ACT Planning and Land Authority

ACEPDcustomerservices@act.gov.au

DA 202342493, Proposal for the Horse Park Drive Tennis Facility

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 issues

1.       Concern about the proposal being considered in isolation

FOG is concerned that this proposal, along with many others, is being considered in spatial isolation, without due consideration of an overall plan to manage and protect the natural values in this landscape. Ginninderra Creek is an important ecological element in the landscape, as a waterway and habitat for many species and the remnant grasslands and native woodlands along its banks, as well as providing critical connectivity for bird, mammal, herpetofauna and invertebrate species. it has been identified within Government as a key connectivity zone from east to west. We urge that all further proposals within the corridor are considered within the landscape context of the natural and habitat values of the Ginninderra Creek corridor.

2.       Direct and indirect impact on the Ginninderra Creek corridor and remnant native vegetation on the proposed site.

An inspection of the site suggested that it was likely the critically endangered Natural Temperate Grassland (NTG) prior to past disturbance. Remnant species still remain, including the River Tussock (Poa labillardierei), dominant on the western site and the banks of the drainage area, and the more easterly areas contain Short Speargrass (Austrostipa sp.) and Wallaby Grass (Rytidosperma sp.). Native herbaceous species observed were Common Woodrush (Asperula conferta), Scrambled Eggs (Goodenia ovata), Common Everlasting Daisy (Chrysocephalum apiculatum) and a native Geranium species. Consistent with this being a natural grassland is the absence of naturally occurring trees. Eucalypts present along the eastern edge outside the boundary of the proposed courts, and wattles along the fence line which divides the eastern and western sides of the proposed court site are most likely planted. 

3.       Potential fragmentation of the riparian connectivity that runs east to west through urban Canberra.

Ginninderra Creek flows along the western edge of the proposed courts and then flows south-south-east on the southern edge of the courts. Another drainage line flows into Ginninderra Creek and would form the northern border of the proposed courts. These are important elements that enhance the corridor for movement of large and small fauna (including invertebrate pollinators). Beyond this the proposed development site Ginninderra Creek on the eastern side of Horse Park Drive is connected across to the vegetated hills to the west.

Recommendations

FOG does not object to the proposed tennis courts, as long as the footprint of the courts and adjacent land use is minimised to protect the existing native grassland and riparian values outside the development site boundary.

Should the development proceed we urge the following measures are undertaken to protect of the remaining vegetation and habitat:

1. The soft landscaping on the western side of the plan is minimised or removed to protect the creek structure and remaining grasslands.
2. The existing creek structure is protected - some of the proposed site work would require destroying some of the creek bank. Consideration should be given to reducing the footprint to prevent destruction of the creek banks – these should be protected from any long-term disturbance as a result of flooding or human trampling.
3. Existing indigenous and wildlife corridors are maintained.
4. Replanting in the urban open space uses only those species that are endemic to the community and typical of the now critically endangered grassy ecosystem which was the naturally occurring vegetation community in this location. This would mean only planting local indigenous vegetation, especially grasses and wildflowers, and very few if any trees. FOG does not support planting native species that are not characteristic of this community.
5. Native grasses and wildflowers within the development site are removed, stored, and reused in landscaping.
6. Landscape planning and vegetation restoration encompass the land around the proposed the courts.
7. A Flora and Fauna Management Plan is prepared for the proposal including, industry-standard measures for the management of soil, surface water, weeds and pollutants, as well as site specific measures. The FFMP should include but not be limited to the following:

1. No vegetation removal or soil disturbance occurs outside the impact areas proposed for the proposal.
2. All workers are inducted and informed of the limits of vegetation clearing and the areas of vegetation to be retained.
3. If any unexpected threatened flora or fauna are identified in the proposal site, work is to cease immediately and the environmental manager is contacted.
4. Fencing around grasslands and creek is installed to prevent inadvertent impact during works.
5. Ongoing management and maintenance of the landscaping is undertaken to ensure weeds are controlled and the native vegetation is maintained. 

Thank you for the opportunity to comment on this proposal. We would be pleased follow up further with the developer about our recommendations, using the email and telephone contacts above.

Yours sincerely

 

Jamie Pittock
President

20 February 2024