Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


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


Lawson South residential development

Reference Number: 2010/5549


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.


FOG has followed closely matters at Lawson and provided submissions and taken an active part in consultations, including the Lawson South Planning Study: draft variation no 299 undertaken by ACTPLA late last year.  FOG generally supports the proposed development, especially as it combines high intensity housing and therefore will have less imprint on the land, with sensible open space provisions, and as it provides for a broad buffer between the urban development and what is planned to be extensive grassland reserves in North Lawson (the Commonwealth-Belconnen Naval Transmitting Station (BNTS) site.


FOG supports the three measures to reduce impact on the natural temperate grassland and the loss of potential habitat for the critically endangered golden sun moth in Lawson South.  As indicated to ACTPLA, FOG supports the establishment and maintenance of at least a 30m buffer zone along the northern edge of Lawson south to protect the endangered ecological communities and conservation listed species in the high value grassland on the BNTS site, including re-establishment of grass cover between the edge road and the boundary fence with native grass species using seed collected from within the grassland or local region.  FOG considers that 24 hour cat containment measures should be mandatory in South Lawson and supports the proposed enforcement of the ACT Government’s cat containment policy for residents of Lawson South as outlined in Draft Variation to the Territory Plan No. 299. FOG also supports the proposal for appropriate placement and use of native species in the landscaping of the future suburb.  FOG has already recommended to ACTPLA that the slopes of Reservoir Hill be revegetated to increase the extent of woodland trees and understorey to replace the existing exotic groundlayer, and to connect it to remaining woodland along the travelling stock route and the side of the hill, and that other open spaces and buffer zones be revegetated with native grassland and woodland species.


While acknowledging that the development footprint has been reduced by 26 hectares “to ensure the ecological features of the land and adjacent land are maintained along with any other significant features”, FOG remains disappointed about the loss of natural temperate grassland, box-gum woodland and golden sun moth habitat that will occur with the proposed development, particularly in the absence of any firm offset proposals for these losses.  It is clear from the information provided that areas of moderate density golden sun moth populations will be lost, and that the development could lead to separation of any remaining moths in the open spaces to the south from the population in Lawson North.  The proposed planting of the open spaces with grassland species may lead to a connection between such populations over the long term, although it is not clear if this will be effective in the face of urban pressures on the open spaces.


FOG pointed out to ACPLA (24 November 2009) that the Ecological Assessment for this project recommended that, due to timing and seasonal limitations to surveys conducted during the current study, consideration should be given to undertaking follow-up threatened species surveys.  We consider these surveys essential before roads and blocks start to be laid out for the new suburb and before offsets are finalized.  In Attachment C to the current proposal, the results of a December 2009 survey for the golden sun moth are presented, with the conclusions being “the moths were widespread in low numbers on much of the site. No definitive statement can be made about the density of this population until it is surveyed under good conditions in mid-season (usually late November).”  This suggests to FOG that all planning and designing of Lawson South should be delayed until at least 2011, to better inform the processes for preferably avoiding, but at least mitigating, the impacts this development proposal will have on this critically endangered species.


FOG put to ACTPLA (24 November 2009) a proposal that the principle of no-net-loss of native vegetation in general and in particular no-net-loss of woodlands, of habitat for Golden Sun Moth and of native habitat of Striped Legless Lizard be adopted.  Remaining areas of woodland and grassland, and sizeable areas of other open space should be conserved and enhanced to create suitable areas of woodland and grassland habitat for a range of species, including threatened species.  To the maximum extent possible, as both the moth and lizard will only move slowly into adjacent habitat, new areas need to be connected with existing habitat.  Consideration should also be given to developing suitable sites for translocation of Ginninderra Peppercress, currently only known to exist in the BNTS, thus making it something unique to Lawson. 


It is disappointing to find no firm offset proposals in this development proposal.  There is mention of the possibility of offsetting the impacts of developing Lawson South by management of parts of Lawson North as a grassland nature reserve and enhancing it both as a natural temperate grassland community and as golden sun moth habitat, assuming the National Capital Authority hands Lawson North over to the ACT Government.  Outside this, mention is made of addressing other potential offset options outside the Lawson area in the context of a broader strategy for golden sun moth conservation in the Canberra area.  However, this is not a firm offset proposal.  In FOG’s view, offsets should actually be in place before a development commences.  As well, offsets should continue for as long as the development continues to have an impact, which in this case will be in perpetuity, i.e. any offset offered should include not just reservation of land but also ongoing conservation management and guaranteed funding of that management in perpetuity.  In other words, the situation with Lawson North and with a broader strategy for golden sun moth conservation in the Canberra area should be drafted in full detail, made public and discussed with the community before proceeding with any development impacting on the moth (particularly given the number of recent development proposals that will have an impact).


Sincerely yours






Geoff Robertson



29 June 2010