Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Yass Valley Council
PO Box 6
Yass  NSW  2582


Dear Sir/Madam

Parkwood Planning Proposal

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 holds particular interest in the environmental assets in and around the Ginninderry development, not only the vegetation of Natural Temperate Grasslands and the Box-Gum Grassy Woodlands, but also creatures that call them home.  FOG has long been a member of a community reference group, Bush on the Boundary, which meets monthly with the Joint Venture.

It is relevant that last week the UN's Intergovernmental Platform on Biodiversity and Ecosystem Services released its analysis that nature is declining at rates unprecedented in human history.  Without doubt, population increase and urban expansion play their part.  All proposals, such as those involved in planning for Parkwood, must be carefully scrutinised to ensure impacts are controlled or, better, avoided.

FOG has particular concerns about conservation management (and restoration), grassy ecosystem fauna (Rosenberg’s Monitor and Pink -tailed Worm Lizard), hollow-bearing paddock trees, broader issues of biodiversity conservation, Aboriginal values in the landscape, and the governance arrangement around conservation management.  FOG considers that complex issues are generated by this proposal, given that many issues involve legislation which changes in both wording and intent at the Sate-Territory border.

Conservation Management: While the Management Trust is proposed to be an ongoing self-managed trust and responsible for the operating the Conservation Corridor, it is important that both NSW and ACT governments, and possibly also the Commonwealth Government, take ultimate responsibility to ensure that the Trust is appropriately funded and managed. In other words, the existence of the trust should not be an exit clause for government to avoid its responsibility for over sighting and funding this conservation area. It is not an auspicious start that the ACT and NSW governments appear set to use different calculations to fund their share of the Trust.

Rosenberg's Monitor:  The protection status for this reptile changes at the border, admittedly though with higher protection afforded by Vulnerable listing in NSW.  However, the situation is complicated by sparse knowledge about this reptile's life cycle.

Rosenberg’s monitor largely relies on grassy woodlands and the species must not be impacted by the development. Given that Parkwood development will take place only ten years or more into the future, final assessments of the impact on the species should be updated then.

Dr. Don Fletcher is undertaking a research project on Rosenberg’s Monitor in the ACT region. The research is now in its second year and while largely focused on two ACT sub-populations in the Naas Valley, it will enable a better understanding the population numbers and behaviour of this animal across the region. While a more detailed description of the research will become available as the project continues its course and its results published, it will assist the impact of the Parkwood development on the Monitor to be assessed more carefully. Preliminary population estimates suggest that there may be a few as 50 to 200 adults in the ACT region. This makes the monitor population in the Conservation Corridor significant. Each adult male animal seems to have two home ranges which may be several kilometres apart. Dr. Fletcher’s research may enable a better understanding of monitor movement within and beyond the Conservation Corridor. This research may also reveal how threats to the monitor population can be abated.

Pink-tailed Worm Lizard:  FOG notes that surveys point to habitat and populations in the proposed urban area.  Comments similar to those for Rosenberg's monitor about adaptive assessment and management apply for the Conservation Corridor.  In the urban areas, FOG is concerned that the Parkwood proposal states that development will result in no net loss of these lizards.  FOG would prefer urban design that removes any need for mitigation - ie no loss in the first place.

Natural Temperate Grassland:  This ecological community is directly listed in the ACT but in NSW is not covered by State legislation and Commonwealth listing is relied upon for evaluation and decision making.  FOG advocates, in view of NSW Biodiversity Conservation frameworks, that such Grassland not be readily traded for commercial or residential-area gain.

Isolated Paddock Trees:  In the ACT, loss of mature native trees (including hollow-bearing trees) and lack of recruitment was legislated as a process threatening the environment in 2018.  FOG understands there is no equivalent in NSW, and therefore has concerns about valuable trunks in the proposed urban area.

Biodiversity in general:  Cat containment is in place for the first two stages of Strathnairn development in the ACT, and expected to continue for ACT stages in future.  Such containment would become pointless if management of this domestic pet was to change at the border.  Further, conservation requires suppression of other feral animals (cats, foxes, deer, rabbits etc.) and invasive weeds, and to the management of native species (Kangaroo, Noisy Miners, Currawongs, larger Parrots, etc.) that may cause overgrazing, habitat destruction, excessive competition for nesting sites, and over predation of smaller threatened and rare fauna.  Again, this requires the closest cross-border coordination.

Aboriginal Values:  FOG as an organisation holds the view that recording and conserving areas of significance to our First Peoples have been inadequate across our nation. In the next ten years, with for example a possible acceptance of a Voice in the Constitution and Makarrata (Treaty and Truth Telling), there may be a game change.  It is only to be expected that views held today will be different in a decade when residential development could begin in Parkwood.  Therefore any stand taken by government now, just as for environmental heritage, must be adaptable to change.

Concerns over the lengthy urban/environment border:  FOG understands that other submissions address the length of the urban/environment boundary. This has been discussed for some time now. FOG is concerned about the length of the boundary making it complex and expensive for weed and pest control, managing human access, etc. and would support any modification of the boundary that reduces its length.

Yours sincerely


Geoff Robertson

15 May 2019