Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Referrals Section (EPBC Act)

Approvals and Wildlife Division

Department of the Environment and Water Resources

GPO Box 787



Dear Madam/Sir


Project 2007/3520, National Capital Authority

Block 22 Section 32, Yarralumla, ACT


This project, referred under the EPBC Act, proposes to develop the site for a diplomatic mission. The site includes remnant natural grassland. Friends of Grasslands (FoG) believes that this proposal warrants further investigation prior to any approval under EPBC as it will have significant impact on a threatened species under the Act: the golden sun moth Synemon plana. Both this species and the natural temperate grassland community are listed as endangered under ACT and Commonwealth legislation; the golden sun moth is listed as 'critically endangered' under EPBC. 


FoG is a community group dedicated to the conservation of native temperate grassy ecosystems, such as grasslands and woodlands. FoG is based in Canberra and its members, numbering about 200, include professional scientists, landowners, land managers and interested members of the public. FoG advocates, educates and advises on matters to do with conservation of grassy ecosystems, and carries out surveys and other on-ground work. 


FoG believes that this referral is not well prepared, with mistakes (e.g. references to date of survey and number of golden sun moths - '18 male' at 4.1.(d) and '8 males' at 7.1), very confusing description of mapped information at figure 8.2 (intended to interpret vegetation values on site), inconsistent reference to the total size of the remnants, and variable referencing of relevant ACT documents (the 2005 ACT Lowland Native Grassland Conservation Strategy: Action Plan no. 28 is footnoted on p.5, but another is referenced on p.11), which makes the information contained within it less credible. 


FoG's reasons for believing that site development will have a significant impact on the golden sun moth are as follows.

The ACT Strategy provides useful background for this matter, as it:

FoG believes that the conservation value of the two identified remnants on the proposed development site - as grassland and as golden sun moth habitat - should be assessed before any action is taken to remove them from the range of sites supporting this critically endangered species, or to degrade their value further. Such assessment is provided for in the ACT Strategy, and should consider the option of retaining the remnants and protecting them as part of, or adjacent to, any reduced site development.

Yours faithfully





Bernadette O'Leary


13 July 2007