Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....




Lawson EPBC Referral
Land Development Agency
GPO Box 158
Canberra City ACT 2601



Dear Sir/Madam


Re: Lawson South Residential Development

Invitation to comment on the Referral and Preliminary Documentation


FOG welcomes this invitation and wishes to follow up on comments it has made in a series of earlier submissions from 2009 to 2011 about development proposals and land-use planning for Lawson.


Page 14 of the Referral shows three categories of sensible measures proposed to mitigate some impacts of planned development.  FOG repeats its support for the 30 metre wide ecological buffer zone and for cat containment.  It is also completely in agreement with the strategies suggested for planting of native species and regeneration of grassland using locally sourced seed.  FOG was similarly reassured to see the commitment on Referral page 10 to preventing weed invasion (garden escapes) into the adjoining high-quality Natural Temperate Grassland (NTG) on Commonwealth land.


The LDA in its Referral clearly states that development will negatively impact upon environmental values of Lawson South.  FOG cannot accept the several assertions made in the Referral that such impacts are either minor or not significant because an expanse of NTG exists in adjoining Lawson North, principally as (a) the future of that land has not been finalized and (b) that land is controlled by the Commonwealth and not the ACT Government.


FOG is much better aligned to the sound assessments in the Preliminary Documentation (PD) dated Nov 2011, prepared by David Hogg Pty. Ltd and informed by advice to LDA from, among others, the SMEC and Umwelt groups and especially that presented as Appendix C in the Preliminary Documentation package.  As carefully explained in Chapter 8 of the PD, a major offsets program is an excellent way to satisfy at the same time the requirements of the Commonwealth EBPC Act and the objectives of the ACT Government to ensure conservation gains.  FOG is convinced that a carefully crafted offsets package like that laid out in Appendix C has guaranteed and major benefits.


At this point FOG would like to point out that a major difficulty facing us when analysing material posted on the LDA website.  This difficulty was due to two questions remaining open– what is the LDA’s assessment of the PD and how far does it intend to implement the PD strategy?  In the absence of information to the contrary, FOG has to infer that the LDA accepts the propositions detailed in the PD and is prepared to proceed with the strategy to the maximum extent.  FOG bases this inference on two statements in chapter 8 of the PD, that “the offsets package has been developed on behalf of the LDA” and that it “has been endorsed by the ACT Government”.


FOG is highly encouraged by many different facets of the approach to natural asset analysis in the PD, particularly the offsets package, which appears to represent best practice in many regards, including:

Overall, this sensible approach should greatly improve the chances of survival of a number of the rare or threatened species and ecosystems on lands, both near to the Lawson South development and in the direct offset area, which would be to FOG’s great satisfaction.


To conclude, FOG notes how refreshingly positive the Preliminary Documentation appears in comparison to the older EPBC Referral 2010/5549.  FOG looks forward to learning the detailed outcome of the EPBC decision and hopes that the full package can be carried through to reality.  FOG would be delighted if this level of approach to conservation were to become standard for land developments in the ACT.


Sincerely yours





John Fitz Gerald



20 March 2012