Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Eastern Broadacre Consultation
Planning Services Branch
ACT Planning and Land Authority
GPO Box 1908
Canberra ACT 2601


Dear Sir/Madam


Planning the Eastern Broadacre Area– a discussion paper, July 2010


Friends of Grasslands (FOG) is a community group dedicated to the conservation of l grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of grassy ecosystems – both natural temperate grasslands and grassy woodlands such as Yellow Box Red Gum communities, 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 welcomes the opportunity to comment on this Discussion Paper.  We are pleased to see that a broadscale approach has been attempted in the study of future development of the Majura and Jerrabomberra valleys (rather than ten separate and fragmented studies), and that conservation uses are included in this approach.  However, we do not believe that this Discussion Paper has done so effectively because the major focus is on employment opportunities in the valleys (see the opening paragraphs in Sections 1.1 and 1.2 of the Paper).  In particular, the landscape values of the valleys are not properly addressed before moving to a fragmented approach to specific sub-areas.


An important reason for the lack of focus on the landscape values is the unavailability of comprehensive biodiversity mapping of the ACT.  Such data would provide information on the distribution of different ecosystems and habitat types for different types of fauna and flora, particularly for threatened species.  It would also identify important connectivity corridors for these and other species. In FOG’s view this deficiency must be addressed and ACT Planning and Land Authority (ACTPLA) should support the development of such data as it will assist in adequate environmental assessments of land identified for development or conservation.


Lacking this data, we do not believe that ACTPLA and its consultants have taken sufficient account of existing partial sources of information covering these valleys, such as the ACT Government’s Action Plans for threatened ecosystems and species, in particular Action Plans 27 (the ACT Lowland Woodland Conservation Strategy) and 28 (the ACT Lowland Native Grassland Conservation Strategy). For example Figure 6.1 in Action Plan 27 shows a number of important connectivity corridors through the two valleys which do not appear in the work of Hogg and hence not in this Discussion Paper or in Appendix 1 of the Macroplan Report.  Another important document is Action Plan 29 (the ACT Aquatic Species and Riparian Zone Conservation Strategy), which is relevant to the Molonglo river corridor and inflowing creeks such as Woolshed Creek and Jerrabomberra Creek.  These waterways also can be important corridors for wildlife and need to be appropriately planned and managed through clearing and revegetation.


We are concerned that the environment is seen as a constraint on economic development, which if necessary is to be overcome (Section 5.2, p. 25, ‘Wherever possible, future planning of Eastern Broadacre will minimise impact on ecologically sensitive …’), rather than an important objective in its own right.  As the ecosystems and species in the valleys are endangered, the basic principle should be that there is no development that impacts on vulnerable or endangered species habitat or ecosystem communities.  All areas of Yellow Box-Red Gum Grassy Woodland, Natural Temperate Grassland or habitat connectivity should be protected from development and, where appropriate, have immediate conservation action taken to and suitable management applied to prevent any loss of their values.


In our view a good Eastern Broadacre Plan will firstly recognise the key ecological features of the valleys in terms of rural and urban and peri-urban developments, woodland, reserves and other open spaces. This area includes well over half of the ACT’s grassland and grassy habitat and nearly half of the ACT’s lowland natural temperate grassland, much of which is not protected in public land (Nature Reserves) [Action Plan 28, Table 4.2, p. 93], as well as several grassland species that are threatened both nationally and in the ACT. The plan should seek good environmental outcomes for those threatened ecosystems and species, and enhance connectivity corridors between conservation areas through linked open spaces and revegetation where appropriate. Wherever possible, areas of high conservation value should be included in reserves.  Where that is not possible – for example in areas controlled by the Commonwealth – the ACT Government should negotiate for some form of conservation management agreement either with the Commonwealth agency concerned or through the Commonwealth environmental agency.


A good Broadacre Plan would also propose economic activity and infrastructure development that did not impact on high value and sensitive ecosystems.  Instead, the current plan includes proposals that cut through high value and sensitive ecosystems, such as the proposed roads through to Kowen which will reduce some of the best native temperate grassland in the ACT (see Action Plan 28, Table 3.2, p. 48), as well as further fragment the area with resultant impacts on threatened native fauna.  Damage to sensitive areas can also result from adverse activity adjacent to these areas, and such boundary effects need to be avoided.


