Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Project Manager

Territory Plan Review Team

ACT Planning and Land Authority

PO Box 1908




Dear Madam/Sir


You may be aware that Friends of Grasslands (FoG) is a community group dedicated to the conservation of native temperate grassy ecosystems, such as grasslands and woodlands. FoG is based in Canberra and its members, numbering about 200, include professional scientists, landowners, land managers and interested members of the public. FoG advocates, educates and advises on matters to do with conservation of grassy ecosystems, and carries out surveys and other on-ground work.  FoG has a productive ongoing relationship with the ACT Government built over many years on land planning, development and management matters. 


FoG notes that the Draft restructured Territory Plan is largely a translation of the existing Territory Plan.  However, FoG provides the attached comments on the draft, including suggestions for policy matters to be addressed in a new Territory Plan. 


Thank you for the opportunity to provide comments/suggestions.  Please contact Bernadette O'Leary (FoG Secretary, on 6247 7959 or if you would like to clarify any of the comments.


Yours faithfully





Kim Pullen


1 June 2007




FoG comments on the draft Restructured Territory Plan and suggestions for policy matters to be followed up in a new Territory Plan (TP)


Comments on the draft Restructured Territory Plan

As a general comment on the draft, FoG notes the need for a navigable and consistently numbered Plan, so that relevant information is easy to (re)locate.  For example, the electronic version is page numbered consecutively and has an index; however, when sections are printed off (as they may need to be for discussion/sharing) it is difficult to determine where they have been taken from as they are not adequately identified (uniquely numbered) either in the electronic text when printed off, or in the published text. 


Public land boundaries and related zoning

FoG notes that Public Land (Nature Reserve) areas in the Jerrabomberra Valley (e.g. Callum Brae Nature Reserve) are currently zoned as Broadacre.  FoG suggests that such Public Land areas are included in the TP in a zoning that is most compatible with land use.  In this case, zoning as Hills, Ridges and Buffers would make them consistent with the rest of Canberra Nature Park.  This would ensure that mapping is unambiguous, and that TP zone objectives are compatible with actual land use/management.


Recognition and protection of significant environmental values

In various places in the restructured TP there are references to protecting 'significant trees', e.g.: in the 'Introduction' to Franklin Precinct Code at p.101; under 'Residential Development Code, Part 1, Element 5: Environment' at '5.3' Trees (p. '18 of 80' of this Code, or p.164 of electronic TP); reference to a 'tree survey' being required under Precinct Codes in the 'Development Code for Subdivision' (p. '4 of 61' of this Code, or p.232 of the electronic TP).


FoG suggests the need to ensure protection of any significant environmental values such as threatened species or ecological communities, and remnant native vegetation - including non-tree vegetation such as natural grasslands or secondary grasslands where woodlands have been removed - in the planning/design, construction and management phases.  Such values should be identified, and may have been already, e.g. as threatened communities or key habitat through Action Plans under the Nature Conservation Act 1980 (such as No.27 on woodlands and No.28 on grasslands), in Conservator of Flora and Fauna directions (NCA s.47) and Management Agreements (NCA pt 9), or related surveys.


FoG suggests that this could be dealt with through the rules/criteria at '3.2.5 Non-Urban Zones Development Code'.  For example, similar to the 'Part 2 General Controls, Element 1 Use and Form, Rule 1.1 Statement of Environmental Effect', the criteria could refer to the statement addressing significant environmental values identified in Action Plans under the NCA, and/or perhaps a statement of compliance could be required from the Conservator.  FoG notes that activities that are inconsistent with management objectives for nature conservation are controlled.


Across various of the land use zones (e.g. 'Broadacre', 'Rural', 'Hills, Ridges and Buffers', 'River Corridor', 'Mountains and Bushlands', 'Parks and Recreation Zones' including 'PR1 Urban Open Space') the zone objectives provide for biodiversity conservation to some extent, including ecological function in at least one case.  FoG suggests that a 'conservation' overlay would be appropriate to identify habitats across the landscape in various zones - including all lands, whether public or private - that are recognised as valuable and/or managed for conservation, and seek to connect them.  Such connection improves the long term conservation outcomes for habitats and the species that use them.


FoG has already raised this matter in discussion with TaMS/PCLB (most recently in a meeting in March 2007).  Although FoG is advised that connectivity is covered at a policy level in the TP (perhaps a reference to the zone objectives), FoG's view is that an overlay would visually recognise significant values and should be unambiguous in its intent. 


This matter is appropriate for Flora and Fauna Committee consideration.  FoG suggests a two stage approach:

FoG notes that plantations are now included in an overlay as a flexible approach. 


Bushfire protection and conservation of native vegetation quality/habitat values

FoG notes that the model Franklin Precinct Code includes bushfire protection rules related to the grassland reserves Mulangarri and North Mitchell Grasslands. Grassy ecosystems are sensitive to inappropriate management, e.g. too frequent burning, physical damage caused by movement of heavy slashing equipment.  While use of buffers on reserved grassland edges is appropriate, as far as possible the frequently-disturbed buffer area should be located outside the protected area, and any model approach should reflect this.  At 'Element 2: Environmental Design, 2.3 Bushfire Protection, C2.3.1', the TP already acknowledges that natural resource management needs specific guidance (i.e. reference to the need for 'an independently prepared bushfire risk assessment...'.  FoG seeks further consideration of how edges - of small remnants in reserved areas in particular - are to be protected; and this should be included in area specific management plans.