Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Mr Andrew Smith
National Capital Authority
GPO Box 373
CANBERRA ACT 2601
Dear Mr Smith
Draft development Control Plan – Belconnen Naval Transmitting Station
Reference Number: 171/10/0003
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 had a long-standing interest in the Belconnen Naval Transmitting Station (BNTS), which contains both high quality endangered natural temperate grasslands and Box-Gum woodlands and several threatened species, including one that is known only from this site. Thus FOG welcomes the BNTS draft Development Control Plan (DCP) and is very pleased to see that all the areas containing conservation values have been excluded from development (precincts D and E), and acknowledge the inclusion of the eastern Themeda grassland (adjacent to Baldwin Drive) in the conservation areas.
As the major area of precinct D is one of the largest remnants of high quality Danthonia grassland in the ACT, contains a significant population of Synemon plana (Golden Sun Moth) and the endemic Lepidium ginninderrense (Ginninderra Peppercress) FOG is urging that steps be taken immediately to manage this area as a grassland reserve. These steps include allocation of sufficient resources and expertise to manage the area properly for its conservation values, maintenance of the secure fencing, management of kangaroo grazing pressures and weed control. Both provision of sufficient resources to the BNTS land manager, and prevention of overgrazing of the area through pro-active management of kangaroos are of particular importance if the high conservation values of this area are to be retained.
The nature of the residential development has the potential to have a negative impact on the grassland and grassy woodland areas, and there are a number of actions FOG would like to see implemented either in the DCP or in the next stage of development:
- Design the residential developments in Lawson north and south to integrate them with the nature reserve and create adequate buffers so that the conservation areas are not used for moderate to high intensity recreation;
- Design the residential developments so that the conservation areas are not impacted by urban run-off or the spread of weeds from urban plantings or gardens. In this context, perhaps Section 2.6.2 should be strengthened to prevent adverse impacts from waste and storm water run-off into the conservation areas, rather than minimising such impacts, since the definition of “minimise” could be interpreted differently by a developer than by a conservation group;
- Change, in Section 2.7.1f, from “The use of native species” to “The use of native species, particularly those compatible with the conservation values of the nearby grassland reserves” (our point is that species such as Acacia baileyana are native but are considered environmental weeds in the ACT). In particular, plantings close to the conservation areas should be required to be compatible with the values of the reserves, rather than “encouraged” to be so;
- Create bushfire buffer zones totally outside the reserves (see sections 2.7.1k and 2.7.2) because of incompatibility between bushfire management in the inner asset zone and the management needed to conserve high quality grassland sites;
- Plan to provide information for and education of future residents so that they understand the importance of the conservation areas and their role in retaining these areas; and
- Establish the area as a 24-hour cat containment zone, and apply this convention to the entire suburb of Lawson.
FOG would appreciate direct notification of any future Concept Plans or development proposals for the area (section 2.7.3).
14 April 2010