Territory Planning Authority
City and Environment Directorate

Re. The Draft Guide for tree removals on design grounds

Friends of Grasslands (FOG) is a community group dedicated to the conservation of grassy ecosystems in south-eastern Australia - natural temperate grasslands and grassy woodlands. FOG advocates, educates and advises on matters to do with the conservation of these ecosystems, and carries out surveys and on-ground work. FOG is based in Canberra and its members include professional scientists, landowners, land managers and interested members of the public.

FOG considers that overall, the Draft Guide for tree removal on design grounds (Guide) achieves an acceptable balance between planning outcomes such as densification and the need to maintain the urban treescape and urban biodiversity.  We believe biodiversity could be better protected by strengthening some elements of the Guide to ensure that applications under the Guide, and also decision making, are ecologically informed.

The Guide should include a section summarising the Urban Forest Strategy 2021-2045^[1] so that applicants better understand the importance of the urban forest, especially the role of mature native trees, the fauna it supports and benefits such as providing shade and cooling.  It is easy to lose sight of the strategy’s important desired outcomes as the legislative and regulatory landscape evolves over time.

FOG is pleased that remnant trees, protected matters and the removal of trees associated with greenfield estates are excluded from this new process.  FOG considers that the policy could include further guidance for users on two matters, the ecological value of the tree and connectivity and ecological corridors.

Ecological value of the tree

While Table 2 in the Guide provides some examples, more clarity is needed on how this is assessed and what information or datatsets the Government will rely on. FOG is most concerned about impacts on urban-adapted woodland bird species that rely on tree and large shrub cover.  There are some contradictions in the table surrounding tree characteristics (for example, a pest species like Cootamundra wattle is also a native tree and a habitat tree).  While remnant trees are specifically excluded from this process, one characteristic favouring retention is ‘Tree provides habitat value for protected fauna or is part of a naturally occurring ecological community’ which could be further explained for users.  The Government should consider whether mature native trees should also be excluded from the process.

Connectivity and ecological corridors

Connectivity should be an important consideration in assessing tree removal applications under this process but go further than consideration of ‘important ecological corridors’ in the blue-green network.  The ‘macro’ ecological corridors in the current mapping are mostly confined to green corridors along public unleased land and underestimate intra-suburban connectivity.  Consideration should acknowledge the importance of trees as stepping stones throughout urban areas and also include consideration of connectivity for specific threatened species rather than just the species groups in the current mapping.  An assessment of local intra-suburban landscape connectivity should be included.

Assessment pathway

FOG suggests that the assessment pathway should include an appropriate trigger (such as proximity to a known remnant box gum woodland patch) that would escalate the decision to the Conservator’s office, if not already factored in.

Further matters related to the Urban Forest Act and urban biodiversity

FOG urges the Government to:

• further refine and add to the Urban Ecological Network mapping especially for protected species and species in decline;
• invest in more restoration of public unleased land, especially larger areas that could constitute core habitat and where fragmentation has been identified;
• on box gum woodland and natural temperate grassland remnants, community conservation groups and land managers should be able to readily remove some trees with minimal processes and without administrative charges;

• Trees are inappropriate and should be able to be easily removed from within and on the boundaries of, e.g., from road reserves abutting, natural temperate grasslands where native flora may be may shaded out or mulched by leaf litter.  Further, by providing perches for birds, predation of threatened insect and reptile flora may increase.  
• In box gum woodlands, invasive non-local trees can outcompete native flora.

• make any future ‘Conserved Areas’ identified in line with the forthcoming Nature Conservation Strategy, that are within a ‘built-up urban area’, exempt from the Urban Forest Act to facilitate appropriate conservation management by both Government and volunteer groups.

Yours sincerely

SIGNED

Professor Jamie Pittock

President, Friends of Grasslands

7 August 2026

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Reference

[1] ACT (2021) Urban Forest Strategy 2021-2045, https://hdp-au-prod-app-act-yoursay-files.s3.ap-southeast-2.amazonaws.com/5616/1710/4101/Urban_Forest_Strategy_2021-2045.pdf