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
Environment, Planning and Sustainable
Development Directorate
Email:
Terrplan@act.gov.au
Dear Sir/Madam
Reference: Draft Integrated Plan for Red Hill Nature Reserve and Surrounds, November 2019
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 its members include professional scientists, landowners, land managers and interested members of the public.
FOG welcomes the draft Integrated Plan for the Red Hill Nature Reserve and its surrounds, believing that the plan sets out, with some reservations expressed below, the information required on which to make the decisions about future developments in the area covered by the plan. The maps provided are most helpful. FOG is also pleased with the consultation that has taken place to arrive at this point, including the sessions held to discuss the draft plan and the series of meeting held prior to the Legislative Assembly resolution. FOG supports many of the recommendations expressed in the plan. Our submission focuses largely on ecological issues and hence the absence on comments on some matters discussed in the plan, beyond our competence, should not be seen as endorsement.
General comments
FOG acknowledges that the Federal Golf Club’s survival is predicated upon it
finding an efficient and economical watering system, which is beyond its current
resources. FOG acknowledges that the proposed club-retirement village
partnership, to include a retirement village with a maximum 125 units on the
current golf course, provides the club with an ideal solution. The
proposal is likely to provide a pleasant residential village for its residents
consistent with a good environmental outcome - the proposer has indicated that
landscaping would extend and enhance the surrounding ecological values. Should
the proposal not go ahead, the Golf Club might be forced to close its doors or
seek a less favourable partner. Should the club close, the area occupied by the
golf course could be returned to its former woodland structure, an outcome which
FOG would support. However, the broader community might find this an
unacceptable option.
While what is proposed is likely a good outcome for both the club and the proponent, the proposal is at the cost to existing ecological assets, especially as the proposal requires constructing an additional road via Kitchener Street. FOG considers that answers to the following issues should be addressed:
- water. During the earlier consultation period, FOG raised the question about access to bore water. Water is becoming a more scarce resource. What ACT government policy exists to ensure that bore water is charged for and efficiently used?
- fire risk. It is essential that all asset protection zones be within the development footprint and not impinge on areas of high quality vegetation.
- retaining biodiversity assets on site. When the ACT government provides a lease, what are the obligations on the lessee to maintain and enhance the biodiversity assets on the site?
- environment offsets. The proposal will result in the loss of biodiversity assets, although in the longer term better management of the whole area might lead to a recovery of biodiversity. A common practice that occurs when biodiversity is lost, is that an offset package is placed on the table. Should this be considered in the current proposal?
Ecological values within and around Red Hill Nature Reserve and links to other areas
FOG supports proposals in the plan to protect the ecological values within and surrounding the Red Hill Nature Reserve as well as formalising existing links and corridors to other open space areas. In particular, it supports:
- Transfer of land to Canberra Nature Park. In principle, FOG supports the transfer of the area indicated in Map 19 from the existing golf course to Canberra Nature Park. This in-principle support is made on the basis that FOG is not aware of the exact ecological values of parcel of land and whether it should be larger or smaller and/or other areas should be transferred.
- Retention of Gowrie Drive in its present form. FOG supports the statement on page p 46, that “Gowrie Drive is a winding, single lane road which provides access to the Federal Golf Course. In order to protect the ecological values adjoining this road, any future expansion or upgrades of this road should be limited to maintenance and safety works. Traffic generation from future development at the Federal Golf Course should remain within the existing capacity of this road.”
- Maintaining existing vegetation links through the golf course. As the plan points out, the Federal Golf Course shares an extensive boundary with the Red Hill Nature Reserve, contains areas of high quality vegetation, and provides links and corridors between the surrounding urban open space and the nature reserve (as indicated on Map 16). FOG agrees that this provides an opportunity to formalise the corridors - some of the broader corridors are in Map 22. FOG also considers that these arrangements should ensure that areas of high quality vegetation are maintained and enhanced. These arrangements should be a component of any development proposal.
- Location of club house, residential village, new golf greens, and new access road. FOG supports the view that any development or re-development should minimise the impact on existing ecological values and care should be taken to maintain existing areas of high quality vegetation and protect trees with hollows. It accepts that should the residential development occur it will be necessary to provide a new access road. However, any new road and other developments that impact on ecological and community amenity (open space) values should be the subject of an offset proposal.
Capping of the old Deakin tip
FOG supports the proposal to cap the old Deakin tip and to seed the surface with native grasses. Concerns about asbestos and possibly contamination are issues that obviously need to be considered.
Rezoning of Deakin Section 66 from the Territory Plan
FOG strongly supports the proposal that the vacant land behind the Deakin Offices and Telstra exchange should be rezoned in recognition of its ecological values and the opportunity taken to remove contamination. It also supports undertaking the remedial work with that taken in relation to the capping of the Deakin Tip. However, FOG queries why the land should be formalised as open space buffer rather than included in Canberra Nature Park.
Yours sincerely
Geoff Robertson
President
30 December 2019