Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Referral Business Entry Point, EIA Policy Section (EPBC Act)
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
Canberra ACT 2601



Dear Sir/Madam


Land Development Agency/Residential development/Mulligans Flat Road/ACT/Bonner 4 East Extension, Gungahlin Number: 2011/6126


FOG welcomes the opportunity to comment on the proposal to extend the Bonner Stage 2 development. Although the proposed development area is small it does raise some important conservation issues.


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.


It seems that most of Bonner Stage 4 has been offered and accepted as an offset for the Ngunnawal 2C development.  It is to be managed for conservation and added to the Little Mulligans Flat Nature Reserve. A small part on the South West edge would be used for housing.  Between the housing and the conservation area would be an inner asset protection zone which would be 30 metres wide. However, another strip 100 metres wide adjoining the IAPZ would be managed as an outer asset protection zone (OAPZ) for bushfire protection of the adjoining urban area. This would be located within the area already offered as an offset, which was to have been managed as a conservation area. 


In FOG’s view this is a totally inappropriate use of an area already offered and accepted as a conservation offset. Essentially they are taking back the offset and putting it to another (non-conservation) use. For this reason we are opposed to the proposal as it currently stands.


Also, conservation areas should be buffered from nearby urban development.  These buffer zones also could readily be used as asset management zones. But the buffer zone should not be included within the conservation area or Nature Reserve.

Although the area to be put aside for urban development contains two small patches of regenerating box-gum woodland, we are not opposed to development on those grounds.




Conservation areas should be managed for conservation purposes and not as urban asset protection zones. We acknowledge the need for such zones but they should be located outside conservation areas, including Nature Reserves.


Conservation areas should also be buffered from nearby urban development. Such buffer zones could also be managed as asset protection zones


Sincerely yours






John Fitz Gerald



28 September 2011