Friends of Grasslands

supporting native grassy ecosystems

PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Applications Secretariat
ACT Planning and Land Authority
PO Box 365
Mitchell†† ACT†† 2911


Dear Sir/Madam


Submission on Development Application 201120676, Block 1171 Weston Creek (suburb of Coombs)


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, but its membership base encompasses people from within all of south-eastern Australia. Its more than 200 members include professional scientists, landowners, land managers and interested members of the public.


FOG welcomes the opportunity to respond to the Development Application. However, it is with some frustration and concern that Friends of Grasslandsí previous comments on this development have not been taken into account in the current application. Generally, our concerns relate to the lack of the strategic and correlating process that we believe should be undertaken, to provide details on the management of recreation, bushfire hazard and conservation within the riparian zone in relation to Block 1171 proposed development. Specifically, our concerns relate to the lack of inclusion of recommendations provided previously by Friends of Grasslands in this development.


In the context of the above concerns, therefore, we submit the following comments.


Bushfire Risk Assessment Report


We welcome the inclusion of the Bushfire Risk Assessment Report with this development application, particularly as no information on bushfire risk has been previously been made publicly available. While generally we support the reportís recommendations, we note with concern the following:


a)††††† The assumption that it is acceptable for the whole of the Outer Asset Zone (OAZ) to be within the riparian corridor, extending over the other side of the river in some areas. FOG does not support the OAZ being within the river corridor. FOG does not believe that bushfire mitigation works will be able to be undertaken within the riparian corridor in such a way that conservation values will be retained (recognising as stated in the report that grassland does require biomass management to retain values). As stated on many occasions, FOG believes that intensive bushfire mitigation works will compromise conservation values, including reduction in habitat values for the Pink-tailed Worm Lizard, general habitat disturbance and increased weed invasion. We do not support using stock grazing along the corridor to reduce biomass. We believe that in this location grazing will reduce water quality, spread weeds, create tracks which will become recreation tracks, and increase erosion.


b)††††† FOG disagrees with the recommendation in the report that the riparian area does not become a reserve. While no reasons for this lack of support are given, we assume it is because the authors of the Bushfire Risk Assessment Report believe managing the riparian corridor as a nature reserve would compromise bushfire management actions. FOG fully supports the establishment of a nature reserve along the entire length of the Lower Molonglo Corridor (see below).


Urban open space within Coombs


There is a lack of detail on how open spaces within the suburb of Coombs and in the inner asset zone will be used to reduce inappropriate recreation within the river corridor. We would like to see details of planning for active recreational activities, including dog exercise areas, bicycle paths and active play areas for children within the inner asset zone and within other urban open space.


It is with some concern that we note that there are 27 large blocks that are being planned to be developed on the northern peninsular in Coombs. While undoubtedly these will provide good return for money for the ACT Government, we believe that such an area would be better used as open space, allowing all members of the public to enjoy the views, undertake active recreation, provide a buffer zone to the riparian corridor and provide an adequate fire-fighting edge on flat land rather than the extremely steep slopes of the river corridor in this location. We are very concerned that the fire danger to residents within this area is very high.


Planting list


The species identified for planting within the suburb of Coombs in urban parks and in the streets are generally supported, but they should not be planted in the buffer of the river corridor, including within the inner asset zone on the edge of the suburb. While we understand that the Chinese Pistachio is a very attractive small tree, we have particular concerns that seeds are spread by birds, and that there is significant suckering as well. We recommend limited use of this species. Both Quercus coccinea and Ulmus parvifolia should be planted away from watercourses. All plants within the suburb should be chosen on the basis that they have low flammability.


We recommend that consideration be given to species used for grassing the inner asset zone that are green in summer and require less mowing. Annual grass invasion will need to be controlled, as will African Lovegrass, both of which provide significant fuel in summer.


Molonglo River Nature Reserve


FOG supports the establishment of a reserve in the Lower Molonglo River Corridor. We believe that a Management Plan should be produced before any residents move into the suburbs adjacent to the river corridor to guide and direct revegetation, weed control, development of tracks and trails, protection of native habitat, utilisation by residents and bushfire mitigation actions.


Resources will be required to ensure there are adequate numbers of rangers to patrol and maintain the river corridor and provide education to the public. A Parkcare group should be established as soon as possible to involve the local residents. Bush on the Boundary (Molonglo) should be consulted and involved in the planning process.


Resources will also be required to establish monitoring of the values in the corridor. Monitoring should be established before any changes occur, and should include monitoring of threatened species, flora and fauna habitat diversity, landscape function and weed invasion. The resources and processes required to remediate loss of diversity should be identified up front.




FPG believes that the ACT Government is pushing too hard to develop as much land as possible within the proximity of the Molonglo River, and that this amount of land being developed will inevitably lead to degradation of the corridorís ecological values, or if not, to enormous resource requirements in the long term to maintain values in the corridor.† We believe that the residential boundary should be pulled back to provide an adequate buffer to the corridor which will mitigate against the need to undertake high intensity bushfire management actions in the riparian corridor, protect habitat and provide for a range of high intensity recreation activities outside the corridor.

Sincerely yours



John Fitz Gerald



30 October 2011