Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Planning Services Branch

ACT Planning and Land Authority

GPO Box 1908



Dear Madam/Sir


I am writing to provide Friends of Grasslands (FoG) comments on the Draft Variation to the Territory Plan No. 281 Molonglo and North Weston, and the associated Preliminary Assessment. 


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 conservation of grassy ecosystems, and carries out surveys and other on‑ground work. FoG is based in Canberra and its more than 200 members include professional scientists, landowners, land managers and interested members of the public.


FoG has worked with other groups, including the Conservation Council of the South East Region and Canberra, to raise community awareness about these proposals and to prepare this response. Our collective engagement over recent years has been frustrated by an apparent disinterest within ACT Government to integrate a range of legitimate ecological and other environmental concerns into this planning process. Many FoG members participated in the various iterations of the proposals and are very concerned that their views have not been taken into account.


FoG's specific comments are included in an attachment to this letter. Comments at: Part I suggest principles which should be the basis for good planning; and Part II, outlines the reasons behind FoG concerns and our position. In summary, FoG's view is as follows.

Finally, FoG's view is that the ACT Government, and ACTPLA in particular - which often make claims about commitment to the environment, good science and community consultation - ought only to make proposals that comply with these principles. FoG cannot accept the lack of such principles in the Molonglo documents.


Yours faithfully



(Mr) Kim Pullen


26 November 2007




Friends of Grasslands comments on DV281 and its PA


Part I: Suggested principles for good planning


FoG's view is that certain general principles should be followed in effective planning processes.


Principle 1. Presentation of arguments, information and summary conclusions should be objective, honest and balanced.


There is much analysisin DV281 and its PA that is fair and objective, but many summary statements are misleading, dishonest and/or fanciful, and there are some important omissions. The following are examples from the DV where summary statements fail the objectivity, honesty and balance tests.


2.1 Background, Strategic context


p9: 'Between 2004 and 2006 further detailed planning and community consultation occurred into the potential for urban development in the Molonglo Valley, resulting in the preparation of the Molonglo Valley Structure Plan (2006). This draft variation implements the general principles identified in the structure plan.'  FoG's view is that a lack of planning/process may lead to key elements of the proposal falling over; many aspects will need to be referred - and may be rejected - under the EPBC Act. The overwhelming feedback from participants in earlier related processes is that the consultations were phoney. See principle 2 below.


p10: 'A key focus of the structure plan is the design of suburbs and neighbourhoods that foster a strong sense of community and promote the principles of sustainable design.'  This type of statement has been made by ACTPLA over many years. No evidence is presented that existing Canberra suburbs demonstrate ‘a strong sense of community’ or ‘sustainable design’.


p10: 'High value woodland and grassland areas will be protected from development. Improved water management in the area will result in positive outcomes for the quality of urban run-off, which will protect and enhance the water quality in the Molonglo River and its receiving waters.'  These comments belie the destruction planned for grasslands and woodlands, and likely poor water quality outcomes.


p10: 'Environmental conservation and ecologically sustainable development are integral to the planning of the area and have determined the physical nature of the structure plan and the principles, policies and codes that will govern development. This will result in high quality design and environmentally sustainable development.'  Such statements are not borne out in the documents.


2.3 Sustainability


p17. 'The Canberra Spatial Plan also identifies the protection of biodiversity as an important element of sustainability .... will ensure that connectivity between key habitat areas remain ... proposes to protect the woodland and grasslands ... [‘Kama’] ... as public land (nature reserve), thereby ensuring its ecological values remain for current and future generations.'  This is extremely misleading: whatever the Spatial Plan may identify, the DV advocates wholesale destruction of biodiversity.


Important omissions include:

Principle 2. Community views and expert advice should be recognised, summarised and addressed in subsequent documents.  


Many hours have been devoted by scientists and members of the community in attending consultations and in providing written comment to ACTPLA. As mentioned earlier, many FoG members consider that their efforts have been ignored. The DV/PA neither record who participated previously and their concerns, nor how these were addressed. This compares unfavourably with the recent process to restructure the Territory Plan. 


Principle 3. Proposals should aim to avoid reduction in natural ecological function, or loss of native vegetation and habitat for native fauna. 


