Friends of Grasslands
supporting native grassy ecosystems
PO Box 987, Civic Square ACT 2608
phone: 02 6288 2413 or 6241 4065
email: advocacy@fog.org.au
web: http://www.fog.org.au
Applications Secretariat
ACT Planning and Land Authority
PO Box 365
Mitchell ACT 2911
email:
actpla_customer_services@act.gov.au
Dear
Sir/Madam
Submission on Development Application
201120676, Block 1171 Weston Creek (suburb of Coombs)
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, but its membership
base encompasses people from within all of south-eastern Australia. Its more
than 200 members include professional scientists, landowners, land managers and
interested members of the public.
FOG welcomes the opportunity to respond to the Development Application. However,
it is with some frustration and concern that Friends of Grasslands’ previous
comments on this development have not been taken into account in the current
application. Generally, our concerns relate to the lack of the strategic and
correlating process that we believe should be undertaken, to provide details on
the management of recreation, bushfire hazard and conservation within the
riparian zone in relation to Block 1171 proposed development. Specifically, our
concerns relate to the lack of inclusion of recommendations provided previously
by Friends of Grasslands in this development.
In the context of the above concerns, therefore, we submit the following
comments.
Bushfire Risk Assessment Report
We welcome the inclusion of the Bushfire Risk Assessment Report with this
development application, particularly as no information on bushfire risk has
been previously been made publicly available. While generally we support the
report’s recommendations, we note with concern the following:
a)
The assumption that it is acceptable for the whole of the Outer Asset
Zone (OAZ) to be within the riparian corridor, extending over the other side of
the river in some areas. FOG does not support the OAZ being within the river
corridor. FOG does not believe that bushfire mitigation works will be able to be
undertaken within the riparian corridor in such a way that conservation values
will be retained (recognising as stated in the report that grassland does
require biomass management to retain values). As stated on many occasions, FOG
believes that intensive bushfire mitigation works will compromise conservation
values, including reduction in habitat values for the Pink-tailed Worm Lizard,
general habitat disturbance and increased weed invasion. We do not support using
stock grazing along the corridor to reduce biomass. We believe that in this
location grazing will reduce water quality, spread weeds, create tracks which
will become recreation tracks, and increase erosion.
b)
FOG
disagrees with the recommendation in the report that the riparian area does not
become a reserve. While no reasons for this lack of support are given, we assume
it is because the authors of the Bushfire Risk
Assessment Report believe managing the riparian corridor as a nature
reserve would compromise bushfire management actions. FOG fully supports the
establishment of a nature reserve along the entire length of the Lower Molonglo
Corridor (see below).
Urban
open space within Coombs
There
is a lack of detail on how open spaces within the suburb of Coombs and in the
inner asset zone will be used to reduce inappropriate recreation within the
river corridor. We would like to see details of planning for active recreational
activities, including dog exercise areas, bicycle paths and active play areas
for children within the inner asset zone and within other urban open space.
It is
with some concern that we note that there are 27 large blocks that are being
planned to be developed on the northern peninsular in Coombs. While undoubtedly
these will provide good return for money for the ACT Government, we believe that
such an area would be better used as open space, allowing all members of the
public to enjoy the views, undertake active recreation, provide a buffer zone to
the riparian corridor and provide an adequate fire-fighting edge on flat land
rather than the extremely steep slopes of the river corridor in this location.
We are very concerned that the fire danger to
residents within this area is very high.
Planting list
The
species identified for planting within the suburb of Coombs in urban parks and
in the streets are generally supported, but they should not be planted in the
buffer of the river corridor, including within the inner asset zone on the edge
of the suburb. While we understand that the Chinese Pistachio is a very
attractive small tree, we have particular concerns that seeds are spread by
birds, and that there is significant suckering as well. We recommend limited use
of this species. Both Quercus coccinea and Ulmus parvifolia should
be planted away from watercourses. All plants within the suburb should be chosen
on the basis that they have low flammability.
We
recommend that consideration be given to species used for grassing the inner
asset zone that are green in summer and require less mowing. Annual grass
invasion will need to be controlled, as will African Lovegrass, both of which
provide significant fuel in summer.
Molonglo River Nature Reserve
FOG
supports the establishment of a reserve in the Lower Molonglo River Corridor. We
believe that a Management Plan should be produced before any residents move into
the suburbs adjacent to the river corridor to guide and direct revegetation,
weed control, development of tracks and trails, protection of native habitat,
utilisation by residents and bushfire mitigation actions.
Resources will be required to ensure there are adequate numbers of rangers to
patrol and maintain the river corridor and provide education to the public. A
Parkcare group should be established as soon as possible to involve the local
residents. Bush on the Boundary (Molonglo) should be consulted and involved in
the planning process.
Resources will also be required to establish monitoring of the values in the
corridor. Monitoring should be established before any changes occur, and should
include monitoring of threatened species, flora and fauna habitat diversity,
landscape function and weed invasion. The resources and processes required to
remediate loss of diversity should be identified up front.
Conclusion
FPG
believes that the ACT Government is pushing too hard to develop as much land as
possible within the proximity of the Molonglo River, and that this amount of
land being developed will inevitably lead to degradation of the corridor’s
ecological values, or if not, to enormous resource requirements in the long term
to maintain values in the corridor. We believe that the residential boundary
should be pulled back to provide an adequate buffer to the corridor which will
mitigate against the need to undertake high intensity bushfire management
actions in the riparian corridor, protect habitat and provide for a range of
high intensity recreation activities outside the corridor.
Sincerely yours
John
Fitz Gerald
President
30
October 2011
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