Response to “Case study: Ginninderra Falls Association and development in West Belconnen”

On the 16th of April 2018 the Ginninderra Falls Association posted the following item on the GFA web site:

Case study: Ginninderra Falls Association and development in West Belconnen

Submitted by Robyn Coghlan on Mon, 16/04/2018 – 6:25pm

The EDO ACT provided advice to the Ginninderra Falls Association (GFA), a community group that advocates for the conservation and protection of the environment in the West Belconnen and adjacent NSW area. The GFA have been engaged in environmental protection and advocacy surrounding the proposed Ginninderry development in West Belconnen. The proposed development covers 1000 hectares of land in the ACT bordering the Murrumbidgee River and 600 hectares across the border in NSW. It will deliver up to 11,500 new homes, house an increasing population and take about 30 years to complete.

The area to be cleared for development is a mix of greenfield land and native vegetation. It is also rich in types of biodiversity that are vulnerable to the impacts of climate change.6 The development is likely to cause the local extinction of the Rosenberg’s Goanna, Little Eagle, Scarlet Robin and Spotted Harrier and to cause significant decline or decline of six other listed ACT and Commonwealth species. Reports by independent fire experts also indicate that the housing development is in fire-prone areas likely to be impacted by a warming clima

Despite the impacts on greenfield land and vulnerable biodiversity, this development has been approved. It is unclear whether consideration of ACT’s emissions reduction targets have been considered in the development application process.

6 Preliminary Biodiversity Survey of the Ginninderra Falls Area (2016), Dr David Wong (Ecologist and Project Officer at the Ginninderra Catchment Group).
7 “Risk Implications of Dynamic Fire Propagation”, presented to YVC on 25th October 2017, by UNSW bushfire scientist Dr Jason Sharples

Our response: 

The ACT Environment Defenders Office (EDO) has lodged a submission to the ACT Government Climate Change Strategy process. The submission includes reference to Ginninderry as a case study.

The “case study” contains a series of errors of fact or gross misinterpretations.

  • The case study says that the “area to be cleared for development is a mix of greenfield land and native vegetation”. This is wrong, there is no “native vegetation” to be cleared other than a small proportion of isolated remnant trees.  Of the remnant tree on the site some will be removed but 70 –  80% will be retained compared to the Canberra Average of about 25% for new estates such as this. And of course vast amounts of new native vegetation will be introduced.  We are working with the Fenner School at the ANU on a research project into remnant tree management and the reintroduction of native woodland environments to urban parkland.
  • It says that the land is “rich in types of biodiversity that are vulnerable to the impacts of climate change” – implying that this biodiversity will be destroyed. All parts of the site that are rich in biodiversity (or indeed have any substantial natural or cultural values) will be protected within the 596 ha conservation reserve.
  • It says that the development is likely to cause the local extinction or decline of various species. This material is sourced from a paper prepared by the Ginninderra Catchment Group in January 2017. That paper has been professionally discredited and was withdrawn by the GCG in January 2018.
  • The Sharples report on bushfire risk has been independently reviewed and also referred to ACT and NSW emergency services agencies for review. Its findings have not caused those agencies to reconsider any aspect of the proposed Ginninderry fire protection measures.  The project has engaged with CSIRO fire experts in order to, through a program of research and trial, further improve fire protection measures over the life of the project. It seems curious that the EDO would single out Ginninderry for comment on this aspect; presumably all of urban Canberra will be subjected to altered fire impacts that may result from climate change.
  • The EDO says that “…it is unclear whether the ACT’s emissions reductions targets have been considered in the development application process.” It would normally be expected that the EDO would have a clear understanding of the ACT statutes related to land development processes. Clarity on this subject is available via an internet search of the Territory Plan.
    • The Territory Plan West Belconnen Concept Plan, item 26 mandates as follows:“Development is to be subject to a system of rating that measures the sustainability aspects of the development to the satisfaction of the Territory agency responsible for sustainability and climate
      The introduction of the green star rating scheme is a consequence of this and requires monitoring and reporting against a broad spectrum of environmental parameters. The household and transport energy use reduction measures implemented over 11,500 households will be a major contribution to the Territory reduction targets.
    • It would also be instructive for the EDO to refer to the “Sustainable living requirements” section of the mandatory “Ginninderry Housing Development Requirements” available on the Ginninderry web site (
    • The EDO is also apparently unaware that Ginninderry is to be Canberra first “no-gas” suburb. This emission reduction measure is virtually unprecedented Australia wide.