Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Land Development Agency
TransACT House
470 Northbourne Avenue
Dickson ACT 2602


Dear Sir/Madam

The Canberra Brickworks & Environs Planning and Development Strategy

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 a number of concerns about the Strategy. Of particular concern is the disregard shown by the ACT Government towards potential impacts on Matters of National Environmental Significance (MNES) – Natural Temperate Grassland (NTG) and Golden Sun Moth (GSM) – should the Strategy be implemented. We believe, that while more ecological studies have been undertaken since the original 2013 Master Plan was released, there has been a blatant disregard of the matters raised in these ecological studies, and that, if the Strategy is fulfilled, it will lead to total destruction of the existing natural values, i.e. endangered Natural Temperate Grassland and critically endangered Golden Sun Moth populations and habitat.

In commenting on this Strategy, FOG notes that the initial development appears to centre around the Canberra Brickworks area but that the Master Plan and Strategy provide information about future development involving the entire study area over the next 8 years.

1.    Natural values

The area considered in the Master Plan that supports Natural Temperate Grassland includes an NTG site identified by the Commissioner for Sustainability and the Environment (CSE) in her 2009 Report on ACT Lowland Native Grassland Investigation: CC08 Dudley Street. A Conservation Category 2 site (a complementary conservation site), Dudley St provides habitat for a population of critically endangered GSM. It was also included in Dr Hodgkinson’s 2014 report to the CSE, Condition of selected Natural Temperate Grassland sites in urban and peri-urban Canberra. In this report, Dr Hodgkinson noted that, while previously the site was approaching a critical threshold because of close and frequent mowing, this threat has now been reduced by raising mowing height and avoiding mowing during the growing and reproduction season for the native plant species present. He also noted that there were two critical thresholds being approached at the site from the threatening processes of weed invasion and soil seed attrition.

The Ecological Assessment Report for the Strategy identified 1.3 ha of NTG within the proposed development footprint, describing the quality as relatively diverse with moderate to high floristic value scores. The report identified two rare/uncommon plants – Swainsona sericea which is listed as a vulnerable species in NSW, and Dianella longifolia which listed as rare on Canberra Nature Map. While the Ecological Assessment also noted some problems with the current management regime in terms of conserving the area’s natural values, the study concluded that the decline in quality since previous studies was not considered substantial.

Approximately 2.5 ha of GSM habitat occurs scattered within the potential development area, excluding habitat identified in 2012 by Rowell that has already been removed by recent road works. Previous studies relating to GSM within the ACT indicate that the moth itself and GSM habitat is located along the road corridors adjoining the east and west of the Brickworks study area, i.e. from slightly west of Hopetoun Circuit to Lady Denman Drive, and further northwest to the Molonglo River (Yarralumla Horse Paddocks). It is feasible to suggest the GSM habitat contained within the study site is part of a larger albeit fragmented habitat area, the removal of which may impact on the movement of the species and therefore the future viability of GSM in Yarralumla.

2.    Consideration of Natural Values within the Strategy

The Strategy does not include appropriate recognition of the importance of the ecological values of the Brickworks study area in relation to these MNES. There are no references to these within the Brickworks Conservation Development Strategy – this Strategy focusses on conservation of the historic site (the Brickworks), but completely ignores conservation of the natural values of the project area.

The Ecological Assessment recommends management of identified areas of habitat retained as open space within the future urban area. The Strategy itself states that “The approach is to establish a high quality, contemporary landscape character … while maximizing conservation and heritage. Approximately 55% of the proposed development site area is public realm” (page 23). The Master Plan indicates, however, that much of the areas of NTG and GSM habitat will be destroyed for residential development. The NTG area adjacent to the Uniting Church is shown as treed in the Master Plan, becoming Denman Park and described on page 24 of the Strategy as “Open grass lawns with scattered trees surrounded by a natural landscape buffer”, i.e. no mention of any attempt to retain the natural habitat and certainly not the NTG area being retained and surrounded by a buffer to minimise urban impacts. The remainder of the NTG area appears to be completely destroyed and replaced by urban dwellings in the Strategy.

FOG can only conclude from the documents presented that the intention is to ignore the conservation values of the site and to completely destroy any NTG and GSM populations there. There appears to have been no account taken of the recommendation in the Ecological Assessment, i.e. “Management of identified areas of habitat to be retained as open space within the future urban area is recommended to be reviewed in light of the findings of this report, to promote the long term viability of golden sun moth”. Nor is there any provision to address the management issues that will result in a high conservation area being immediately adjacent to urban development, e.g. by provision of a buffer zone.

In this context, on page 7 the Strategy indicates that the development is consistent with ACT Planning Strategy Value the land and natural resources of the region by working collaboratively to manage urban growth, ensure connectivity and continuity in the natural systems and conserve, where appropriate, agriculturally productive land because it “Connects development in study area with surrounding open space and green corridors in Yarralumla, Deakin and Curtin”. In FOG’s view destroying NTG and replacing it with urban treed parks and buildings does not provide any connectivity or continuity with natural systems or show any value or concern for the land and natural resources of the region – this statement should be completely removed from the Strategy if it remains in its current form.

FOG is particularly concerned about the brief section on ecology (section 4.9). This section acknowledges that the development will have a significant impact on MNES under the Commonwealth’s EPBC Act (although there is no acknowledgement of impacts under the ACT’s Nature Conservation Act), and mentions the necessary preparation of a referral under this Act. The discussion then proposes possible offset measures without mentioning avoidance or mitigation measures. Raising offsets at this stage of the process begs the question of whether an implicit decision has been made to develop the site already, although the appropriate referrals and decision process under the EPBC Act are still to come.

3.    Offset considerations

In FOG’s view, offsets should only be considered where a proposed development is completely unavoidable, e.g. essential urban infrastructure. The proposal in this case is to replace areas with conservation values with housing and an urban park, neither of which could be considered essential nor unavoidable. With regard to the proposed offsets, “contributing to the improvement of existing high-quality natural temperate grassland and golden sun moth habitat, or providing financial support to a number of conservation activities presently under operation”, we have no surety that they will result in no net loss (the aim of offsets) of NTG or GSM across the ACT. Rather they sound like an attempt to “buy off” conservation issues.

With regard to the timeframe proposed for this development, it appears that some components of the proposed destruction of the NTG area and GSM habitat are slated to occur in stage 1 (3 to 5 years) and the remainder in stage 2 (6 to 8 years) (pages 37-38 of the Strategy). There is no indication of when MNES might be considered. FOG is concerned that the NTG area will be neglected or poorly managed, so that when it is time to assess the quality of the site, its values have deteriorated and it will be easier to justify its destruction under both Acts.


As we pointed out in our previous submission on the Strategy (8 July 2014), recommendation 3 in Dr Hodgkinson’s report (page 3) states: “These grasslands [NTG] are now at sub-marginal levels in the ACT and there should be no offsets of this threatened community in land development.” FOG’s view is that the NTG area and GSM habitat should not be developed and should be provided with an adequate buffer to mitigate against nearby urban impacts, as well as the improved management recommended by Dr Hodgkinson.

Yours sincerely


Sarah Sharp

20 March 2015