Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614



Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601

Dear Sir/Madam

Canberra Brickworks Precinct access road and Dudley Street upgrade, Yarralumla, ACT

Referral no: 2017/8072

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia, included related fauna species. 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.

As noted in our submission of 1 November 2017 concerning referral no 2017/8074, FOG has had a long-standing interest in the natural values of the area in the vicinity of the Canberra Brickworks in Yarralumla. In 2014 and 2015 we commented on drafts of the Planning and Development Strategy for the Brickworks and environs. However, it is clear from the current proposal that these views were ignored and that no value has been placed on the natural values of the area.

Also as noted in that submission, referral 2017/8074 and this referral are interconnected and should have been dealt with as one item. We are responding to this referral separately, but emphasise that they are clearly related and losses to biodiversity as a result of the brickworks development and associated infrastructure are cumulative. We believe that these cumulative impacts are significant and are being treated as inconsequential matters, with scant consideration of legislative requirements and government policy.

Specific comments

1.       Loss of habitat

FOG notes that attempts have been made to minimize the impact of the proposed road on the Golden Sun Moth (GSM) population and Natural Temperate Grassland (NTG) adjacent to Dudley Street. Notwithstanding this, the proposal will destroy 17% (0.13 ha) of the NTG at the site, as well as 35% (2.54 ha) of GSM habitat and impact on the remainder through edge effects and fragmentation. This is likely to have a profound impact on its longer term viability. Impacts on the remaining grassland will include changed drainage, as noted in the assessment documentation, and increased edge effects due to the proximity of the road to the grassland. This will lead to more weed invasion (especially Chilean Needlegrass and African Lovegrass). While the referral proposes fencing to minimize disturbance and revegetate with native grasses, a plan that will protect this urban grassland is required. We draw your attention to examples of attractive and well-protected and managed urban grasslands in Marshall A., 2014. Start with the grasslands: design guidelines to support native grasslands in urban areas (

2.       Cumulative impacts

With regard to the GSM population, as stated in our response to referral no 2017/7074, FOG is concerned about the impact of the entire development proposed (buildings, roads, other infrastructure, landscape modification) on the GSM population, as well as increasing fragmentation of the species in the wider area near the Brickworks. Again, we note that there has been no assessment of the impact of removal of part of the GSM population on the long term viability of the remaining population in the area, and that the two referrals precede findings of the third survey recommended by Biosis. This information should have been part of the referral documentation (and available for public comment) before the referral was considered.

3.       Offsetting

The approach to development proposals impacting on threatened species is to avoid first, mitigate if possible, with offsets implemented as a last resort. FOG does not consider that the "avoid" principle has been applied and believes alternative solutions should be considered that would not require extensive enlargement of Dudley Street.

While FOG has considerable concerns about the use of offsets, given it usually results in net loss of species and habitat, we do regretfully accept that offsets are better than no compensation for biodiversity losses. In September 2015, FOG wrote to the Environment and Planning area of the ACT Government concerning advanced offsets (see attached letter). While noting that it did not support the necessity of needing such offsets in the first place, FOG provided a list of grassland sites in the ACT that we were aware of that would benefit from increased care and might be considered as possible advanced offsets. That list included both the Dudley Street and North Mitchell Grasslands.

In the unfortunate situation of the proposed road being allowed to impact on both the NTG and GSM habitat, offsets will be needed. Given the time this development proposal has been in the planning, FOG does not understand why a detailed offset proposal hasn’t been provided. While agreeing that the North Mitchell grassland might be a suitable offset for this proposal, it is not clear to FOG why protection of the remaining GSM habitat and NTG in the Dudley Street site has not been proposed. We seek consideration of a fully developed offset proposal that protects, enlarges and enhances the remaining habitat by undertaking restoration activities that includes enlarging and joining the two high quality NTG patches as well as protection and enhancement of the North Mitchell Grassland. The offset proposal needs to be fully developed and costed.

It is difficult to believe that the omission of this option to protect and improve the Dudley Street Grassland is anything other than a signal that this site is likely to be lost in the future, as part of this development or another.

We draw your attention to page 7 of the ACT Environmental Offsets Policy (August 2014):

"Ideally, offsets are secured and in place before the development is approved"

In this case there is no reason for offsets not to be in place before development approvals (including this referral decision) are given.


ACT governments of all persuasions have had a strong commitment to the protection and conservation of NTG, a critically endangered ecological community. Likewise, they have had a strong commitment to protecting the habitat of threatened grassland fauna and flora species, reflecting the high values that community places on biodiversity conservation. There are examples of outstanding grassland management and support for associated research carried out by the ACT government. However, it is equally clear that elements within government see patches of NTG and other threatened species habitat as only having a nuisance value.

The current proposal illustrates what can only be called indifference to the ongoing protection and management of these remnants, despite there being a requirement by Commonwealth and ACT law to protect such areas. We regard the proposal as piecemeal and incomplete. Correctly, it recognizes the reduction in size of remnants implied in the proposal as well as other negative impacts that may follow on. However, it ignores the cumulative impact of this proposal and related proposals such as 2017/8074. There is no guarantee that subsequent proposals will not further encroach and destroy the conservation values of these sites. The discussion of an offset to improve the North Mitchell Grasslands are vague, lack any detail and un-costed.

