Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Referral Business Entry Point, EIA Policy Section (EPBC Act)

Approvals and Wildlife Division

Department of the Environment, Water, Heritage and the Arts

GPO Box 787




Dear Madam/Sir


EPBC referral 2008/4175 Crace


I am writing to provide comments by Friends of Grasslands (FoG) on this referral of a proposal to develop a new residential suburb in Gungahlin ACT.


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 and others (e.g. the Conservation Council of the SE Region and Canberra) have followed the development of this proposal, and FoG notes that consultation to date has largely been verbal.


FoG understands that the proposed development may result in the destruction of EEC box gum woodland, and poses threats to areas of EEC natural temperate grassland and the vulnerable striped legless lizard. Although FoG does not oppose the development of Crace, and acknowledges that biodiversity issues have been addressed to some extent, the proposal does not address actual and potential threats to EECs and threatened species adequately, nor does it address ongoing clearing of native vegetation adequately. FoG's view, which it intends to advocate in the proposed (but slow) review of the Nature Conservation Act 1980, is that any removal of quality native vegetation should be offset so that there is no net loss, which is consistent with Australian Government policy.


FoG's comments on the referral follow.


Opportunity to contribute to woodland landscape character. Although the referral does address retention of some habitat (see below) there is an opportunity for suburban landscaping to fit with the character of the grassy woodland (although somewhat degraded) that is going to be largely replaced. For example, FoG understands (from the ecological assessment by Hogg and Nash in April 2008 referring to the concept plan) that 'formal plantings of both eucalypts and oaks' are proposed on an open space corridor between the development and the Barton Highway. With more careful species selection (e.g. local woodland species instead of exotic oaks), such open space areas, together with street trees and other plantings on public land within the suburb, could replace some of the natural values to be destroyed through development.


Commitment to offsetting loss. 'Native rehabilitation' of the proposed hill reserve (6.1ha retaining around 2.2ha of regenerating woodland and other 'semi-natural open space') mentioned as a possible consideration of Stage 2 of the development should be an offsetting requirement for the loss of grassy woodland proposed in Stage 1. Any such restoration should be carefully considered, with input from the ACT Government's grassy woodland specialists, to encourage use of a range of species to ensure both diversity and structure. FoG's view is that it would be appropriate for developers to cover the cost of such 'offsetting' management, given that they are taking the financial benefit for the native vegetation loss, and the new residents would benefit from the environmental quality.


Unexpected regeneration success. The extent of regeneration of grasses and eucalypts on the site in recent years with reduced 'management intensity' has led to the need for review of an earlier ecological assessment. Unfortunately, because of planning processes meanwhile, the extent of development is not really being affected (reduced) to protect more of the now more obvious remnant values. The statement at 5.1(d) that the 'areas of regenerating  ... woodland ... [retained]... will be larger and more diverse than those woodland patches present when the land was withdrawn' is not entirely true; the potential was not apparent, but not yet lost as those areas to be developed will be.


Mitigation measures are not yet specified. Regarding construction of stormwater/sewerage services (to protect regenerating woodland on the eastern edge of the development bordering Gungaderra Nature Reserve), these should include at least: minimal disturbance (e.g. by works vehicle traffic, storage and movement of pipes, management of spoil, temporary drainage); careful line placement (with expert input); and sensitive rehabilitation/revegetation with appropriate local woodland/grassland species, and related measures to prevent weeds being introduced on site (e.g. in landscaping materials) and moving into the reserve. Although the referral defers to this being 'addressed as part of the Stage 2 development', this referral is meant to cover both stages. The deferral is also relevant to mitigation required to protect natural temperate grassland, potential habitat for species such as the striped legless lizard, in the adjoining Gungaderra Nature Reserve. FoG notes that there is no mention (other than of potential weediness in Gungahlin generally, which is not resolved) of managing the future human impacts of the suburb being brought to the edge of the Reserve, e.g. containment of cats.


Wildlife movement. Although the ecological assessment addresses potential corridors and connectivity, the referral does not address them specifically. There is potential to encourage at least some species (e.g. woodland birds) to move through the suburb if the areas retained/rehabilitated, and the open spaces in the suburb, are managed to the standards understood to be required for such movements (e.g. relating to size of patches and distances apart).


FoG would like to think that DEWHA recognises the effort of small groups such as ours to provide comments on proposals such as this within short statutory timeframes, and will consider our comments with a view to improving the likely outcome for the environment and the human community through placing appropriate conditions on development approval under EPBC to protect threatened grassy woodlands and grasslands.

Yours faithfully






Geoff Robertson

Acting President

8 May 2008


cc ACT Commissioner for Sustainability and the Environment

     ACT Conservator of Flora and Fauna

     Limestone Plains Group