Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Applications Secretariat Section
Customer Services
ACT Planning and Land Authority
PO Box 365 Mitchell ACT 2911



Dear Sir/Madam


Throsby District Playing Fields: Environmental Impact Statement


As noted in the Environmental Impact Statement (EIS), Friends of Grassland (FOG) has raised concerns about this proposal in the past, and has some further comments to make, both concerning the EIS itself and the overall development proposal.


1.      Mitigation strategy


We note the intent, in the mitigation strategy of Table 11, to have a qualified ecologist inspect areas of potential habitat for the Striped Legless-Lizard prior to impacts from construction works, and to remove any individuals identified to suitable adjacent habitat. While we consider it important to keep individuals out of harm’s way, the survival of translocated lizards in nearby habitat is both uncertain and unknown. As such, translocation does not, in our view, constitute full mitigation of this impact if lizards are found.


The mitigation strategy states that native plantings and weed management would continue for “not less than two years or until revegetation has been successful”. Due to variability of conditions from year to year, FOG considers that the minimal period should be longer, at least three years and preferably five. Differences in average rainfall and monthly temperatures from year to year favour different species and, in particular, the spread of different weeds. Two years is, in our view, insufficient to ensure that sleeper weeds do not take advantage of construction-related disturbance when climatic conditions suit them.


2.      Offset strategy


FOG’s advocates the principle 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 has strongly advocated over some time for a set of principles to be used to determine offsets across the ACT but the ACT Government has not yet 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 net loss will be prevented.


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, amongst other things, that no single offset is used for more than one development proposal, that consideration is given to resourcing long term management of offset areas, and that offsets are in place before development commences. FOG remains concerned that offsets, particularly indirect offsets as suggested in Table 12 of the Draft EIS, 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.


3.      Strategic approach to conservation matters in Gungahlin


As we have stated in previous submissions to both the ACT and Commonwealth governments, a strategic approach to conservation of grassy ecosystems in Gungahlin is needed. The recent EPBC referral about a Moncrieff Residential Development made 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 all developments and 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. FOG has not been made aware of the Review’s scope, timeframe, consultation processes or who is undertaking it, but continuing to plan development in parallel with the Review seems to defeat its main purpose.


FOG remains 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 impact on conservation values seems small but the cumulative effect over time may both be quite significant and threaten connectivity between high quality areas. Development of a strategic approach would provide opportunities to address connectivity issues for both existing reserves and future offsets, and to maximize the effectiveness of offsets in conserving our natural environment in the long term.



Sincerely yours





John Fitz Gerald



30 October 2011