Queanbeyan-Palerang Regional Council
council@qprc.nsw.gov.au

 

Dear Mayor Winchester, Deputy Mayor, and Councillors,

Re: Dunns Creek Road

Friends of Grasslands Inc is a community group dedicated to conserving grassy ecosystems in south-eastern Australia, including natural and temperate grasslands and grassy woodlands. Our members include professional scientists, landowners, land managers, and members of the public, all committed to protecting these landscapes for the long term.

The Conservation Council ACT Region is the peak non-government environment organisation for the Canberra region. Since 1981, we have spoken up for a healthy environment and a sustainable future. We campaign for a safe climate, to protect biodiversity in urban and natural areas, to protect and enhance waterways, reduce waste, and promote sustainable transport and planning for our region.

Friends of Grasslands Inc and the Conservation Council ACT Region (together, we or our) submit that Options 1B, 5 and 8 must be excluded from further consideration because they would route Dunns Creek Road directly through the 280 hectare (ha) ‘Wandiyali-Environa Wildlife Sanctuary’ (Sanctuary) which is protected by two Biodiversity Stewardship Agreements (156.3 ha) and a Conservation Agreement (~84 ha) (conservation covenants), all executed under the Biodiversity Conservation Act 2016 (BC Act).

We submit that Option 2C must be excluded from further consideration because it would route Dunns Creek Road directly through ‘Beatty Hill’ (303 ha) which is also protected by another Biodiversity Stewardship Agreement executed under the BC Act.

Stantec, consultants for Queanbeyan-Palerang Regional Council (QPRC), have already advised options 1B, 5 and 8 are very likely unable to lawfully proceed, and recommend against pursuing them. We agree, and argue the same logic applies to require the protection of Beatty Hill.

Biodiversity Stewardship Agreement (offset) and conservation areas are securely protected by s 5.10 and s 5.23(2-3) of the BC Act, respectively. According to the NSW Biodiversity Conservation Trust’s Policy - variation and termination of BCT agreements, the Trust applies the following principles when considering requests to vary or terminate an agreement:

We strongly support not revoking or varying these validly executed and legally enforceable agreements in favour of Dunns Creek Road options 1B, 2C, 5 or 8. We ask QPRC to state these exclusions clearly and unconditionally, rather than leaving it open pending speculative future legislative change.  

The Sanctuary represents more than 25 years of publicly and privately funded conservation work that has carefully restored important ecological functions in critically endangered Box Gum Grassy Woodland (BGGW), home to numerous threatened species. Independent expert ecological analysis indicates the biodiversity impact of options 1B, 5 and 8 has been understated in Stantec’s assessment, which relies on outdated survey data and omits several species now known to occur in the investigation area.

On 31 May 2024, the NSW Government purchased the biodiversity credits generated by the execution of Biodiversity Stewardship Agreement BS0157 over Beatty Hill, through the Credits Supply Fund reverse auction (RA438), for $439,725 (TenderHub online).

We think it sends a terrible message to the people who manage, and who think they have securely protected covenanted sites, that within a decade of the establishment of the Sanctuary the QPRC is prepared to contemplate its destruction.

Our concerns are not confined to the Sanctuary- and Beatty Hill route options. The remaining options (2A, 2B and the No-Dunns Creek Road variants) have not been assessed to a consistent standard. Several options threaten significant grassy-ecosystem habitat, and the road corridor width flagged to at least one affected resident (approximately 100 metres (m)) substantially exceeds the design standard set out in QPRC's own report (29‑36 m). The economic case for a wide, dual-carriageway reserve is weak: every dual-carriageway option performs worse on Benefit-Cost Ratio than its single-lane equivalent, and only one build option, a single-lane alignment avoiding the Sanctuary (option 2A), clears the minimum viability threshold at all.

We do not ask that the road be routed through Fernleigh Park instead of covenanted sites; rather, we the request that the legally unavailable options be removed from consideration and that no remaining option to be preferred until all have been assessed equivalently.

We are concerned about the integrity of the decision-making process itself. Public comments made by the Mayor and the NSW Member for Monaro ahead of the close of consultation appear to signal a preferred outcome, i.e., reviving the Sanctuary-route alignment via anticipated legislative change, while ruling out impacts on Fernleigh Park residents. This pre-empts both this consultation process and QPRC's own consultant's recommendation. Repeating, we ask QPRC to confirm that no option will be pursued on the basis of legislation that does not yet exist, and that the final decision be made transparently based on the current law and evidence.

