Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Re. Whitlam DA 202240629, Whitlam Section 34 Block 10, Estate Development Plan Whitlam Stage 4

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 native 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 provided considerable comment on the Whitlam development in the past years, in particular in relation to the protection of Kama Reserve and the Molonglo River Reserve from loss of biodiversity condition as a result of the development. We have always reiterated that the NES plan needs to be adhered to, as the fundamental legislative agreement between the ACT and the Commonwealth Governments on protection of the natural environmental values in the Molonglo Valley.

In relation to the buffer zone adjacent to Whitlam Stage 4 we stress yet again that we do not believe the NES agreement is being complied with. The Molonglo NES Plan states that one action will be to:

“Establish a buffer outside the Kama Nature Reserve between the reserve and the proposed development area, and allow for appropriate uses consistent with nature conservation uses of the reserve. The buffer will be developed to ensure that fire management is undertaken outside of the Kama Nature Reserve and will provide protection against urban edge effects

We do not believe that the mitigation actions identified in the DA will be sufficient to protect the Kama Reserve and the heritage area to the east of the reserve from significant modification in relation to: a) a wildfire event from the west; b) development of infrastructure within the buffer and particularly within the heritage area; and c) ongoing recreation impacts.

Specifically, we believe the ‘impact’ on 3 ha of the heritage area to the east of the Kama Reserve (Figure 1.3 Landscape Masterplan from the Navin Officer Statement of Heritage Effects report, 2022, copied below) is totally unjustified, particularly given that a significant proportion will be destroyed, and a further proportion modified to meet IAPZ conditions and development of a modified recreation area. There are areas of habitat for the threatened Pink-tailed Worm-lizard within the heritage area (including within the area determined for development). We urge that no urban development or infrastructure occur in the natural heritage listed area where it will destroy or significantly damage ecological values.

Within the context of the above objection to the destruction and impact on three hectares of the heritage area, FOG is in support of the mitigation actions identified in the Kama Interface Indicative Design Plan prepared for the Suburban Land Agency (August 2022) (SUPP-KIMS_APPENDIX-01) which will at least reduce some of the impact. However, we urge that management within the buffer be undertaken by staff whose primary priority is to achieve conservation management in this area, and to ensure that staff have appropriate knowledge base and resources to do so effectively.

We would be happy to discuss alternative options for protection and management of the buffer zone.

Yours sincerely


Professor Jamie Pittock
6 October 2022