Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Draft ACT Planning Strategy
Submissions
Environment and Sustainable Development
GPO Box 158
Canberra City ACT 2601
email:
esdd_communications@act.gov.au
Dear Sir/Madam
Draft ACT Planning Strategy
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.
As part of its work, FOG has, over the years, responded to many development applications within the ACT that impact upon endangered grassy ecosystems and species. Consequently, FOG is pleased to see, in the Strategy document, recognition of the conflicting demands of urban development and biodiversity conservation.
FOG supports strategy 8 and many of the actions listed in this section of the document, including a regional plan for biodiversity, investment in data collection, collation and mapping for conserving areas of high ecological value or connectivity, and identifying controls and incentives for managing high conservation value land outside reserves. However, we are disappointed to see no mention of biodiversity as a value of the land in the key challenges listed on page 10 of the Strategy. Value of the land means different things to different people, so biodiversity should be mentioned as the value being referred to, particularly in view of the rare and endangered species and ecosystems found in the ACT.
FOG notes that the Planning Strategy considers it important to continue to manage our nature reserves and to manage the urban edge and interface with the rural and natural environments. An ongoing concern is that although this principle appears in this and similar documents, resourcing for management activities is often insufficient to maintain the conservation value of sites.
FOG has been asking for strategic approaches to urban development (with respect to its impact on high quality grassy ecosystem areas) for some time, so supports preparation of a western edge broadacre study and the continuing action to “assess the impacts on biodiversity of potential land use decisions at a strategic level” (page 56). In FOG’s view, while this is being attempted in some areas (e.g. the Eastern Broadacre study), piecemeal urban development is continuing in others, such as in Gungahlin. A strategic approach needs to be applied to all areas where proposed development will impact upon endangered grassy ecosystem habitat, not just some.
FOG’s major concern with the planning strategy is the lack of concrete targets and outcomes for biodiversity values. The table on page 68 has quite specific targets for the first six strategies, but only the production of a regional biodiversity plan for the eighth. While this is excellent in itself, a plan is not valuable unless it leads to actions that make a difference on the ground. We would like to propose other, more concrete targets that we believe are achievable over the next five years:
- No further urban developments or development proposals on land with biodiversity values until a strategic assessment has been done of all of the higher conservation value land within that part of the ACT, with stakeholder agreement to areas retained for conservation (and, for that matter, to strategic offset proposals);
- Production of a synthesized data base and maps of areas with high ecological value or connectivity;
- Identification of land of high conservation value, both inside and outside reserves, as “no go” for urban development (including infrastructure). Habitat that connects such areas should also be identified.
Sincerely yours
John Fitz Gerald
President
29 November 2011