We request that QPRC:

Our detailed reasoning is set out below. Should any clarification be sought, please do not hesitate to contact us by email at advocacy@fog.org.au

Yours sincerely,

SIGNED

SIGNED

Prof Jamie Pittock

President, Friends of Grasslands Inc

6 October 2026

Dr Simon Copland
Executive Director, Conservation Council ACT Region

6 October 2026

1. Introduction and Summary of Position

We welcome the opportunity to comment on QPRC's Options Review for Dunns Creek Road. We have reviewed the Stantec Options Review Report, its two accompanying economic appraisals, and an ecological analysis prepared in response to the report by the respected local ecologist Dr Michael Mulvaney (enclosed). We have also had regard to the concerns raised by the manager of the Sanctuary, and to public statements made by QPRC's Mayor and the NSW Member for Monaro in relation to this project.

We hold concerns about every option currently on the table, but our central and most urgent concern is this: four of the options, 1B, 2C, 5 and 8, would route a major arterial road directly through areas which are legally protected by conservation covenants. These options should be excluded from further consideration now, not carried forward as "live" options pending some future change in the law. They are not simply environmentally undesirable; they are, on the QPRC's own consultant's advice, very likely legally unachievable. Three options (1B, 5 and 8) would destroy an area of BGGW in Windiyali whose value has been built up over more than a decade of public and private investment, and, as set out below, the ecological value of the site has been understated in Stantec’s report.

We are concerned that:

We ask that QPRC rule out Options 1B, 2C, 5 and 8 outright, and ensure that whatever option is ultimately pursued is assessed to a consistent, current and transparent standard.

2. Background

2.1 A fifteen-year history without a secured corridor

Dunns Creek Road has been discussed for well over a decade without ever being built or its corridor formally secured. QPRC initiated the original corridor study in 2008, and GHD carried out successive rounds of investigation through to 2015, when QPRC adopted as its preferred route "Option 5", an alignment passing east of the escarpment and, on the current mapping, through what is now the Sanctuary. Critically, that preferred route was never gazetted (Sebar 2026). No statutory reservation was placed on the corridor and, in the years that followed, the land needed for it became subject to conservation covenants which are legally enforceable (detailed in Section 3 below).

In the meantime, the project attracted a series of political commitments, without ever attracting the funding, planning approvals or statutory protection needed to make it a reality:

This is the material context for the current options review: for well over a decade, residents of Googong, Jerrabomberra and the surrounding rural residential areas have received genuinely mixed signals from politicians promising the road, from a developer denying it was needed or likely, and from QPRC that adopted then never implemented a preferred route. No landholder acquiring property in this period could have relied on a single, settled position as to whether the road would be built, or where.

2.2 The consequence: environmental protection was established over the "preferred" corridor in good faith

Because the 2015 preferred route was never gazetted or otherwise legally secured, the land in and around that alignment remained available for other uses. Relevantly, the Sanctuary was established following the execution of validly-executed conservation covenants, and following Commonwealth, State and philanthropic investment in restoring it (Section 3.2). None of this investment was made in defiance of a known road reservation; it was made because no such reservation existed. Landholders and funding bodies committed resources to conservation on the understanding, entirely reasonable at the time, that the ‘preferred route’ nominated a decade earlier had not been formalised and had no legal force.

It is only now, as QPRC brings forward a fresh options review, that this history is being treated as an obstacle begging an "offsetting the offset" mechanism floated anecdotally in discussions with the NSW Government (see Section 3.1). We are advised the credits generated by the protection of 156.3 ha of the Sanctuary under Biodiversity Stewardship Agreements were purchased and retired by QPRC to fulfil part of their offset requirements for the construction of Edwin Land Extension. The existence of all four conservation covenants, and the purchase and/or retirement of credits for the three Biodiversity Stewardship Agreements, is sufficient reason to abandon the route options now that would destroy protected areas.

Assuming our intelligence is correct and QPRC have indeed retired biodiversity credits to offset the impacts of the Edwin Land Parkway, it is notable that the Stantec’s report did not ask the QPRC what QPRC think should become of the offset obligation the retirement of those credits satisfied, nor what advice has QPRC received on this point.

