Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Attention Block 799 District of Gungahlin Referral
Land Development Agency
GPO Box 158



Dear Sir/Madam


Block 799 Gunghalin: 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.


FOG has already provided submissions on the proposal to develop block 799 to the Commonwealth under the initial EPBC referral. As stated there, FOG’s view is that there should be no development that impacts on vulnerable or endangered species habitat or ecosystem communities, and in principle we oppose the proposed development and the use of offsets in these circumstances.


In relation to natural temperate grassland (NTG), we note that the majority of the grassland is mainly native pasture and lacks diversity. We also note that, while there is a small population of Golden Sun Moth present, the report concludes that development of the site is unlikely to impact the species in any real way.


However, the recent survey for the striped legless lizard (Delmar impar) confirmed that there is a good sized population of the lizard within Block 799. The report concluded that assessment of the importance of the striped legless lizard population at Block 799 in the ACT context is limited by the lack of comparable survey information for other known sites in the ACT. FOG’s concern in relation to these results is that current data on the striped legless lizard is inadequate. There has been only one recent comparable study elsewhere of the species (by Brett Howland in Mulanggari), and that the current size of populations in the other sites (four reserves in Gungahlin and Dunlop, Majura Training area and Jerrabomberra) is unknown. Numbers from this survey appear similar to those at Mulanggari, indicating that the site is likely to be of significance in terms of conservation of this vulnerable species.


FOG repeats its concern with the implication that reserves set aside fifteen years ago constitute some sort of offset for this proposed development. In our view, those reserves were offsets for urban developments happening at that time, and cannot continue to offset an ongoing stream of developments in perpetuity. Offsets relating to current and proposed developments must be supplementary and not substitutes for existing commitments, e.g. they should not replace existing reserves or government funding to maintain such reserves. Our recollection is that the three grassland reserves in Gungahlin were established as “offsets” of other developments in Gungahlin at that time and that Kenny was effectively left “on hold” but never identified to be developed without re- investigation of its importance for the striped legless lizard and other grassland species. FOG members who were involved in grassland issues at that time are not aware of either any written statement that conflicts with this recollection or any public statement that the three grassland reserves were a once-only trade off against future development of all other striped legless lizard sites. In any case, we argue that any new potential development has to be reconsidered in its current context, since circumstances have changed over the last fifteen years in terms of conservation of this species.


FOG acknowledges that the offsets identified in this report may well result in much better management of existing habitat, as well as better knowledge of the current status of the population. We remain concerned, however, about the lack of knowledge about the importance of what could be the second largest population of the species in Gungahlin.


Ideally, all existing habitats across the ACT should be re-surveyed prior to development of any part of Kenny (including block 799) that contains the striped legless lizard. It would be unacceptable to develop block 799, only to discover as part of the offset monitoring, that we had lost a significant portion of the remaining population of the species. If the decision is made to go ahead with this development, we would argue very strongly that the proposed monitoring be completed successfully and that Kenny be surveyed for the lizard before any development proposal is started for Kenny. However, FOG advocates for a moratorium on development until better current data on the species is collected.


Sincerely yours





John Fitz Gerald



10 July 2011