Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Gungahlin Strategic Assessment
Level 2 Telstra House
490 Northbourne Avenue
Dickson ACT 2602



Dear Sir/Madam


Gungahlin Strategic Assessment


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 interest in conservation in the Gungahlin area and provided comments on many of the previous environmental assessments and development proposals for this area.


FOG welcomes the strategic approach to assessing land suitable for development, and has long called for such an approach, in order to avoid consideration of conservation impacts in a piecemeal fashion. We believe that the Gungahlin Strategic Assessment provides the opportunity to achieve the best outcome, balancing conservation with the need for further urban development.


FOG would prefer that no areas containing threatened species or ecological communities be developed, i.e. that higher conservation value areas in Moncrieff, Jacka and Throsby be preserved as well as those in the proposed Biodiversity Plan. However, recognising that requirements for urban development will lead to some areas being lost, the proposed Biodiversity Plan has positives from a conservation perspective in that a number of the impacts on threatened species and ecological communities are avoided. FOG is supportive of many features of the Plan, including the addition of 298 ha to the Mulligan’s Flat–Goorooyarroo Nature Reserve and the resultant improved shape (in terms of reducing edge effects) for this reserve, the creation of nature reserves in Kenny and Kinlyside, the proposed improved connectivity in Box-Gum Woodland through the northern edge of the ACT, and many of the proposed governance measures. On the other hand, impacts on the Golden Sun Moth are significant, and FOG has concerns about the offset package. As well, there are some areas where improvements to the Plan could be made to ensure that the Plan does, in fact, deliver the results it promises. Comments on these follow.


Application of the Precautionary Principle

As a general statement FOG believes that many offset actions are not proven to prevent loss of species or degradation of habitat. These include the 100 m buffer zone which, without evidence, is supposed to provide adequate protection to Superb Parrot nesting trees, whilst also serving a role as a bushfire Outer Asset Protection Zone; the assumption that Golden Sun Moth will naturally move into uninhabited land if it is made more habitable; and the assumption that management for retention of ecological values is compatible with managing land for bushfire mitigation (if Outer Asset Zones are incorporated into areas to be retained for conservation). FOG supports a stronger use of the Precautionary Principle, in that such actions should only be applied after they are proved to not impact MNES.  


Direct offsets

FOG notes in the Conservation Actions section (pages 31-34) of the Biodiversity Plan that a number of the actions (e.g. creation of new reserves) are planned to occur prior to commencement of construction in the nearby urban area. This is in accordance with the general view, also held by FOG, that offsets should be in place prior to the development occurring. However, FOG is concerned that, in fact, decisions about areas to be developed have already been taken and that offset proposals have been made with this in mind. Our reason for thinking this is the indicative land release proposed for 2013-14 (page 12 of the Biodiversity Plan). With so many blocks proposed for release in Throsby, Moncrieff and Kenny within the next 15 months, it is difficult to see how measured consideration of impacts can occur and any direct offsets required be in place in that timeframe.


Calculation of direct offsets

FOG believes that ultimately the Biodiversity Plan is likely to be a stand-alone document, but the criteria used to undertake the analysis for strategic development are not mentioned in the Biodiversity Plan. We recommend that a summary of Chapter 7 of the Assessment Report be included in the Biodiversity Plan, for example as an appendix, to guide the reading of the Biodiversity Plan.


The analysis method used in the Assessment Report shows an improved connectivity for the high quality Box–Gum Woodland areas in the north of Gungahlin. However, given the general nature of the discussion, it is not possible for a group such as FOG to determine, from the information given, whether or not the proposed direct offset areas are reasonable for the losses being incurred. While recognising that the Commonwealth’s EPBC Offset Assessment Guide may not be meant for larger area assessments such as this Strategic Assessment and may not take into account improved connectivity, and without any training in the use of the guide, we attempted to make use of it to gain an idea of whether or not the proposed direct offsets appear reasonable (land set aside plus rehabilitation of reserved land).


One reason for doing this was the inclusion of previously reserved areas (and resources to maintain those areas) in the direct offset package. FOG believes that areas previously set aside for protection of MNES should not be considered in this offset package or used as advance offsets. The Biodiversity Plan (page 44) makes mention of previous advanced avoidance and offset actions. In our view, much of this would constitute offsets for earlier developments in Gungahlin and should not be included in the calculation of offsets for the current development proposals.


In doing this exercise, we made use of the quality ratings for the different MNES provided on pages 52 53 of the Biodiversity Plan. However, we do not understand the derivation of these ratings, nor exactly what they mean. The Plan should provide some information and references about both their meaning and their derivation. As well, the Biodiversity Plan itself gives no indication of the methodology used to calculate direct offsets. Given that the Plan is likely to be used as a stand-alone document, a summary of this methodology should be included in the Plan, at least in an appendix.