According to QPRC’s frequently asked questions on the Dunns Creek Road website: no process has been conducted in NSW to find new offsets for the destruction of any existing biodiversity stewardship site; the NSW Department advised the BCT it would not support development affecting the site; that it will likely be more than a year before QPRC knows whether an “offset to an offset” process can proceed; and that the criteria include consideration of impacts on the predator-proof infrastructure and the Australian Wildlife Conservancy reintroduction programme.

2.3 New residents and properties now face the same uncertainty

The current options review has, by necessity, moved the investigation area south into Fernleigh Park and surrounding rural residential land, because the original alignment is no longer available. Media reporting in September 2026 confirms that the current six route options and associated property impacts were only released for consultation in August, that between three and 22 properties could be affected depending on the option chosen, and that QPRC has indicated it is "too pre-emptive" to say whether or when any land acquisition would occur (Sebar 2026). Residents in this area, some who have lived on their land for close to 40 years, report having had no prior indication that a major arterial road might one day be routed through or immediately adjacent to their homes, and describe the process to date as inadequate (Sebar 2026).

We raise this history not simply as a grievance on residents' behalf, but because it is directly relevant to how QPRC should now weigh the options: a corridor that was allowed to lapse, was not protected, and over which significant, publicly-funded conservation outcomes were subsequently and lawfully secured, should not be revived at the expense of that investment merely because it was once ‘preferred’. Nor should the burden of the road's absence from long-term planning now fall onto residents and landholders who had no reason to expect it.

3. Options Through the Sanctuary Must Be Ruled Out (Options 1B, 5 and 8)

3.1 Legal barrier: Biodiversity Stewardship Agreements

Four parcels of land within the Dunns Creek Road study area are subject to conservation covenants lawfully executed under the BC Act, including land forming part of the Sanctuary. These agreements place restrictions on the land titles requiring conservation in perpetuity. Under section 5.16 of the BC Act, development affecting such land can only proceed with Ministerial consent, and only if one of three conditions is met: the development has no adverse effect on the protected values; replacement biodiversity credits are purchased to offset the loss; or the development is essential for a public purpose of special significance to the State (Stantec 2026, p. 56).

QPRC's own consultants advise that the first and third of these tests are unlikely to be met, leaving only the "purchase of replacement credits" pathway (Stantec 2026, p. 56). This pathway would require an existing landholder to surrender biodiversity credits they already hold, at what the Options Review describes as a likely very costly, complex and legally untested "offsetting an offset" exercise. Local Land Services and the NSW Biodiversity Conservation Trust have already advised QPRC that no impacts to these biodiversity conservation areas are possible. The Options Review Report's recommendation on this is unambiguous: options affecting the sites under conservation covenant should not be pursued "due to the ecological importance of the sites and potential for community concern or opposition” (Stantec 2026, p. 60).

We agree with this conclusion, as far as it goes. However, we are concerned that the Report simultaneously records "anecdotal" discussions between QPRC and the NSW Government about possible future legislative change that could permit these options to proceed (Stantec 2026, p. 56). Our position is that a road option cannot be kept alive on the strength of a change in the law that does not yet exist, has no defined mechanism, and no indicative timeframe. Planning decisions of this magnitude must be made on the law as it stands. If and when any legislative change is actually enacted, it can be considered on its merits at that time; however, it should form no part of the current option selection process, and QPRC should say so unambiguously in its decision.

3.2 What would be destroyed

The scale of what is at stake is set out in detail in documentation about the Sanctuary's history, partnerships and projects. The Sanctuary protects 280 ha, approximately 70 per cent of which is Critically Endangered BGGW, together with native grasslands and around 1.5 km of Jerrabomberra Creek riparian habitat. BGGW is protected to the maximum extent possible under the Environment Protection and Biodiversity Conservation Act 1999 (Cth). The Sanctuary supports 386 identified flora taxa, 128 bird taxa, 28 mammal taxa, 20 reptile taxa and 237 invertebrate taxa, including multiple species listed as threatened under Commonwealth, NSW and/or ACT legislation. Threatened species occurring on the Sanctuary include: Koala, Phascolarctos cinereus (Gula); Gang-gang Cockatoo, Callocephalon fimbriatum; Pink-tailed Worm Lizard, Aprasia parapulchella; Golden Sun Moth, Synemon plana; Hoary Sunray, Leucochrysum albicans var. tricolor; and Small Purple-pea, Swainsona recta.

