Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Access Canberra Customer Services,
PO Box 365,
Mitchell ACT 2911

Dear Sir/Madam

Denman Prospect 2 Estate: EIS exemption

Application reference number (202100040)

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 has a long standing interest in those areas of high value native grassy ecosystems in the Molonglo area, is familiar with the Molonglo Strategic Assessment and has made numerous submissions about the impact of urban development in the Molonglo area.

FOG’s view is that the EIS exemption for Denman Prospect 2 Estate should not be granted. The following summarizes our reasons for this view, with further details being provided in the attachments.

Box Gum Woodland values

FOG undertook vegetation assessments in January 2022, which demonstrate that the values of the deferred area might be higher than concluded in the Ecological Impact Assessment for this project (see attachment 1 for details). In our view there are some parts of the area that appear to meet the criteria for EPBC-listed critically endangered Box-Gum Woodland, even though other parts are weedy. For this reason, the area should at the very least be subject to an EIS that considers all of its ecological values in more detail.


While noting that the area to be located in the proposed urban area is relatively small, FOG is of the view that it is rich in birdlife and potentially used for breeding by some woodland species (see attachment 2). A more detailed analysis of the impacts on threatened and rare woodland birds is needed. Reasons for this include the lack of inclusion of data on these birds from sources such as eBird, the absence of a discussion of removal of hollow bearing trees and of the impacts of the proposed nearby urban development on birds in the area remaining, connectivity issues, and reduction in the available habitat in a known bird hotspot.


The aim of the Molonglo Strategic Assessment was to consider the development of eastern Molonglo from a strategic landscape perspective and so deliver the best outcomes from a conservation perspective. Considering the deferred area in isolation and without regard to the adjoining woodland areas or wider connectivity benefits would be reverting to the days of piecemeal developments, where each argues that their impact is small, whereas in fact the combined total will be significant. The deferred area is part of a connectivity link: the impacts of the proposal should be assessed in detail and from a landscape perspective, taking into consideration the future of the adjoining woodland areas.

Edge effects

Developing the deferred area will increase the impact of edge effects such as bushfire management, increased visitation and incursions by weeds, domestic and feral animals (see attachment 3).

Other values

There are fauna species present that add to the biodiversity value of the deferred area. The report does not mention the two records of the nationally vulnerable Pink-tailed Work Lizard, Aprasia parapulchella, (PTWL). The report does note the presence of trees supporting active nests of the Coconut Ant, Papyrius nitidus, which is essential to the survival of the nationally rare Small Ant‐blue Butterfly, Acrodipsas myrmecophila, but this is not considered further.

In recent years Bluett’s Block has become increasingly used by residents of Molonglo and others undertaking citizen science and it will undoubtedly become important for future community Landcare activities.

See attachment 4.


FOG’s view is that the EIS exemption for Denman Prospect 2 Estate should not be granted – its values are such that further assessment is warranted. Instead, FOG prefers that the deferred area be conserved and managed as part of a larger conservation reserve to be established at Bluett’s Block-Piney Ridge.

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

8 February 2022

Attachment 1: Box-Gum Grassy Woodland values

In January 2022 a FOG ecologist undertook assessments of the quality of the vegetation in the deferred area. FOG's surveys of PCT-ACT25-Zone 2 (see table below) and analysis of the data suggests that much of this area falls under the definition of the EPBC-listed CEEC White Box Yellow Box Blakely's Red Gum Grassy Woodland and Derived Native Grassland (Box-Gum Grassy Woodland), with a groundlayer largely dominated by native perennial species. Our survey found a sufficient number of the “important species”, other native non-grass species and native tree species to place it firmly within that ecological community as described by the CEEC listing. FOG assessed this area as representing a transition zone between the Box-Gum Grassy Woodland that is more prominent on the lower slopes and flats with deeper soils, and the intact dry forest of the upper slopes.

FOG's assessment of PCT-ACT16-Zone 2 is that part of this area also falls under the definition of the EPBC-listed CEEC Box-Gum Grassy Woodland. Of significance here is that there are many old-growth Blakely's Red Gums, Eucalyptus blakelyi, many of which have hollows. There is also a large patch of regenerating trees of the same species. Much of this area has a groundlayer dominated by native grasses and has a low cover of exotic perennial, biennial and annual exotic species. Data collected on 27 January 2022 in this zone demonstrated that much of this zone meets the criterion of having a native dominated groundlayer (with a step-point transect revealing 67.5% native cover and 32.5% exotic cover).

