Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



The Manager

Planning and Land Policy Section

ACT Planning and Land Authority

GPO Box 1908



Dear Madam/Sir


Draft Variation to the Territory Plan No. 285

Symonston Bl 17 Sn 12 - extension of Broadacre 10E Area Specific Policy


This proposed Draft Variation is to extend the 10E Area Specific Policy to enable use of the subject site as a mobile home park, to facilitate a land swap with the current lessee of the Narrabundah Long Stay Caravan park on Bl 8 Sn 97 Symonston. The amendment is consistent with a proposed Draft Amendment 67 to the National Capital Plan.


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 has also provided comments on the related Draft Amendment 67 to the NCP. FoG's comments on both the above related to the grassland earless dragon Tympanocryptis pinguicolla (GED), listed as an endangered species under both Commonwealth and ACT legislation. FoG's view was that the proposed works (referred under EPBC) should be rejected, or at least warranted further investigation prior to any approval, and that the NCP amendment was not supported, as development may have significant impact on the GED, 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 GED and its habitat, are consistent with the Conservator's comments (at 2.8). FoG has some general comments on the draft variation and some specific comments in support of the Conservator's comments.


General comments 


Text at 2.4.2 indicates that adjustment to 'proposed land use policy boundaries' may occur 'following detailed surveys'. FoG suggests that any decision about land use at the site needs to be made on the basis of sufficient and current information (e.g. about occurrence of GED in the subject area and the relationship of that to remaining populations) and that the variation, or any development approvals, should not be made until such information exists.


Text at 2.5 is confusing about the actual commitment of the ACT Government to the residents at the Narrabundah Long Stay Caravan Park; swapping the site is not 'continu(ing) on the (same) site'. There is also a question about 'some form of certainty for the residents', given that on-sale of the site (as happened in 2006) may again mean that a new owner may seek to develop the site for another purpose; is their any actual commitment to a long term long stay caravan park?


Text at 2.7.1 indicates that long term planning intent is not being pursued in an organised way, given that the Canberra Spatial Plan has 'identified the area along Monaro Highway potentially as a future employment corridor' but 'further detailed studies have not been completed'; the proposal is reactive and appears opportunistic.


Specific comments in support of the Conservator's comments


Significance of the area as habitat for the GED. As stated, the ACT Government strategy regarding the species is set out in A vision splendid of the grassy plains extended: ACT lowland native grassland conservation strategy, Action Plan No. 28. There are likely to be only two remaining significant populations anywhere. Although the species has been recorded in areas around Cooma, this is thought to be a separate sub-species. No other populations are known, although there may be small isolated populations elsewhere.


The future of this species is far from secure. As stated, the swap site is 'part of about 50 ha of contiguous GED habitat'. The policy of the ACT Government was to protect every remaining population of the species (only allowing broad scale development that would not interfere with the species habitat) until the issue of retaining a long stay caravan park at Symonston emerged. 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.

FoG is very concerned that this proposal could go ahead because GED habitat is apparently secure locally, given that 'GED habitat adjacent to the land-swap development and key habitat in the Majura Valley are both subject to future road proposals'. This chance of further habitat loss provides solid justification for retaining whatever remains on the subject site.


Quality of the site. The comments identify that the proposed development will 'destroy about 1.5% of the habitat for GED that remains in the Jerrabomberra Valley'. However, this estimation does not consider the quality of remaining habitat or the remaining occurrence of the species. FoG is very concerned by the recent crash in GED numbers across its limited range; 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%. Given that the estimation of GED numbers and, therefore, the significance of the site as habitat, is based on 1997 trapping surveys, and the long dry periods, other developments and lapses in management since that time, FoG's view is that further survey is required to confirm the status of the species, establish the appropriateness of any development, and identify the likely impacts on the conservation of the species and its habitat. As is also noted, the 'lower quality habitat has the potential to be improved through appropriate management', but only if it is retained.


FoG supports the Conservator's recommendations (a) to (d), except that for (a) FoG's view is that the 'remaining area' continues to include the subject site.


FoG is on the public record as being opposed to the development of the subject site, although sympathetic to the plight of the residents at the long-stay caravan park. Our opposition has been greatly strengthened with recent likely losses to GED numbers and habitat quality because of long dry periods, other developments and lapses in management across its range.


If the proposed variation were to be made, 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 faithfully




Kim Pullen

3 September 2007