This is not simply land with vegetation on it; the Sanctuary is one of the best-documented, most intensively restored and most heavily co-invested conservation properties in the region. Since the conservation covenants were registered on the land titles in 2017–18, the Sanctuary has become a Commonwealth "Safe Haven" for threatened species (Sanctuary 2026, p. 2). The Sanctuary has entered into partnerships with more than 30 government and non-government organisations, including the Australian Wildlife Conservancy, the Australian National Botanic Gardens, the Australian National University, University of Canberra, University of Sydney, Jerrabomberra High School, NSW Local Land Services, the NSW Biodiversity Conservation Trust, Greening Australia, and Molonglo Conservation Group, among others. Projects delivered on the property, many funded through Australian Government Threatened Species Recovery Fund, National Landcare and NSW Environmental Trust programs, include predator-exclusion fencing and species reintroduction, targeted recovery programs for the Small Purple-pea, Gula population monitoring across the Southern Tablelands, and multiple riparian and woodland connectivity projects linking the property to the wider landscape between the Brindabellas and the coast.

Any of Options 1B, 5 or 8 would cut directly through this investment. These options would compromise the predator-exclusion fencing that many recovering species now depend on, severing the very connectivity corridors that multiple, separately funded projects have spent years establishing, and clearing sections of Critically Endangered BGGW that cannot be meaningfully replaced elsewhere at comparable quality within any realistic timeframe.

3.3 The ecological impact has been understated, not overstated

We are particularly concerned that the Options Review's environmental assessment substantially understates the biodiversity impact of the Sanctuary-route options, as set out in detail in the accompanying analysis prepared by Mulvaney. In summary:

Taken together, this means the true ecological cost of Options 1B, 5 and 8 is very likely far greater than anything so far quantified in QPRC's own documentation. This documentation gap warrants correction before any further consideration is given to these options.

3.4 The Sanctuary manager's position

We endorse and adopt the concerns raised directly by the Sanctuary's manager in response to this options review. In summary, their paper notes that: the road options passing through the Sanctuary would clear substantial areas of BGGW under legally binding conservation covenants, in contrast to the alternative options [we note: with the exception of option 2C] which intersect no stewardship sites at all; the disruption to north-south and east-west biodiversity connectivity corridors would isolate wildlife populations on either side of the road; the "halo effect" of disturbance (Sanctuary manager, p. 2) extends well beyond the cleared footprint; the Stantec report's conclusion is that the legal conditions for Ministerial consent to develop the covenanted sites are unlikely to be met, without giving weight to speculative future legislative change; and that, based on the Options Review's cost-benefit analysis using the most favourable discount rate, all options through the Sanctuary fail to meet the required economic viability threshold. This finding will be worse, not better, once the currently unquantified costs of "offsetting an offset" and any additional ministerial approval requirements are taken into account.

For all of these reasons, we agree with he Sanctuary manager that Options 1B, 5 and 8 should be formally excluded from further consideration by QPRC, and that this exclusion should be stated plainly and unconditionally in QPRC's response to this consultation process. These options should not be left open pending a hypothetical change in State legislation.

4. Concerns About the Remaining Options (2A, 2B, No-DCR)

Excluding Options 1B, 2C, 5 and 8 does not mean the remaining options are unproblematic. We hold the following concerns about the options that avoid the Sanctuary and other land under conservation covenant.

4.1 Inconsistent assessment across options

QPRC's own Options Review Report does not assess all options to an equivalent standard, which makes a genuine like-for-like comparison difficult. The Report's summary table of biodiversity, Crown land and planning constraints (Table 8-1) quantifies impacts for Option 5, Option 2A and the No-Dunns Creek Road variants only. Options 1B, 8, 2B and 2C are not quantified in that table at all, despite 1B, 2C and 8 also intersecting the Sanctuary and covenanted land, and 2B representing a significant alternative alignment through the southern study area. Option 5 has been treated throughout the Report as "the representative alignment" for the Sanctuary-route options, but this is not a substitute for assessing each option on its own footprint.

We do not consider it appropriate for QPRC to make a route decision, or even to continue narrowing the field of options, while several of the options under consideration have not been measured against the same criteria as the others. We ask that QPRC either commission equivalent, itemised assessment of every option still under consideration, or formally remove from consideration any option that has not been assessed to that standard.

