Environment, Planning and Sustainable Development Directorate

ACT Planning System Review and Reform Project | YourSay ACT

 

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.

Summary of major concerns

Aspirations vs reality

Protection of heritage and biodiversity values: FOG acknowledges and fully supports the aspirations/objectives/big drivers that recognise the importance of environmental matters, succinctly stated in each of the draft District Strategies (e.g., p. 41, Draft Belconnen District Strategy):

The protection of heritage and biodiversity values is mandated by ACT Government and Australian Government law and should be a primary consideration in all planning and development decisions.

However, the descriptions, district maps or Territory Plan do not demonstrate how this primary consideration can be implemented. There is no identification of how the areas of heritage and biodiversity value outside the reserve system will be protected. Frequently, the blue-green network is identified as primarily a recreational and active-travel network. The maps fail to identify many conservation areas, some have overlays of development options. How heritage values, particularly Indigenous heritage values, will be protected are not identified. Our submission aims to provide recommendations to ensure this mandate will be met.

Further, if protection is mandated, then protection … must be a primary consideration in all planning and development decisions.

Draft Territory Plan

Land use zones do not exist to identify or protect off-reserve areas of conservation significance. The proposed (equivalent to existing) land use zones are human-centric, emphasising ‘importance as a visual backdrop and a unified landscape setting’ in the non-urban zone (NUZ3) or ‘contribute to the recreational or social needs of the community’ (PRZ1). These land use zones are outdated, given the areas of Critically Endangered Ecological Communities and threatened species that occur outside the reserve system require legislative protection if the mandate above is to be implemented.

Draft district strategies

The draft District Plans are not fit for purpose:

The blue-green network does not distinguish between highly modified mostly recreational open space and areas of conservation value by area, by use or by protection mechanisms.

Conservation Areas are identified as a category on the maps, but in the majority of maps of the blue-green network, are only applied to areas that are designated nature reserves. The term is neither defined in the glossaries nor identified as a land use category or overlay. We suggest that the definition of the Conservation Areas should be:

Detail in the district maps: We believe that as they stand, the district maps are not fit for purpose, as legal documents. Part C, Planning Principles of the Territory Plan, states: District strategies state the long-term planning policy and goals for districts, consistent with the Planning Strategy (Section 38 of the Planning Act 2023). The District Strategies do not provide adequate coverage or scale or accuracy to demonstrate that they can achieve this objective. A higher level of detailed mapping and explanation is required to ensure the long term policy and goals for districts are transparently clear, accurate and reflect intentions. 

There are inconsistencies between the Territory Plan maps and the District strategy maps, that include (but may not be limited to):

• Coombs: there is a Future Urban Area overlay on the peninsula on the Territory Plan maps in Part A. Administration and Governance; the decision has been made that this will not be developed as a residential area.
• Gungaderra Nature Reserve is identified as a Future Urban Area in the Territory Plan maps in the document, Part A. Administration and Governance.
• Lawson Grassland has been identified as suburban land in the Territory Plan maps in the document, Administration and Governance. This land, the former Belconnen Naval Base, is Commonwealth land, administered by Defence Housing Estate. It is not Territory land, and it has very high conservation values with a large area of critically endangered Natural Temperate Grassland and a number of nationally and ACT listed threatened species. 
• Figure 14 of the Economic access and opportunity across the city has incorrectly included part of Mugga Mugga Cottage and Grassland (between Hindmarsh Drive and Mugga Lane).

Key definitions are omitted in the glossary including but not limited to: conservation area; biodiversity conservation network; future urban area.

Further input by community groups

FOG is a major advocate for grassy ecosystems and their threatened species and other biota, and we have been involved for many years in extensive collaboration with Government over conservation matters pertaining to grassy ecosystems. FOG and other community stakeholders have considerable knowledge of the ACT’s ecological landscape that can provide more detail in relation to the existing natural values that should be included in the blue-green network.

Summary of major recommendations

Recommendation 1. The draft Territory Plan and draft District Strategies should be finalised only after amendments are made and following further consultation, and include consideration of the recommendations of the Inquiry into the Planning Bill (22 December 2022) relating to environmental matters (recommendations 38 to 46).

Recommendation 2. Demonstrate that primary consideration is provided to the protection of heritage and biodiversity values in all planning and development decisions.

Recommendation 3. Define Conservation Areas as:

Areas of conservation value are areas that are outside the reserve system that contain threatened ecological communities, habitat for threatened species and/or important links between remnants and natural or restored waterways. These areas include public (unleased) and leased land, urban and rural land.

Ensure there are opportunities to incorporate new Conservation Areas if:

1. other matters are identified as threatened under the EPBC Act or NC Act;
2. areas are identified as containing existing matters of environmental significance; or
3. other areas of cultural, scientific or heritage value are included.

Recommendation 4: Include in the Territory Plan an additional land use zone for Conservation Areas to ensure areas outside the reserve system that are of high conservation and/or heritage value and connectivity significance are provided protection, while at the same time, allowing for compatible land uses to be retained.

Recommendation 5. Revise the draft district plan maps to identify all Conservation Areas and remove inaccuracies and discrepancies between the District maps and the Territory Plan maps.

Recommendation 6. Provide the opportunity for FOG and other stakeholders to identify important remnants of grassy ecosystems as off-reserve Conservation Areas on both leased and unleased land.  

We elaborate on these issues in the following sections of our response.

We welcome the opportunity to discuss these issues further with you. 

Yours sincerely

 

Professor Jamie Pittock
President

3 March 2023

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Section 1. Overall comments

The opportunity exists in this Planning Review to fully implement the stated guiding drivers identified in the District Strategies, to ensure the natural and cultural values of the city and the Territory are effectively protected, valued and conserved, according to the mandate (above).

Our comments on the District Strategies and Territory Plan are centred around achieving this. We believe that the potential is there for the ACT and Canberra to be internationally recognised as a leader in planning for the future, through implementing a balanced plan that truly protects, respects and values natural and cultural assets, while achieving economic and social aspirations.

