Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Mr Todd Rohl

Managing Director, Planning and Urban Design

National Capital Authority

GPO Box 373



Dear Mr Rohl


National Capital Plan Draft Amendment 67

Provisions for Mobile Home Park, Symonston


This proposed amendment is to allow for a Mobile Home Park to be established on Block 17 Section 102 Symonston, and formalise the existing caravan parks on Blocks 6 and 8 Section 97 Symonston.  The amendment is apparently consistent with a proposed draft Variation to the Territory Plan (no. 285).

Friends of Grassland (FoG) is a community group dedicated to the conservation of native temperate grassy ecosystems, such as grasslands and woodlands. FoG is based in Canberra and its members, numbering over 200, include professional scientists, landowners, land managers and interested members of the public. FoG advocates, educates and advises on matters to do with conservation of grassy ecosystems, and carries out surveys and other on‑ground work.


FoG recently provided comments to the Australian Government Department of Environment and Water Resources on a referral under the EPBC Act of a proposal relating to Bl 17 Sn 102,  to service the land and issue a lease to a developer. FoG's comments related to the grassland earless dragon Tympanocryptis pinguicolla, listed as an endangered species under both Commonwealth and ACT legislation. FoG's view was that the proposal should be rejected, or at least warranted further investigation, prior to any approval under EPBC, as it may have significant impact on the grassland earless dragon, i.e. it may destroy both members of a population of this species and its habitat. 


FoG's reasons for believing that the swap site should not be developed, as it may have a significant impact on the grassland earless dragon and its habitat, are as follows.

The grassland earless dragon has been recorded in areas around Cooma, but this is thought to be a separate sub-species. No other populations are known, although there may be small isolated populations elsewhere. Surveying for the species is both problematic and costly; FoG members have been involved in such surveys. Unfortunately, the last survey of the subject site was undertaken in 1999, and there is no more information about the current status of the species.


FoG is on the public record as being opposed to the development of the site, although sympathetic to the plight of the residents at the long-stay caravan park. Our opposition has been greatly strengthened with the recent crash in grassland earless dragon numbers; for example, poor management at the Majura Field Firing Range has resulted in surveyed numbers there falling, according to our best advice, by 80%. Developments at Canberra Airport have seen removal of individuals and habitat from that site. Elsewhere, the impacts of the drought in the Jerrabomberra Valley, have seen numbers drop by 20%. It has always been difficult to obtain precise numbers for the species, but only several hundred individuals may remain in the wild. This is an appalling picture for the species survival and, in the circumstances, FoG's view is that all remaining habitats should be protected.


If the proposed amendment/variation were to be made to the respective Plans, and proposed developments were to be allowed - which FoG does not support - it is critical that:

FoG's experience, gained from observing management on Defence lands at Majura and the Canberra Airport, is that conservation management is not guaranteed if left in private or inexperienced hands.

Yours sincerely





Kim Pullen

30 August 2007