Given that ACT Government legislation and policy seeks to protect natural ecological function, native plants and animals and their habitat, it is mind boggling that the DV could present such a blatant attack on all of these values. FoG accepts that there will be cases where natural values will be lost or degraded, but this should be exceptional and should be offset (see Principle 6 below). Most Australian jurisdictions have targeted native vegetation legislation which seeks to achieve 'no net loss' of native vegetation, for example by: prohibiting clearing, especially of vegetation listed as threatened; and providing for clearing only where there is an offset. FoG advocates for improvements to ACT legislation along these lines.


Principle 4. Proposals should not reduce the habitat of threatened and rare native species of fauna and flora, or threatened or seriously declining natural ecosystems.  


This is a more specific principle to protect rare and threatened species and ecological communities. Again, while FoG accepts that there may be rare cases where some destruction of habitat is unavoidable, the DV fails this principle to an unacceptable extent.    


Principle 5. Planning should aim to achieve good management of native vegetation and habitat, and where possible restore them and provide for good connectivity.  


Not only should development not destroy native vegetation and habitat, it should take advantage of opportunities to provide positive biodiversity outcomes, such as improved conservation management and strategic vegetation/landscape connections. While this has been raised as a critical issue in consultation, the documents do not address such opportunities. 


Principle 6. Where any proposal would lead to the destruction, degradation or potential threat to ecological function, native vegetation, habitat, threatened or declining native species and/or ecological communities, suitable offsets should be made and/or mitigation works funded.  


As already recognised (see principles 3 and 4 above) sometimes it is not possible to retain all natural values. In such situations, under the nationally accepted goal of 'no net loss' of native vegetation, suitable offsets should be identified; e.g. loss of habitat for a particular species should be offset with protection of like habitat elsewhere. Where a development will lead to (even potential) deterioration of vegetation/habitat, mitigation works should be funded to avoid that outcome. FoG is extremely concerned to note that, in the case of the pink-tailed worm lizard, the DV states that a large area of habitat may be lost, but offers no mitigation strategy; this is failure of planning process at a scale of professional negligence.


Principle 7. There should be no destruction of natural landscapes and or indigenous people’s heritage.


FoG is outraged by the following statement re possible construction of a dam (DV p15) 'it is more appropriate to the incised topography of the river valley which has steep sided (and often rocky) banks ... lake would raise the water level above much of the steep sided areas, resulting in easier and safer public access'.  FoG finds it hard to believe that even ACTPLA would seriously advocate building a dam to make nature safer by obliterating natural landscapes. Similarly, ACTPLA seems to pay no heed to retaining indigenous heritage, of which natural landscapes are an important element.


Principle 8. The use of terms such as 'sustainability' should be clearly defined.  


The use of undefined jargon undermines respect for planning documents.      


Part ll. Reasons for FoG’s position


Natural temperate grasslands and yellow-box red gum grassy woodland (YBRGGW) are threatened communities


FoG is committed to the retention of grassy ecosystem remnants and their restoration, and to protecting and enhancing their connectivity. These have also been the aspirations of successive ACT Governments, although there have been some significant failings.


The DV (pp13-14) outlines: the status of the two communities under the Nature Conservation Act and the EPBC Act; the proposed loss of around 5.4% of the remaining YBRGGW community in the ACT; that the loss of YBRGGW community in the Molonglo Valley is likely to be locally and regionally significant; proposed reservation of part of ‘Kama’; Conservator's advice re need for studies to determine appropriate buffers areas and management strategies, and potential for such studies to help identify spatial/ecological characteristics of areas of connectivity to integrate urban/conservation land use objectives; and the need to refer the proposal under EPBC. These are obviously significant values and issues.


FoG's view is that destruction of native vegetation - particularly threatened ecological communities - is not acceptable here, especially when large areas are proposed for destruction. The lack of information on proposed buffers - after so long a period of 'planning' - reflects poorly on ACTPLA. This proposal provides an opportunity for the ACT to work strategically with the Australian Government regarding EPBC implications.


Threats to habitat for already threatened and declining birds


Other submissions (e.g. from the Canberra Ornithologists Group) will provide detail on likely impacts on bird species/habitat. FoG has consistently emphasised the link between the decline of many local bird species and their grassy ecosystem habitat. We know that the current proposals can only hasten species demise, and feel ashamed that planners/fellow residents would advocate the destruction of such habitat. This does not reflect positively on Canberra as the 'natural capital'. For example, the DV (2.2 Env Assmt, p13) outlines the likely impacts on the little eagle and its status (nominated for listing in the ACT), but offers no options for mitigation.


