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


York Park – Carpark Access Road Reference Number: 2010/5548


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 is very concerned about this development and the proposed carpark itself due to the presence of the endangered Golden Sun Moth (GSM) (Synemon Plana) in York Park.  The GSM is listed as critically endangered both nationally and in New South Wales, Victoria and the ACT.   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.  Because the GSM is a critically endangered species, any site at which it is present should not be developed or impacted upon until the species has recovered.


To preserve endangered species and ecosystems for future generations, there must be some areas that are “no go”.  If, in such an area, a development is deemed to be absolutely essential, losses should be minimized.  It is hard to see how a multi-storey carpark and its access road could be considered absolutely essential, particularly in the light of climate change and the need to reduce our dependence on cars and make better use of alternatives such as public transport.  With regard to York Park, FOG regards this site as iconic, and it is one of the sites identified in Action Plan 28 as being of high value.  The site, despite being small, has remained viable and continues to support a GSM population.  On a recent site visit, FOG noted that there is an issue with weeds on the site, but that the site is in better condition than it has been in the past.  With improved management and no impacts from development activities, FOG believes that the site could be restored to a very good condition, with the consequence of maintaining and perhaps increasing the GSM population.


FOG notes that the current proposal has been designed to minimise the impact on the site and the GSM, but considers that a loss of 6.5% on a small but important site like this still to be significant.  Similarly, the unknown but likely impact of the carpark might be able to be reduced, but will still have an effect.  The proposal suggests that the site could be shaded by as much as 42% during the winter, which is likely to have considerable effect on the microclimate of the site and could lead to a significant increase in weed recruitment to the detriment of the native species and ultimately to the GSM (e.g. by delaying emergence and mating of the moths until later in the season when conditions are unsuitable for mating and egg-laying).


FOG notes that three alternative locations for the additional connection from the carpark development to the external road network were considered but that two were “considered unacceptable by the NCA because of existing or future development constraints”.  Without information about these, it is difficult to comment on alternatives to the current proposal.  However, FOG finds it unacceptable that an area of endangered ecosystem be given lower priority than nebulous “future development constraints”.  Even if an alternative access were possible, the likely impact of shading from the carpark is still a serious issue and should, in FOG’s view, preclude this development.


This is a site on which there has been ongoing scientific monitoring of the GSM over a long period.  FOG is appalled at the use of science to help justify the proposed carpark, as suggested by “…offer the opportunity for assessing whether microclimatic changes associated with limited building shading have a significant adverse impact on the golden sun moth”. Surely it is more important, when dealing with a critically endangered species, to ensure that such long term monitoring not be compromised?  The issue of shading of the site has come up some years ago, and FOG’s view now is the same as in the past: any development that shades the site in any way should not be allowed to proceed.


In the last few weeks FOG has seen and commented on five development proposals impacting on the GSM, of which this is the latest.  All of them use the argument that the moth is in low numbers on the site or that the area being affected is small.  The observation that the GSM is present (albeit in low numbers) at more sites than previously thought should be providing an opportunity to take stock of how we can increase the numbers of this critically endangered species, not being used as an argument to proceed with a number of non-essential urban developments because there are more moths somewhere else.  It is this sort of attitude that has led to this (and many other) species becoming vulnerable or endangered in the first place.


Once again, FOG asks that a more strategic approach to the conservation of this species is considered and discussed with the community before any development of any of these sites (including York Park) occurs.  While attachment G contains the document “A Strategic Approach to the Conservation and Environmental Assessment of Golden Sun Moth Sites in the Canberra Area”, as far as FOG is aware, there has been no strategic approach presented to the community for comment or adopted by any level of government.  Given the number of development proposals impacting on the GSM that are being referred to the Commonwealth for consideration under the EPBC act, surely it is time to stop and consider a more strategic approach before proceeding with so many developments.


In conclusion, FOG is totally opposed to this development or the multi-storey carpark for which this development proposal is the forerunner.  York Park is an icon site with scientific values as well as conservation values, and any development affecting it should not go ahead.  As well, FOG would like to see better management of the site and is willing to work with the National Capital Authority to improve the conservation values of the site.



Sincerely yours





Geoff Robertson



5 July 2010