Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Mr. David Rhind
Commonwealth and Territories Section
Environment Assessment Branch
Department of the Environment, Water Heritage and the Arts
PO Box 787 Canberra ACT 2600
02 6274 2611


Dear David


Bonner stage 4, Gungahlin, ACT – site servicing and land release

Reference Number: 2009/4816


I am writing to provide comments by Friends of Grasslands (FoG) on this referral of a proposal for site servicing and land release for Bonner stage 4, Gungahlin, ACT.  In responding to this referral, FoG notes that the development proposal will result in the loss of secondary grassland (that forms part of a White Box – Yellow Box – Blakely’s Red Gum woodland community) containing a critically endangered species, the golden sun moth (GSM) (Synemon plana), as well as an area of the endangered community White Box – Yellow Box – Blakely’s Red Gum woodlands.  Other uncommon and vulnerable species have also been sighted in the area, including the Perunga grasshopper (Perunga ochracea), bunch wiregrass (Aristida behriana), dwarf milkwort (Polygala japonica), tough scurf-pea (Cullen tenax), and the white-winged triller (Lalage sueurii).  FoG recognizes that the proposal has been modified from the original Bonner Concept Plan to achieve more effective conservation of GSM habitat, but still has a number of concerns about the proposal.


The ecological assessment of development options raises four options, but it isn’t clear to FoG from the submission which option is preferred.  FoG considers options 1, 2 and 4 unacceptable because of the large area (65-70%) of box-gum woodland that would be lost.  Option 3 is the best of the four options presented, with 32% of box-gum woodland being lost.  As stated in the ecological assessment, this option “which conserves a large, compact and diverse area would be the most favourable for conserving these other biodiversity values”.  On the other hand, “... the theoretical benefits of the grassland blocks in this respect are unlikely to be realised in practice for Option 2. Options 1 and 4 involve intensive development of the largest area of habitat and would therefore be expected to have the greatest direct impact.”  Given this, FoG considers options 1, 2 and 4 to be unacceptable, and option 3 the only option that should be considered.


In fact, FoG’s view is that the best approach at this stage is to follow the suggestion at the conclusion of the GSM report attached to the proposal: “In view of the more specific knowledge of GSM distribution within the site, it would be worth reviewing the urban boundary and the subdivision layout to determine whether an alternative design for this part of Bonner could be achieved which provided more effective conservation of the GSM while still providing an acceptable development solution.”  FoG not only strongly supports this suggestion, but also considers that ecological assessments in the entire area should be completed before any trade-offs in areas of endangered communities and species are made.  The proposal indicates that reduction in the total dwelling yield for Bonner will put pressure on future developments in areas of Jacka and Moncreiff where ecological assessments have not yet been completed.  It does not seem appropriate to be asked to accept losses now as a possible trade-off to leaving areas of unknown quality in the future.


FoG notes, in section 4 of the proposal, the measures (to be written into the deed(s) of agreement or construction contracts for developing the estate) to avoid or reduce overspill impacts (particularly during the construction period) but does not consider them to be sufficient.  As well as providing edge roads around the development and fences at the outer limits of construction corridors, the deeds of agreement or construction contracts should include recognition of the natural values being protected and the need to avoid damage to them.  If the measures are breached, significant financial disincentive should be used to remediate any damage caused.


In the longer term, the GSM areas need to be managed for anticipated future human impacts such as foot traffic (e.g. by appropriate fencing or paths), and dumping.  Bushfire and other management tracks and structures should be outside the GSM areas.


Ongoing management of the grassland areas will need to be at a higher intensity than is typical practice in Canberra Nature Park areas if the GSM population is to be maintained in the long term.  Management of any area where the GSM is found currently needs to include maintenance of suitable habitat for the GSM, rather than allowing eucalypt regeneration to exclude the GSM over time.  The Land Development Agency advises that, while it is an ACT Government responsibility, ongoing management of the grassland areas for the GSM falls outside its control and makes no commitment in this regard.  FoG’s view is that discussion of long term management of this area should be considered at this stage rather than being left to be picked up (possibly) at some nebulous time in the future.  Surely the appropriate agency within the ACT Government could be consulted now about management issues?  As the area in question is adjacent to Mulligans Flat Nature Reserve, a logical step would be to extend the nature reserve boundary to include any GSM habitat that is not located entirely within the Bonner development.  Designation of areas as reserve and commencement of management of these areas at the beginning of the development process could assist in prevention of accidental damage to these areas during the construction process as well as educating the new community about conservation of this rare insect.


FoG is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FoG advocates, educates and advises on matters to do with the conservation of grassy ecosystems, and carries out surveys and other on-ground work. FoG is based in Canberra and its more than 200 members include professional scientists, landowners, land managers and interested members of the public.


Sincerely yours





Geoff Robertson