ACT’s planning design and implementation should promote a vision of Canberra as a City in Nature (reflecting a more up to date concept of the Bush Capital) that recognises the natural landscape and the enhancement of that through the use of indigenous plantings, based on sound ecological principles. The Report on the Inquiry into Nature in our City, published February 2020, should be referenced in the strategy.

Too often the concept of ‘nature’ is mistakenly correlated with natural landscapes. While ‘nature’ may be green or blue spaces, usually with trees present, they lack the complexity, diversity and function of ‘natural landscapes’. These areas contain varied diversity of ecological and vegetation communities, many threatened and rare species, far more complex functionality, and frequently contain first nations heritage. Regrettably, when “nature” is used in many planning documents, what is promoted is a dumbed-down view of nature, devoid of reference to the indigenous vegetation and fauna that we live amongst and influence.

The Plan and Strategies must be significantly tightened and better presented to ensure understanding and compliance by users. Every word needs to count, as it will be used to argue for development applications to be allowed or disallowed.

The Biodiversity Network

The paper, A Biodiversity Network for the ACT (BRIEFING_BIODIVERSITY NETWORK _Final_Version_December (conservationcouncil.org.au), jointly prepared by the Conservation Council ACT Region and Friends of Grasslands, provides a clear guide to integrate protection of biodiversity in the ACT across all tenures and land uses, to include areas outside the nature reserve system, especially but not exclusively, those containing remnants of threatened communities, threatened species, or other conservation values including remnant mature native trees.

The Biodiversity Network in the paper strives to implement a particular category of the International Union for the Conservation of Nature (IUCN) for a protected area network. This is titled ‘Other effective area-based conservation measures’ (OECM). The category identifies that OECMs may be managed for many different objectives, but they must deliver effective conservation. They may be managed with conservation as a primary or secondary objective or long-term conservation may simply be the ancillary result of management activities (IUCN, 2019)[1]. This approach is tenure free. We believe that the opportunity exists to identify Conservation Areas regardless of tenure and on leased as well as unleased land, that meet the OECM criteria, where compatible land uses may continue, but for which legislative protection, as well as conservation management, are assigned. The Biodiversity Network would encompass not only the Nature Reserves and the Namadgi National Park, but other areas, which in the majority of cases would maintain their current land use.

We have noted the use of the term the ‘Biodiversity Conservation Network’, and the category ‘Conservation Area’ identified on the blue-green network maps. These should be defined in the glossary, so that it is clear whether they do or do not refer to the same concept we propose. We also note, with one exception, that on the maps only existing nature reserves are identified as conservation areas. We believe there has been an attempt to meld the concepts identified in the Conservation Council/Friends of Grasslands paper, but that the draft will not achieve the goals identified in the paper.

Section 2. Draft Territory Plan

Suggested wording changes in our submission are indicated in blue.

Proposed New Territory Plan – Supporting Report

Loss of Overlays

As stated on Page 37 of the Supporting report, the overlays “are not specific assessment requirements for a development application”. However, the management objectives in Schedule 4.2 of the Planning Bill 2022, place restrictions on the type and level of development that can occur in various zones. In terms of having a clear, easy-to-use planning system it is important that the existence, location and relevance to planning decisions of the overlay zones is widely known and readily accessible, not just identified in ACTMapi. For example, the management objectives for a wilderness area would exclude or place severe restrictions on the development of infrastructure or ancillary services or ecotourism, while the primacy of conservation land use is the key objective for national parks and nature reserves.

Reference to the management objective for public land including Conservation Areas should be made in the strategic district documents.

C.2 Statement of principles of good planning

Planning is not just about development, it is about a liveable city that encompasses human welfare, heritage, culture and the environment that we live in and are responsible for.

The natural environment conservation principle needs rewording to specifically include native vegetation and for policies and planning design to seek the enhancement and restoration of the condition and functioning of ACT’s natural environment. This is important as most native vegetation subject to development in the ACT is either nationally endangered grassland or woodland and there is already substantial effort towards enhancing ACT’s natural environment which must be supported by good planning. The identification and protection of Conservation Areas will provide surety that biodiversity and the functions that it provides are a fundamental element of the city and Territory we live in. Modify the principle as follows:

2.7   Natural environmental conservation principles mean the following:

a.       Planning and design should promote healthy, diverse and resilient ecosystems, by avoiding loss of habitat, native vegetation and other key threatening processes for biodiversity.

b.       Policies, planning and design should integrate and promote —

1. nature-based solutions to climate change and water security.
2. the valuation and maintenance of the ecosystem services and amenity provided by a healthy natural environment.
3. restoration and enhancement of natural environment condition, diversity and connection.

c.       Biodiversity connectivity and habitat values should be integrated across urban areas, including through appropriate planning for, and landscaping of, urban open space and travel corridors.

Part A. Administration and Governance

Mapping discrepancies

We have found that there are designations in the maps in the Territory Plan document which are inconsistent with the maps in the District Strategies, there may also be others we have not observed:

• Gungaderra Nature Reserve has a Future Urban Area (FUA) overlay.
• Lawson Grassland, formerly the Belconnen Naval Station, is shown as Territory Land, designated suburban land, although it is Commonwealth land.
• Coombs peninsular is shown with a Future Urban Area overlay; the decision has been made that this will not be developed as a residential area.

Incorrect overlays and designations in the Territory Plan need to be removed.

Planning and land use zones for low-lying native ecosystemsms

Few lowland grassy ecosystems and smaller waterways that are at direct and constant threat of loss due to development, associated infrastructure, weed incursion and mismanagement are included in the blue-green network. Many of these areas contain threatened ecological communities, threatened species habitat, other high conservation value remnants and provide corridors between larger areas. Currently there are no land use zones that adequately recognise these Conservation Areas.

There is a need to identify Conservation Areas up front and provide designated protection to limit land uses that result in destruction of, or disturbance to, habitat. It is recommended existing land use zones could be modified to include conservation as the fundamental desired outcomes, or alternatively a new land use zone could be created to protect the environmental integrity of the ecosystems within the lower hills and valleys that are outside the reserve system. This includes not only the urban areas but also surrounding rural landscape.

