Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Executive Director
Key Sites and Regional Assessments
Department of Planning, Industry and Environment
Locked Bag 5022
Parramatta NSW 2124


Dear Sir/Madam

Snowy Mountains Special Activation Precinct

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 has many members in surrounding New South Wales. Its members include professional scientists, landowners, land managers and interested members of the public.

Snowy Mountains Special Activation Precinct: Draft Master Plan June 2021

Principles: Environmental resilience (page 25)

FOG completely supports the objective to “Protect environmentally sensitive areas”, and the proposed partnership with the National Parks and Wildlife Service and Snowy Monaro Regional Council to develop site-specific biodiversity mapping for sub-precincts. However, we are concerned about the reference to an offset strategy where avoidance and mitigation cannot be achieved. FOG is not convinced that offsets do, in fact, lead to no net loss of the species or ecosystem being impacted. Our view is that, in many cases, there is a net loss of the species or ecosystem across the landscape. In this regard, the Independent Review of the EPBC Act – Final Report, October 2020 (Professor Graeme Samuel AC) observes that “Some proponents see offsets as something to be negotiated from the outset, rather than making a commitment to fulsome exploration (and exhaustion) of options to avoid or mitigate impacts.” This objective needs to clearly state that offsets would only be considered in extraordinary circumstances.

Principles: Carrying capacity (page 28)

FOG supports this principle in general. However, the wording “Foster the protection of key environmental, social and cultural values via an appropriate carrying capacity framework” implies that important but not “key” environmental values will not be considered. It is essential, particularly in the face of climate change, that all environmental values be protected and be taken into account when developing the carrying capacity framework.

East Jindabyne Alternative Structure Plan Option

In relation to the East Jindabyne Alternative Structure Plan Option, FOG notes that the alternative Structure Plan proposes to develop part of the East Jindabyne area while only retaining small separated areas of moderate to high diversity Snow Gum woodland and offsetting losses due to the development proposed. FOG is opposed to this for two reasons.

The first is that fragmenting such areas of woodland will, in the long run, lead to a decrease in their biodiversity values and eventual demise. A fundamental component of good urban design that will enhance the protection and management of nature conservation areas that abut urban areas is: (1) to maximise reserve size, (2) to minimise edge effects and (3) to not increase fragmentation within the conservation area. Likely edge effects of the proposal include nutrient and sediment run off into the adjacent conservation area, spread of weeds and garden escapees, predation by pest birds and mammals, increased trampling by people and other recreational use. As well, fragmentation reduces gene flow between different Snow Gum woodland patches. With regard to the references to “High value vegetation incorporated into future road reserve and / or residential development” and “Retained high value vegetation integrated into medium density residential development” in the two options proposed, any high value vegetation incorporated into a residential development is unlikely to retain its values in the long term so should be regarded as a loss.

The second is that we have been informed that much of the headland is Poa/Themeda grassland. Despite Natural Temperate Grassland and similar grassy ecosystems being listed as critically endangered, the emphasis in the structure plan appears to have shifted from conserving the grassland areas to retaining some patches of Snow Gum woodland and using the grassland area for “passive recreation, walking and cycling trails, seating nodes, small scale nature play”. While there is reference to “conservation of grasslands”, the area to be retained is not large and will be impacted by all of the other proposed uses. As well there is reference to offsets, presumably because of destruction of grassland areas by the proposed development. It is essential that the biodiversity values of the entire area be assessed fully by a grassland ecologist and that no impacts on any endangered grassland areas occur by neither the residential development nor the recreation uses proposed. Offsets should not be used when it is possible to avoid any impacts on listed threatened ecosystems.

In conclusion, FOG’s view is that the biodiversity values of the East Jindabyne headland area should be left intact and enhanced rather than destroyed, as will inevitably occur with the proposed structure plan options.

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

13 August 2021