Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Commonwealth and Territories Section
Approvals and Wildlife Division

Department of the Sustainability, Environment, Water, Population and Communities
GPO Box 787
Canberra ACT 2601



Dear Madam/Sir


Crawford School extension, ANU

Reference number: 2010/5764


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.


At this project site is a very biodiverse remnant of the critically endangered White-box Yellow-box Blakely’s Red-gum (WYBR) Grassy Woodland ecological community. Further, the endangered Hoary Sunray (Leucochrysum albicans var. tricolor) occurs in remnant R2, the closest Grassy Woodland area to the proposed new building. FOG considers that this proposal requires intervention because it impacts on matters on a listed ecological community and plant species that are matters of national environmental significance (NES), and the referral documentation fails to address adequately their conservation. As well, in our view the proponent has not fulfilled the conditions applying to a previous approval for the development of the Crawford School on this site (EBPC 2007/3665).


Ostensibly the footprint of the proposed extension does not cover the remnant Grassy Woodland. However, FOG is concerned that considerable damage will be done to the Grassy Woodland and the Hoary Sunray population, particularly during the construction process. This concern arises from damage that occurred in these Grassy Woodland remnants when the Crawford School building was originally constructed, in breach of previous approval conditions (EBPC 2007/3665). For instance, during construction of the Crawford School building, the protective fence line was moved a few metres and damage occurred to some of the most floristically diverse sections of Grassy Woodland remnant R2, including parts containing a Hoary Sunray population.


FOG is also concerned about other issues in relation to adherence to the conditions of EPBC 2007/3665.The previous approval resulted in Grassy Woodland habitat previously linked by lower-quality grassland being totally separated by the construction footprint into remnants R1 and R2. The Minister required ANU to “rehabilitate” disturbed areas and lands adjacent to the Crawford School building. Instead, it appears that ANU has sown these areas with exotic species, a number of which have proven invasive of the remaining grassy woodland habitat (including R1 and R2). Specifically ANU was required by EPBC conditions 2007/3665 to:


a)      “Submit for approval ... an Environmental Management Plan” within seven months of construction and then implement the approved plan.


While the ANU Environmental Management Plan 2009-2015 commits to “Restore ecosystems, especially at Old Canberra House Grasslands”, FOG remains concerned about the continuing lack of protection for these high quality remnants. In particular, we understand that the ANU Plan S908/PR/180A and the draft Campus Development Plan still reserve these lands for “major buildings” and that ANU Protection Zones ‘B’ only covers the International Sculpture Park, not the Grassy Woodland remnants. As well, we understand that the draft Campus Master Plan reserves other areas for protection but fails to reserve the Grassy Woodlands, and that a draft Biodiversity Management Plan proposing to reserve the remnants has not been approved by ANU administration.


b)      “Rehabilitate the ... ecological community affected”


As far as FOG is aware, none of the disturbed areas were revegetated with indigenous species, and the rehabilitation was undertaken by short-term contractors, without additional resources for rehabilitation and weed control in the longer term.

c)      “Manage and prevent the encroachment of weeds into all remnants”


It appears that the ANU Grassy Woodland remnants continue to be degraded by weeds like African Lovegrass, Brassica, Chilean Needle Grass, Flatweed, Lamb’s Ear, Plantain, Paspalum, Cape Weed, Clover, Wild Oats and a number of thistle species. FOG understands that weed control has been attempted by the ANU, but that significant progress here has only been possible due to contributions by unpaid volunteers.


In relation to this new referral, FOG makes the following points:


(1)     While the referral suggests that there will be no direct impact on the Grassy Woodland areas and contains mitigation measures for the construction period, considerable emphasis is placed on heritage values and other trees. In this context, the ecologist’s report notes that “although the study area contains the only remaining good quality native vegetation on the ANU site, the conservation value of this Remnant Grassy Woodland has continued to be undervalued and/or ignored.”


(2)     The endangered Hoary Sunray (Leucochrysum albicans var. tricolor) is also present at the northern boundary of vegetation patch R2 as noted in the text of the Ecologists Report. However it does not feature on the map, Figure 3.1 of the Ecologist’s Report. This is important because this area borders the proposed fence line to the construction site. While it appears to be protected in drawings of the Site Establishment and Reinstatement Plans by a kink in the boundary line, it appears to be missed completely in other plans (eg AR PSP 102). FOG therefore considers the referral to be deficient in measures to protect this endangered species.


(3)     Section 4 of the referral document states that “R1-R5 will be rehabilitated to mimic the prevailing mosaic characteristics of the remnant sites”. In FOG’s view this should be extended to rehabilitate the gaps between the five remnants, a project that would require ongoing funding over the five years or so it would take to do so adequately.


(4)     We support the mitigation activities proposed by ANU to protect remnant grasslands R1 and R2 from accidental damage during the project, but would like to add that all fence boundaries should include a buffer zone around the Grassy Woodland areas, with weed incursion along such fencing being actively managed during the entire project.


(5)     Some specific details of the Site Reinstatement Plan might need further consideration, such as the efficacy of using a mulch barrier planted through with envirocells of native species in a remnant grassland situation, and ensuring that species planted match those in the immediately adjacent remnants (e.g. Patches R1 and R2 have no Dianella revoluta but do contain a range of Austrodanthonia species). Local native plant propagators, and possibly the local expertise in the Fenner School and ANU Green, could be engaged to optimise this process.


As a consequence FOG urges the Minister to declare the new referral a controlled action and to ensure that ANU does produce satisfactory outcomes in terms of conserving this biodiverse Grassy Woodland area.


FOG recommends that ANU be required to:


a)      Amend all its campus plans to delineate the remnant Grassy Woodland vegetation identified in the Ecologist’s Report and reserve it from new development;


b)      Enter a Conservation Agreement under the EPBC Act, Part 14 to protect and conserve Grassy Woodland remnants R1-R5 and adjacent lands;


c)      Reconnect Grassy Woodland remnants R1-R5 by restoration of indigenous species over the damaged lands between them;


d)      Commit an additional budget to ANU Gardens and Grounds sufficient to restore and maintain the Grassy Woodland remnants R1-R5 and adjoining lands for a number of years after the development; and


e)      Place interpretive signs outside the original Crawford Building and this extension to explain the importance of the Grassy Woodlands.


Production by ANU of a Public Environment Report is needed to fully address the previous referral conditions and put in place convincing ecological management measures.


Sincerely yours





Geoff Robertson



20 December 2010