Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Chief Planner
National Capital Authority
GPO Box 373
Canberra ACT 2601


Dear Sir/Madam

National Capital Plan draft amendment 86 – Revised National Capital Plan

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 welcomes this further opportunity to comment on proposed changes to the National Capital Plan.

Land use policy for the Commonwealth Scientific and Industrial Research Organisation (CSIRO), Ginninderra

The document summarising the proposed changes to the National Capital Plan Exposure Draft, includes changes to the land use policy for the CSIRO's site at Ginninderra from 'Hills, Ridges and Buffer Spaces' to 'Urban Areas'. This change is expressed in the ‘General Policy Plan Metropolitan Canberra’ (Figure 2 in the revised National Capital Plan, pages 23 and 27).1

It is FOG’s understanding that this land will remain national land and that in due course a precinct code will be developed for the site which will further refine the permitted land uses for the site. FOG is concerned that a blanket change in land use may adversely affect areas of remnant box gum grassy woodland and scattered trees which may have high conservation values. Without an environmental assessment it is not possible to assess these potential values. The areas of concern are parts of Blocks 1630 and 1609, Belconnen. FOG’s view is that until an environmental assessment is done, parts of Blocks 1630 and 1609, Belconnen should remain ‘Hills, Ridges and Buffer Spaces’. An environmental assessment would inform the development of a precinct code for the site.

Any environmental assessment should examine the connectivity values these areas may have with grassland and grassy woodland areas in the north of the ACT. Consideration should also be given to providing a buffer within the CSIRO site to protect the conservation values of Hall Cemetery.

Stirling Park

FOG’s request that the provision for extension of Empire Circuit through Stirling Park be removed was acknowledged but did not receive a response. A road through that area of Stirling Park would critically and adversely affect nationally significant species and ecological communities in the Park. For this reason FOG asks that the provision for extension of Empire Circuit through Stirling Park be removed from the National Capital Plan.

We urge the Authority to consider a change in land use for Stirling Park (including the portion east of Haines Creek) from ‘National Capital Use’ to ‘Nature Conservation Area’, or, at the very least, that all of the uncontested lands that form the bulk of Stirling Park become a ‘Nature Conservation Area’.

Nature Conservation Areas

FOG’s recommendation for ‘Nature Conservation Area’ to be a permitted land use listed in the precinct codes for Designated Areas has been set aside on the grounds that a Nature Conservation Area is defined as ‘an area declared or intended to be declared under relevant ACT legislation to be a Reserve area ...’. Since, in the NCA’s view, it is unlikely that reserves will be established in many precincts, it does not consider it necessary to add ‘Nature Conservation Area’ to all precinct codes. However, FOG’s view is that not listing ‘Nature Conservation Area’ as a permitted land use in a given precinct code pre-empts any future decision under ACT legislation to create a Reserve area since the Territory Plan cannot be inconsistent with the National Capital Plan!

If listing ‘Nature Conservation Area’ as a permitted land use in all Designated Areas is unacceptable, FOG asks that it be listed in the Precinct Codes associated with the Natural Temperate Grasslands at Yarramundi Reach, and the Box Gum Grassy Woodlands at Stirling Park and Scrivener’s Hut. These areas contain populations of threatened species and endangered ecological communities that are protected as Matters of National Environmental Significance (MNES) under the Environment Protection and Biodiversity Conservation Act and should be protected with ‘Nature Conservation Area’ status.

At the very least, in this revision of the National Capital Plan, ‘Open space’ should be a permitted land use in the Parliamentary Zone  and the Diplomatic (Yarralumla, Deakin and O’Malley) Precinct Codes. Stirling Park and Scrivener’s Hut should then be rezoned to ‘Open space’. This at least allows recognition of the unique natural values of these two sites.

Yours sincerely



Naarilla Hirsch
Advocacy coordinator
12 November 2015

1.       Supporting documentation refers to Block 1603 instead of Block 1630 in several places. Figure 2 ‘General Policy Plan Metropolitan Canberra’ is repeated in the revised National Capital Plan – is this intentional?