ACT lowland native grasslands investigation:
Belconnen Naval Transmission Site (BNTS)


On 15 November 2007 the Minister for the Environment, Water and Climate Change, Jon Stanhope, pursuant to section 12(1)(b) of the Commissioner for the Environment Act 1993, directed that I undertake an Investigation into the lowland native grasslands.  A copy of the Terms of Reference for the Investigation is at Attachment A (15.1 kB pdf).

On 21 November 2007 a meeting was held with key stakeholders for a roundtable discussion concerning relevant matters relating to the Investigation.  Some stakeholders sought clarification regarding the scope of the Investigation particularly as to whether it would include threatened species.

On 29 November 2007 the Minister advised that:

Investigation of Lowland Native Grasslands their associated threatened communities and species, as well as threats to, and identification of measures for protecting these, and other species are an inherent part of the Terms of Reference.

Following receipt of this advice from the Minister, a Commissioner's comment was attached to the Terms of Reference. A copy of this document is at Attachment B (12.8 kB pdf).

A media release, from the Commissioner’s office, advising of the Investigation and inviting submissions was issued on 30 November 2007.  A copy of the media release is at Attachment C (19.3 kB pdf).

On 1 December 2007 an advertisement was placed in The Canberra Times that also advised of the Investigation and invited submissions.  A copy of the advertisement is at Attachment D (12.3 kB pdf).

Both the press release and the advertisement advised that the time for lodging submissions relating to the Belconnen Defence site otherwise known as the Belconnen Naval Transmitting Station (BNTS) closed on 14 December 2007 and that the closing date for all other submissions was 25 January 2008.  Early submissions on the BNTS site were required because the secure area within the BNTS appeared to require urgent attention.  Accordingly, the first part of the Investigation focuses on this site.

Public submissions were received from a total of 12 community organisations and individuals in respect of the BNTS site although some of these submissions also dealt with issues associated with other sites.  A list of these submissions is at Attachment E (10.5 kB pdf).

For the purposes of the Investigation a number of meetings with officers in the Department of Defence (Defence) including with the Secretary of that Department were held.  Defence provided a high level of assistance and co-operation in respect of the Investigation.  For example, the Department of Defence made available a number of documents relating to the natural temperate grassland within the BNTS and associated matters. In addition, the Department of Defence provided access to the secure area within the BNTS on a number of occasions so that the state of the natural temperate grassland could be assessed.

Officers of the department of Territories and Municipal Services (TAMS) provided information relevant to the Investigation and were also very helpful.

Belconnen Naval Transmission Station (BNTS)

BNTS is within the suburb of Lawson and occupies approximately 143 hectares of the northern portion of that suburb. The existing suburbs of McKellar, Giralang and Kaleen and undeveloped Territory land to the South surround the site.The BNTS land has been declared National Land pursuant to section 27 (1) of the Commonwealth Australian Capital Territory (Planning and Land Management) Act 1988 and is under the control of the Commonwealth Department of Defence. 

The secure area of BNTS occupies approximately 115 hectares and it has a security fence running along its perimeter. The secure area of BNTS contains the majority of the site’s natural temperate grassland (endangered ecological community under Territory and Commonwealth legislation) with some smaller areas outside the security fence on abutting Defence land.  Within this grassland can be found the golden sun moth (endangered under Territory and Commonwealth legislation), ginninderra peppercress (endangered under Territory legislation and vulnerable and critical habitat under Commonwealth legislation) and perunga grasshopper (vulnerable under Territory legislation).

Map of Belconnen Naval Transmission Station, Lawson
Map of Belconnen Naval Transmission Station, Lawson

Natural Temperate Grassland

Natural temperate grassland is one of the ACT’s most threatened ecosystems.  It is estimated that 20,000 ha of natural temperate grasslands occurred in the ACT prior to European settlement.  Only approximately 5% (1,000 hectares) of this grassland remains today. Nationally, less than 1% of this community remains1. 

