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


Macgregor West 2 Estate development

Reference Number: 2010/5520 


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.


In considering the proposal to develop Macgregor West, FOG notes that the development avoids an area with high numbers of the Golden Sun Moth (GSM) and that mitigation measures such as diversion of stormwater from this area are proposed. Noting that the development boundary is close to the area of high density GSM, bushfire and other buffers should be part of the estate area and not encroach into the GSM areas, since bushfire management is not, at this time, totally compatible with conservation management of a native grassland area.


As FOG has stated in recent comments on other development proposals in the north of Canberra, the argument that the GSM is in low numbers in an area 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” found 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 pertinent given two other recent development proposals making the same argument (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 the GSM, and how they 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 in the north of Canberra occurs.  One important aspect from the FOG report supports the findings in the Macgregor GSM Conservation Report about GSM having been recorded in significant numbers through some stands of exotic Chilean Needle Grass.  FOG strongly argues that no programmes eradicating this introduced weed should proceed through any area of this type (i.e. one where the GSM occurs) until such time as professional ecological research into this association has reached its conclusion and informed recommendations made.


In FOG’s view, offsets for impacts on endangered species or ecosystems should only be considered as a last resort, which this does not appear to be. If, despite this, the decision is made to proceed with the development, FOG has a number of comments about the offset proposal. Firstly, as the GSM is known to occur in the area, offsets are essential. While acknowledging that the proposed offset area is of higher quality (in terms of the GSM) than the area that is being lost, FOG considers the offset ratio of 3:1 to be the minimum that should be agreed to.  In fact, in the short term the net result across the landscape is a reduction in both GSM numbers and habitat, since the GSM population and habitat in MacGregor West is being lost permanently.  Only if sufficient other habitat is restored and, as a result, GSM numbers increase could the development be considered to create, in the long term, anything other than a net loss in this endangered species. From this perspective, there needs to be long term commitment to rehabilitation and management for a positive result for the GSM.


Any offset proposal needs to include some covenant that will protect the offset site in perpetuity, conservation management of that site, and sufficient funding to support that management in the long term, not just for a year or two. The site needs a management plan that includes “bush regeneration” principles and strategies to maintain or increase the GSM population present, and any rehabilitation must be done to an acceptable standard. As well, the offset should be in place before the development commences. There needs to be a process in place to track the offset and take corrective action if needed, with long term monitoring and penalties included in the offset and applied for non-compliance.


While some information about the proposed offset is available in the development documentation, it is still lacking in sufficient detail to reassure FOG that the offset will be effective. In particular, some of the specific suggestions in the David Hogg 2010 report “Golden Sun Moth Conservation in North-West Belconnen” have been excluded from the referral document, raising further concerns about the likely effectiveness of the proposed offset. In terms of any rehabilitation activities, the development proposal itself notes a lack of clarity in what constitutes suitable GSM habitat. This needs to be clarified before the offset is agreed to and the development commences.


Sincerely yours





Geoff Robertson



15 June 2010