For example, the existing land use zone NUZ3 could be modified to reflect the existing, rather than historic, values in which ecosystems on the low hills and plains were not valued. These changes would increase the outcomes for conservation of the lowland ecosystems, including on rural leased land:  

NUZ3 – Hills Ridges and Buffer Zone

The fundamental desired outcome for the NUZ3 zone is to conserve the environmental integrity of the hill system and other areas of high conservation value and connectivity significance to conserve the significant cultural and natural heritage resources and a diversity of natural habitats and wildlife corridors,

Other important desired outcomes to be achieved in the NUZ3 zone:

1. Provide a visual backdrop and a unified landscape setting for Canberra
2. Provide opportunities for appropriate recreational uses.
3. Provide predominantly open buffer spaces for the visual separation of towns and to provide residents with easy access to hills, ridges and buffer areas and associated recreation facilities.
4. Provide opportunities for appropriate environmental education and scientific research activities.

Alternatively, a specific Urban Open Space land use zone (PRZ3) could be included to protect Conservation Areas within the urban space (including easements, transport and access corridors), in which conservation is the primary objective, but that allow for other compatible uses.   

Section 3. Draft District Strategies

FOG welcomes the development of  district plans for Canberra, incorporating green-blue spaces, and a focus on the city and first nations’ heritage. This is a good step forward towards a more holistic approach to planning the future of Canberra. However, a general theme in this submission is that further revision is required in order to fulfil the objectives of protection of local indigenous biota in our city and surrounds, the retention and restoration of local flora and fauna and protection of first nations heritage.

The blue-green network

FOG applauds that the Blue-green Network, as a concept, is identified prominently as the first of the five drivers mentioned, and the frequent identification of these values throughout the documents.

However, it is misleading when the application of planning for this network effectively only relates to their use for recreation, infrastructure or other similar purposes. It does not recognise that many of these areas are of high importance for their natural conservation values. For example, two thirds of the Natural Temperate Grassland sites are outside the ACT’s reserve system (data extracted from ACT Government 2017)[2].  It is not at all clear how the mandate requiring protection of biodiversity values could be achieved if these areas are not differentiated from modified areas identified in the blue-green network and protected.

Such areas are not only important for biota, supporting local wildlife, but provide essential services through climate change mitigation, mitigate climate extremes, enhance water retention, and support wellbeing and mental health.

Conservation Areas

FOG supports the inclusion of the category ‘Conservation Area’ across tenure applied on the maps. However, there is no definition of what this term refers to in the glossary. Only one area apart from Nature Reserves is identified as a Conservation Area (between Tennant St and Molonglo River, Fyshwick).

The District Strategies should identify all Conservation Areas in each district that contain threatened species and communities, other important habitat and corridors, and demonstrate how these entities will be retained in the planning arena. Examples that are not included in the draft maps are listed below in our comments for each district, although further review is required to comprehensively identify and map all areas of conservation significance.

Networks and connections

The word “connections” is used liberally in the document and in different ways, including “connections created by foot and cycle paths to shops, playgrounds, and open space”, “public transport” and to “restore environmental … values”. Its various intentions in the document should in each use be clarified, particularly in relation to connectivity in the Blue-Green network.

The loose use of the term ‘connections’ in relation to the Blue-Green Network are especially misleading in that while the blue-green network purports to refer to environmental connections, the description of the network of connections in the district strategies as defined aims “fill in gaps and connections in the primary, secondary and tertiary networks to enable people to move through and experience elements of the natural environment”, in other words, tracks and roads. The primary aim should be to improve ecological connectivity. While this may be appropriate for some areas, such movements should be secondary to the movement of biota. For example, there is a discrepancy when the strategy identifies the major waterways in their upper reaches as a primary network , but not in their lower reaches further from the residential areas. As opposed to this, ecologically, these waterways are a primary network along their entire length. The two types of connectivity should be mapped separately.  

There is no reference in the planning maps of the location of mature and hollow bearing trees or a representation of natural corridors and how they will be impacted by the proposed planning strategy  and certainly no mention of how they would be protected from development.

Ecological Connectivity

Care needs to be taken that connectivity has a whole of landscape approach and is not fragmented by an over-focus within individual Strategy districts. For example, it is admirable that a key direction for Woden is connectivity between its nature reserves including Mount Mugga, Oakey Hill, Red Hill. Mount Taylor and Farrer Ridge. However, it is vital that these woodland reserves maintain and improve connection to the Molonglo and Murrumbidgee rivers from where connections exist to much of eastern Australia. It is this continental scale linkage and Woden’s connection to it that enables the migration and nomadic movements of hundreds of birds, insects, bats and other wildlife. Similar landscape scale connections exist for all the strategic areas and they are a key conservation asset.

Figure 31 in the Gungahlin district strategy shows a number of connections, at least two of which we would query. These are the connections (which would appear to be bicycle paths) that are shown passing through Nadjung Mada and Gungaderra Grassland Reserves. These will cause disturbance and might cause fragmentation of Striped Legless Lizard habitat as well as create other biodiversity hazards. It is important that any connections through green-blue areas be carefully designed, or even avoided, where these may injure natural values.

Work by CSIRO (Doerr et al 2010)[3] found that most wildlife, including insects, birds, bats and spiders can move across the landscape provided trees are no more than 150 metres apart and the gap between large (at least 10ha) habitat patches is less than 1.3 km. This menu for connectivity lies behind the ACTMapi mapping of connectivity for landscape and planning. The treed connection across Canberra’s landscape is pretty functional, but what is missing in places are regular 10 ha patches of habitat. The ACTMapi layer has a tool that enables identification of where restoration of such patches is most effective and achievable. Conservation and enhancement of these “stepping stones” will be critical to meeting the Blue-Green network objective. 

Increased planting and encouragement of existing indigenous plants in public places including roadsides and nature strips can enhance their roles as conservation corridors. However, such plantings must reflect the existing conservation significance of that site (as a remnant, as a connection between remnants, or as old growth trees that support wildlife, and importantly ensure no trees are planted in natural grassland or other native grassland in which native herbaceous diversity is high.

