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 ref no. 2007/3734
Residential development, Macgregor ACT
This project, referred under the EPBC Act, proposes to develop land to extend the suburb of Macgregor. The referral refers to 'a large population' [4.1(d)] of the golden sun moth Synemon plana 'north of the intended development area within the Ginninderra Creek Corridor'; this species is listed as critically endangered under EPBC, and endangered (special protection status) under ACT legislation. Most remaining occurrences of this species are in the ACT region, and the key threat to it is continued loss and fragmentation of habitat, including through urban development. The referral also refers to the development site including 'natural temperate grassland' (NTG). The relevant ACT Action Plan shows occurrence of this community (listed as an endangered ecological community under EPBC and in the ACT) to the north/northwest of the development site.
Friends of Grassland (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 over 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's reasons for believing that the proposed development may lead to significant impacts relevant to EPBC are that: the value of NTG on and adjacent to the site is unclear; and the referral makes no attempt to put mitigation measures in place to protect the golden sun moth and its habitat.
FoG suggests that - depending on the remnant values of the site, which are not addressed adequately in the referral but may extend those of the locally identified NTG occurrence - the proposed development should seek to minimise destruction of or damage to the community, where possible. Given that the Action Plan does not even identify the population of the golden sun moth - yet it exists and is 'large' - it is possible that the overall value of the NTG in this area of the ACT, to conserve threatened species and the ecological community, requires further study prior to further development.
FoG believes that this proposal needs to address mitigation measures adequately prior to any approval under EPBC as, if development activities were to spill beyond the identified development site, they may have significant impact on the species' population and its habitat. At '6. Measures to avoid or reduce impacts', the referral simply states 'not applicable', presumably because the habitat site is beyond the holding lease boundary; FoG's view is that this is not good enough. Minimum mitigation measures that should be put in place before approval of this development, to avoid spillover effects on the habitat, include the following:
- placement of a fence between the development site and the adjacent golden sun moth habitat to keep traffic and machinery and materials off the habitat; it is not clear from the referral if the 'golden sun moth boundary' shown in the relevant map is to be fenced
- no services to be routed through the habitat
- no runoff or debris to be directed at the habitat.
FoG is keen to ensure long term conservation outcomes for grassland remnants and the threatened species they contain. This referral should also have addressed strategies for limiting impacts on the threatened species and its habitat (at least) in the long term as a result of the location and exent of adjacent resident human population. This may include things like permanent fencing and signposting of the habitat. Other remnant grasslands in the ACT (e.g. Dunlop Grassland) provide examples of where steps have been taken to identify sites and manage them for conservation in an urban setting.
FoG looks forward to your consideration of these comments, further consideration of remnant NTG values and improvements to the proposal, if approved, to ensure short to long term mitigation of potential impacts on the endangered ecological community and the endangered species and its habitat.
8 October 2007
 A vision splendid of the grassy plains extended: ACT lowland native grassland conservation strategy, Action Plan No. 28