4.2 Impacts on Fernleigh Park and other grassy ecosystem remnants

Avoiding the Sanctuary does not mean avoiding serious environmental and social harm. Mulvaney's analysis makes clear that all of Options 2A, 2B and 2C are themselves "highly likely to have significant impacts" on endangered vegetation and on the Golden Sun Moth, Pink-tailed Worm Lizard, threatened woodland birds and potentially the Koala, Perunga Grasshopper and Silky Swainson's Pea, Swainsona sericea. Much of the route corridor for these options, like that of the Sanctuary-route options, passes through habitat that is known or judged likely to be high-quality Pink-tailed Worm Lizard habitat.

The social impact is also substantial and immediate. Design Option 2A alone is documented in the Options Review as crossing directly through a property dwelling, sheds and a water tank, affecting six driveways along Cavanagh Close, and requiring acquisition of a further dwelling and a large portion of an adjoining block near the Old Cooma Road intersection. This is consistent with, and corroborated by, resident accounts: Fernleigh Park resident Chris Kenyon describes a flagged corridor passing within a few metres of neighbouring houses and reports more than 100 residents attending a single community meeting to object; long-term Googong-area landholder Wesley Kilham, whose family has spent 46 years restoring native bush on his property, has publicly stated that the alignment nearest his block would require his home to be compulsorily acquired, and that his wider community risks being "dissected" by a busy arterial road (Sebar 2026). Media reporting indicates that, across the six currently proposed Dunns Creek Road routes, between three and 22 properties could be affected depending on which option is chosen (Sebar 2026).

Our position is not that these impacts should be traded off against the Sanctuary or Beatty Hill. That is because these options are not comparable given the covenanted lands’ legal protections and irreplaceable ecological value.

Rather, QPRC should not treat the non-Sanctuary options as a ‘safe’ default simply because they avoid land under conservation covenant. They warrant the same level of environmental and social scrutiny as any other option, and should not be nominated as a fallback preference without that scrutiny having occurred.

4.3 Road reserve / corridor width concerns

QPRC's adopted design criteria (Options Review, Table 4-1 and Table 4-2) specify a single, defined cross-section for all Dunns Creek Road options depending only on lane configuration: 29 m plus batters for a single carriageway (one lane each direction), and 36 m plus batters for a dual carriageway (two lanes each direction). This standard is applied uniformly across the design options, which is appropriate.

However, the corridor being flagged to affected landholders on the ground substantially exceeds this design standard. Fernleigh Park resident Chris Kenyon describes the surveyed corridor through his and neighbouring properties as 100 m wide. This is more than double the 36-metre dual-carriageway reserve, and well over triple the 29-metre single-carriageway reserve, that the Report's own design criteria call for. We are not aware of any explanation in the Options Review Report of what this wider flagged corridor represents, whether it is a temporary investigation/property-preservation corridor rather than the final road reserve, or whether it has been applied consistently across all Dunns Creek Road options.

We ask that QPRC publicly clarify: what the flagged 100-metre corridor represents and its relationship to the 29 m / 36 m design reserve; whether the same width has been used consistently for every option under consideration; and why affected residents were not given this clarification at the time flags were placed on their land. Where a wider corridor has been retained purely for planning flexibility, we ask that it be narrowed to reflect the actual design requirement as soon as practicable, given the anxiety this uncertainty is evidently causing affected landholders.

4.4 The economic case for a wide, dual-carriageway reserve is weak

The traffic modelling underpinning the economic appraisals shows relatively modest forecast demand: AM peak-hour vehicle-hours travelled across the whole network are in the order of 1200‑1300 hours, and vehicle-kilometres travelled are in the tens of thousands per peak hour, i.e., not the volumes typically associated with a full dual-carriageway arterial. This is reflected in the QPRC's own consultants' findings: every dual-carriageway design option performs worse on Benefit-Cost Ratio than its single-lane equivalent, and the single-lane Option 2A(s) is the only Dunns Creek Road build option (other than the No-DCR South upgrade) that clears the minimum BCR threshold of 1 at all, doing so only narrowly (1.13 at a five per cent discount rate, 0.87 at seven per cent). Every Sanctuary-route option, single lane or dual, returns a BCR below 1 even before the additional, currently unquantified costs of "offsetting an offset" are factored in.

This matters directly to the road reserve question raised above. If the economic case does not support a dual-carriageway design for any option, there is no principled basis for preserving corridor width, property setbacks or planning uncertainty calibrated to a dual-carriageway (or wider) standard. We ask QPRC to confirm that any corridor preserved going forward reflects the single-lane design standard that its own economic analysis actually supports, rather than a precautionary allowance for a larger road that the numbers do not justify.

