Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


The Manager,

Development Policy Section,

ACT Planning and Land Authority,

GPO Box 1908,

Canberra ACT 2601



Dear Sir/Madam


Lawson South Planning Study: draft variation no 299


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 more than 200 members include professional scientists, landowners, land managers and interested members of the public.


FOG has followed closely matters at Lawson and provided submissions and taken an active part in consultations.  A previous submission on the draft planning study was provided in May 2009.  FOG generally supports the proposed development, especially as it combines high intensity housing and therefore will have less imprint on the land, with sensible open space provisions, and as it provides for a broad buffer between the urban development and what is to be extensive grassland reserves in North Lawson (the Commonwealth-Belconnen Naval Transmitting Station (BNTS) site.


FOG supports the establishment and maintenance of at least a 30m buffer zone along the northern edge of Lawson south to protect the endangered ecological communities and conservation listed species in the high value grassland on the BNTS site, including re-establishment of grass cover between the edge road and the boundary fence with native grass species using seed collected from within the grassland or local region.  FOG notes that an environmental management plan (EMP) for the ecological buffer zone will be required as part of the estate development plan (EDP), including no use of invasive species in landscaping and a mandatory cat containment policy for Lawson South.  This EMP should contain a commitment to maintain this buffer as a native grassland and keep it free of weeds, essential to ensure that the new suburb does not impact on the adjoining high value grassland.  The buffer zone should also absorb the requisite inner and outer asset protection zone, so that no damaging actions will be required within the Commonwealth BNTS site to protect the suburb of Lawson South. 


FOG considers that 24 hour cat containment measures should be mandatory in South Lawson, irrespective of whether they are individual blocks (as is mentioned in the current study) or higher density housing. 


Signposting and literature should point to the importance of Lawson as a home for threatened species.  This should be reinforced by only using local grassland and woodland plants for landscaping of open space throughout the whole suburb and encouraging their use in home gardens.  Apart from the species mentioned in the planning study, another threatened species, the superb parrot, probably already uses Lawson and its presence should likewise be promoted.


The study mentions little in the way of offsets, particularly for the substantial area of native ecosystems that would be lost.  There is mention of a “tree management plan incorporating the principle of no-net-loss of native vegetation” (and FOG supports retention of native trees wherever possible) but much of the area being lost is native grassland or pasture and will not be addressed by any tree management plan.  FOG believes that in the development of Lawson South, there is ample scope to apply this principle, as well as to pick up a theme of Lawson South being a home to Canberrans living a sustainable lifestyle in harmony with nature and particularly supporting several threatened species.  In fact it would be rather unique in this respect.  Experience with Forde residents, through the monitoring by Bush on the Boundary, suggests that promoting harmony with nature is a positive market signal.


We therefore propose that the principle of no-net-loss of native vegetation in general and in particular no-net-loss of woodlands, habitat for Golden Sun Moth and native habitat of Striped Legless Lizard be adopted.  Remaining areas of woodland and grassland, and sizeable areas of other open space should be conserved and enhanced to create suitable areas of woodland and grassland habitat for a range of species, including threatened species.  To the maximum extent possible, as both the moth and lizard will only move slowly into adjacent habitat, new areas need to be connected with existing habitat.  Consideration should also be given to developing suitable sites for translocation of Ginninderra Peppercress, currently only known to exist in the BNTS, thus making it something unique to Lawson. 


We believe that the following areas are particularly suited to revegetation using indigenous trees, shrubs and herbaceous species characteristic of natural grasslands and Yellow Box – Red Gum grassy woodlands to enhance woodland habitat on the higher hillslopes and grassland habitat on the lower hillslopes above Lake Ginninderra, particularly where these areas form corridors across the landscape:

The Ecological Assessment recommends that, due to timing and seasonal limitations to surveys conducted during the current study, consideration should be given to undertaking further threatened species surveys to provide further data for these species.  It also mentions longer term monitoring, possibly as part of an environmental management plan, to provide information on habitat use and trends over time that can be used to inform management arrangements.  We consider these surveys essential before planning for the new suburb and discussion of offsets is finalized, as the results may affect both planning and offsets, but could not find mention of these surveys in the list of further investigations required.


FOG notes that there are patches of native pasture through the area near the electricity substation, with Stipa species under the power lines.  FOG’s view is that the area should be maintained as a native grassland rather than planted with trees, as is proposed in the plan. 


Finally, in construction of the suburb’s infrastructure and development of the suburb itself, care needs to be taken to ensure any native grassland or grassy woodland areas being left untouched are not accidentally damaged during the construction process, with the emphasis being on prevention or minimisation of damage to such areas.


Sincerely yours






Naarilla Hirsch (FOG Advocacy Coordinator)

for Geoff Robertson



24 November 2009