Friends of Grasslands

supporting native grassy ecosystems


PO Box 440

Jamison Centre

Macquarie ACT 2614

Phone: 02 62.. ....

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

Dear Sir/Madam


Hotel and Carpark Development, Section 22 Barton, ACT: reconsideration request
Reference number: 2012/6606

From the Preliminary Documentation report in the reconsideration request documentation for the proposed development adjoining York Park in Barton, it appears to Friends of Grasslands (FOG) that the addition environmental information supporting the developer’s claim that this should not be a controlled action relates to the argument that winter shading from the development is not likely to affect Golden Sun Moth (GSM) larval development. In particular, the argument appears to be based on two assumptions concerning GSM larvae: that the larvae will occur at greater soil depths at York Park, and that the larvae may move up or down through the soil profile in response to changes in environmental conditions (section 6.5.1, p24).

FOG does not consider that there is sufficient scientific evidence to support either assumption at this point in time. In this context FOG notes that Anett Richter and William Osborne are of the view that “…the behaviour and ecological requirements of the [GSM] larvae are not known” (Richter and Osborne, Final Report: Golden Sun Moth (Synemon Plana) at the former Belconnen Naval Transmitting Station: Larval abundance and floristic composition and structure at contaminated sites in NTG, University of Canberra, 2009). The same report noted that GSM larvae are concentrated in the top layers of the soil at this site, between 0.3cm and 4.0cm in winter.

In relation to the comment that GSM larvae are commonly found at 10 cm, FOG’s understanding was that the research being undertaken at the University of Canberra was in relation to translocation of GSM larvae rather than a study of the characteristics of the larvae. As the results of this research have not yet been published, it is not clear to FOG whether this observation could apply to the GSM larvae at York Park, since there is no information available to us about it, including the types of soil in question, the range of depths GSM larvae were found at, the time of year the observations were made, or whether the comment related to a casual observation or to part of the core research being undertaken.

In relation to the assumption that larvae may move up or down through the soil profile, FOG is not aware of any research that indicates that this does not have a negative impact on the larval development. For example, if GSM larvae are forced to a lower level in the soil due to shading, will their feeding requirements be met adequately at this level? If there are greater temperature fluctuations on a daily basis, do the larvae move more frequently and, if so, what is the energetic cost of this movement in terms of their long term survival?

In relation to the subsequent analysis of soil temperature, solar exposure and air temperature, FOG’s view is that it needs careful examination. From the data, it appears that at shallower soil depths, soil temperature is affected by solar exposure at all times of the year. Also, the shading data only matches up with the data from this analysis for June, so it is not clear how much of the site would be affected by shading in May and August, when the analysis indicates a stronger relationship between solar exposure and soil temperature.

In the case of a critically endangered species such as the GSM, FOG considers that decisions about development proposals should be based on whether there is any scientific evidence that proposed changes will not impact on the species viability. Until this evidence is available, any assumptions made should err on the conservative side. In the case of York Park, FOG does not consider the additional evidence sufficient to remove its objections to the proposed development.

Yours sincerely

Sarah Sharp


21 March 2013