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
CANBERRA ACT 2601
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 vegetation species identified on the site (both grasses and forbs), and the occurrence of the golden sun moth, indicate that the remnant represents the endangered ecological community.
- Neither the condition reported, nor the occurrence of 'bare soil', necessarily detract from the site's remnant values. The site was surveyed during a very dry period, and has since recovered to a better condition. 'Bare soil' includes cryptogamic crust, a feature of grasslands. The referral notes the relatively weed free nature of the remnants.
- Golden sun moth habitat is located across a range of sites of varying size (mostly small) and quality in the ACT, and this is likely to be the reason for the species survival. Loss of such sites over time may mean the loss of this species. The referral implies (at 6) that it would be reasonable to develop the site as there are other 'more viable habitats' near by. The larger of the sites referred to at 6.1 do not have golden sun moths recorded; the one which does is smaller than the proposed development site. The security of other sites is uncertain. FoG's view is that these are strong reasons to retain and conserve the remnants on the proposed development site as part of the land use matrix.
The ACT Strategy provides useful background for this matter, as it:
- identifies direct loss of grassland (e.g. by urban development) as a threat to remaining grassland areas, and continued removal and fragmentation of habitat as key threats to grassland fauna; the latter is of particular significance for invertebrates - despite their conservation requirements (e.g. patch connectivity, species mix) not being well understood
- the threat to the golden sun moth is identified specifically as its grassland habitat is already extremely fragmented
- seeks to protect such habitat both on- and off-reserve; only 25% of known golden sun moth habitat is protected in reserves, and long term protection is not assured until its habitat is better reserved - new priority sites are added to the ACT Strategy as they are recognised, including three in close proximity to the proposed development site since identifies 'maintaining or increasing population size' as a major conservation issue for the golden sun moth, and the protection of 'existing viable populations of golden sun moth' as a conservation objective, noting that there is not sufficient knowledge of what constitutes such a population [as 18 males were found, and females are hard to locate as they are flightless, the remnants may well contain the minimum viable population size of 50 used as a threshold in EPBC guidelines, a significant portion of the population in a highly fragmented landscape]
- includes a conservation planning principle of retaining both larger and higher quality conservation sites and fragments.
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.
13 July 2007