Interface of urban-commercial and green-blue areas: Nature in the city

The impacts of commercial/urban interfaces must be addressed through the placement of buffers to adjacent blue-green areas. Some negative impacts that commercial/urban areas may have on reserves include (a) misuse of the reserve by local residents and visitors such as dumping rubbish, and walking dogs on or off lead that may negatively impact indigenous vegetation and fauna; (b) garden plantings that may cause weed problems in the reserve; (c) light and noise impacts that may negatively impact native fauna; and (d) possible fears of local residents about reptiles and fire management. An example of an area which is currently acting as a buffer to a reserve is the Gungahlin town centre east area which is adjacent to Mulanggari Nature Reserve. The town centre east area contains a remnant box gum woodland, an ephemeral wetland, habitat for water birds, and at least one tree on the ACT tree register. The current Gungahlin town centre east proposal does not address the interface between the Gungahlin east and Mulanggari grasslands.

A strategy to obtain positive outcomes for local residents and visitors is for government and the local community to work together to formulate plans to allow the public to visit and use the buffer, while ensuring the adjacent conservation areas are retained (and enhanced). The development of the Concept Plan for Budjan Galindji Franklin Grassland applies this strategy, based on best practice design and planning for native grasslands (Williams et al., 2015) [4]

Recommendations, Blue-Green Network

Suggested wording changes are indicated in blue.

1.       The blue-green network needs to differentiate between modified landscapes where such activities are justified, and the “biodiversity conservation network” (p. 41, Ecology and Heritage section), i.e., those areas that contain important natural biota. Use of such areas should be legislatively protected for their conservation values and identified as Conservation Areas. It should also recognise opportunities in which areas of conservation values within the blue-green network may be enlarged, enhanced or restored to enhance habitat values and connectivity.

We recommend the definition be changed to:

Blue-green landscape/infrastructure/network: ‘Blue’ refers to waterways including creeks and wetlands within the landscape. ‘Green’ refers to the trees, urban forests, gardens, parks and open space. The Blue-green network includes a sub-set of sites, the Biodiversity [Conservation] Network, that contain remnants of threatened communities, native fauna habitat including mature native trees and areas that connect these remnants.

2.       It is an important distinction that trees are not a natural component of natural grasslands. Grassland connectivity is about maintaining a continuous cover of predominantly native grass and native herb understorey. Therefore, connectivity across grasslands must not include the planting of trees or shrubs in or shading grasslands.

3.       The descriptions of the three network levels need to be modified to ensure the primary aim is to protect conservation values where these occur, with planning around them correspondingly respected.  

Suggested rewording is:

The blue-green network is a foundational element of the district strategies. A key aim is to protect and enhance biodiversity and conservation values and, where compatible with this aim,  is to fill in gaps and connections in the primary, secondary and tertiary networks to enable people to move through and experience elements of the natural environment where this is compatible with biodiversity and conservation values.

In addition, the description of the three levels needs revision: 

Primary network: spans Canberra, along the waterways which bring life to this place – the Molonglo River, Sullivan’s Creek, Ginninderra Creek and Yarralumla Creek and other waterways, the nature reserves and the unbuilt Hills, Ridges and Buffers. Any active travel and recreational functions should be secondary.

Secondary network: intersects with the primary network through and between districts, building upon those elements of the conservation estate that are outside the reserve and main aquatic system and if compatible, the existing active travel networks.

Blue-green connections: extend liveable blue-green network by establishing priority connections between remnants to restore, protect and expand the blue and green network, and secondarily for connections for people.

4.       Table 3. Objectives for district planning – blue-green network

An additional objective needs to be included: Restore, protect and expand the biodiversity conservation network as part of the blue-green network.  The existing third objective omits the major aim for these areas.

The fifth objective should include two additional elements:

1. incorporate and maintain existing mature native trees and
2. the expansion of the urban tree canopy cover is not appropriate for native grasslands.

5.       Given the centrality of the blue-green network concept and the associated maps elsewhere in this document the Glossary of Terms should necessarily include clear and sufficiently explanatory definitions of what the various Blue-green network legend terms mean and how they have been determined. Although some of them are explained to varying degrees of adequacy elsewhere in this document they should be readily found in the Glossary and consistently applied throughout the Strategy.

6.       Define the term Conservation Area as areas within the Biodiversity Conservation Network that:

1. include remnants of threatened ecological communities;
2. contain habitat for threatened species;
3. provide important corridors between remnants; and
4. areas containing important cultural, heritage or scientific values.

7.       Where conservation areas occur on rural and urban leases inclusion in the biodiversity network should be achieved through mutual government/lessee agreement, to ensure compliance.

Ngunnawal country & first nations people

We welcome the statement that Canberra occupies Ngunnawal country, and its people and culture should be respected. However, we believe the statements on page 22 and elsewhere should specifically identify:

• The significance of the ACT government commitment to creating an ACT voice, treaty and truth telling for first nations’ people. The discussion to progress a treaty has been initiated.
• Learning about and adoption of traditional land management practices should be a foundation, or starting point, to manage our biodiversity.
• The initiative by ACT government to adopt education programs to promote an understanding of first nations’, particularly Ngunnawal, language and culture and the creation of employment programs to train and employ first nations’ people.  

Design, layout and accuracy of the documents

The first 80 pages or so of the separate district strategies is the same in each document, but this is not clear unless the introductory information in each is compared. Separating out each district also compartmentalises each district. While districts can be a useful division for planning, they do not make sense ecologically or socially. Therefore, we urge a greater link between them, perhaps by merging the district strategies into one document so it is clear the principles are uniform, but separate chapters consider each district..

Many of our comments refer to similar sections in different district documents, but given they occur on different pages it has been difficult to refer to the specific pages to which our comments relate. 

Maps

The District Strategies are presented at a coarse scale and lack detail. The maps are not fit for purpose and need to be significantly amended. We recommend maps are available that can be reduced or enlarged to see the detail, exact placement of proposals and consider them in context.

