Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Mr Andrew Smith
Chief Planner
National Capital Authority
GPO Box 373


Dear Mr Smith

Development Control Plan 16/01 Blocks 4 & 5 Section 38 Campbell

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 is concerned that the provisions of this Development Control Plan (DCP) may not be compatible with the future viability of the endangered species and communities on and adjacent to Blocks 4 & 5, Section 38 Campbell (the Site) covered by the DCP. In particular, Landscape Zones 2 and 3 set out in the DCP will not offer adequate protection to these endangered species and communities.  FOG is also concerned that the landscape character proscribed under the DCP will adversely affect the endangered species and communities on and adjacent to the Site.  The attached diagram, Figure 1, indicates the location of the endangered species and communities and their relationship to the Landscape Zones.

The area is next to a significant population of the endangered Hoary Sunray (Leucochrysum albicans var. tricolor). While this population has persisted adjacent to a low density office and carpark, it would almost certainly be impacted, if not totally destroyed in the long term, by high density residential and commercial developments on the Site. This population will be made more vulnerable because of its proximity to the designated secondary access to the Site.

An area of Natural Temperate Grassland (NTG) listed in the ACT Government’s Action Plan 281 as an area of conservation category 2 occupies part of the Site and an adjacent site. While the area within the Site may not seem large, it is significant for two reasons. Firstly, quite small areas of NTG can persist and remain viable in the long term if managed appropriately. Secondly, this area of NTG is in fact part of a larger area on the adjoining block. Destroying this NTG area will impact on the long term viability of the NTG patch on the adjoining block. In this context, I would draw your attention to the recent change of status under the Commonwealth EPBC Act for NTG in the South Eastern Highlands – from endangered to critically endangered.

While FOG is pleased that a high standard of landscape design is required for the Site, the provision that ‘a continuous canopy of endemic trees shall dominate the border of the site commensurate with the landscape character of Mount Ainslie’ (Part 2, Urban design principles) is of concern.  A continuous canopy will provide dense shade and create an environment in which the grasslands cannot thrive.  The landscape character of Mt Ainslie is predominately grassy woodland, not natural temperate grassland. Hoary Sunray, though found in grassy woodlands well as natural temperate grasslands, does not cope well with dense shade.

The creation of Landscape Zones which are a regulation distance from the site boundary offers clarity and certainty to the developer; it ignores, however, the natural values of the site.  For example, a landscape Zone 2 which echoed the location of the NTG area on that part of the Site would better protect the remaining NTG.  Landscape Zone 3 could be similarly modified and perhaps become narrower in places where the NTG and Hoary Sunray will not be impacted.

FOG hopes that some revision of the DCP can be made which will help mitigate adverse environmental impacts on the Site and the adjacent land which will almost certainly occur from any development of the site under the DCP as currently drafted.


Yours sincerely


Naarilla Hirsch
Advocacy coordinator

9 April 2016


1.              ACT Government (2005) ‘A Vision Splendid of the Grassy Plains Extended – ACT Lowland Native Grassland Conservation Strategy’. Action Plan 28. Environment ACT, Canberra