The regeneration of the tree species characteristic of Box-Gum Woodland and the largely perennial native-dominated groundlayers of PCT-ACT25-Zone 2 and PCT-ACT25 Zone 2 suggest that part of the area could meet the EPBC criteria for this CEEC, the high cover of Blackberry, Rubus fruticosus, notwithstanding. It could be argued that allowing the weeds to proliferate as they have done is a lack of duty of care by the land’s owner. The possibility of dealing with the significant weed species on the site, particularly the removal of the Blackberry, and then monitoring for the recovery of native regeneration has not been explored as an option.

Results of flora value assessment undertaken by FOG at the Deferred Area on Bluett’s Block, 5 January 2022


Transect number







Length of transect (km)







Number of non-grass species







Number of important species







Total number of native species (includes additional grasses)








1.       “Important species” are as in the Listing advice for the Box-Gum Grassy Woodland CEEC, at

2.       Non-grass species include forbs and herbs but not trees, sedges or rushes, as in the Listing Advice

Attachment 2:  Woodland birds

Bluett’s Block is a known bird hotspot (see While it can be argued that the area to be removed is relatively small, development on it will nevertheless reduce the habitat available to a number of threatened and rare birds. Individuals displaced by the development will not be able to move nearby since in general all available habitat is at carrying capacity.

While the Ecological Impact Assessment does acknowledge that the midstorey and shrublayer in all three zones are likely to be of value as refuge, foraging habitat, and/or nesting habitat for many small woodland bird species, it does not include data from sources such as eBird. EBird records a total of 135 bird species for Bluett’s Block, including some threatened, declining and rare bird species. The species of greatest conservation concern that have been recorded at Bluett’s Block in eBird are listed below.

This list is a mix of birds that use the habitat provided by the dry forest of PCT‐ACT25-Zone 1 and birds that prefer more open woodland, as is found in PCT‐ACT25-Zone 2 and PCT‐ACT16-Zone 2. The latter are likely to be displaced by the proposed development. These include the winter-visiting Scarlet Robin, Petrocia boodang, and Flame Robin, Petroica phoenicea, which are often found in very open habitats when not breeding. There is insufficient information to understand fully the impacts on birds using the more open woodland areas.

The Report states that the Area of Concern was found to support a number of fauna habitat features, including the fifteen (15) mature remnant trees that occur in PCT‐ACT16-Zone 2, some of which contain hollows that provide nesting/roosting habitat to a variety of native birds, insectivorous bats, and arboreal mammals. FOG's assessment is that these old-growth trees are likely to be suitable nesting sites for the often colonial-nesting Superb Parrot, Polytelis swainsonii, which have already been recorded at Bluett’s Block. As such, these trees belong to the CEEC Box-Gum Grassy Woodland and should not be alienated from the intact vegetation of the rest of the site. Additionally, there is a significantly large patch of recruiting Blakely’s Red Gum trees, and these were found to be particularly healthy (i.e., not affected by Psyllid attack which is frequently seen on recruiting and mature Blakely's Red Gums).

If the development proceeds, it is likely that having houses close to the remaining bird habitat will degrade its use by bird populations due to increased visitation, increased lighting, increased noise, and increased access by pet and ruderal animals such as dogs, the Common Myna, Acridotheres tristis, and rats.

Birds recorded at Bluett’s Block

The following are woodland birds of concern that have been recorded at Bluett’s Block (see eBird at, together with their conservation status. Those marked by * are woodland specialists that preferentially use open woodland and derived grassland habitats:

Painted Buttonquail - Turnix varius - a declining woodland bird in Reid (2000)

Gang-gang Cockatoo, Callocephalon fimbriatum - listed as vulnerable in NSW, and nominated for endangered listing under the EPBC Act - see

*Superb Parrot, Polytelis swainsonii – listed as vulnerable in the ACT, NSW and nationally under the EPBC Act, and as threatened in Victoria

Chestnut-rumped Heathwren, Hylacola pyrrhopygia - a rare species in the ACT, with c.15 known locations in the ACT, and Bluett’s Block an acknowledged hotspot for the species, see:

* Speckled Warbler - Pyrrholaemus sagittatus - listed as vulnerable in NSW - Reid (2000)

*Southern Whiteface - Aphelocephala leucopsis - an ACT woodland bird of concern – Reid (2000), and nominated for vulnerable listing under the EPBC Act – see

*White-winged Triller - Lalage tricolor - listed as vulnerable in the ACT

Varied Sittella - Daphoenositta chrysoptera - listed as vulnerable in NSW - Reid (2000)

