Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614

email: advocacy@fog.org.au
web: www.fog.org.au

LDA
TransACT House
470 Northbourne Avenue
Dickson ACT 2602
email: brickworks@act.gov.au

 

Dear Sir/Madam

Canberra brickworks + Environs Planning and Development Strategy

Friends of Grasslands (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 members include professional scientists, landowners, land managers and interested members of the public.

The strategy and associated site analyses are totally inadequate in the lack of recognition that within the developed site there is an area containing a nationally threatened endangered community and a population of the critically endangered Golden Sun Moth, both of which will be completely destroyed as a result of this development. The site analysis (section 1.15) quotes: “Natural Temperate Grassland: A native ecological community that is dominated by native species of perennial grasses. There is also a diversity of other native .. (illegible) plants present. ...These sites are highly degraded due to stock grazing and alteration since European settlement.” It is unclear where this last sentence was referenced from, and what studies were undertaken to support this statement. This inaccurate statement is the only reference in the strategy to the destruction of 2.2 ha of endangered community the Golden Sun Moth population. According to the ACT Government’s ACT Lowland Native Grassland Conservation Strategy (Action Plan 28), published in 2005, the site is identified as having a Botanical Significance Rating of 3, which equates to a moderate value, and recognises it as an area containing the endangered community.

A study in 2014by Dr Ken Hodgkinson undertaken on behalf of the Commissioner for Sustainability and Environment identified that the site is in low floristic condition (although it still meets the criteria as a site containing the endangered community). Recommendation 3 in Dr Hodgkinson’s report (P. 3) states: “These grasslands are now at sub-marginal levels in the ACT and there should be no offsets of this threatened community in land development.” On the basis of Dr Hodgkinson’s recommendations to the Commissioner the site should not be developed.

This total lack of analysis of the impacts on a local, regional and national level resulting from the destruction of this endangered grassland and Golden Sun Moth population is unacceptable.

Friends of Grasslands does not support the loss of this grassland without due consideration of the impacts. However, as it is expected that the ecological values will be ignored and the area developed, an adequate offset site must be identified for protection in perpetuity, to be managed with adequate resources.

Yours sincerely


Sarah Sharp
President

8 July 2014