Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608


Mick Welsh
Commonwealth and Territories Section
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
Ph: 02 6274 1692



Dear Mick


Forde North Development, Gunghalin, ACT

Reference Number 2010/5439


A major concern of FOG in relation to this development is the presence of the endangered Golden Sun Moth (GSM) (Synemon Plana) in this area.  The GSM is listed as critically endangered both nationally and in New South Wales, Victoria and the ACT.  The Ecological Assessment notes the presence of GSM in this area and its significance as a GSM breeding ground.


The argument that the GSM is in low numbers in Forde North is not, in FOG’s view, sufficient to justify developing the area.  The recent report “Community Monitoring of Golden Sun Moths in the Australian Capital Territory Region, 2008-2009” pointed out that the GSM was only present as small or medium-sizes populations at most locations where it was found, and only high abundances at a few sites, not surprising given that the GSM is critically endangered.  WWF has nominated the GSM as one of the ten Aussie battlers, species that are at great risk of extinction and require urgent help to survive.  The argument that the impact of developing sites with low GSM numbers is minor in the wider context of golden sun moth conservation in the ACT could result in the loss of most or all such sites to development over time, with the net effect of a significant impact on this endangered species – a point that is especially pertinent given two development proposals making the same argument currently (for Forde North and Throsby).


Because the GSM is a critically endangered species, any site at which it is present should not be developed until the species has recovered.  At this stage we lack information about the moth’s ecology, the importance of sites where there are low populations of GSM, and how moths might move into new areas and become more abundant (which may be what is occurring on this site).  FOG has been studying the GSM and can provide a copy of the report “Community Monitoring of Golden Sun Moths in the Australian Capital Territory Region, 2008-2009” if desired.  At the very least, a more strategic approach to the conservation of this species is needed before any development of sites such as Forde North occurs.


According to the Ecological Assessment, Area A meets the EPBC Act criteria for Box – Gum Woodland.  While this area lies largely outside the development zone, part of it would be impacted by the proposed development.  In FOG’s view, all of this area (and a suitable buffer zone) should be excluded from any development activities.


On visiting the site, FOG saw two areas of the creek with severe erosion, but, the remainder of the creek is in reasonable condition, so it is not clear why the creek needs to be completely re-engineered along its entire length, leading to destruction of all of the secondary grassland and golden sun moth habitat within the development site.  It is also not clear why the entire creek needs to be re-engineered if Forde North is not developed.  If only the severely eroded areas were re-engineered, large areas of Themeda would be retained.  The trees along the creek line include magnificent specimens. The creek line is also an important small bird habitat and corridor. The proposal as it currently stands would remove these.


If it is decided that the creek needs to be completely re-engineered for public safety reasons, substantial offsets should be offered, but are not evident in the proposal.  There is a suggestion to attempt to relocate the GSM into appropriately landscaped areas, although it lacks expert opinion about the likely effectiveness of such an approach.  The results of such an experiment would be useful information to have in the future and could form part of a strategic approach to conservation of the GSM.  However, there is no assurance that it will work, so a direct offset is also needed.


As well as GSM habitat, Forde North contains secondary grassland which is part of Box-Gum Woodland and which is listed under Action Plan no 27 “ACT Lowland Woodland Grassland Strategy” as such.  On inspection recently, FOG observed that at least half of the grass in the area was redleg grass (Bothriochloa macro) rather than exotics – this difference from the Ecological Assessment no doubt due to the time of year the two sets of observations were made.  As well, there were extensive areas of Themeda along drainage lines.  There were some woody weeds and serrated tussock present, which suggests that the land has been neglected recently in terms of control of declared weeds.  This area of secondary grassland will be lost if the area is developed, wasting any opportunity to restore the area in the future.  Because of this and the presence of the GSM, FOG would prefer that the area not be developed.  If it is, then offsets must to be offered for the loss of an extensive area of secondary grassland as well as a GSM breeding area.


FOG notes in the proposal that Forde Developments have met with representatives of the ACT Government to discuss the co-ordination of offsets for Forde North within a wider ACT Government offset strategy.  While the ACT Government may “aim to be in a position to guarantee that any negotiated offsets in the assessment of this submission would be satisfied by the ACT Government”, this is not reassuring from a community perspective.  At this stage we understand that the ACT Government has not yet finalized its offset policy, and there has certainly been no opportunity for the ACT community to assess this policy and its implications, and decide if they meet the community’s requirements.  Offset policies and principles, and their application to particular development proposals, need to be made available in the public domain before the proposals are approved and proceed.  In this case, offsets would need to be significant, and are not evident in the proposal.


FOG supports mandatory cat containment in Forde North.  The Ecological Assessment does not consider the separation of the Forde North development from Mulligans Flat Nature Reserve by the former Gundaroo Road to be an adequate buffer to prevent garden plants from escaping into the reserve.  FOG supports education for the new residents on appropriate garden species, but also considers that additional resources will be needed into the future to prevent the spread of weeds from the residential area into the reserve area.  There is no mention of bushfire buffer zones in the proposal.  The buffer should be 300m wide and be contained within the development and the former Gundaroo Road.


FOG was strongly opposed to earlier developments at Forde, and decries the lack of opportunity for community groups and independent experts to look more clearly at the issues on the ground in this case.  In other development proposals, such consultations have taken place, giving concerned groups the opportunity to possibly influence the design in order to obtain better biodiversity outcomes.  Instead, we see a proposal that will result in a loss of biodiversity, with little in the way of an ecologically strategic approach or any attempt to retain areas of higher conservation value.


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



22 April 2010