5. Process and Transparency Concerns

We are concerned that public statements made by elected representatives ahead of the close of this consultation period risk pre-empting its outcome, and in doing so risk undermining both the credibility of the process and the legal position QPRC's own consultants have identified.

In an ABC Radio Canberra interview broadcast on 4 September 2026, Mayor Winchester stated that QPRC's likely decision would be to pursue the original 2015 preferred route, i.e., an alignment through the covenanted land, including by seeking the NSW Government's agreement to permit development within the offset area, explicitly in preference to a route through Fernleigh Park. In the same segment, the NSW Member for Monaro stated that he does not support a route through Fernleigh Park, that he would like to see the originally designated Dunns Creek Road line revived "for whenever in the future that might happen," and separately acknowledged that traffic modelling shows the road would save affected motorists very little travel time.

We make three points about this. First, both statements were made before the consultation period on this options review had closed, and appear to indicate a preferred direction (a Sanctuary-route alignment) that QPRC's own commissioned Report recommends against pursuing for the legal and ecological reasons set out in Section 3 above. Whatever the good intentions behind ruling out impacts on Fernleigh Park residents, doing so by signalling in the media that a Sanctuary-route alignment is instead the preferred path, ahead of and independently of the public submission process, risks giving affected communities and interested parties the reasonable impression that this consultation is not being approached with an open mind.

Second, the preference indicated relies explicitly on a change to State legislation that, as at the date of this submission, does not exist, has no defined content, and no announced timeframe. This is a point QPRC's consultant’s report treats with appropriate caution by declining to give it weight in formal recommendations. Public comments by elected representatives should reflect the same caution. QPRC should not allow a hoped-for legislative change to shape the practical direction of this process in advance of the consultation closing, still less in advance of the legal opportunity for a change existing.

Third, ruling out one class of impacts (property and amenity impacts on Fernleigh Park) while apparently favouring another (irreversible ecological loss at a nationally significant conservation site) is itself a substantive planning decision that deserves to be made transparently, on the record, against clearly stated criteria. We consider informal signalling ahead of the close of submissions deprives the community of the reasoning it would need to respond. If QPRC considers there are legitimate grounds to prefer avoiding impacts on established residential communities over avoiding impacts on the Sanctuary, that reasoning should be set out and tested through the consultation process, not asserted as a foregone conclusion.

We ask QPRC to state clearly, in its response to this consultation, that:

6. Summary of Requested Actions

We request that QPRC:

  1. Formally exclude Options 1B, 2C, 5 and 8 from further consideration, on the basis that they are very likely legally unachievable under the BC Act as it currently stands, they would destroy conservation assets including with three of these options an irreplaceable, heavily co-invested Sanctuary whose ecological value has been understated in the current assessment.
  2. Decline to give weight to anticipated legislative change when selecting a preferred option, and state this position publicly.
  3. Commission equivalent, itemised environmental and planning assessment of every option remaining under consideration so that QPRC and the community can compare options on a consistent basis, using current survey data rather than the dated 2009 GHD survey and limited desktop assessments relied on to date.
  4. Publicly clarify the road reserve / corridor width methodology, including what the approximately 100-metre corridor flagged to residents represents, whether it has been applied consistently across all options, and whether it will be narrowed to reflect the single-lane design standard that the economic analysis actually supports.
  5. Ensure the decision-making process is transparent and free of predetermination, including by clarifying that public comments made by individual councillors or elected officials ahead of the close of consultation do not represent QPRC's formal position, and by publishing clear reasons for whatever option is ultimately preferred.
  6. Give appropriate weight to the cumulative, decade-long uncertainty faced by residents in both Googong and the Fernleigh Park/rural residential area, given the mixed and at times contradictory information provided over time about whether, and where, this road would be built. Ensure any further consultation is conducted with the transparency this history warrants.

References

Dunns Creek Road - Stage 2 - Connection from Old Cooma Road

Analysis by Dr Michael Mulvaney, Friends of Grasslands

Large, well-connected and nationally important patches of critically endangered woodland and natural temperate grassland occur across the proposed activity area. It is therefore not surprising that the area also supports many threatened woodland and grassland species. Apart from doing absolutely nothing, all options have the potential to result in significant biodiversity impacts, including on communities and species listed as threatened by the Commonwealth, NSW and/or ACT Governments.

