Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....





Referral Business Entry Point, EIA Policy Section (EPBC Act)
Approvals and Wildlife Division
Department of Sustainability, Environment, Water, Population and Communities
GPO Box 787
Canberra ACT 2601



Dear Sir/Madam


Campbell Station 5 Development, ACT

Reference number: 2012/6292


The 0.48 ha natural temperate grassland (NTG) area at the SW corner on this site was assessed by the Commissioner for Sustainability and the Environment (CSE) in 2009 as of category 2 quality but approaching a critical status. FOG visited the site late in 2011 and, at that time, made a similar assessment. The Research and Monitoring Unit (now Conservation Planning and Research Section of the ACT Environment and Sustainable Development Directorate) have also described the area as robust and remaining in a stable condition for at least 15 years. All these evaluations indicate that the grassland values of the site could be retrieved with appropriate management.


FOG is disappointed that the option for retaining the NTG remnant was discarded early in the planning process. An opportunity to have a unique part of our natural heritage in the heart of Canberra has been brushed over. Retention of the NTG remnant, with appropriate signage and educational material about the significance of the area, would have made this site unique – as far as we know, a first in terms of the concept. A relatively small amount of funding, partly to deal with the current weeds and the remainder put into trust for long term weed management, would have been a good offset for the probable destruction of the Golden Sun Moth population in the northern part of the development area. Instead, prior to formal agreement to the loss of the site, the NTG remnant was damaged further by the excavation of nine test holes, with regeneration in these areas being incomplete.


The Referral proposes that the category 2 status of this area together with its size and the National Recovery Plan for Native Temperate Grasslands can justify destruction of the “low priority” site. However, the Referral also acknowledges that the National Recovery Plan actually states “given the small amount of natural temperate grassland remaining, all sites containing the endangered ecological community should be considered as habitat critical to the survival of the community”. In the face of the continual piecemeal destruction of endangered NTG and box-gum woodlands that is occurring in the ACT, FOG is seriously disappointed that retention of the NTG site is not considered and totally dissatisfied that appropriate offsets have not been proposed. FOG members attended the public consultation session on 12th November 2011. At that session mention was made of at least collecting seed from the native plants in this grassland for use elsewhere in the development if the NTG remnant is destroyed, but there is no mention of this in the Referral. FOG recommends that The Land Development Agency be directed to rethink its proposal.


FOG is a community group dedicated to the conservation of indigenous 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.


Sincerely yours





John Fitz Gerald



5 March 2012