Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Mr Andrew Smith
Chief Planner
National Capital Authority
GPO Box 373
Canberra    ACT    2601



Dear Mr Smith


Draft Development Control Plan – Belconnen Naval Transmitting Station

Reference Number: 12/09


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 members include professional scientists, landowners, land managers and interested members of the public.


FOG has had a long-standing interest in the Belconnen Naval Transmitting Station (BNTS), and provided comments on the current Development Control Plan (DCP) (171/10/0003) in April 2009. In reviewing the draft DCP 12/09, FOG notes that the changes to the previous DCP are in identifying areas that may be utilised as an Asset Protection Zone for the purposes of bushfire protection activities. As stated in its submission of 14 April 2009, FOG believes that bushfire buffer zones should be totally outside reserves and high quality conservation areas such as this site. For this reason FOG opposes the proposed changes to the DCP.


If, despite this view, the changes go ahead, FOG thinks that the wording is inadequate. The wording as is does not distinguish between Inner and Outer Asset Zones and, as such, actually allows Inner Asset Zones to impinge upon the high quality conservation areas in precinct D. The wording also lacks any requirement for a developer to comply with the Commonwealth’s requirements under the EPBC Act for monitoring and management of that part of the Outer Asset Zone occurring within the high conservation areas. The wording of any such changes that are made should limit the impingement of the asset zone to outer asset zone only, specifically exclude its use as an inner asset zone, and specify compliance with the Commonwealth’s conditions for these areas.


Another concern FOG has in relation to asset protection zones is the area that will be needed for this purpose around any residential development in precincts A and B. If, in the future, outer asset zones for these precincts are added and extend into the neighbouring precincts, then most of precinct D will in fact be an outer asset zone and managed for bushfires rather than for conservation.


As far as FOG is aware, bushfire management in outer asset zones that intrude into nature reserves takes precedence over and is not always compatible with conservation management. For this reason FOG strongly objects to any asset protection zone within conservation areas, or to any development that would require the imposition of an asset protection zone within such areas.


Sincerely yours





John Fitz Gerald


28 November 2012