Our conclusions following this exercise differs from that in the Assessment Report, possibly because we did not have information about some of the variables input to the EPBC Offsets Assessment Guide, and no doubt were more conservative in our selection of risk and confidence percentages. To FOG it appears that the direct offset areas proposed for the Striped Legless Lizard are reasonable, but that this is not necessarily the case for Box–Gum Woodland or the Golden Sun Moth. More details of our conclusions are in the following sections.


Striped Legless Lizard impacts and offsets

While FOG would prefer that none of the Striped Legless Lizard habitat and population is affected by the proposed development, it accepts the argument that creation of the new reserve in Kenny is offsets for the impact on the Striped Legless Lizard for the proposed developments in North Gungahlin, provided that improvements are made to their habitat in Kenny (as per page 48 of the Biodiversity Plan) and that there is no impact on Mulanggari Nature Reserve (including no Outer Asset Zone intruding into the reserve). However, as stated before, we do not believe that previous actions of shifting Gungahlin town centre and creating Mulanggari Grassland reserve should be considered retrospective offsets. We believe that consideration should be given to rescuing individual lizards before clearance of the land, for either translocation or application of research.


FOG is pleased to see the proposed creation of a reserve in Kenny, which will protect the Striped Legless Lizard population in this area and provide a fourth reserve for this species in the Gungahlin area, as well as protecting some Box–Gum Woodland. However, FOG notes that there is a groundwater discharge area that may be disturbed following development of adjacent areas and associated storm water management, and that impact to this has an Extreme risk rating in the Preliminary Risk Assessment (page 17). FOG’s view is that further investigation of the likely impact on groundwater systems and ways to avoid significant impact to the Box-Gum Woodland in the future reserve needs to occur before urban development proceeds.


Box–Gum Woodland impacts and offsets

FOG is pleased to see that no high quality Box–Gum Woodland will be affected by the proposal, and that a substantial component of the moderate-high quality woodland has also been avoided. Our analysis using the EPBC offset assessment guide indicates that only by including most of the previously reserved areas does this meet offset requirements; however, this may not take into account the improved connectivity and reduced edge effects of the proposals in terms of long term conservation. The addition of the small area of Box–Gum Woodland adjoining Superb Parrot nesting sites in East Throsby would go a long way to allaying our concerns in this area.


FOG is also pleased that the conflict between management for Box–Gum Woodland regeneration and for habitat for grassland depended species such as the Striped Legless Lizard and the Golden Sun Moth is acknowledged and included in the Plan (pages 46-47 of the Biodiversity Plan). On the other hand, FOG notes that there is a recommendation on page 48 of the Biodiversity Plan that stock should be removed from Superb Parrot habitat. Such recommendations should be informed by the reserves management plan to achieve best conservation outcomes. As it is likely that some biomass removal will be required for maintenance of ecological values, it is important that such recommendations are made in the context of whole-of-reserve management (which as one of its goals should include any steps needed to maintain Superb Parrot habitat).


With the indirect impacts of both construction activities and urban living on high quality areas, there are several mitigation actions listed on page 81 of the Biodiversity Plan for the Construction Environment Management Plan. There are a number of other mitigation actions that are also essential, including fencing and training/education of both construction workers and the community. Given the strategic nature of this document, presumably these will emerge at a later stage? Community groups such as FOG would appreciate the opportunity to comment on these to ensure that community concerns are included, in a timeframe that enables them to be actioned effectively.


Golden Sun Moth impacts and offsets

FOG acknowledges that the Plan is avoiding 310.8 ha of Golden Sun Moth habitat in Kinlyside and north Throsby. In terms of the aim of improving Golden Sun Moth habitat in suitable areas, such areas would need to be clearly identified. The Plan lacks information about the location or size of the areas that would be targeted by such an offset, so it is not clear how the offset would lead to no net loss of Golden Sun Moth across the landscape. In fact, the Plan states that the aim is for no net reduction in areas occupied by the Golden Sun Moth for retained and reserved populations, with encouragement of Golden Sun Moth colonisation along the urban fringe. FOG is not aware of any evidence to support the proposal that colonisation of Golden Sun Moth will occur in such uninhabited areas. In other words, there will be a significant loss of Golden Sun Moth from Gungahlin.


