Territory Planning Authority
ACEPDcustomerservices@act.gov.au

Re. Development proposed at 722 Canberra Ave Jerrabomberra, DA202544243

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

As during the Stage 1 notification, FOG strongly advise that DA 202544243 be rejected.

While there have been some changes to the original design, the fundamental issue remains. As detailed previously and re-iterated below, the proposal will have significant direct and indirect impacts on one of Australia’s most important remnants of Natural Temperate Grassland (NTG). It is inappropriate and poor planning to plonk intensive small lot industrial use as a northern enclave into the nationally important grassland and the habitat it provides to threatened species. 

The grassland is bordered by Canberra Avenue and Hindmarsh Drive to the north, Monaro Highway to the west, Lanyon Drive to the south and the rail line and built areas of Harman to the east. As indicated on ACTMapi (which provides a general mapping guide), about 2/3 of this 10,000ha grassland is currently composed of native grassland and one-third exotic. Virtually all the area is either known threatened fauna habitat or has the potential to regenerate back to such habitat in a relatively short-term, meaning it is an ideal candidate for a nature repair or other form of restoration project. As well as being one of the largest existing remnants of NTG, the area supports the largest known population of the critically endangered Canberra Grassland Earless Dragon, nationally large populations of the threatened Ginninderra Peppercress, Striped Legless Lizard, Canberra Raspy Cricket and Golden Sun Moth, while it is also habitat of significant populations of the Button Wrinklewort daisy, Perunga Grasshopper and Key’s Matchstick Grasshopper, which are either nationally endangered or vulnerable.

While it may not be legally required for development to await the benefit of a Strategic Assessment, it is a legal requirement that the potential impact of the proposal be considered within the context of the landscape in which it sits, rather than the narrow focus within the proposal documents. The proposal sits within a landscape of immense ecological significance and function, where boundaries between exotic and native grassland, and threatened species distribution are not fixed but vary with time. The neighbouring Cookanella lands are a prime example. A decade ago they were in poor condition with threatened species largely confined to the rockier areas. Today the neighbouring lands are in good condition and it would appear that threatened animals are now more widespread.

Large remnants of NTG are so rare and under such threat from invasive species and climate change that remaining large functioning patches should be treasured and enhanced, not subject to further stresses and boundary encroachment via inconsistent and damaging uses.

It is inconceivable that development of 44 small lot industrial allotments would not have a significant impact on the lands and ecology in which it would sit. A casual inspection of such lots at nearby Fyshwick or Hume clearly demonstrates that they are a hub for weed and feral animal establishment and a source for spread into neighbouring lands. The weeds and pests within these areas includes high density and abundance of high risk species of recognised national concern, such as African Love Grass, Chilean Needle Grass, Serrated Tussock, Blackberry, St John’s Wort, European Wasp, Rabbits and feral cats. This is not surprising, as unlike the present rural lease arrangement, the owners of each lot would have no incentive and little understanding or capability to control the exotic species on their lot, while high levels of disturbance and waste favour the establishment of weeds and pests.

Weed and pest management plans may look good on paper – but how over the long term (decades) and across all lot owners will regular (i.e. at least twice yearly) and effective management actions be paid for and occur?

The direct impact caused by the establishment of a 100m Outer Asset Protection Zone are not detailed or considered in the latest documentation. As a matter of principle, the required fire management should be within the proposed development area and not forced onto a neighbour or over important threatened species’ habitat.

The proposal will greatly increase the number of perch points from which medium sized birds, like Magpies, Ravens, and Indian Mynas and larger raptors would increase the local predation pressure on threatened fauna. It is not clear how the proposal documents came to the categorical conclusion that predation would be no more than 20 metres from a perch, when this goes against what is reported in the literature. Prey visibility will depend on predator perch height, distance and vegetation height. Andersson et.al. (2009) provide a good overview of the issue [1]. Their experiments on coastal pastures found that from a 20cm high perch most of the visibility (of a rectangular plate or mounted wader bird) was lost after a distance of 20m, but that much visibility still remained after 120m from a perch of 8m high. It is likely that predator effectiveness reduces over large areas so that most predation will be closer to perches that what visibility allows, while the targets in the experiment were larger than the size of the local threatened fauna, nevertheless the significance of increased perch points should not be so lightly dismissed as in the proposal document and it is a real and significant potential impact.

It is also unclear why eucalypts (perch points) are still to be planted close to the western boundary of the development, adjacent to Cookanella.

The recent proposal documents have failed to detail the route and direct disturbance of all the required offsite infrastructure connections, or if they have been described the potential impacts, and avoidance and minimisation measures, have yet to be adequately addressed.

The latest proposal is still to be informed by adequate fauna surveys for a number of species. It would be premature for design approval to occur until at least these surveys are available. The proposal documents are neither credible nor truthful in claims that the proposal will not have significant adverse impacts. The proposal threatens to degrade one of Australia’s most important grassland remnants, with the focus it will provide for weed and pest establishment and spread a particular and certain threat.

Yours sincerely,

SIGNED

Professor Jamie Pittock

President, Friends of Grasslands

17 November 2025

[1] Andersson M, Wallander J and Isaksson D. (2009) Predator perches: a visual search perspective. Functional Ecology 23:2 p373-379, https://besjournals.onlinelibrary.wiley.com/doi/10.1111/j.1365-2435.2008.01512.x