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
Development of Ngunnawal Residential Estate 2C
Reference Number: 2010/5648
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 considers that the proposed development of Ngunnawal 2C should be regarded as a controlled action and that development should not proceed until either there are proposals that would protect areas of secondary grassland and golden sun moth (GSM) habitat present at the site, or an adequate, concrete and workable strategy is adopted to ensure survival of box woodland and GSM habitat on a landscape scale.
The ecological assessment in attachment B states that “The assessment by this firm in 2003 (Ref. 2) determined that, despite being categorised as yellow box – red gum woodland/secondary grassland in the draft of that Action Plan, Areas A, B, and C did not meet the criteria for inclusion as the endangered ecological community due to the presence of predominantly exotic pasture with few native grasses and forbs, and thus did not impose a constraint on development.” Not only is this contrary to the view expressed in the ACT Lowland Woodland Conservation Strategy (Action Plan No. 27), but also it does not fit with FOG’s recent observations. On 4 October, this woodland contained healthy patches of several uncommon and rare plants, Diusis chryseopsis, Stachhousia monogyna, and Wurmbea dioica, none of which are mentioned in the submission. As most of the 2C area is off limits to members of the public, it was only possibly for us to observe the area from the other side of the fence. From such observations, there appear to be large patches dominated by (i) kangaroo grass and common everlasting (Chryosocephalum apiculatum), signature species for natural grasslands, (ii) spear grass, and (iii) wallaby grass, and (iv) exotic grasses and forbs. Normally patches of kangaroo grass would be regarded as native grassland, spear grass areas as native pasture, and wallaby grass may fall on either side of the native grassland/pasture divide. The presence of GSM in associated with wallaby grass, suggests that it should be regarded as grassland rather than native pasture.
While acknowledging that the area of high quality Box woodland derived grassland being impacted on the edge of the proposed development is small, further urban development in the vicinity is likely to have a longer term impact on the remaining woodland area. However, there are no proposals to mitigate such impacts or to offset them (so that any losses occurring here may result in gains elsewhere).
The proposal suggests that there are small numbers of GSM present. Since the moth is endangered, there should be no development occurring in areas where GSM are present. As well, areas of adjoining potential habitat should also not be developed until investigated fully, also taking into consideration connectivity of GSM habitat. Our view on GSM is guided by the following:
- The current status of the moth is critically endangered. In recent years there has been growing evidence that there may be more moth habitat than previously thought. FOG would support a review of the status of the moth, but that would need to be based upon a proper scientific assessment. Until the current status of the moth is changed, sites on which it occurs should be “no go” areas.
- The proposal suggests that there is a strategic approach to conservation of the moth (put together by David Hogg). FOG welcomes the work that that has been put into this, but notes that it is not a recovery plan for the moth. As far as we are aware, this strategic approach has not been reviewed by independent experts or by stakeholders such as FOG, nor has it been adopted by the ACT government. As well, we are concerned about the suggestion concerning translocation of the moth when it is not clear if this will aid in the long-term survival of the moth.
- The submission states that the moth is in low numbers on the site, despite the fact that 24 moths were sighted in a 1.25 hour walk around. No indication of the comparison sites is given. The community monitoring of GSM undertaken in 2008-09 indicates that the moth is only in very high abundance at six sites in the ACT, and that a site with this number of moths may be an important population outside those six sites.
FOG recommends that actions at the site be frozen until
- more work is done on establishing the status of the moth at the site, and
- there is a proper plan, agreed to by all stakeholders, for recovery of the moth.
5 October 2010