Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Elton Consulting
P.O Box 41
Dickson ACT 2602


Dear Sir/Madam

West Belconnen Strategic Assessment

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.

FOG appreciates the opportunity to be part of the community consultation for this project. This, together with a high level of consultation with experts in a range of ecological and social fields, has enabled broad and deep discussion of the impact of various development options on Matters of National Environmental Significance (MNES) in the West Belconnen area, and resulted in development of clear strategies to achieve optimal outcomes for our grassy ecosystems and dependent species.

In commenting on the Urban Development at West Belconnen: Program Report and accompanying West Belconnen Project Strategic Assessment (Umwelt April 2016), FOG considers the approach taken with the proposed urban development is a leading model for environmentally sound development in the ACT. While much will depend on detailed development proposals, continuity of approach across the border and successful operation of the proposed West Belconnen and Parkwood Environmental Management Trust (EMT), the Program proposed in the Strategic Assessment and the detailed research on which it is based, should maintain environmental values for the site as well as deliver a very desirable place in which to live.

Conservation corridor

The creation of the West Belconnen Conservation Corridor (WBCC) with a ‘nature reserve’ planning overlay in the ACT and an area in NSW with ‘Environmental Management (E3)’ zoning will be fundamental to protection of at least two MNES in the site. The creation of the Corridor should be an outstanding achievement based on a commitment to the site’s environmental values and to detailed research about those values. It will provide connectivity between MNES habitat areas across the site and via offsets, beyond the site. Much will depend, however, on the content and implementation of the WBCC Reserve Management Plan and individual Construction Environment Management Plans to ensure the WBCC thrives.

While FOG accepts that it is not possible at this stage to indicate the precise boundary of the WBCC in the NSW area of the site because it is presently defined by arbitrary property boundaries, it would like to see both the ACT and NSW parts of the WBCC shown clearly in all site diagrams which depict the WBCC. This includes the strip along Ginninderra Creek which is not shown, for example, in Figure 2 in the Program Report and Figure 2-1 in the Umwelt Assessment Report.

Consistently showing the entire WBCC (annotated as to the provisional nature of the NSW section) is important. Because of the long term nature of this development, education of the residents and wider community as to the environmental values and goals will be fundamental to the success of the program outlined in the strategic assessment. A proper understanding of the extent of the WBCC, from the outset and ongoing, will be a key part of that education. It will also inform detailed planning of the various stages of the Development in respect of the urban edge design and appropriate species selection.

FOG strongly supports the provision in the draft West Belconnen Reserve Management Plan (RMP) that bushfire asset protection zones be external to the conservation corridor (p54, Program Report). FOG recommends the Report make clear that all bushfire asset protection zones will be within urban development. The extensive urban edge between the residential development and WBCC shown in the Masterplan raises concerns about potential impacts at the edge on areas of high conservation value such as Ginninderra Falls. In addition to asset protection zones being within the urban development, FOG recommends that the Program Report and the Masterplan identify buffer zones between the urban edge and the conservation corridor and show their indicative width (i.e. distance between the urban edge and the Corridor) and uses that are compatible with protection of the conservation corridor.

FOG endorses the comments by Dr P Gibbons (p.4 Review of West Belconnen environmental offsets ) that minor adjustments to the Corridor boundary would result in more Pink-tailed Worm-lizard (PTWL) habitat being included in the WBCC. FOG understands that many areas of PTWL habitat in the Corridor have recently been identified as Natural Temperate Grassland, another MNES and also a critically endangered community. Smoothing the ‘wrinkled’ edges of the boundary will further optimise the conservation outcomes envisaged for the Corridor.

MNES and Offsets

FOG supports the approach taken in the Program to mitigate and avoid adverse effects on the environmental values of the site generally and on MNES in particular (e.g. passing the sewer tunnel beneath PTWL habitat andinclucing100% Box Gum Woodland within the river corridor). The continuity provided by the Wallaroo Road offset and its proximity to the Dunlop Grassland Nature Reserve is welcomed particularly as it enables a more strategic approach to implementing existing commitments to enhancing connectivity between the Dunlop Grassland Reserve and the Jarramlee offset area.

FOG is concerned that the proposed route for the extension of Ginninderra Drive (pp12-13 Program), which will impact on an existing offset, not set a precedent. FOG wishes to put on record its strong view that in future, offset areas should be regarded as ‘no go’ areas. Nevertheless, FOG accepts that this is the best outcome environmentally and supports the steps proposed to minimise the impact through the design of the extension and the speed limit to be imposed.

FOG agrees with the conclusions in the Umwelt Assessment Report relating to offsets for Golden Sun Moth (p171), Pink tailed Worm Lizard (p.184) and Box Gum Woodland (p.192). The approach to offsets in this case, and the additional actions proposed in the Plan (trialling of translocation methods etc. for GSM and habitat restoration of native grasslands) are strongly supported.

Trust and Management Plan

FOG supports the proposal to establish an independently funded Environmental Management Trust (EMT) to manage the WBCC, and the stated aims for the Conservation Corridor. Costing models for the EMT must be thorough as the future of WBCC depends on the sound operation of the Trust. It must be financially viable and must be able to fund best practice management and support and implement excellent, independent research.

The Reserve Management Plan (RMP) for the Corridor as outlined in the Program Report is also supported and FOG looks forward to seeing the detailed RMP in due course. The proposed ongoing monitoring and reporting to support an adaptive management approach is refreshing to see. Again, the detail will be important. The public annual reports on MNES represent quite a commitment and will play an important role in ensuing all is on track. It is assumed these reports will go to the Trust for consideration as well as being made available publically via the internet. The five yearly review of the program, requiring consultation and endorsement, is strongly supported.


Yours sincerely



Naarilla Hirsch
Advocacy coordinator

10 June 2016