Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Poplars Developments Pty Ltd


Dear Sir/Madam

The Poplars, Jerrabomberra, NSW – Preliminary Documentation

Referral no: 2020/8801

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 indicated in its initial submission on this referral (16 October 2020), since its inception FOG has had an interest in the conservation values of the Poplars. In our submission we asked that the remnant of Box Gum Woodland in the north east corner (PCT 1334 zone 1) should be excluded from future development and should be managed for its conservation values, with the long term aim of improving its condition and including it in the Poplars North BioBanking Site. FOG notes that the preliminary documentation retains 0.18 ha of this area (which includes the hoary sunray population) but 0.42 ha will be lost due to a local access road. The preliminary documentation (PD) states that the area to be retained will be protected and managed as part of the Poplars North BioBanking Site. However, it is referred to as “open space” and it isn’t clear if the area will be formally included in the BioBanking Site and be behind the ‘person proof’ fence between the development area and the BioBanking Sites – which, in FOG’s view, it needs to be.

The critically endangered Golden Sun Moth Synemon Plana occurs throughout the proposed development area, with 13.51 ha (13%) impacted by the proposed action. FOG’s view is that there should be no clearance of habitat where threatened species occur, although we recognise that in this situation the Environa Drive development already approved will fragment some of this population and that avoidance of all of the GSM habitat areas is unlikely with this proposal. The PD makes reference to possible rezoning of the land in the south-western corner of “The Poplars”, where there is also GSM records and habitat. As stated elsewhere, FOG is concerned about piecemeal consideration of the impacts of successive development proposals on MNES and think that the impacts of all possible developments on those areas of the Poplars outside the two BioBanking Sites should be considered at the same time.

It isn’t clear from the PD if bushfire management zones will be included in the development footprint and not in the BioBanking Site. In our view this is essential, since biodiversity management and bushfire management of an area often differ.

The PD states that “The proposed landscaping will generally consist of deciduous street trees with groups of native trees located on the periphery of the estate”. The landscape masterplan should not include any exotic or native species that have the potential to become weeds. Also plantings along the boundary with the BioBanking Sites should be local native species.

While noting that the development is for business and education purposes rather than residential, our view is that mandatory cat containment should be a standard for any new development adjacent to a conservation area. This might prevent feeding of stray cats from business premises as sometimes occurs.

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

6 July 2021