Our analysis using the EPBC offset assessment guide indicates that only by including most, if not all, the previously reserved areas does the proposed direct Golden Sun Moth offset meet offset requirements in terms of preserving Golden Sun Moth habitat. Given that some larger populations will be impacted, and that Golden Sun Moth translocation has been the subject of research from earlier offsets, FOG’s view is that there should be further attempts made to minimise net loss of the moth across the landscape. The aim for future developments in Gungahlin should be to attempt translocation of moths from areas that are being developed to areas of suitable habitat in reserves. Such translocation should be one of the offsets for the Golden Sun Moth in this Strategic Assessment. However, the timeframe for release of residential blocks (page 12 of the Biodiversity Plan) appears to preclude this as an action. If they are not to be reserved, areas with reasonable populations of Golden Sun Moth (e.g. in Moncrieff and Taylor) should not be developed until the results of this translocation research are known and have been applied to translocate the populations being lost to suitable reserved habitat successfully.


FOG notes that one of the offsets for the Golden Sun Moth is research into the potential compatibility of bushfire hazard management requirements with Golden Sun Moth habitat requirements. While this information would be useful, FOG has concerns about whether or not it will add to the conservation of the species in Gungahlin due to the long timeframe for research projects to deliver results, lack of resources to implement research results, and the consequences if the research gives a negative result. There needs to be a commitment to preserving Golden Sun Moth habitat along conservation lines until such research is completed and the results known. Otherwise there is the risk of destroying Golden Sun Moth habitat and populations without being able to restore them once there is a better understanding of how to balance the two requirements.


In summary, the proposals in the Biodiversity Plan will result in loss of Golden Sun Moth populations in Gungahlin. There are two direct offsets listed on page 47. The first, that of habitat improvement, is supported, while noting that it may not be effective as it is not clear if Golden Sun Moths will colonise uninhabited areas. The second is a research project, the results of which will not be known in time to be of value in the Gungahlin area. As well, research is an indirect offset rather than a direct offset and, given that the outcome is “Encouragement of Golden Sun Moth colonisation … where appropriate and practicable” and the research results are unknown, this does not, in FOG’s view, constitute a direct offset. A third possibility, that of translocation of some of the impacted Golden Sun Moth populations, has not been raised, presumably because of the uncertainty of a positive result from current research and the long time frames needed to obtain conclusive results and implement them. Overall, the offset package for the Golden Sun Moth is not adequate and will lead to loss of the Moth in Gungahlin.


Indirect offsets

Research projects have been suggested as part of the indirect offset package. As lack of knowledge hampers our attempts to preserve threatened species and ecological communities, FOG in principle supports such projects. However, it does have a few concerns with such projects, some of which have already been touched upon:

In relation to the suggestions that “…this measure may also include research into translocation of golden sun moths” (page 50 of the Biodiversity Plan), such research is already underway and is part of the offset package for development of Forde North (EPBC referral 2010/5439). Inclusion of the same research here implies that either the same offset is being used twice, or that the original amount of funding was insufficient. The first of these is completely inappropriate, the second is an indication that offset research funding is inadequate to achieve the original aim and as such is not an adequate offset if results cannot be guaranteed.



The proposed additions to existing nature reserves and to the Hills Ridges and Buffers area preserve the existing connectivity between high quality endangered Box–Gum Woodland patches in the north of Gungahlin, and allow for connectivity through to similar adjoining areas in New South Wales. However, the proposed reserve in Kenny is essentially isolated, with no identified direct link between the Kenny woodland and that to the north in Goorooyarroo. In FOG’s view there should be a corridor of vegetation such as trees linking the new Kenny reserve to Goorooyarroo Nature Reserve. This will assist in retaining the values of the new Kenny reserve and movement of species such as the Superb Parrot.


Edge effects and bushfire asset zones

FOG notes that consideration will be given to a number of factors that might minimise the impact of the urban development on nature reserves. FOG thinks that these are essential and that all of those listed on page 40 of the Biodiversity Plan should be mandatory in design of the new urban areas, rather than just “considered”.


The Biodiversity Plan (page 39) states that all Inner Asset Protection Zones will be outside reserve and avoided areas, and that the intent is to manage bushfire hazards without disturbing threatened species. However, FOG has concerns about any bushfire Outer Asset Zones being within Nature Reserves or Hills Ridges and Buffers because of the impact of bushfire hazard requirements on conservation values. Bushfire mowing regimes are often incompatible with endangered species habitat requirements – one example is that of the impact of mowing on Striped Legless Lizard habitat off Flemington Road (see page 17 of the Assessment Report). While the intent might be to manage outer asset zones in a manner compatible with the conservation needs of each site, FOG is concerned that in the long term this will not always be adhered to, to the detriment of the endangered species occurring on the site. As already mentioned, the Precautionary Principle needs to apply so that there are no compromises to either bush fire management or to implementation of ecological management, i.e. all Outer Asset Zones need to be outside the areas of conservation value.


