Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Environment, Planning and Sustainable Development Directorate Customer Service
GPO Box 158
Canberra  ACT  2601


Dear Sir/Madam

EIS exemption 201800010: Ginninderry, Stage 2 and all subsequent stages in the ACT

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia, included related fauna species. 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 also has members in surrounding New South Wales.

FOG recommends to the Minister that this approval for exemption from EIS not be granted.

FOG has engaged with matters in the Ginninderry development since they have been in the public domain. It has appreciated the privilege of a seat on the Bush on the Boundary consultation group convened through the Conservation Council (ACT) and has actively participated in considerations of that group.

FOG is well aware of the huge amount of environmental assessment, analysis, publication and consultation that has been undertaken by the Development Joint Venture. This urban development planning aspect is far ahead of any other in the region when it comes to environmental values, and the developers deserve community congratulations about the quality and convictions of intentions and objectives stated in their plans. However, the Suburban Land Agency and Riverview Developments are primarily concerned with developing and selling residential blocks, and much of the associated environmental intention still remains to be implemented.

Our understanding is that an EIS exemption can be granted if “recent studies have adequately addressed the expected environmental impacts of the proposal”. FOG’s view is that, to be adequate, the application needs to build on the studies by releasing, and having at least started to implement, plans for management of reserves and offset areas. Offering general statements about intention for the future of these matters is not sufficient - without details of plans, it is impossible for the Minister to determine the full environmental impacts of the Ginninderry development in the ACT or whether offsets in or out of the ACT are likely to be effective.

FOG also submits that the conditions of EPBC Approval for Ginninderry Stage1 issued by the Commonwealth Department of Environment 1-9-2017, and in force until 2067, must surely be the overriding instruction. That EPBC Approval required many actions to occur before any construction was to proceed on Ginninderry Stage 2 and beyond. From FOG's perspective of the set of conditions, the most important action required to occur is the establishment of the West Belconnen Conservation Corridor (WBCC) and particularly of its Management Plan and oversighting Trust.

Only once the WBCC has been planned, endorsed and approved with the range of authorities involved, and is actually operational, can the possible environmental impacts be known in detail. FOG argues that, at least until the WBCC is operational, each of the 18 or so development stages envisaged in the ACT needs to be assessed via EIS.

FOG is particularly concerned about the following issues that are environmentally significant and need to be addressed with agreed and detailed plans as soon as possible:

To summarise, FOG is does not agree that EIS exemption is the way forward. There are extensive issues that require wide participation by not only government and other authorities but also by groups like FOG and individuals with ecological expertise. We cannot say that a merit-track approach to subsequent development stages will necessarily be to the detriment of the environment. However we can advocate that open and transparent planning is likely to give the best result, as onerous as that might be for the Joint Venture. Open process is also consistent with the aspirations of the developer and of government at all levels – consult and engage the community to the maximum extent.

Yours sincerely


Geoff Robertson

29 April 2018