Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Mr. David Rhind
Commonwealth and Territories Section
Environment Assessment Branch
Department of the Environment, Water Heritage and the Arts
PO Box 787 Canberra ACT 2600
02 6274 2611



Dear Mr Rhind


ACTPLA development in the suburb of Coombs and Wright, Molonglo Valley, ACT

Reference Numbers: 2009/5041 and 2009/5050


Friends of Grasslands (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 the 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 reviewed the submissions by ACTPLA on the proposed development of the suburbs of Wright and Coombs. It has found the documents provided with the submission very valuable in coming to its assessment.


The Pink-tailed Worm Lizard (PTWL) has been listed as vulnerable under both the Environment Protection and Biodiversity ACT (EPBC Act) and the ACT Nature Conservation Act. The PTWL occurs in the Molonglo Valley on the outskirts of the area marked for Coombs and, to a lesser extent, Wright, but ACTPLA submitted that neither suburb (nor the proposed trunk sewer) is a direct threat to the Pink-tailed Worm Lizard (PTWL) habitat. The submission acknowledged that the development poses significant threats to the PTWL through processes such as removal of rocks, invasion of weeds and modification of habitat through tree planting, and recognised that a number of actions needed to be undertaken to secure PTWL habitat. Those actions listed, which FOG strongly supports, included buffers between the urban area (and trunk sewer) and the habitat (the submission proposed a 20m plus road barrier), cat containment, conservation management for the area, minimization of pedestrian and vehicle traffic through the area, and fencing.


The submission made reference to these actions or principles being included in the riparian management strategy and (ultimately) the formal plan of management documents. However, the submission does not give a timeframe for preparing these documents, nor a commitment to an implementation plan, nor is any funding source mentioned. In FOG’s view, neither development should proceed until there is a much stronger commitment to actual PTWL conservation.


Sincerely yours




Geoff Robertson



2 September 2009