By compartmentalising the planning strategy, initially within the ACT border, then further into the nine districts, the idea of ecological connectivity is conceptually lost, creating artificial hard boundaries. For example, in Belconnen this ignores major consequences of future urban development into NSW by Riverview. In East Canberra and Tuggeranong, all the current Jerrabomberra, Tralee, and other potential development areas are likewise ignored, although it impacts considerably both ecologically, socially and physically on the landscape.

A key aim of the district strategies is to provide clear guidance to help deliver desired planning outcomes. The lack of detail within the District Plans creates uncertainty and inconsistency and will result in poor and contested planning, rather than strategic and transparent outcomes.

The over-arching maps of planning district intent have been poorly put together with mapped planning intentions being inconsistent with stated aims within the Strategy and with other figures provided. For example, Figure 32 of the East Canberra Strategy identifies with purple shading the land in the vicinity of the airport that provides economic access and opportunity, while Figure 31 shows protected habitat including natural temperate grasslands that the strategy aims to protect. However, the overarching map shows an economic precinct that excludes some of the built airport and includes some of the neighbouring natural grasslands on public lands. Does this mean that some parts of the existing developed airport area are no longer suitable for economic use and that the plan is endorsing development on critically endangered grassland and threatened fauna habitat?

These maps should also show information on remnant indigenous vegetation within the built-up area, outside the green-blue areas and features such as ephemeral and other wetlands and open spaces with remnant native trees.

Far more accurate mapping is available on publicly available resources, including Conservation Connectivity areas of Protected Flora and Fauna, Potential Priority Connectivity Areas and Potential Habitat Areas. They are based on:

• ACTmapi Significant Species, Vegetation Communities & Registered Trees map layers;
• Canberra Nature Park Reserve Management Plan 2021 maps Connections with Rivers & Landscape Connections and Cooleman Ridge NR Natural values;
• Grassland and Woodland Strategies; and
• City Services map of existing Urban Parks and Places volunteer groups.

In addition, community, including FOG, is aware of other areas that are not currently mapped.

Errors in mapping

Examination of the district maps has identified clear errors. Examples are provided below, but it is very likely that others exist.

Figure 31 of the East Canberra District Strategy shows the West Majura grasslands as protected habitat but the overarching map includes these critically endangered grasslands in a possible change area for employment. Given that the importance of the grassland is widely documented and their mapped distribution is readily available it is unclear why such planning ambiguity and inconsistency has been presented as part of a district plan.

Figure 14 in each of the district strategies – Economic access and opportunity across the city: This figure has incorrectly included part of Mugga Mugga Cottage and Grassland (between Hindmarsh Drive and Mugga Lane). Areas of conservation value need to be removed from the purple shading of this map. The shading was probably meant to capture the detention centre and pound facilities and not Mugga Mugga Grassland.

Recommendations, Maps

1.       Mapping should clearly show overall planning intent and possibilities and not vague lines that are open to multiple interpretations.

2.       Sub-district maps need to show:

• All sites identified in the grassland, woodland and riparian strategies, labelled with their site names.
• All other sites that have been identified since the strategies were published or which are identified through further investigation, plus other sites with remnant vegetation.
• The legal (land use zone), e.g. reserves, open space and/or conservation status of all sites, e.g. threatened species habitat, threatened ecological community.
• The presence of remnant and exotic vegetation. Remnant vegetation should be classified by woodland, grassland and other vegetation and whether indigenous vegetation is of high, medium and low quality. In the case of the woodland, the upper, mid and ground storey should be assessed separately.  
• Potential areas that should be targeted for restoration. These could include both remnants and non-remnant areas. Priority should be given to sites where the quality and patch size can be improved and those which allow quality sites to be connected.

3.       Discrepancies between land uses identified in the Territory Plan maps and District Strategy maps need to be rectified, at least in regards to Gungaderra Nature Reserve, Commonwealth land at Lawson, Coombs Peninsular and Mugga Mugga.

Comments on the nine draft district strategies

Detailed comments are provided for most of the district strategies, particularly those identified for future development options, and those with greater numbers of biodiverse remnants, however, where comments are made in regard to one specific district, they are frequently relevant to the other districts.

Overall, FOG is concerned that mapping is inaccurate and inadequate for both consultation and planning purposes. The inclusion or exclusion of particular proposals and areas seem to be ad hoc, and are far from inclusive.

Draft Belconnen District Strategy

There are direct conflicts between proposals in the strategy and blue-green network/connectivity objectives. In addition, some will have significant implications for the community in terms of traffic, parking and services, within the district and across districts.

Lawson North

The Lawson North proposal by the Defence Housing Estate is not finalised and is under contention for its significant impact on NTG, GSM and other habitat. The area identified as “Lawson” (the former Belconnen Naval Station) is a significantly large area of CEEC NTG, the original known population of the Ginninderra Peppercress, important habitat for the threatened GSM. This area is Commonwealth land, managed by the Defence Housing Estate. This is identified in the Territory Plan Administration and Governance document as suburban land (RZ2). This is incorrect.

Lake Ginninderra (east)

This site is marked potential development and is Change Area 5 in Figure 31, p94-5.  The outline covers an alarmingly large area on the eastern lake side. While much of that is poorly managed and weed infested paddock area required to be grazed for fuel reduction, there are significant environmental (and recreational) values on the lakeshore strip of land between the lake and the potential site .

The site is discussed more in Fig 41 on p119.  The location of its new edge street is much less alarming in Figure 41 than that at larger scale in Fig 31.  Even though there is more information provided, omitted from these maps are key conservation values, including an area of NTG (see ACTmapi grassland layer), generally known as Diddams Close, currently highlighted by TCCS conservation bollards, a small population of the endangered Small Purple Pea Swainsona recta and the diverse native ground and shrub layer under planted eucalypts.  If high-rise development could be contemplated for the site (retail and residential) that must not impact the conservation values of the lakeshore strip, including potential emergence of desire-line tracks, or other illegal recreational disturbance. 

