Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Jamison Centre
Macquarie ACT 2614
email: advocacy@fog.org.au
web: www.fog.org.au
Queanbeyan
City Council
PO Box 90
Queanbeyan NSW 2620
email:
council@qcc.nsw.gov.au
Dear Sir/Madam
Draft South Jerrabomberra Development Control Plan (DCP) 2014
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 members include professional scientists, landowners, land managers and interested members of the public.
Preliminary and Context
FOG welcomes the inclusion in the DCP aims and purpose (1.5j) of the identification, protection and management of environmentally and culturally sensitive areas. FOG would, however, like to see the conservation, management and enhancement of conservation areas in perpetuity also included as aims of the DCP.
There is a requirement (1.11) in the DCP for neighbourhood structure plans to show, among other things, the location of cultural heritage sites and threatened species (but not threatened ecological communities). Significant areas in the DCP are zoned E2 Environmental Conservation and therefore represent a key element of the landscape character of the South Jerrabomberra area. FOG recommends that the location of E2 zones should be included in neighbourhood structure plans where there is a shared boundary and similarly, in subdivision applications (1.12) it is important there be high level recognition of the significance of conservation areas so that conservation awareness is embraced as fundamental part of the development processes for the area from the outset.
Master Plan
The stated purpose (3.1) of the Master Plan is to
guide the orderly and sequential development through the next 5-25 years, providing the community with information on the community facilities and open space, neighbourhood centres, residential neighbourhoods and employment lands to be developed, this includes a Staging Plan.
For reasons above, FOG would like to see ‘, management and enhancement of conservation areas’ inserted after ‘residential neighbourhoods’.
The Master Plan objectives (3.2) should also foster management and enhancement of conservation areas through a conservation management plan based best practice principles and linked to the management of bushfire zones and recreational open space.
Map 1 (3.3) shows a water main going through a conservation area, with a reservoir impinging upon the conservation area. Such developments and consequent maintenance activities inevitably have a negative impact on conservation values, both during construction and long term maintenance activities. FOG asks that more information be provided about the possible impact of this main on conservation values, with consideration being given to alternative routes for the water main that will have a smaller impact on the conservation area.
The ‘Desired Future Character’ (3.4) of the Poplars and South Tralee should include environmental conservation areas up front with explicit reference to endangered ecosystems in those areas – Natural Temperate Grasslands and White Box-Yellow Box-Blakely's Red Gum Grassy Woodland and Derived Native Grassland.
Neighbourhood Structure Plan controls in relation to biodiversity (3.7.4) should not only strive to minimise impacts on threatened species and ecological communities – it should only allow subdivision which avoids any impact on E2 Environmental Conservation areas.
In Section 8.4, FOG notes the intent to ‘Treat run-off from development such that it does not adversely impact on downstream flora and fauna during construction and post development phases’, but is not clear which of the controls will ensure that this does not happen.
Provision in the Master Plan for additional Structure Plan controls for visual and acoustic buffers (8.17) should be augmented with environmental buffers where any development (business park, community centre, recreation, residential etc.) has a shared border with E2 Environmental conservation area and these should be absorbed within the development area. Planning guidelines for this kind of ‘environmental buffer’ can be found in Marshall, A. (2013)1. The purpose of the buffer is to protect conservation areas from weeds, intrusion by humans and animals or blown litter. Such a buffer could also provide required bushfire buffer zones. Landscaping and edge treatment controls in environmental buffer areas should be designed to avoid any adverse impacts on conversation areas (ie plant species found in the conservation areas and no weedy species). Good visual access to conservation areas and educational signage should, however, be provided to encourage greater awareness, understanding and enjoyment of the value of these areas.
FOG believes there is a real opportunity for South Jerrabomberra to become an exemplar of sought after, high quality urban development that has environmental conservation as a starting point rather than an afterthought.
Yours sincerely
Sarah Sharp
President
10 December 2014
1. Marshall, A. (2013). Start with the grasslands: Design guidelines to support native grasslands in urban areas. Melbourne, Victorian National Parks Association. http://vnpa.org.au/admin/library/attachments/PDFs/Reports/Start%20with%20the%20Grasslands_Final%20Draft-1.pdf