Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Referral Business Entry Point, EIA Policy Section (EPBC Act)
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
Canberra ACT 2601



Dear Sir/Madam


Moncrieff Residential Development

Number: 2011/6113


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


FOG welcomes the opportunity to comment on the proposed development in Moncrieff, since it impacts on endangered box-gum woodland, and also the endangered golden sun moth (GSM). FOG’s view is that there should be no development that impacts on vulnerable or endangered species and their habitat, or on endangered ecosystem communities. In principle, FOG opposes all aspects of this referral that impact on high quality box-gum woodland and on high density golden sun moth sites. The major concerns FOG has with this referral are:


1.      Strategic approach to conservation matters in Gungahlin


FOG notes that the referral makes reference to an ACT Government project to review the current state of conservation and future management of matters of National Environmental Significance in Gungahlin. Given that this review is to take a strategic approach to conservation matters in the northern parts of the ACT, FOG’s view is that the Moncrieff Residential Development and other referrals in the north of Canberra should be deferred until the results of the review are available and both the Commonwealth and stakeholders have had a chance to examine and comment on them. No indication is given of the review’s scope, timeframe, consultation processes or who is undertaking it, however, but hurrying to continue development in parallel with the review seems, in part, to defeat the purpose of such an endeavour.


As stated in our response to the proposed Mirrabei Drive extension last year, and in other recent submissions, FOG is opposed to a continuation of the current piecemeal approach to assessment of impacts of development in those areas with conservation value in the north of Canberra. This piecemeal approach benefits developers at the expense of the environment, since each individual impact on conservation values seems small but the cumulative effect over time may both be quite significant and preclude improvement of connectivity between high quality areas.


2.      Connectivity issues


Following on from the first point, FOG considers it essential to look at connectivity issues across the whole of this northern part of the ACT before making decisions about development of individual suburbs. Development of Jacka and Taylor to the north of Moncrieff will obviously have an impact on the connectivity of any box-gum woodland or secondary grassland retained within Moncrieff. However, without knowing what might be planned for these future developments, it is difficult to assess the long-term connectivity between retained conservation areas within Moncrieff and other high quality areas to the north and west.


Looking at connectivity within Moncrieff itself, the preferred option presented in the referral only retains 15 ha threatened Yellow Box – Blakely’s Red Gum grassy woodland in three distinct patches. FOG has concerns about the long term viability of these remnants in terms of their conservation values, given factors such as the small sizes of the patches, the lack of connectivity between them, and the high perimeter to area ratio adjoining urban areas. An option that enhances connectivity is, in our view, much more desirable.


3.      Buffer zones


FOG could find no reference to buffer zones in the document. Buffer zones for bushfire and other management need to be within the development footprint rather than within land retained because of its conservation values. For example, the area proposed to be set aside in the south-west in option 5B is narrow, so addition of a buffer zone will decrease even more the area that could be managed without compromising golden sun moth conservation. In this context, the consultant’s “Golden Sun Moth Strategy” recommends that the ACT Government should “Establish a viable habitat area outside development in planning for Moncrieff South” (underline ours).


4.      Offsets


FOG’s view in principle is that there should be no development that impacts on vulnerable or endangered species, habitat or ecosystem communities, and it opposes the use of offsets in these circumstances. However, FOG recognises that in some situations development will result in loss of conservation values, and believes that where this occurs there needs to be a strategy in place to achieve no net loss for the impacted species or ecosystem. FOG strongly advocates for a set of principles to be used to determine offsets. The ACT Government has not developed an offset policy. While reference is made to an offset package in this referral, detail is lacking, so that it is difficult to assess whether no net loss will be achieved. As other planned developments in the Belconnen and Gungahlin areas will also impact on native grassy ecosystems, an integrated approach to offset proposals is needed, to ensure:


a)      No double dipping, i.e. the same offset being used for more than one development proposal;

b)      The opportunity to address connectivity issues for both existing reserves and proposed offsets;

c)      The opportunity to maximize the effectiveness of offsets in terms of conserving our natural environment in the long term;

d)      Consideration is given to resources for long term management of offset areas; and

e)      Offsets are in place before development commences.


FOG remains concerned that offsets, particularly indirect offsets, will be seen as a way to get around the destruction of native vegetation, with the final result being a net loss of our endangered grassy ecosystems.


5.      Developer’s preferred option


Of the options presented, FOG sees option 5B as the least desirable since it results in the least retention of grassy ecosystems. As well as the reasons above, FOG does not understand the reason for the multiple water features in option 5B, in particular the large water feature to the south-west. This feature destroys any connectivity between the high-GSM population area to the west and the high quality areas to the east. It potentially will change the local conditions to the detriment of the adjoining native areas. It will also encourage the formation of informal tracks from nearby housing through the higher quality areas to the water feature. Such features, if needed, are better placed within the urban area and away from higher quality native vegetation.


If the development proceeds, FOG would prefer to see an option that has minimal impact on box-gum woodland and GSM habitat, supplemented by suitable buffer zones and a commitment to the provision of connectivity corridors through the future suburbs to the north west and north east on Moncrieff (if necessary with appropriate revegetation of the connectivity corridors).




FOG opposes further development or finalisation of development planning in Belconnen and Gungahlin that impacts on endangered and vulnerable grassy ecosystems and species until a strategic review is undertaken (with opportunity for public input) and the best approach to conserving these ecosystems and species into the future has been determined and acted upon.


Sincerely yours




John Fitz Gerald



28 September 2011