Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Strategic Assessment – Molonglo and North Weston
Planning Services Branch
ACT Planning and Land Authority
GPO Box 1908
Canberra ACT 2601


Dear Sir/Madam


Molonglo Valley Plan for Protection of Matters of National Environmental Significance:
Framework and Draft Strategic Assessment


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 been concerned about conservation issues in the Molonglo Valley for some time, and supports a coordinated strategic approach to assessment of the area.  However, we are still concerned that piecemeal assessment of the whole Valley is continuing, with the omission of the stormwater and recreation strategies from these Assessment documents.  These strategies are needed to control activities that could have a potentially significant impact on the ecological values in the Valley, both in the proposed urban development area and beyond.  Without inclusion of these issues in the Strategic Assessment Report, FOG is able to give at best, only interim comments, based on a stormwater scenario with the lowest impact option being adopted (as described on Page 27, Strategic Assessment Report).  If any but the least impact options are put up in future, the impacts will need to be reassessed in detail.


FOG notes (on p5 of the Draft Plan) that the final NES Plan will require a more comprehensive description of the proposed commitments, but that both the documents for comment and the verbal advice at information sessions suggest that this draft plan is the final opportunity the public will have to comment on these matters.  As already stated for stormwater and recreation strategies, this is a major concern. It is also of concern in relation to offsets for environmental losses, since the current documents lack detail in this area.  Box-Gum Woodland is critically endangered, so any loss of high quality areas is to be avoided.  It is premature, in FOG’s opinion, to be finalising these documents before the ACT Government has decided and publicly released its policy on environmental offsets, and before offset details for the Molonglo Valley development have been released. Environmental offsets should be “like for like” (p135, Strategic Assessment Report or Strategic Assessment Report), yet there is insufficient information to be able to determine how much critically endangered Box-Gum Woodland will be lost.  FOG recommends that the Plan not be finalised nor forwarded to the Commonwealth Minister until there has been public consultation on both the ACT Government’s offset policy and the specific offsets being offered in the Molonglo Valley.


FOG notes that the lake and dam wall options proposed in the draft Structure Plan have not been included in the final Structure Plan (p24 and 27, Strategic Assessment Report), also that the relevant decision is still pending.  FOG does not support the inclusion of both lake and dam wall options in any Molonglo Valley developments proposed into the future.  Again FOG considers it premature to be finalising these documents until such time as the ACT Government has decided and released into the public domain its long-term stormwater strategy for this Valley.


FOG is also very concerned about the potential impact of the two bridge crossings.  The north-south bridge, in particular, seems to go through one of the wider zones of high quality Aprasia parapulchella (Pink-tailed Worm Lizard) habitat along that part of the river, and also cuts a recorded population of the lizard into two.  Both bridges will have a direct impact on the Pink-tailed Worm Lizard as they go through habitat supporting the lizard (ps 49 and 95, Strategic Assessment Report).  Indirect impacts will be higher, both during construction and in the long term. Even if the bridges are designed to minimise their footprint and mitigate their effects on both the Pink-tailed Worm Lizard and Box-Gum Woodland, they will still have a significant effects on the Pink-tailed Worm Lizard.  There is insufficient information available to indicate why the bridges must be located in these sites rather than in other sites where the impact on the Pink-tailed Worm Lizard would be less significant.  With this in mind, FOG recommends that the location of the bridges should be changed.


No specific offsets for the fragmentation of the Box-Gum Woodland in patch K have been identified in the Strategic Assessment Report, although an offset for the impact on the Pink-tailed Worm Lizard is proposed (p5, Strategic Assessment Report).  Information about the genetics of the Pink-tailed Worm Lizard (the proposed indirect offset) is really needed prior to development occurring (in particular prior to construction of the two bridges).  In addition, such information is not useful if insufficient resources are available to implement any management strategies arising out of this research.  Consequently, FOG does not consider this offset sufficient and recommends that, if the bridge location is not changed and offsets are needed, it be extended in two ways.  The first is to implement all possible mitigation measures during the construction process, following up with high quality rehabilitation post-construction.  The second is to include provision of resources for management strategies until a measurable outcome such as increases in the remaining population of Pink-tailed Worm Lizard is achieved.  Withoutthese, there will be a net loss in this vulnerable species.


FOG strongly supports changing the status of the river corridor downstream from Coombs (action 7) to protect the quality Pink-tailed Worm Lizard habitat there.  This action is essential and preferably will be implemented before development commences.  Likewise, FOG supports the proposed variation to the Territory Plan to protect the Box-Gum Woodlands in West Molonglo from development (action 16).


FOG notes that community facilities such as walking trails and recreation areas are proposed within the East Molonglo river corridor, together with possible further extension to the trunk sewer, and that the details of these have not yet been defined (p26, Strategic Assessment Report).  As indicated in the Strategic Assessment Report (p94), the direct and indirect impact of these facilities on the Pink-tailed Worm Lizard is unknown but in FOG’s view could be substantial and lead to significant loss of both Pink-tailed Worm Lizard population and habitat.  In other cases, where residential and commercial centres are located adjacent to high quality bushland, the bushland has become more degraded over time.


