Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Mr Gary Rake
Chief Executive
National Capital Authority
GPO Box 373
Canberra ACT 2601



Dear Mr Rake


Submission on options for new diplomatic estates




I write to submit Friends of Grasslands (FOG) response to the National Capital Authority (NCA)’s request for community views on options for new diplomatic estates.  These points reinforce those from our meeting with you on the 13th September 2011.


The NCA has proposed three sites as options: a) south west of Stirling Ridge, b) near the Yarralumla brickworks, and c) adjacent to the Federal Golf Course. In this submission we outline important aspects for the NCA’s assessments of the suitability of these locations and our views about the options put forward by the NCA.


FOG is a non-government organization established to promote the conservation of grassy ecosystems in the ACT and southern NSW through education, field work and advocacy. Our partnership agreement with the NCA has seen FOG undertake conservation work on national capital lands since 2009.


Matters for assessment


Our interest in the three sites identified by the NCA as options for new diplomatic estates is that they contain habitat delineated by ACT authorities for nationally threatened grassland species and ecological communities that enjoy protection under the Commonwealth Environment Protection and Biodiversity Conservation (EPBC) Act. It is our view that habitats of such threatened biota should be excluded from consideration for development of diplomatic estates.


Recommendation 1: The NCA should delineate areas of habitat for species and ecological communities identified as threatened under ACT and Commonwealth legislation and rule these areas out of further consideration for development as diplomatic estates.


A number of the threatened species that occur in these ecosystems are only identifiable on a seasonal basis (such as when they flower) or are migratory (such as the endangered woodland birds). Consequently a credible environmental assessment requires research by recognized botanical and zoological experts in grassy ecosystem at the right times of year, generally late spring and early summer in this case. A credible assessment will provide greater certainty by avoiding unexpected barriers to development, such as third party legal action to invalidate approvals under the EPBC Act.  A credible assessment will meet with FOG’s support.


Recommendation 2: The NCA recruit recognized botanical and zoological experts in grassy ecosystems to assess the presence or absence of threatened species and ecological communities on the three sites and delineate their habitats. In terms of species these assessments should give particular attention to the: Button Wrinklewort, Golden Sun Moth, threatened lizard species, endangered woodland bird species and hollow-dwelling wildlife.


We also consider that only sites where development enjoys substantial community support should be considered further for diplomatic estate purposes.


Recommendation 3: The NCA exclude further consideration of sites where the local community opposes development.


We now offer our views on the options proposed by the NCA.


a)      South west of Stirling Ridge


Most of Stirling Park is of national biodiversity significance (ACT Government 2004 & 2005) and should be permanently reserved for nature conservation. The area identified by the NCA south west of Stirling Ridge is of lower biodiversity value. We do not consider that this site should be further assessed, but if it were we think it should be further constrained by a botanical survey to delineate the edge of Button Wrinklewort and grassy woodland habitat. The necessary buffer zone required for management of fire, weeds, recreation and security of possible developments must be outside the high conservation value habitat.


FOG considers that there are other reasons why this land should not be developed. The identified site is too close to the Lake and will detract from landscape values and recreational use of the area. It risks fragmenting the habitat of the Eastern Grey Kangaroo population in Stirling Park, leading to road accidents and other management problems. FOG is concerned at the potential for diplomatic missions to be a source of weed infestation from inappropriate garden plantings into the high conservation value habitat. We note that the site is smaller than the area the NCA requires for diplomatic missions. Further, local residents oppose this development.


Recommendation 4: The Stirling Ridge site is not further considered for development.


b)      Near the Yarralumla brickworks


The proposed Yarralumla brickworks site is large. A small portion of it, 1.5 hectares known as the Dudley Street grasslands, is recognized as significant habitat for the critically endangered Golden Sun Moth and two types of temperate grassland ecological communities (ACT Government 2005). FOG proposes that this minor portion of the site, plus a buffer zone sufficient to manage fire, weeds and recreational access, be excluded from further assessment. FOG also notes that the Yarralumla Residents’ Association has expressed support for appropriate and well-planned development of the remainder of the identified site.


Recommendation 5: The Yarralumla brickworks site is further considered for development with the exclusion of the Dudley Street grasslands plus an appropriate buffer zone.


c)      Adjacent to the Federal Golf Course


The lands adjacent to the Federal Golf Course are Yellow-Box Red-Gum Grassy Woodland of national biodiversity significance (ACT Government 2004) and deserve to be permanently reserved for nature conservation. This site should not be further assessed for development. There is strong community opposition to development of this site.


Recommendation 6: The Federal Golf Course site is not further considered for development.


In terms of the NCA’s request for alternative options, FOG understands that the area known as the Curtin horse paddocks has low biodiversity values and proposes that these be assessed in place of the areas south west of Stirling Ridge and adjacent to the Federal Golf Course.


Yours sincerely






John Fitz Gerald



13 September 2011





ACT Government, 2004. Woodlands for wildlife: ACT lowland woodland conservation strategy, Canberra, Environment ACT.


ACT Government, 2005. A vision splendid of the grassy plains extended: ACT lowland native grassland conservation strategy, Canberra, Arts, Heritage and Environment.