Proposed Research and Education Precinct, Bruce (including the University of Canberra, Australian Institute of Sport, Canberra Institute for Technology, Radford College, Calvary Hospital and surrounding green space), and Sustainable neighbourhood areas (UC campus and AIS), p.99 and p.111.

These areas mapped include/overlap with important wildlife corridors that are mapped on the Blue-Green network map p.99, especially areas around Calvary Hospital (zoned NUZ3), and the green space between Gossan Hill and John Knight Park (i.e. behind CISAC), currently the site for some UC residences and parking.  Gang -gang nesting sites occur around Calvary and Superb Parrots are frequently seen at AIS. In addition, the area contains rare orchid habitat.

The UC campus contains areas of woodland, shrubby forest and a significant number of mature native trees. It therefore provides connectivity north to Lawson.

Proposed light rail extension

The proposed light rail extension along Belconnen Way between Black Mountain and Bruce Ridge and then north along Haydon Dr, together with the proposed changes to expand the research and education precinct, indicate how important it is to assess and mitigate impacts on connectivity on a landscape scale given the strong connections between Lawson, Bruce, Lyneham and O’Connor. This is a clear example of how a single-district analysis misses some important cross-district considerations, as highlighted in our general comments above.

Additional Conservation Areas include, but are not limited to:

• Glenloch Interchange, William Hovell Drive and Tuggeranong Parkway
• Flea Bog Flat, corner of Belconnen Way and Hayden Drive, Bruce
• Umbagong District Park, Latham
• Croke Place, Evatt
• Diddams Close native grasslands and Small Purple Pea habitat, Lake Ginninderra
• Lawson Hill, South Lawson road easement
• Research and Education Precinct including UC
• Mt Rogers, Fraser
• Kuringa Woodland, Fraser
• Higgins Woodland, Brazel St Higgins
• Hall Horse Paddocks
• Ginninderra Creek (corridor)
• Hall Cemetery
• Fassifern, Jarramlee and West Belconnen Ponds, Dunlop

Draft Gungahlin District Strategy

Improving connectivity

Many areas of Gungahlin have been inadequately mapped for their biodiversity values. For example, there are many small remnant grassland patches along the upper Ginninderra Creek and its tributaries. These remnants would be key areas to enhance patch size and habitat corridors through restorative work.

Other areas including the proposed Crace open area revamp provide the opportunity to retain and enhance natural values while still providing for recreational activities.

The Gungahlin town centre east proposal

This draft proposal or intended land use is omitted from the Gungahlin district map. The land use of this area is not identified, and information provided in the draft for that submission seems to simply ignore natural assets that occur in the proposed development area which contains a remnant box gum woodland, an ephemeral wetland, home to many water birds, and at least one tree on the ACT tree register. Obviously, Gungahlin district plans should identify all natural assets so that these are protected and well managed in future Gungahlin region development. 

Additional Conservation Areas include, but are not limited to:

• Kenny Grasslands
• Gungahlin Town Centre east

Draft Inner North District and City Strategy

Due to the age, the density of the built environment and the fact that this area primarily once contained naturally treeless grassland, there are few open spaces dominated by native understorey or native trees. The native biota that remains within parks, walkways are of particular importance to maintain east-west ecological connectivity.

Additional Conservation Areas include, but are not limited to:

• Ainslie Volcanics Grassland, Wolseley Drive, Campbell
• St Johns Church Golden Sun Moth habitat
• Lyneham Ridge Eucalpyt Plantation and Lyneham Horse Paddocks grassy woodland, corner of Ellenborough St at Barton Highway intersection
• Dryandra St Woodland, corner of Dryandra St south and Belconnen Way
• Sullivans Creek wetlands

Draft Inner South District Strategy

Wildlife connection along Melbourne Avenue

Wording on page 88, identifies Melbourne Avenue to Red Hill as a regionally significant connectivity corridor. The Link Via Red Hill, Melbourne Avenue, plantings and remnant woodland on Capital Hill and then onto Stirling Ridge is indeed an important wildlife connection. This importance needs to be reflected in the mapping of the Green-Blue network and in implementation actions.

The following changes are proposed to the second paragraph of the Blue Green network p98:

Priority connectivity areas include along Jerrabomberra Creek, feeding into the wetlands, and in the west around Yarralumla and via Melbourne Avenue and Parliament House connections between Red Hill and Stirling Ridge. Red Hill Nature Reserve and Stirling Ridge support high quality Box-Gum woodland and diverse and rare wildlife. The inner south contains the highest known concentration of Gang-gang breeding hollows and large populations of the endangered Button Wrinklewort daisy. There are important natural grassland remnants at Yarralumla and Bass Gardens. The general area of Gurubung Dhaura (Stirling Ridge, National Land) also has highly important cultural values for local first nations’ people.  The relatively recent Westlake Settlement in part of the same footprint has significant European heritage value.

While many of these ecological values and heritage elements are protected by legislation, any new development in the district must consider and enhance these conservation values. Water sensitive urban design (WSUD) initiatives in future developments will be critical to improving water quality of ecosystems and creek corridors.

Wildlife connections

We note the odd specific inclusion of the Bass Gardens remnant grassland, given, with very few exceptions, other grassland and woodland remnants are not identified or included. The following additions are suggested to Table 10, Inner south initiatives:

Enhance and maintain native grasslands and grassy woodlands along the Molonglo River corridor north and east of Fyshwick, and within the suburbs;

Enhance the condition of the wildlife connection along Melbourne Avenue and between Parliament House and Stirling Ridge, linking significant woodland at Red Hill, Parliament House and Stirling Ridge.

West Deakin

An additional principle should be:

                Minimise adverse indirect impacts on Red Hill Nature Reserve and its wildlife.

Tennant St Grassland (Fyshwick)

On the blue-green network the entire area west of the Molonglo River in Fyshwick is identified as a conservation area. However, on Figure 36, Sustainable Neighbourhoods Figure 36, it is identified as a Possible change area (which requires definition). This is another example of why the conservation area term needs to be defined (and areas retained).