In relation to the proposed 100 m buffer for the Superb Parrot breeding sites in Throsby, FOG is not aware of any research proving that this buffer is sufficient to maintain breeding of Superb Parrots in the area in the long term. Until such proof is available, a wider buffer should be maintained. From the Assessment Report (page 105), it appears that the 100 m buffer zone would also include the Outer Asset Zone, and thus be subject to bush fire mitigation actions, as well as other possible edge effects and disturbances. As a Precautionary Principle, the Superb Parrot breeding buffer zone should be managed entirely for conservation of the species, with any other activity such as bush fire mitigation occurring outside this buffer, i.e. a larger area should be set aside from development in the south-eastern end of Throsby than is identified in the Biodiversity Plan.



Existing resources are stretched in terms of maintenance of existing reserves. Indeed using figures of what budget is required to maintain values and relate this to past expenditure (as an offset) does not take into account reality, which, FOG suspects, is that not anything like the budget required to retain values is actually what has been spent in the past. Relying on the vagaries of Government budgeting alone is unlikely to be sufficient – past experience has shown that resources allocated to activities such as weed control are insufficient to maintain reserved areas in an adequate condition. In this we refer to concerns raised by the Commissioner for Sustainability and the Environment in her investigation into management of Canberra Nature Park. This is a problem that is likely to increase over time with more droughts due to climate change and an ever-increasing number of exotic plants likely to become serious weeds in our natural areas. Changes in Government and in Government policy also affect the resources allocated to maintenance activities such as weed control through the general budget process.


On page 25 of the Biodiversity Plan, there is reference to funding of the direct actions to “ensure sufficient seed funding for in-perpetuity management”. However, this does not appear to translate to specific reference to such funding or funding arrangements in the summary of direct and indirect offsets (Tables 4.4 and 4.5), nor in the list of conservation actions that target threatened species and ecological communities (table 4.1). There is reference to the ACT Government funding the Plan Implementation Team for the operational life of the Plan (page 27), and also of “creation of a perpetual fund to continue to enhance environmental management in the ACT following conclusion of the Plan” (page 57), but no specific action listed to be undertaken in this regard. FOG’s view is that funds need to be set aside for management of all offsets in the long term. For example, a special-purpose Trust fund could be created, with the interest earned used for ongoing management. FOG recommends that establishment of this type of long term funding and financial arrangements be added to the list of mandatory offset actions in the Plan.


FOG believes that such seed funding could be used to employ a “Bush Management Team” that would assist reserve managers, conservation volunteers and fire management teams to undertake conservation management. We have attached the proposal developed by FOG to explain how such a team could be employed.


In the discussion of offsets, there is no indication of the level of funding that might be available for both direct offset actions such as rehabilitation work and indirect offset actions such as research projects. Experience on other local offset projects (e.g. at Canberra Airport and the Murrumbidgee to Googong pipeline project) has shown that rehabilitation is costly and needs to be continued for some time, and there is no evidence from these projects yet that rehabilitation is successful on the scale required to offset destruction of existing habitat. The Biodiversity Plan acknowledges the uncertainty in the amount of habitat improvement that might be achieved (page 58), and indicates that this uncertainty will be addressed through the adaptive management process. Unfortunately, one of the most likely reasons for not achieving habitat improvement is insufficient resources to undertake what is required. There needs to be commitment in the Plan for long term funding for both rehabilitation and maintenance of reserved areas.


Another concern to FOG is maintenance of conservation values in those areas currently under rural lease but to come into reserves or Hills, Ridges and Buffers in the future. It is unrealistic to expect lessees with limited time left on their lease to put resources in to maintaining conservation values on their leasehold land. Lessees need support or assistance of some kind (e.g. stewardship) to maintain the values of the areas that will be moving into reserves, e.g. with weed control.



FOG notes that the Plan Implementation Team is to be a multi-agency group but independent of the parent directorates and will be guided by expert input from relevant agencies (page 49 of the Biodiversity Plan). For the Plan to be successful, it is essential that those on the Team have sufficient expertise to deliver the desired conservation outcomes. In particular, expertise in bush regeneration will be needed to deliver the habitat improvement component of the offsets, and the Team should include non-government scientists to ensure it is guided by best ecological advice available. As well, at least the initial management plans and the four year plan review need to be peer reviewed by external referees.


One concern FOG has is of the consequences if the Plan is not fully carried through. From a conservation point of view, this would result in a net loss of multiple threatened species and ecological communities. The section on compliance and enforcement (section 5.4) gives no indication of repercussions if commitments made in the Plan are not achieved.



While FOG sees a number of positive features in the Gungahlin Strategic Assessment papers, there are a number of changes that could be added to the package to help avoid the situation of net loss to the threatened species and ecological communities impacted by the proposal. These are listed above, with particularly significant issues being:

Yours sincerely





Sarah Sharp


18 April 2013


Attachment: Bush Management Team proposal