UBC worked with science experts including Cate Tauss, Prof Hans Lambers and Daniel Jan Martin from The Beeliar Group as well as the conservation NGOs Wildflower Society (WSWA), Nature Reserves Preservation Group (NRPG) and BirdlifeWA   in developing our submission to the City of Gosnells.  Submissions closed on 28 August 2023.

On this page is our collective assessment of the proposal and advice for submissions.

UBC’s Submission is here


save the gbsw 300This is the two minute submission option!

The Beeliar Group developed an online campaign so that you can send an email of concern to the City of Gosnells, copied to the Ministers for Environment and for Planning.

Follow this link to register your concern. It will take only two minutes to complete.



The Greater Brixton Street Wetlands is the most biodiverse area of native vegetation on the Swan Coastal Plain.

230711 GBSW Hero 5 600This image shows only a few of the species you can find there. Its unique biodiversity is attributed to the specialised plant adaptations responding to the complex soils, chemistry and hydrology of the site. This area supports naturally vegetated wetlands that are rare or no longer exist elsewhere, and it is one of the largest consolidated wetland areas of high conservation value on the Swan Coastal Plain. If the hydrology is further disturbed, it is inevitable that there will be loss of habitat and species. The Friends of Brixton Street Wetlands have been a long-term member of UBC – their patch is here.

The threat: The City of Gosnells has invited public comment on its plans for the development of Precincts 2 and 3B in the Maddington Kenwick Strategic Employment Area (MKSEA). They are proposing two amendments to their town planning scheme to rezone land to business development. These precincts sit either size of the Greater Brixton Street Wetlands with insufficient buffer zones that we believe will greatly diminished the GBSW, putting hundreds of species at risk, some of which grow nowhere else in the world.

The alternative: Implementing adequate buffers around the GBSW and the Yule Brook can protect this critical wetland and its biodiversity whilst only reducing the development envelope by 27%.


The EPA issued advice in accordance with section 16(j) of the Environmental Protection Act 1986 in October 2022 specifically about the Greater Brixton Street Wetlands. A summary is here. As well as providing advice on protecting and enhancing the environmental values of GBSW, the EPA also outlined the expectations for proposals and planning schemes around:

  • Traditional owner engagement
  • Protection of ecological and hydrological values (refer also to the offsets statement)
  • Hydrological and hydrogeological investigations
  • Stormwater management and drainage
  • Buffers
  • Cumulative Impacts

They conclude with the statement: Continued piecemeal development without enhancing the protection of the GBSW may result in further degradation of the area’s unique and significant environmental values.


We believe the proponents have misunderstood the complexity of the area and have thus under-estimated the impacts that industrial/business development will have on the GBSW. Much has been written scientifically about this area, and that research appears to have been given little regard. Furthermore. the proponents also do not appear to have given full regard to recent EPA advice on the Greater Brixton Street Wetlands specifically and Conservation Category Wetlands generally


the beeliar groups vision yule brook regional park 1 5 v2 600The importance of the hydrology of this area can be seen in the map of the hydroplain produced by Daniel Jan Martin.  And in the image below you can see how the MKSEA sits on top of that precious hydroplain.

The Greater Brixton Street Working Group (GBSW Working Group) proposes that, if the buffer zones were set at 100 metres, and the rural lots within the envelope of the GBSW were not rezoned, the development footprint would be reduced by only 27%, whilst allowing the wetland to maintain its size, connectivity, and seasonal water flows essential to its survival for future generations. You can see this in the comparison images.

230711 GBSW Hero 4reduced 600

GBSW Working Group strongly support the proposal of The Beeliar Group – Professors for Environmental Responsibility to create the Yule Brook Regional Park.

230711 GBSW Hero 2 600


Our Submission Guide is here. Word Version    PDF version

When writing your submission remember to state your position at the start; comment under specific headings and give a strong concluding paragraph. It can also be helpful to personalise your story using one or more of these ideas:

  • I am/we are active community conservation volunteer/s caring for my/our local bushland [NAME IT].  I am also aware of the importance of ecological linkages between our patches
  • I have knowledge/understanding about our local environment and the interconnectedness of patches of neighborhood nature
  • What is important to you…..   ( eg keeping what we still have…)
  • What are you concerned about…  (eg impacts on hydrology  / removal of bushland with impacts on fauna  (inc insects, reptiles, birds, marsupials)

We have several other documents about the GBSW that may help you add to your submission. The Beeliar Group’s proposal for a new Yule Brook Regional Park is here. See presentations from our workshop on 24 July – Daniel Jan Martin; Cate Tauss; Colma Keating and Christine Richardson. And the Nature Reserves Preservation Group of Kalamunda (NRPG) have also developed a submission guide. You can find it here].


Submissions have now closed. We hope that you copied your submission to 1 or 2 people from the list here.


Colma and Christine

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