Additional Conservation Areas include, but are not limited to:

• St Marks Native Grassland (leased land), Barton
• Bullan Mura Grassy Woodland, Alexandrina Drive Yarralumla 
• Blue Gum Point, Alexandrina Drive Yarralumla
• Black St Grassland, Alexandrina Drive Yarralumla
• Griffith-Hughes Woodland
• Dudley St Grassland Yarralumla
• Hughes-Garran Woodland
• Griffith Woodland
• Tennant St Grassland, Fyshwick (this grassland is under-represented in ACTMapi)

Draft Molonglo District Strategy

Western Edge investigation area

The playing down/omission of the western edge investigation area from the District Strategy Plan map, Blue-green network, and other maps is concerning. No further information and discussion is provided other than brief references to its potential for future development and a new district and mitigation against associated bushfire risks (pp 7 and 16) and a map and showing parts of this area adjacent to the Weston Creek and Molonglo Districts in Figure 25 (Weston Creek District map). Its environmental values and connectivity significance are being discounted and excluded.

FOG does not support development in this high conservation value area. In particular, none of Bluett’s Block should not be considered for future urban area and should be protected by an adequate ecological buffer from development.

Additional Conservation Areas include, but are not limited to:

• Bluett’s Block, Cotter Road
• Kama West, William Hovell Drive
• Springfield property, Molonglo

Draft Tuggeranong District Strategy

Tuggeranong contains mature and remnant trees recognised as keystone species and found across the suburban fabric on both private and public land. In parks and in private gardens. Their presence is foundational to maintaining local biodiversity, quality of life for residents and movement for local native species. Some are scattered and others form part of natural corridors documented in the connectivity rasters on ACTMAPi.

Tuggeranong's urban fabric contains important plant and animal species which fall outside the reserve system. They are recorded and available on ACTMAPi but do not appear in the Draft Tuggeranong District Strategy.

The Tuggeranong District Strategy indicates the Blue /Green Network and other transport corridors will be driven through the habitat of these species some occupying comparatively small areas. The inevitable outcome of this kind of planning is the loss of these natural values.

Additional Conservation Areas include, but are not limited to:

• Isabella Pond grassland, Monash
• Tuggeranong Grassland
• Swainsona population, Kambah

Draft Weston Creek District Strategy

It is concerning that the only conservation areas shown in the Weston Creek District Strategy Plan map are existing Nature Reserves. Here, the term Nature Reserve seems to be inconsistent with how it is used and shown in the all district map (Fig 13) and Weston Creek specific (Fig 32) Blue-green network maps. In Weston Creek District Strategy Plan map the term Nature Reserve seems to also include Conservation Connectivity areas shown in Fig 32 as potential habitat areas, potential priority connectivity areas, and protected flora and fauna areas. This inconsistency reinforces the earlier comments about the need to improve the clarity of the Blue-green network graphics and provide clear and consistent definitions of the various legend items in the Glossary of Terms.

There are a number of relevant Conservation Connectivity areas that are missing from and/or not clearly identified in Weston Creek – Blue-green network map.

Draft Woden Valley District Strategy

Conflict between Blue Green Driver and Economic Access and Opportunity Driver

The district Strategy presents two conflicting drivers, and it is unclear how both will be achieved. The blue-green driver correctly identifies Yarralumla and Long Gully Creeks and their enhancement as key to connectivity within and between the districts, but intensive residential development based along a future light-rail network is planned in this area of ecological connection. It is crucial that it is understood that a long thin line of trees will have little connectivity value and that for the connection to work it needs to contain large areas of retained and restored habitat. In this context natural grasslands at North Curtin and transitional woodland in Mawson that adjoin Yarralumla Creek are vital components of the Creeks’ connectivity.

As shown in the Strategies mapping, these vegetation remnants are also crucial to east west connections, linking woodlands at O’Malley to Mt Taylor and the Callum Brae, Mugga, Red Hill woodland patch (the second largest Yellow Box-Red Gum woodland patch in the nation) via Yarralumla Creek and connections through Curtin to the Molonglo River.

The existing connections at these locations are important for the movement of Superb Parrots breeding in the Lower Molonglo and Gang-gangs breeding on Red Hill and Mugga to move to and from foraging areas across Woden.

For the Strategy to fulfil it aims substantial areas of vegetation will need to be retained and restored within the vicinity and along Yarralumla Creek.

Additional Blue-green network initiatives

The following are needed if suitability of important aspects of Woden’s wildlife are to be achieved:

• retention of a viable Golden Sun Moth populations.
• Enhance and restore waterways, green corridors and viable habitat patches from Yarralumla Creek along Athllon Drive and Yamba Drive, including connectivity with Farrer Ridge at the head of the creek.
• Enhance the movement and foraging of the Superb Parrot, Gang-gang and other threatened species through the green-blue network and use of preferred food plants in local plantings.

Opportunities and constraints

The Gang-gang p. 87

Woden (including neighbouring Red Hill) contains the highest known concentration, anywhere in Australia, of nesting hollows of the nationally endangered Gang-gang (Callocephalon fimbriatum). A large (in a national context) population of the nationally threatened Golden Sun Moth exists on Curtin Horse Paddocks. Thus, the following word change is suggested:

Threatened species such as habitat of the Gang-gang, Golden Sun Moth, Pink-tailed Worm Lizard, Perunga Grasshopper, Button Wrinklewort, Small Purple Pea, Hoary Sunray, Little Eagle and Superb Parrot.

Principles for Curtin Horse Paddocks p119

In order to be consistent with the Strategies drivers and objectives the principle need to include

• retention of a viable Golden Sun Moth population.
• retention and enhancement of the functioning wildlife connection based along Yarralumla Creek as part of a city wide blue-green network (Note -this connection is vital to the functioning and wildlife diversity of nationally important woodland on Red Hill and beyond).
• Consider opportunities to enhance the creekline for local area amenity and ecology – part of a city- wide blue-green network where possible.

Curtin edge north and south

The following wording is suggested to reflect key drivers of the Strategy:

Any future development at this site should contribute to a positive built frontage and address to Yarra Glen, improve access to and oversight of light rail stations, and consider a biodiversity sensitive urban interface, protecting the potential re-naturalised creek corridor and its functioning as a wildlife corridor from impacts of urbanisation.