Similarly we are concerned about the VHST route shown in Figure 8, and the acknowledgement that it has ‘the potential to affect ecologically sensitive areas including important grasslands and threatened species’ (p. 25).  While the Defence Department is unlikely to relinquish its land to allow this route, from a conservation perspective the proposal should not be put forward at all given its impact on such sensitive areas.  Remaining areas of grassy woodland and native temperate grassland in the valleys should be retained and no further clearing should be allowed.  Any infrastructure should go around rather than through such habitat.  We have lost too much already.


The remainder of our comments relate to the areas identified for further study in the Discussion Paper.  Our comments focus on the need to conserve threatened grassy ecosystems and the species found therein.


Area A:


FOG supports the potential nature reserve being formally gazetted as a nature reserve, and recommends that this be done immediately. Connectivity corridors should be maintained and enhanced through conservation agreements with landholders, and through incentives to improve habitat.


Areas B & C:


The many old trees in area B should be retained and natural replacement encouraged.


FOG is strongly opposed to fragmentation of the grasslands within and between areas B and C by the three proposed Kowen roads.  These will reduce the grasslands through their footprint and also fragment the grasslands further, a problem that has already occurred in the northern part of the airport.


We support the proposed grasslands nature reserves to the West (adjacent to Campbell Park and labelled Woolshed Creek in Figure 8 of the Discussion paper).


Areas D & E:


The small population of Rutidosis leptorhynchoides in area E needs to be protected.


As mentioned above, the Molonglo River and Jerrabomberra Creek are important habitat corridors and should be rehabilitated (the Molonglo also runs through area F).


Drainage from proposed development areas into the Jerrabomberra Wetlands (outside the study area) needs to be carefully managed.


Area F:


Action Plan 27, Figure 6.1 identifies an important habitat corridor both north and south of this area.  Any development of this area should make suitable provision to join up these corridors through appropriate revegetation and open space.  The Newline woodland to the north of this area (Defence land which is to be transferred to the ACT Government) forms part of this link and is valuable habitat which should be incorporated into the reserve system once it has been cleared of any dangerous materials.


Area G:


The Discussion Paper notes that ‘parts of the area have high ecological values because of the presence of important lowland grasslands and the habitat they provide for various species, including the Grassland Earless Dragon.’  In our view, parts of this area have been managed badly to date.  Enforceable conservation management agreements need to be negotiated with the landholders.  Uncertainty about the future of such leases gives no incentive to adopt good environmental practices. We support the extension of the Jerrabomberra East Nature Reserve as indicated in Figure 8.


North-south connectivity needs to be provided to link up with the Majura Valley.  It may be appropriate to include the woodland across the ACT/NSW border in such a link.  However, developmental proposals for some of the NSW woodland areas are either being considered (e.g. the recent South Jerrabomberra urban development project submitted for consideration under the Commonwealth EPBC Act)or likely in the future.  While acknowledging problems in addressing issues across different jurisdictions, FOG’s view is that the ecological values of areas on either side of the NSW/ACT border should be considered together, not completely separately, to reduce loss of these endangered communities and take account of all connectivity issues.


Area H:


The old zoo site adjoining Mugga Lane should be incorporated into Callum Brae Nature Reserve.  While it contains a lot of exotic species including pest weeds, some provide valuable habitat for small birds.  Replacement by more appropriate native vegetation should be done gradually so that suitable habitat is maintained.


We support the recommendations from the Southern Broadacre Planning Study to conserve the area of remaining endangered grassland to the north of Callum Brae (south of Narrabundah Lane, i.e. the grassland remaining after the Narrabundah Long Stay Caravan Swap.) and adding this to the Jerrabomberra West Nature Reserve.


Area I:


The Yellow Box Red Gum woodland adjoining the quarry for the present should be managed for its conservation values with a view to adding it to Callum Brae Nature Reserve once the quarry operations cease to be a safety concern.


Area J:


We note that the lands on the western side of Mugga Lane in areas I and J were not included in the environmental assessment by Hogg.  They are important as both yellow box-red gum woodland areas and as connectivity corridors (Action Plan 27, Figure 6.1).  This connectivity role should not be adversely affected by any further development.


FOG is happy to elaborate on any of the points made in this response to the Discussion Paper.


Sincerely yours





Geoff Robertson



28 November 2010