Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608


Attn: Ngunnawal EPBC Referral
Land Development Agency
GPO Box 158
Canberra City  ACT  2601



Dear Sir/Madam


Ngunnawal Residential Estate Stage 2C, Gungahlin, ACT EPBC referral


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.


In reviewing this paper, there are three distinct areas that FOG would like to comment on: the golden sun moth (GSM), yellow box red gum grassy woodland, and offset proposals.


FOG welcomes the preparation of the proposed strategic approach to the conservation and environmental assessment of golden sun moth sites in the Canberra area. However, we still have several concerns about this matter. The first is that, as far as we are aware, this strategic approach has not been reviewed by independent experts. In this regard, FOG recently wrote to the Commissioner for Sustainability and the Environment (CSE) about this issue (see attached letter), but has not yet received a reply. The targets proposed in the report sound reasonable to a non-expert, but need to be reviewed to determine whether the number of sites proposed in each area are sufficient to not only enable the GSM to survive indefinitely, but also see its population increase sufficiently so that it no longer needs to be listed as either endangered or threatened.


As well, preparation of a strategic approach does not mean that it will be adopted by the ACT Government or implemented. There has been ample time since this strategic plan was first drafted (it was available in the public arena at least as early as February 2009) for both an independent review to have been undertaken, and for the ACT Government to consult with stakeholders and consider adopting an agreed strategy. Instead, we see an updated version of this draft document (which, as far as we know, has no status from the ACT Government’s perspective) being used to continue a piecemeal approach to urban development, the consequence of which will be net loss of GSM population. In this context, we note that the Land Development Agency is reviewing the concept plan for Moncrieff with a view to producing a refinement which would establish a grassland and woodland conservation reserve to conserve a large part (of the order of 50 percent) of the golden sun moth habitat. Given the closeness of the two areas, FOG would prefer that they were considered together, so that it is clearer to the community as to what the total impact the proposed developments would have on the GSM.


FOG remains very concerned about the continual encroachment into and destruction of GSM sites. The current status of the moth is critically endangered. While recent information suggests that the moth is found at an increased number of sites, albeit sometimes in low numbers, this should not mean that destruction of the majority of these sites is a reasonable action. 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, all sites on which it occurs should be “no go” areas, and it should not be assumed that its conservation status is secure.


Before proceeding with this development, FOG considers that:


FOG notes attachment D, the “Background paper for roundtable discussion on development and implementation of an ACT Woodland Restoration Plan”, although we are not clear as to the status of this paper in the context of the current proposal. However, we provide these comments as they may be of relevance for future proposals in Moncrieff as well. Despite its long standing interest in yellow box-red gum grassy woodlands (YBRGGW), FOG was not invited to this roundtable and has had no opportunity to input to this discussion. While we agree with many of the conclusions of the report, we have some concerns about the recommendations for restoration activities as they stand. In FOG’s view, restoration of YBRGGW should involve expert advice as well as work undertaken by volunteers. An expert bushland regeneration team with a high level of skills in ecological restoration and management needs to be involved to ensure that restoration work is as effective as possible in terms of restoring the original YBRGGW habitat.


In general, FOG opposes any developments that necessitate the use of offsets. In our view, there should be no development in high conservation areas, and losses from development should be minimized in any area with a conservation value. Having said this, we make the following comments about the offset section of the Preliminary Documentation.


We note the statement that “Given the major initiatives that the ACT Government has already taken to conserve known golden sun moth habitat … it can be argued that the ACT Government has already established a significant credit balance in this respect through the Action Plans and subsequent land use decisions, some of which have still to be carried to their conclusions”. FOG has two concerns with this statement. The first is the assumption that conservation measures taken in the past to offset losses occurring at that time can be used again to offset further losses. Offsets are single-use, and we view the areas reserved in the past as offsets for losses occurring at that time. The concept of offsets is that, at the very least, there should be no net loss – in fact, FOG’s view is that for endangered and threatened species and ecosystems, we should aim for a net gain. The current proposal will result in a net loss. The second is the acknowledgement that some of these past decisions have not yet been carried through. The implications of this are that we do have net loss across the landscape. Following through with these conservation measures is in fact completing previous offsets and should not be offered as a new offset.


The discussion paper suggests that “the use of an offset ratio of 1:1 represents a pragmatic approach to safeguarding environmental protection while a ratio of 1:3 represents an upper limit that may be applicable in other jurisdictions that do not have as extensive a history of environmental protection as does the ACT”. In FOG’s view an offset ratio of 1:1 is too low given the history of inadequate resourcing of conservation reserves and other environmental problems such as weed control, leading to degradation of high quality grassland and grassy woodland sites. Examples include the grassy woodland site under discussion in this proposal, and the numerous grassland sites the CSE identified as being in or approaching a critical condition (60% of ACT lowland grassland sites – see the CSE’s Report on ACT Lowland Native Grassland Investigation). As well, offsets should be aimed at “net gain”, not maintenance of the status quo, if there is any hope of these species and ecosystems eventually becoming sufficiently common in the landscape to no longer needing to be listed as endangered. We also lack information about relative conservation values of the different sites proposed. In general, the offset land should be of at least similar quality to that being lost (or restored to that quality by experts before being used as an offset). We also lack information about the basis on which these offset ratios were derived, or how they might be applied in an ACT context, since the ACT Government has not yet released its offset policy into the public arena, despite using it as the basis of discussion in recent development proposals (including this one).


The document makes reference to the possibility of grassland site MA06 (Majura West) being offered as an offset for several development proposals in Gungahlin. In FOG’s view this needs further discussion and consideration. We were advised by the Minister for Environment, Water and Climate Change (Simon Corbell) in 2009 that this site will be gazetted as reserve in 2010. In our view, offsets must be supplementary and not substituting for already existing commitments, which this reserve could be viewed as. Offsets should be “like for like”, which in this case means the presence of the GSM on the site. Offsets should be in place before the development commences. In this case, if MA06 were used as an offset, the area would need to be reserved and work undertaken (.e.g. by a bush regeneration team) to improve the quality of the area, and also to determine if the GSM is already on the site. Ongoing funding that is additional to current reserve funding is needed to ensure that the site improves and maintains its conservation values.


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. It certainly should not be offered as an offset until there is evidence that such translocation is effective.


Sincerely yours






Geoff Robertson



24 January 2011