FOG does not support the recommendation for a buffer zone that is just 20m wide around all high quality Pink-tailed Worm Lizard habitat – wider zones are recommended for better protection.  Preferably, the entire riparian area should be fenced off, with tracks to the river at selected, low impact sites. It is essential that all Pink-tailed Worm Lizard habitat (and surrounding buffer zones) be fenced, including corridors between populations, and that walking trails and significant recreational facilities are located away from and upslope from these fenced areas.  Including nearby moderate quality habitat inside such fences may mitigate this problem and will also allow for future expansion of the Pink-tailed Worm Lizard population.  Siting the more active recreational facilities in the urban area rather than in the river corridor may also lessen the impact on this vulnerable species.  FOG is concerned about the lack of detail provided in the Structure Plan about the management regime to be used to ensure specific issues in relation to Box-Gum Woodland and Pink-tailed Worm Lizard habitat within the river corridor are addressed, and recommends that more detail be provided for public comment before these documents are finalised.


FOG has already, in a recent submission about the trunk sewer in Coombs/Wright, drawn attention to concerns about the impact of this on Pink-tailed Worm Lizard habitat, particularly in relation to sediment control and the steepness of some of the slopes running down to the Molonglo.  It is essential that action 6 is fully enacted and that there is ongoing independent monitoring to ensure compliance with the measures proposed by Osborne (2009).  Monitoring for and management of weeds introduced by these construction activities is another issue that needs to be addressed specifically.


FOG is very concerned about the loss of patch D.  This is one of the best areas of critically endangered Box-Gum Woodland within East Molonglo, with a high floristic diversity, high tree hollow density and connectivity to the river corridor.  Not only will 60% be lost to the major group centre, leaving a much smaller and consequently more vulnerable fragment, but the remaining area adjacent to this centre will be vulnerable to damage both during and after development.  In addition, no offsets for the loss of such a valuable area have been specifically identified.  FOG opposes development of patch D and proposes that the group centre be located elsewhere.  The Strategic Assessment Report (p25) indicates that the “lakeside” site was considered but we could find no indication of where that was, nor of how strong the advantages for the “hillside” site were and how these truly justify destroying such a good area of endangered Box-Gum Woodland.


If the decision is made to develop patch D, the offsets offered by the ACT government need to be significant and the remainder of the area should be reserved so that it is excluded from future development.  Fencing around the remaining area is essential to protect it from damage, together with provision of information to future residents about the value of the area. 


As patch J is of reasonable quality and is immediately adjacent to the Canberra International Arboretum, FOG suggests that this area be added to the Arboretum, to be managed by the Southern Tablelands Ecosystems Park (STEP) as part of the native component of the Arboretum.  The same consideration should be given to patch N.


Buffer zones for Kama Reserve should be outside the reserve area and at least that needed for the outer asset area, i.e. 300m (p28, Strategic Assessment Report), rather than the 200m proposed (p118).  A similar 300m buffer should apply to other conservation areas.  Weeds need to be managed in all such buffer zones, with regeneration of the buffers (within the constraints of bushfire management) if possible.  There needs to be ongoing monitoring of the quality of Kama Reserve to identify impacts from the urban areas and to mitigate their effects early.


The spread of weeds from the initial development and later from urban gardens and mowing of urban open spaces and buffer areas is a potentially serious impact to all of the nearby reserves and conservation areas.  For example, the Strategic Assessment Report (p99) notes that impacts on the Natural Temperate Grassland in Kama Reserve are possible without appropriate management and protection of the Reserve.  The presence of weeds often has a large impact on Pink-tailed Worm Lizard populations.  There are also some serious weed problems in the degraded part of the river corridor.  If deterioration of the high conservation areas is to be prevented, sufficient resources need to be made available to manage all reserves, to remove existing weeds from the river corridor and reserve areas, and to manage weed incursions over the long term.  Given the current problems in resourcing weed control in other parts of the ACT, new resources will be needed to cover the Molonglo Valley.


FOG supports the mitigation and management measures in the Strategic Assessment Report (summarised in Appendix I), while recommending that the best way to minimise some of the impacts is to change the location of some features, such as the north-south bridge.  In particular, funding for development and implementation of plans of management (actions 9 and 11) needs to be adequate to achieve good permanent conservation results.   Development and implementation of a rehabilitation plan (action 5) should be assisted by those with expertise in bush regeneration and in Pink-tailed Worm Lizard management.  The principle of minimum impact from construction and ongoing urban activities should be overriding – this should reduce both costs of and need for rehabilitation as well as maximising environment quality and biodiversity surrounding this new development.


FOG recommends that Plans of Management for the river corridor and reserve areas are made before development of the Molonglo Valley commences.  There needs to be a clear understanding by developers of the requirements (in terms of siting facilities) of the conservation areas before infrastructure is locked into place.  Again, sufficient resources need to be committed on an ongoing basis (and in particular during the course of the development activities) to implement the Plans of Management, and to effective monitorcompliance.


Sincerely yours





Geoff Robertson


22 April 2010