Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Environment, Planning and Sustainable Development Directorate Customer Service
GPO Box 158
Canberra  ACT  2601


Dear Sir/Madam

Development Application 201834846 - ESTATE DEVELOPMENT PLAN for Ginninderry Estate (Stage 2)

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 also has members in surrounding New South Wales.

FOG has engaged with matters in the Ginninderry development since they have been in the public domain. It has appreciated the privilege of a seat on the Bush on the Boundary consultation group convened through the Conservation Council (ACT) and has actively participated in considerations of that group.

FOG is well aware of the huge amount of environmental assessment, analysis, publication and consultation that has been undertaken by the Development Joint Venture. This urban development planning aspect is far ahead of any other in the region when it comes to consideration of environmental values, not least for grassy woodlands and native grasslands in and around this large project.

FOG expressed strong support in its submission (6 April 2017) to the DA for Ginninderry Stage 1, primarily for the approach to preserving existing trees and recreating vegetation of grasses and forbs around the bases of the trees retained inside the urban area. FOG said at that time that we were particularly looking forward to learning how extensive treatment T3 involving soil removal would fare in the proposed system of Fenner School Urban Laboratory Parks. FOG remains eager to see this work progress since the only action to date in Stage 1 has been enclosure of the trees in temporary fences marking outlines of pocket parks. While FOG is disappointed that no treatments have yet been applied, it remains enthusiastic about the revegetation plan which is proposed to continue its general form into Stage 2. FOG feels a need to point out that many of these pocket parks, both on the ground in Stage 1 and in the plan for EDP 2, are very small and could well prove vulnerable to edge effects including weed invasion and neglect by careless builders and contractors, and later by residents. Also while connectivity between these small parks might be useful for large birds transiting through suburban Strathnairn, it arguably is not for small birds or for ground-based insects and reptiles. It remains to be seen how well hollows are going to be used by all animals. So the approach has significant challenges and its benefits will only become clear many years into the future.

FOG also made submission on 29 April 2018 to the project's application for EIS exemption in future stages in the ACT. FOG raised issues around the planned West Belconnen Conservation Corridor and its operating Trust and bushfire management, and around environmental offset management programs. The Minister in his subsequent determination to exempt EIS did list resolutions on all of these amongst key conditions for any subsequent Development Applications. Briefings by the developer to community groups including FOG late in 2018 show promising signs of progress in these matters. FOG does appreciate that major effort and time is required to finalise these management plans, to have them endorsed and approved with the range of authorities involved, and finally to commence operations. However, as a community organisation, FOG feels obliged to keep pressure applied until that happens, particularly given the time it has taken to finalise management plans in other developments such as Molonglo. FOG looks forward to the ACT Environment and Planning Directorate and the Commonwealth Department of the Environment ensuring full compliance with published conditions and directions.

In short for EDP 2, FOG is encouraged by the high tree retention rate and associated revegetation system in the pocket parks. It hopes that other open spaces in EDP 2, including road- and track-sides and pond banks, are used as a focus for many showy native grasses, forbs and shrubs. Also that future residents will be encouraged to grow Australian plants in their gardens to host a whole range of endemic animals.

Yours sincerely


Geoff Robertson

4 January 2019