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


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:

FOG recommends that actions at the site be frozen until


Sincerely yours





Geoff Robertson



5 October 2010