*Rufous Whistler - Pachycephala rufiventris – declining – Reid (2000)

*Dusky Woodswallow - Artamus cyanopterus - listed as vulnerable in NSW - Reid (2000)

*Scarlet Robin, Petroica boodang - listed as vulnerable in the ACT and in NSW

*Flame Robin - Petroica phoenicea - listed as vulnerable in NSW

Eastern Yellow Robin - Eopsaltria australis - declining – Reid (2000)

*Diamond Firetail - Stagonopleura guttata - listed as vulnerable in NSW, an ACT woodland bird of concern - Reid (2000) , and nominated for vulnerable listing under the EPBC Act – see

*Double-barred Finch - Stizoptera bichenovii - an ACT woodland bird of concern


1.       Reid, J (2000) Threatened and Declining Birds in the New South Wales Sheep-Wheat Belt: ii. Landscape Relationships – Modelling Bird Atlas Data against Vegetation Cover. Consultancy report to NSW National Parks and Wildlife Service. CSIRO Sustainable Ecosystems, Canberra. (see

2.       ACT woodland birds of concern at

Attachment 3: connectivity and edge effects


The deferred area and the woodland to its northwest are part of a connectivity link from the woodlands and forests on Mt Stromlo and beyond through to Kama Nature Reserve, and then to The Pinnacle, Mt Painter, Aranda Bushland and to Black Mountain Reserve. Development on or clearing of the deferred area will reduce connectivity to the south by about a third, potentially creating a choke point at the southern boundary of Bluett’s Block. If, instead, the site is managed for conservation values and weeds are reduced, there is the potential to enhance this connectivity.

In addition, considering this area in isolation reverts to the piecemeal development of the past, where minor impacts of individual developments were argued, although in fact the cumulative impacts were significant. Further investigation is needed to assess the use of the deferred area for habitat connectivity, such as migration and dispersal corridors, and use of the relatively more productive low-lying area along the creek as a drought refuge.

With the current urban development nearby, the deferred area is now part of the west Molonglo area and should be evaluated on a landscape basis as part of that area. To retain the important connectivity features of the area, FOG suggests that it be retained as part of a larger conservation reserve to be established at Bluett’s Block-Piney Ridge.

Bushfire considerations

While the report states that a full Bushfire Assessment will be required to support the EDP DA, it then states that all APZ requirements shall be located within the area identified for urban development. However, the prescribed fire regimes in the neighbouring woodland areas may degrade somewhat the habitat value of the Red Stringybark Dry Forest, although probably not to the extent that important woodland birds would not still utilise the area at times. It is not clear what degree of physical fuel removal may be required or what has precedence – a Bushfire Management Plan or DA conditions. The exact nature of fire risk reduction measures needs to be clarified.

Other urban edge effects

The proposal will place the urban fringe adjoining intact woodland areas. As already discussed, this will degrade the use of the woodland by birds due to increased human visitation, increased lighting, increased noise, and increased access by pet and pest animals. As well, it increases the potential for garden escapees to establish as weeds in the woodland areas.

Attachment 4: other values

Other fauna

The proposed deferred area actually includes two recorded locations of the nationally vulnerable Pink-tailed Worm Lizard, Aprasia parapulchella, (PTWL), which have not been included in the Assessment Report. Both were recorded in 2019 by Aaron Clausen on Canberra Nature Map (see and

The presence of trees supporting active nests of the Coconut Ant, Papyrius nitidus, the host species that is essential to the survival of the nationally rare Small Ant‐blue Butterfly, Acrodipsas myrmecophila. As this is under consideration for listing in the ACT, it adds to the biodiversity values of the deferred area.

Community use

Because of its very high value as bird habitat, the vegetation and fauna of Bluett’s Block is increasingly being used as a recreational resource by many residents of Molonglo and others more broadly in the Canberra community. For example, it has been visited by birders undertaking eBird surveys starting in 2014, with a total of 135 bird species being recorded since then. Many contributions of other fauna records have been made to Canberra Nature Map, including 904 images of many types of flora and fauna species (filed under Piney Ridge, the NatureMap's name for the site: see These two citizen science apps alone demonstrate how important Bluett’s Block is to the Molonglo and wider Canberra public as an important educational and recreational site.

Development of the deferred area will deny the community easy access to a rehabilitating sample of Box-Gum Grassy Woodland and Derived Native Grassland. While it might be argued that there are other such sites in the ACT, this is one of the few that is south of the Molonglo River and readily accessible by residents from the south of Canberra. It will also deny incipient Landcare groups in the area an opportunity to participate in further restoring the site.