Natural temperate grassland is a native ecological community that is dominated by native species of perennial tussock grasses.  The dominant grasses are Themeda triandra, Austrodanthonia species, Austrostipa species, Bothriochloa macra and Poa species.  The upper canopy stratum generally varies in height from mid-high (0.25–0.5 metres) to tall (0.5–1.0 metres). There is also a diversity of native herbaceous plants (forbs), which may comprise up to 70% of species present.  The community is naturally treeless or has less than 10% projective foliage cover of trees, shrubs and sedges in its tallest stratum.  In the ACT it occurs where tree growth is limited by cold air drainage, generally below 625 metres altitude [1].

Under the ACT Nature Conservation Act 1980 the Minister for the Environment, on the recommendation of the Flora and Fauna Committee, has declared that the natural temperate grassland is an endangered community.  The grassland is also listed as an endangered ecological community under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPCB Act).

The natural temperate grassland at BNTS has a botanical significance rating of 2[2]. This means that the natural temperate grassland at BNTS has high botanical significance[3]. There are only three sites in the ACT, which contain natural temperate grassland, which has a high botanical significance rating and which are over 50 ha in size[4]. BNTS is one of these three sites[5].

Threatened Species

At BNTS the natural temperate grassland is the habitat of the perunga grasshopper (which the Minister, on the recommendation of the Flora and Fauna Committee, has declared to be a vulnerable species), the golden sun moth and the ginninderra peppercress (both of which the Minister, on the recommendation of the Flora and Fauna Committee, has declared to be endangered species).  Another vulnerable species, the striped legless lizard, has been found outside the secure area; however, it was most likely present in the secure area at BNTS in former years.

Under the EPBC Act the golden sun moth is listed as critically endangered and the ginninderra peppercress and striped legless lizard are listed as vulnerable.

Eastern Grey Kangaroos

Within the secure area of BNTS eastern grey kangaroos (kangaroos) are contained. As at 10 December 2007 there were approximately 588 kangaroos within the secure area.

Approximately 60 female kangaroos in this population are tagged and are being used for fertility research purposes.  Of these 60 kangaroos, 40 have been subject to trial fertility control measures and the remaining 20 have been used as controls.


Within the context of the terms of reference for the investigation (Attachments A (15.1 kB pdf) and B (12.8 kB pdf)) the six critical questions in relation to the BNTS site appear to be:

  1. Should the natural temperate grassland and the threatened species within the grassland at BNTS be conserved?
  2. What is the current state of the natural temperate grassland at BNTS?
  3. If the current state of the natural temperate grassland at BNTS is less than optimal, what is the cause?
  4. What action is necessary to conserve the natural temperate grassland and threatened species that have the grassland as their habitat?
  5. If action to conserve the natural temperate grassland requires removal of some or all of the kangaroos, what is the most humane method of removing the kangaroos within the constraints of the BNTS site?

Expert Panel

To assist in resolving the six critical questions related to BNTS, as outlined above, an interdisciplinary approach was considered desirable.  To this end a panel of experts from different disciplines was formed. The expert panel consisted of:

  • a plant ecologist who could advise me on the current state of the natural temperate grassland and threatened species that have grassland as their habitat (Dr Sue McIntyre);
  • an expert in relation to kangaroos (Professor David Morgan);
  • an expert in relation to animal welfare issues (Michael Linke); and
  • a veterinarian experienced in animal research and animal ethics to provide practical advice in relation to animal management (Dr Andrew Braid).

A copy of the curriculum vitae for each of these experts is at Attachment F (231 kB pdf).

The expert panel met as a group on 25 January 2008 and on that day inspected the natural temperate grassland at BNTS.  The expert panel was provided with a copy of all the submissions received in relation to the Investigation together with a number of other documents relevant to the issues identified above.  The expert panel was requested to consider the six issues identified above and provide an interdisciplinary expert report.


[1] ACT Government, 2005 A vision splendid of the grassy plains extended: ACT lowland native grassland conservation strategy. Action Plan No. 28 (Arts, Heritage and Environment, Canberra), paragraph 2.1.4
[2] ibid paragraph 3.4.6
[3] ibid  see table 3.1 and paragraph 3.4.6
[4] ibid  paragraph 3.4.6
[5] the other two sites are the Majura Training Area and Mulanggari Nature Reserve