
documentation is that an EIS is prepared to inform the wider community about a
proposal and offer the opportunity for public comment. Its preparation does not
necessarily involve additional technical analysis than would otherwise be the case,
but requires much effort to present the important environmental information in a
succinct form which the lay person can understand. The value of the EIS process
lies in the extent and quality of community feedback, in particular its ability to attract
constructive comments which can lead to a better environmental outcome.

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 9

In practice, the level of public response to an EIS tends to depend on the level of
controversy associated with a project rather than necessarily the scale of its impacts.
This in turn is influenced by how many people are potentially affected, usually
adversely but sometimes beneficially. Responses commonly take the form of an
objection, which may or may not be supported by rational argument. While these are
legitimate from the viewpoint of allowing people to express their opinions, they do not
necessarily add to the information that influences decisions on a project. Some
responses, however, may present information which is not readily obtainable through
the environmental assessment process that precedes the EIS, for example, local
community uses of an area or seasonal observations of plants or animals which are
generally not detectable. Such information may be useful in influencing the course
of a project.

The EIS is just one tool that can be used for public engagement in relation to a
project. Its relative effectiveness compared with other tools, such as direct
stakeholder consultation or community information sessions, depends on the nature
of the project and the extent of public interest. It is not possible using a prescriptive
approach, such as that in Schedule 4 of the P&D Act, to determine whether an EIS is
effective or efficient in engaging the community in relation to a specific project.
Given the extensive resources required to write an effective EIS, there are often
alternative approaches which can achieve a better outcome for less cost or effort.

If an EIS is prepared for the Sandford Street extension, the key issues that would
need to be discussed, based on the preliminary scoping assessment in Section 3,
are as follows:

• Impacts on native vegetation, including consideration of the value of the

regenerating woodland as part of the yellow box – red gum grassy woodland
community – minor impact.
• Impact on mature remnant eucalypts – minor impact.
• Impacts on Sullivans Creek as a watercourse and ecological corridor – minor
impact.
• Hydrogeological impacts on the 2CA transmitter site – probably no impact.
• Traffic impacts – likely to be beneficial.
• Land use impacts on affected rural land – may be significant to the affected
lessee but minor in a broad context.
• Effects on the equestrian trail – minor.
• Access/ accessibility – likely to be beneficial, related to traffic impacts.
• Effects on existing services and infrastructure – minor (if any), addressed
through the design process.
• Construction impacts – minor and temporary.

None of the other issues considered in the scoping assessment would generate any
meaningful discussion in an EIS. In summary, there do not appear to be any major
environmental issues or matters of public controversy that would justify public airing
through an EIS.

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 10

The value of an EIS for the road can be further questioned in terms of its context.
Specifically, discussion of many of the road impacts on the existing semi-rural
environment would be meaningless when the adjacent development of Kenny is to
take place a few years later. Issues of this nature need to be debated at a more
strategic level in the decision-making process, as has occurred through the original
Gungahlin EIS (Ref. 2).

In addressing the above issues, the most relevant individuals or interest groups are
likely to be as follows:

• Any rural lessees affected by the road.

• Users of the equestrian trail.
• Government agencies with an interest in aspects of the project (e.g. Research
and Planning section of Parks, Conservation and Lands, managers of the
Bimberi Youth Justice Centre).
• Community environmental groups that take an interest in a wide range of
projects in and around Canberra (e.g. Conservation Council, Friends of
Grasslands).

While future residents of Kenny, particularly those backing onto the road, may have
a legitimate interest, it is not possible to identify those people at present.

It is assumed that there would be ongoing consultation with affected lessees during
the project. Government agencies would be consulted through the normal
interdepartmental consultation processes. If any community groups are interested in
the project (e.g. environmental groups, Gungahlin Community Council), they could
be informed through a community information session which could, if necessary, be
complemented with a field inspection of areas of interest. These measures are likely
to be more effective than an EIS in addressing any environmental details that might
otherwise have been overlooked in the planning and design process.

The wider Canberra community is likely to regard the road extension as a routine
minor development project of little environmental consequence and would be unlikely
to take any interest in an EIS.

References

1. Hogg, D. Scoping as an effective tool in environmental planning and

assessment. Paper presented to the Annual Conference of the Environment
Institute of Australia and New Zealand, Adelaide, September 2006.

2. National Capital Development Commission. Gungahlin. Environmental

impact statement. Final statement. January 1989.

3. WP Brown and Partners Pty Ltd. Kenny – Sandford Street extension.

Feasibility study. Final Report. September 2001.

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009

 11

4. ACT Government. Woodlands for Wildlife: ACT Lowland Woodland

Conservation Strategy. Action Plan No. 27, 2004. Environment ACT,
Canberra.

5. Ref. 3. Section 4.7 Ecological considerations. Prepared by David Hogg Pty

Ltd.

6. McIntosh, J. and Hogg, D.McC. Sandford Street extension to the Federal

Highway. Ecological assessment. Report by David Hogg Pty Ltd to Carndo
Young Pty Ltd, June 2009 (draft).

7. Australian Archaeological Survey Consultants. Preliminary cultural resource

surveys of future suburbs of Gungahlin. Report to ACT Planning Authority,
DELP Brief 94/4, 1994. Cited in Ref. 3

8. Saunders, P. Cultural heritage survey of Sullivans Creek catchment area,

Gungahlin, ACT. 2000. Cited in Ref. 3

SANDFORD STREET EXTENSION SCOPING STUDY – JULY 2009