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

South Canberra Memorial Park

Referral no: 2019/8595

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.

As a strong supporter of grassy ecosystems including the Yellow Box-Blakey’s Red Gum community, FOG is opposed to applications which remove remnants of endangered grassy ecological communities. However, we are often given the opportunity to comment on developments that will invariably impact such communities – our second best approach is to urge that the development minimise the impact on such communities, use landscaping techniques that will enhance the remaining vegetation, and offer a suitable offset package so that there is no net loss.

We consider that the proposal incorporates many of our second best principles. We note that that a key objective of the proposed action is to provide a setting that retains the natural ecological values of the project area, so that the development layout has also been designed in a manner that will minimise the impact on the areas of Box-Gum Woodland (with 2.59 ha or 89%) being conserved. It also permits the retention of most (i.e. 92 or 87%) of the remnant eucalypt trees in the project area – an important consideration in the ACT where loss of hollow bearing trees has been declared a threatening process. However, noting that the 14 trees to be removed include two larger trees, we would like the larger trees to be retained if at all possible.

We note that the landscaping will include plantings of 100 suitable indigenous trees, a mid-layer of indigenous shrubs and indigenous ground storey species. We certainly support the latter. We would suggest that the choice and placing of plants be done in consultation with people experienced in this matter – there are some species (both exotic and native) that should not be planted close to conservation areas. One list of such species developed by the Weeds Advisory Group is attached.

We would urge that the landscaping may include habitat-enhancing features such as suitable placed fallen timber, areas of rock and mini wetlands. We would also recommend that in areas subject to human traffic that suitable native grasses be used. We would further urge that no non-indigenous plants be used and that landscape be used to promote the importance of use of indigenous vegetation communities and species as an essential element in biodiversity conservation. The landscape plan could also incorporate elements that promote an understanding of the indigenous cultural values of the plants used. 

Yours sincerely


Geoff Robertson

6 May 2020


Species to avoid planting

(obtained from the Weeds Advisory Group)

High level of concern: established weeds in ACT native areas:

Mahonia aquifolium

Pistacia chinensis

Moderate level of concern: weeds found in ACT native areas, but less likely to invade from established areas than above:

Acacia boormanii

Acacia cultriformis

Acacia pravissima

Species are weeds elsewhere (see Richardson et al., Weeds of the South-East)

Agapanthus africanus

Fraxinus excelsior ‘Aurea Pendula’

Fraxinus excelsior ‘Aurea’

Fraxinus excelsior ‘Westhof’s Glorie  (F. velutina rootstock)

Fraxinus ornus

Berberis darwinii

Berberis thunbergii f. atropurpurea’

Species in this genus are weeds in ACT, have berries, produce high numbers of seedlings and/or are likely or possible to cause problems

Cotoneaster  ‘Yarralumla’

Cotoneaster dammeri

Cotoneaster horizontalis

Cotoneaster microphyllus

Crataegus ‘Smithiana’

Crataegus laevigata (syn.  oxyacantha) ‘Paul’s Scarlet’

Grevillea rosmarinifolia

Grevillea rosmarinifolia (Rankin Springs)

Ulmus ‘Sapporo Autumn Gold’

Ulmus americana

Ulmus glabra ‘Horizontalis’

Ulmus glabra ‘Lutescens’

Ulmus parvifolia ‘Emer I’ Athena

Ulmus parvifolia ‘Emer II’ Alee

Ulmus parvifolia ‘Todd’

Ulmus parvifolia ‘Yarralumla Clone’

Ulmus procera

Vinca minor:

Vinca minor ‘Alba’