Re. DA 202341697 - Riverside pavilion

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 native 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 is generally highly supportive of this proposal in the Ginninderry Conservation Corridor. It undoubtedly is the result of important consultation with many advisory groups, not least the Ginninderry Aboriginal Advisory Group. The planned building should produce an exciting facility suited to its surrounds, offering a great opportunity for the public to access the Corridor and learn about its major cultural, environmental and conservation values.

FOG would like to highlight three points specific to this development, and one comment regarding the consultation process. It is hoped that this comment may aid in improving the accessibility of future development applications submitted by the Ginninderry group.

1. Offsets (section 8, document SUPP-202341697-EIS-ECOLOGICAL_IMPACT-01)

FOG is pleased to note the detail given. FOG fully supports the revision to utilise 34.2 ha to offset the impact of the development on 1.03 ha of Natural Temperate Grassland of the South Eastern Highlands (NTG-SEH). Additionally, FOG supports the recommendation that restoration activities be specifically tailored to the offset area. However, while the report states that the goal of achieving restoration to a pre-European benchmark is not considered feasible for NTG-SEH, FOG would like to see clear justification for decisions made to achieve a less clearly defined standard. For the impacts on 0.18 ha of Box-Gum woodland, where it seems 12 planted trees will be removed, FOG expects that offsetting will occur via the improvement of other MNES areas. While the condition of the understorey within the impacted area is unknown, FOG encourages the planting of shrubs in the offset area to provide habitat for birds, insects and other species dependent on that functional component.

FOG also notes the emphasis given to PTWL impacts. Generally, the suggested mitigation and offsetting treatments are acceptable. However, the item of Habitat Crossing (single location shown in Fig 6 on p28) is surprisingly underdeveloped. FOG did see the plan and section in the document collection (PLAN-202341697-FAUNA_CROSSING-01 and SECTION-202341697-FAUNA_CROSSING-01) but was able to decipher little about operational detail. Clearly such a structure is a “least-worst” solution to a road permanently severing an area of PTWL habitat, but FOG is unaware that such constructions have been proven to assist PTWL movements. It is hoped that scientific value (as per section 8.2, ‘Pink-tailed Worm-lizard', paragraph 2) would be added to a structure in this case by detailed and prolonged monitoring of its effects and publication of results, thereby informing all considerations for similar future works. Similar comment applies to the indicative locations nearby for 5 sites of habitat restoration (fig 6 again) to improve connectivity.

FOG looks forward to finding, if the DA is approved, that such issues are managed in a clear and informed manner.

2. Species proposed for native plantings in (document SUPP-202341697-LANDSCAPE_DESIGN-01)

FOG considers the planting list to be mostly appropriate for the GCC, an environmentally sensitive location. It is also nice to see ‘bush tucker’ selections included within this list. However, FOG would like to highlight the following species as inappropriate:

In ‘Shrubs’, Grevillea rosmarinifolia should not be planted – it is regarded as a weed of grasslands and woodlands in temperate regions. See Weeds of Australia website and ACT Plant Census, which notes it as exotic and naturalised.

In ‘Grasses and Aquatics’ - Cyperus exaltatus is quite an uncommon native on Southern Tablelands and should be avoided. Additionally, Paspalum distichum is ranked exotic and naturalised in ACT Plant Census.

3. Landscape design (document SUPP-202341697-LANDSCAPE_DESIGN-01)

FOG found this document difficult to navigate because it is unclear how much of its detail is general in nature. An important example is the tree strategy on p77. There are clear zones of shade sensibly planned for carpark, nature play area, and learning/education hubs (LSCAPEMASTER-202341697-ILLUSTRATIVE-01). However, the design also includes (p45) “Dense native vegetation at pathway intersections”. FOG suggests this statement be clarified or reconsidered due to the fact that it may encourage amenity plantings that contravene the Bushfire risk assessment (BUSHFIRERISK-202341697-01) and are incompatible with the stated aim of regenerating native grassland areas (areas coded 3 in the LSCAPEMASTER). The density of trees proposed along paths (best seen PERSP-202341697-03) would lead to the creation of open grassy woodlands, which are quite different in function to a native grassland. Additionally, by encouraging dense plantings, it may be difficult to satisfy the maintenance criteria in the Bushfire risk analysis in areas close to APZs. Specifically, that woodland should have 3-5 m canopy separation, that grassland and open woodland should be slashed to and kept at 200mm high every bushfire season, or that no fuel ladders be created.

Finally, there is a general indication in several documents of the package that the roof of the building could be covered by native vegetation connected directly to the surroundings. FOG could find no analysis whether or not there is an APZ risk or possibly benefit (through potential protection from ember attack) from this green roof feature. FOG is otherwise generally in support of the innovation for this feature, especially if the roof can include many native grassland wildflowers supporting native pollinators.

4. DA package as a whole

Not for the first time, FOG points out that the documentation for major projects such as this actively discourages the public from connecting with and commenting about the respective proposal. FOG points out that the document package on EPSDD website comprised 132 documents, very few of them with names that indicate what detail is contained within. Furthermore, it is unhelpful that the package is sorted alphabetically by filename. It would be far preferable to have substructure, with some level of information about the listed files. FOG consumed many hours searching back and forward through the package to find specific information.

As FOG pointed out previously, it understands that major packages have to contain a wide range of information. However, it would greatly assist the public to navigate the packages through the institution of a requirement for the proponent (or EPSDD) to prepare a 1-2 page executive summary with appropriate indexes and cross references, with the potential to include hyperlinks to specific documents. The public cannot be expected to decode all relevant information via such terse sentences. A prime example, in APP-202341697-03, is the full description of your proposal “Construction of site access and vehicular circulation routes; construction of the Riverside Pavilion comprising a single storey building with total 1,168m2 GFA; construction of surface car parking; site servicing; landscaping including children’s play area; fencing; lighting; signage and associated site works.”

Yours sincerely

 

Sarah Sharp

Advocacy convenor

16/8/23