Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608



Commonwealth and Territories Section
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts



Dear Sir/Madam


Residential development, MacGregor West 2 Estate

Reference Number: 2010/5520


In considering the draft recommendation report on the proposal to develop Macgregor West, FOG is pleased to see that some of its concerns expressed in its earlier submission on this development being addressed.  In particular, FOG welcomes the addition of a buffer zone along the offset area boundary and the requirement for the proponent to develop a management plan for the offset area to include mitigation of indirect residential impacts on the Golden Sun Moth (GSM) habitat, interpretative signage, research to be directed at replacing Chilean needle grass with native grasses (noting this also has GSM implications such as impacts upon any populations currently existing amongst the needle grasses), and management of the area in perpetuity.  FOG would be interested in looking at the management plan once it is drafted, and could provide comments if requested.  Similarly, FOG would be interested in the results of any audits the Department undertakes on this project.


One comment FOG would like to make about the conditions is the need for the results of the research into replacing Chilean needle grass with native grasses to be incorporated into the offset area management plan, if appropriate.


Of course, FOG remains disappointed that some GSM habitat will be lost, particularly given the number of recent development proposals impacting on the moth.  As we said in our earlier submission, 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.  As we have indicated in other submissions, a more strategic approach to the conservation of the GSM is needed before any further development of GSM sites in Canberra occurs.  One suggestion to progress such an approach might be a workshop of stakeholders to look at the overall management of GSM sites and protection of this species in perpetuity within the ACT.


Sincerely yours





Geoff Robertson



9 August 2010