Further threatened species - the pink-tailed worm lizard


The DV (2.2 Env Assmt, pp 13-14) also outlines the threatened status of the pink-tailed worm lizard (PTWL, Aprasia parapulchella) - including its restriction to 'undisturbed' habitat - identifies the lower Molonglo River corridor as important habitat (a stronghold), and states the significant local/regional impacts (and potentially national) proposed on this species: loss of 3.6% of the local habitat; further direct impact of 2.4% if an online lake was to be constructed; potential for a further 18% impact to suitable habitat through indirect impacts from nearby urban development. Although such impacts will require EPBC referral and a management plan is proposed, the scale of what is proposed (24% destroyed/degraded?) is well beyond reasonable. This is in context of the ACT Government's stated defence of another threatened reptile species, the grassland earless dragon Tympanocryptis pinguicolla. Dramatically reducing the area of PTWL habitat, together with loss to developments and other threats elsewhere, could see the demise of this reptile.


FoG's view is that the proposed habitat reduction of 3.6% should be avoided by pulling back development and/or finding alternative strategies. Given the proposed lake serves no ecological or other purpose for which alternatives do not exist, needlessly reducing the PTWL habitat by 2.4% should not even be considered. Any further potential impacts on 18% of habitat should be avoided by specific mitigation, e.g. strategic fencing.


Need for and potential impacts of the proposed lake


The DV (pp14-16) suggests that little work has been done on the lake proposal other than some exploring of feasibility, notes that approval would require full EIA, and indicates that the PA 'addresses a more specific development scenario'. This disconnection between DV and PA is confusing at least. The DV does provide some detail, about the proposed dam wall, the scope of impoundment (extensive) and related ponds, and states the purpose as the 'most viable stormwater management' without further explanation.


As stated already, FoG's view is that the proposed lake serves no purpose for which alternatives do not exist and we oppose it. This proposal threatens existing landscape features (including Coppins Crossing), important native vegetation, wildlife corridors and habitat. 


The reasons advanced for the lake are hardly substantial, and FoG argues they are ill considered. For example:

After this unconvincing reasoning, the PA (p15) fails to outline adequately the negative impacts of the proposed lake except for mentioning loss of raptor nests and PTWL habitat, and inundation of a significant length (6.7 km) of riparian corridor containing a series of existing pools and rapids, together with native and non-native vegetation.


Vegetation subject to drowning


While the PA addresses the riparian zone (2.4.3 Riparian zone, pp81-82), it is given little or no importance in the DV. The PA recognises the historical riparian zone values of the lower Molonglo, and diminishment through urbanisation, thermal pollution, mining residues, impacts from adjacent land uses and poor riparian management; but notes the potential to regenerate degraded systems through effective land management, water quality improvements and flow management. The PA also notes the values of uncommon flora and fauna species, and occurrence of regionally significant riparian communities including riverine shrub associations; also reedlands, sedgelands and rushes, and a fernland community. The PA contrasts the highly modified riparian and river corridor system upstream of Coppins Crossing, primarily from pastoral uses and burnt pine plantations, while noting some habitat values (raptors and PTWL). The PA also identifies unusually high floristic diversity in the lower Molonglo River corridor downstream of Coppins Crossing, again with highly modified riparian vegetation (only fragments of native vegetation), above Coppins Crossing, noting past plantation and weed issues.


FoG's view is that these statements do not adequately address conservation values/options in the riparian zone. For example:

Landscape values


Landscape values are subjective. FoG suggests that the ACT could invest in natural landscape quality, as opposed to the simplified approach of past planning. Canberrans continuing access to natural landscapes within the urban area (at least to the west) results from restricting developments (e.g. rules on hilltops) and generous provision of compatible sites for urban development adjacent to sensitive sites (such as riparian zones).  


Protection from bushfire


While the DV suggests that the proposed development will reduce the risk from bushfire, there are many ways to manage bushfire risk without going to the extreme of building a lake. These include (DV p16) edge protection zones and fuel management. See comments above about the lack of justification for a lake for bushfire management.


Transport provision


FoG finds the statements about need for new/upgraded roads and public transport extremely disappointing. Canberra’s roads and lack of adequate public transport are major contributors to greenhouse gases. Where are the bold and imaginative new ideas to address transport issues?


Heritage values


FoG's view is that heritage values should be assessed adequately as part of this process: at a landscape not a postcard (site based) scale.