Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Civic Square ACT 2608



Ms Vicki Middleton,

Assistant Secretary,

Environment Assessment Branch,

Department of Environment, Water, Heritage and the Arts,

Canberra ACT


Re: Invitation to Comment Upon:

Request by ACTPLA for reconsideration of decision under Section 78A of the Environment Protection and Biodiversity Conservation Act 1999 – urban development in parts of the suburb of Coombs – Molonglo Valley, ACT (EPBC 2009/5050)


Friends of Grasslands (FOG) submitted a comment on 2 Sep 2009 in response to the original consideration of EBPC 2009/5050.


The Group has studied the set of documents released in the new Invitation to Comment and wishes to make the following points:


It is reassuring to find that management strategy is emerging, including the proposal for formal management documents.  However, we remain concerned until the final documents and agreements are in place that opportunities may be missed in protecting the grasslands important for the conservation of Aprasia parapulchella.


FOG notes the efforts made in developing ‘substantial new information’, including the new project for confirmatory habitat mapping, plus the commissioning of other advice from Dr. Osborne, leading to environmental assessment of the amended Referral Area.  The changes requested to the original Referral Action seem to be generally well integrated, informed and justified by the new information.  FOG especially welcomes the declarations of details in Attachment 1’s table of Measures to be matched by (Construction) Requirements.


There is one issue, in ACTPLA’s requested Change 2, which will require particular care during planning, construction and rehabilitation in the vicinity of manholes 25 and 26.  The impingement of the sewer realignment on medium quality habitat, while it is only planned to be 2 metres wide at maximum, is unwelcome considering the habitat zone itself is not especially wide and it sits on steeper slopes that run down to the Molonglo.  We note that Dr. Osborne cautions (Attachment 6, Area D) “provided the habitat is fenced on the upslope side with sediment control fencing the habitat should be protected”.  We also note that special treatment (Attachment 1, Section B8) is planned for this particularly critical zone.  It is essential that the proposed Environmental Protection Agreement with the contractor (Attachment 1, Section B1) is fully enacted via the proposed programme of ongoing “independent monitoring to ensure compliance”.


For all other grassland areas, we propose that the principle of minimum impact from construction be overriding – this should reduce both costs of and need for rehabilitation as well as maximising environment quality and biodiversity surrounding this new suburb.


Sincerely yours






Geoff Robertson

FOG President.


18 March, 2010