Friends of Grassland strongly agrees with the Council’s Dunns Creek Road factsheet, that there is no possibility of development through the registered biodiversity conservation lands and the Wandiyali Wildlife Sanctuary. They are just too important and would be impacted to greatly by road development. Options 1B, 5 and 8 should be rejected by QPRC and not further investigated.

Options 2A, 2B and 2C are highly likely to have significant impacts on endangered vegetation and on the Golden Sun Moth, Pink Tailed Worm Lizard, threatened woodland birds and potentially other species such as the Koala, Perunga Grasshopper and Silky Swanson’s Pea.

Understating of environmental impacts

The Stantec report’s consideration of the Conservation/Wandiyali options, as well of those of options 2A, 2B and 2C, have significantly understated both the degree and scope of likely biodiversity impacts. This is largely because the Stantec report is based upon a now dated 2009 GHD biodiversity survey, a Patmore report restricted to one ACT horsepaddock and a recent desktop review of information based on satellite mapping and limited survey or sighting information across an area largely closed to public access. An under-estimation of impacts has occurred because:

  • Perunga Grasshopper (Perunga ochracea) which is currently listed as vulnerable in the ACT. The Commonwealth is currently seeking public comment on a draft listing assessment of Perunga as a nationally endangered species. There are five records of this difficult to locate species along on near one or more of the road options; and
  • the Varied Sittella and Scarlet Robin both are woodland birds, with the investigation area supporting a very large and well connected patch of suitable habitat.

Biodiversity conservation lands and the Wandiyali Wildlife Sanctuary

It is inappropriate for a road to be built within the registered biodiversity conservation lands and the Wandiyali Wildlife Sanctuary. This is not only for legal reasons, but because these areas comprise one of the largest, best condition and most diverse Box Gum woodland remnants anywhere. This woodland type is critically endangered and the lands in question contain one of the best examples of this this woodland type and arguably is viable and known habitat of more threatened and rare woodland species than other remnants of its woodland type. 

There are now many more species considered threatened, or which are now known from this woodland remnant than was the case in 2009 or were considered in the 2026 review report. These include the Koala, Swanson’s Silky Pea, Button Wrinklewort, the grasshopper Perunga orchracea, and a further suite of woodland birds including the Gang-gang Cockatoo, Southern Whiteface, Dusky Woodswallow, Brown Treecreeper, Little Eagle, Varied Sittella, White-winged Triller, Scarlet Robin, Flame Robin, Hooded Robin, Red-capped Robin, Speckled Warbler, Diamond Firetail and Double-barred Finch. The woodland is also now known to support relatively large populations of Golden Sun Moth and Pink-tailed Worm Lizard.

An indication of the very high condition and biodiversity importance of the wider Wandiyali area is that a further eight woodland plants rare within the ACT –Queanbeyan area occur in the understorey and it is habitat of several regionally rare butterfly and beetle species. Additional regionally rare plant species present include Brachycome willisii, Cullen tenax, Dianella sp. aff longifolia, Glossotina elatoides, Leptorhynchus elongates, Lespedeza juncaea, Polygala japonica and Samolus verelarandi. Regionally rare invertebrates recorded in the woodland include the Moonlight Jewel Butterfly (Hypochrysops delicia), the Aurifera Jewel Beetle (Selagis aurifera) and Grey-furrowed Rose Chafer (Trichaulax philipsii).

The road options through theses areas would significantly disrupt connectivity and would also significantly compromise the functioning of the predator proof fence currently in place around Wandiyali and the viability of susceptible species such as bandicoots and woodland birds that within the sanctuary are recovering from the impacts of predation by exotic predators.

No DCR – northern Option

Should this option proceed, care will need to be taken to avoid works and disturbance within Natural Temperate Grassland and known habitat of threatened fauna, including Golden Sun Moth, Canberra Grassland Earless Dragon and Canberra Raspy Cricket.

Similarly, Box Gum Woodland and remnant eucalypt trees should be protected along Cooma Road.

No DCR – southern Option

Box Gum Woodland and remnant eucalypt trees should be protected along Cooma Road. The patch of woodland at the southern end, within and bordering the NSW Government Royalla Stock Reserve (now an area subject to conservation management) and known habitat of several threatened plants and animals is particularly important in this regard. The nationally endangered Key’s Matchstick Grasshopper (Keyacris scura) is known from the woodland betwwen the road and the ACT border,