We would like to see the proposal considered in its entirety. The first step should be strategic assessment of all the cumulative elements of the development, including all infrastructure related to this and impacts on the broader environment of Yarralumla. Then should follow a full investigation of options that consider "avoidance, mitigation and offsetting" of deleterious impacts on the natural environment. There should be proposals to enhance the remaining areas (this might include fencing and signage as well as revegetation), aimed at both informing the public of the values of these remnants and also ensuring indefinite reservation and appropriate management of these areas. Regarding the North Mitchell Grasslands, a properly costed proposal should be prepared.

FOG has previously been involved in extensive meetings with ACT Government and others regarding strategic development elsewhere, including Gungahlin, Majura Parkway and the Murrumbidgee to Googong Pipeline. We would welcome the opportunity to be involved in discussions about the Yarralumla Brickworks development and associated infrastructure in relation to mitigating impacts on the natural values of the area.

FOG does not support the current proposal and requests that the issues raised in our submission be addressed.

Yours sincerely


Sarah Sharp
Advocacy Coordinator

9 November 2017



Kathryn Tracy
Natural Environment
Environment and Planning
GPO Box 158 Canberra ACT 2601

Dear Kathy

Advanced offsets

With the increasing use of biodiversity offsets for urban development impacting on higher quality Natural Temperate Grassland (NTG) and Box Gum Grassy Woodland (BGGW) areas and their dependent species, FOG is concerned that some sites of value are not being maintained while their future remains uncertain. FOG is supportive of identifying possible future offsets ("advanced offsets") and ensuring they are managed to retain and enhance their values before actually being used as an offset, as well as after the offset decision.

Some time ago we discussed the possibility of providing you with a list of sites that we believe could be used as offset sites. These are all sites that are important for conservation and connectivity but are outside the reserve system, and are vulnerable to degradation and/or lack of recognition of their values. A list of possible advanced offsets is attached. The list is in two parts: ACT government land and Commonwealth land. While we recognise that Commonwealth land is outside the control of the ACT government, we have included these sites as we believe that it is important that they be identified so that they can be managed appropriately.

This list is not a definitive list, rather a list of sites that we are aware of that would benefit from increased care and might be possible advanced offsets. We would be happy to discuss the contents of this list and why we selected the sites on it at a meeting, and can be contacted at the email address above.

Note that FOG’s suggestion of using these areas as advanced offsets in no way supports the necessity of needing such offsets in the first place. In our view, all NTG and BGGW areas with conservation value should not be subject to urban development and should be managed to enhance their conservation value. However, we recognise that at times impacts on high quality areas will occur, and are seeking to minimise the net loss of these ecosystems across the landscape.

Yours sincerely


Sarah Sharp

24 September 2015


Potential Territory offset sites


Block/Section, Current designation

Values (A/P 28 id number if relevant)

Management requirements

Umbagong Park, Latham (Blue Devil Grassland)

B1S129 Latham UOS

NTG (BE04a)


North Mitchell grassland

B4S47 Franklin HRB

Lepidium ginninderrense

NTG (GU04)

Biomass management

Isabella Ponds

Block 20, Section 67 Monash UOS

NTG (TU01), potential PTWL habitat


Lyneham Ridge, Ellenborough St

Includes parts of B9 S57 Lyneham, B1 S154 Kaleen


Control of woody weeds, Serrated Tussock. Currently grazed by cattle

Hall Horse Paddocks, between Gibbes St and Barton Highway

Includes parts of B3, 6, 7, 8 S18 Hall HRB


Rotational grazing

B2S128, Yarralumla

B2S128, Yarralumla


Woody weed control

Rural lease, on eastern corner of Oaks Estate road and Pialligo Drive

Block 680, Majura

BGGW (part), very old trees. Also important aboriginal cultural values (including artefacts)

Weed control, enhancement of understorey

Campbell Park and Majura West, some Territory, some national land

Includes parts of B692, 695, 564, 723 Majura


Management plan

Mt Rogers

B63 Fraser UOS



Quick St Ainslie (CSIRO Headquarters)

B3 S60, B4, 5, S63, Hills, Ridges and Buffers



Travelling Stock Reserves, including Naas Valley TSR


Values unknown


Glenloch Interchange, including Pryor’s Snow Gums

No block id

Snow Gum woodland, NTG (BE11)

Control of St John’s Wort, woody weeds, erosion

Dudley St

B3 S94 Yarralumla UOS

NTG (CC08)

Burn, herbaceous weeds

Woods Lane

Includes parts of B2040


Weeding, protection from disturbance

Potential offset sites on Commonwealth land



Values (2005 Grassland strategic plan no.)

Mgmt requirements

Stirling Park

B4 S22, B3, S128 Yarralumla


Control of woody weeds

Scriveners Hut

B1 S2 Capital Hill


Control of woody weeds

Yarramundi Reach Urban Open Space

B1339 Canberra Central


Control of weeds, burn

ACCC, Barton

B31 S6 Barton


Control of weeds, biomass management


B2236 Jerrabomberra


Control of weeds (JE07)

Guilfoyle St

B20 S66


Control of woody weeds, invasive grasses. Possibly burn

Jindalee Cr, O’Malley

Block 4, S10-12, 18-21 O’Malley


Control of woody weeds

York Park National Land (Department of Finance)

B3 S22 Barton


Weeding, possibly fix drainage issues