The principles for the Curtin Edge North to South, North Woden, Phillip and Athllon Drive , Mawson and Farrer North and Mawson and Farrer South

The following should be included:

• retention and enhancement of the functioning wildlife connection based along Yarralumla Creek as part of a city wide blue-green network.
• Consider opportunities to enhance the creekline for local area amenity and ecology – part of a city- wide blue-green network where possible.

Retention of woodland at Phillip – Athllon Drive

This area contains a high quality remnant of grassland/Box-Gum woodland transition remnant as well as smaller areas of Box-Gum woodland and mixed plantings, which are restoring native vegetation elements to the corridor. Thus, the following should be an additional planning principle:

• Retention and enhancement of remnant grassland/woodland vegetation

Implementation Table p151

The following should be added to the first row of the table:

• retention of a viable Golden Sun Moth population
• Enhance the movement and foraging of the Superb Parrot, Gang-gang and other threatened species through the green-blue network and use of preferred food plants in local plantings
• Additional key areas to be incorporated and mapped as conservation areas, include (but are not exclusive):

Additional Conservation Areas include, but are not limited to:

• Curtin Horse Paddocks conservation habitat
• Wildlife connection along Yarralumla Creek and elsewhere across Woden Valley
• Remnant woodland at Athllon Drive, Phillip

Draft East Canberra District Strategy

Canberra Grassland Earless Dragon, Canberra Spider Orchid and Canberra Raspy Cricket

Conservation of these threatened species should be a key direction. East Canberra contains over 90% of the global habitat of the Canberra Grassland Earless Dragon (Tympanocryptis lineata). The remaining habitat is in the adjoining Poplars area of NSW.  Similarly, within East Canberra, is over 90% of the known population of the nationally endangered Canberra Spider Orchid (Caladenia actensis) and most of the population of the Canberra Raspy Cricket (Cooraboorama canberrae) a local endemic genus, which meets Commonwealth listing criteria. Given the restricted and threatened nature of these species and that the Commonwealth has recently committed to try and prevent any further extinctions, it is likely that these three species will be a key consideration of any planning or development decisions that the Commonwealth makes in the East Canberra area.

Therefore, it makes sense for the East Canberra District Plan to specify that it aims to also prevent the extinction of these essentially east Canberra species and highlight this as part of a key direction. Suggested wording is:

Protect, conserve and enhance priority grassland, woodland and aquatic habitats and environmental values, including along the Molonglo River and Jerrabomberra and Woolshed creeks, and habitat of three threatened species that are largely restricted to East Canberra, the Canberra Grassland Earless Dragon, the Canberra Spider Orchid and the Canberra Raspy Cricket

It is also suggested that the following be added to the words on Page 94 under the Blue-green network section.

Grassland and woodland habitat in East Canberra is critical for the national survival of the Canberra Grassland Earless Dragon, Canberra Spider Orchid and Canberra Raspy Cricket.

Table 9 – suggested word changes:

Enhance, restore and connect priority areas of grassland and Grassland Earless Dragon and Canberra Raspy Cricket habitat, particularly north and east of Canberra Airport and in the south around existing grassland reserves and adjacent in NSW

Map stylisation is inaccurate, inconsistent and misleading

As raised in general comments the mapping needs to better reflect that of the following subject specific mapped and written content. At the moment it appears to be a map of glorified thought bubbles rather than a useful planning guide.

• the airport precinct should accurately reflect the location of the airport and Ikea land,
• areas of critically endangered grassland and woodland should be removed from possible development precincts , including the West Majura Grasslands, grasslands to the north and east of the airport, and woodland within and adjoining Mt Majura reserve. 
• the environmental precinct to the west of West Jerrabomberra Nature reserve should reflect the mapping of vegetation and habitat values in Figure 31.

Figure 31 – some mapping errors need correcting:

The Nature Reserve and Conservation Area hatchings are missing key Nature Reserve and offset areas including parts of Mugga Mugga Nature Reserve, East Jerrabomberra Grassland Nature Reserve, Woolshed Creek Nature Reserve and West Majura Grasslands Nature Reserve.

Wildlife connections into NSW

The district strategy should also consider and map key wildlife connections to native vegetation in neighbouring NSW (Figure 31). As indicated on the connectivity layers within ACTmapi, woodland vegetation towards the southern end and middle of Hume provides an important link between the woodlands of Wanniassa Hills, Isaacs and beyond in the ACT and woodland in the Googong area of NSW

High speed rail alignment

Figure 33 shows a proposed alignment across the top of Mt Ainslie Nature Reserve, including traversing a large remnant of critically endangered Box –Gum woodland, habitat of the endangered Canberra Spider Orchid and important threatened woodland bird and Rosenberg’s Goanna breeding habitat. It is highly unlikely that this route would proceed, and its development certainly would be at odds with the Blue-Green driver that under pins the Strategy. So why show it? Particularly as an explanation behind why the proposed alignment was chosen is missing. Similarly the alignment of the alternate route to the airport bisects West Majura Grasslands. It would need to closely align with the Majura parkway and not cut across Woolshed Creek Nature reserve to be considered as a serious alternative.

Additional key areas to be incorporated and mapped as conservation areas, include (but are not exclusive):

Additional Conservation Areas include, but are not limited to:

• Majura Valley West grassland and woodland (adjacent to Mt Ainslie and Mt Majura Nature Reserves and Campbell Park offices)
• Majura Valley East grassland and woodland (adjacent to the Airport and the Defence Area)
• Majura Road, Majura Valley
• Rural leases, Majura Valley
• Mugga Mugga Homestead, Jerrabomberra
• ‘Callum Brae’ property, Jerrabomberra
• Woods Lane, Jerrabomberra
• ‘Cookanalla’ Grassland Earless Dragon habitat, Jerrabomberra
• Amtech east, Jerrabomberra

Other Conservation Areas within and outside the nine districts that should be considered for inclusion are:

• Horse Paddocks
• TSRs, many existing corridors linking urban open space and nature reserves
• Transport corridors.