Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601

Dear Sir/Madam

Canberra Brickworks, Yarralumla, ACT

Referral no: 2017/8074

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia, included related fauna species. 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.

FOG has had a long standing interest in the natural values of the area in the vicinity of the Canberra Brickworks in Yarralumla. In 2014 and 2015 we commented on drafts of the Planning and Development Strategy for the Brickworks and environs. However, it is clear from the current proposal that these views were ignored and that no value has been placed on the natural values of the area. A copy of our comments on the 2015 draft is attached for information on our views in general concerning this area.

In relation to the current referral, FOG is concerned that the impact of this development will be to destroy an existing Golden Sun Moth (GSM) population, as well as increasing fragmentation of the species in the wider area near the Brickworks. In relation to the impact of the development on the GSM population, from the Biosis report it appears that this could be larger than previously thought:

"Golden Sun Moth records were more widely distributed north of Denman Street than reported in Umwelt (2015)".

There is also no assessment of the impact of removal of part of the GSM population on the long term viability of the remaining population in the area.

In addition, this application precedes findings of the third survey recommended by Biosis:

"Given the disparity between the extent and density of Golden Sun Moth records reported by Umwelt (2015) and those reported here, it is recommended that the completion of a third targeted survey is undertaken in 2017. Targeted survey should encompass areas of Golden Sun Moth habitat beyond the subject site between Denman and Dudley Streets in order to gain a better understanding of Golden Sun Moth extent in the locality. This information will provide important context to future environmental impact assessment associated with the proposed subject site development."

This information should be part of the referral documentation (and available for public comment) before the referral is considered.

The approach to development proposals impacting on threatened species should be to avoid first, mitigate if possible, with offsets as a last resort. As this development is not essential infrastructure or similar, FOG does not consider that the "avoid" principle has been applied and is opposed to the development in its current form.

While FOG has considerable concerns about the use of offsets, given there is little evidence of any net gain, and in fact, usually results in net loss of species and habitat, we do regretfully accept that offsets are better than no compensation for biodiversity losses. In the unfortunate situation of the proposed development being allowed to destroy the GSM population, offsets will be needed. Given the time this development proposal has been in the pipeline, FOG is staggered that there is no off set proposal provided with this referral in fact, offsets are not even suggested, merely:

"Further opportunities for avoidance of impacts are limited; however these will be reviewed and addressed in the EIS. Measures to minimise impacts will be described in detail in the EIS, which will be prepared under the bilateral agreement".

We draw your attention to page 7 of the ACT Environmental Offsets Policy (August 2014):

"Ideally, offsets are secured and in place before the development is approved"

In this case there is no reason for offsets not to be in place before development approvals (including this referral approval) are given. With the current development, offsets cannot even be calculated at the moment, since the actual GSM population size at the site and impact on the wider GSM population in the area is not known.

It is noted indeed, that, since the release of this referral, a further referral has been released for public comment (Referral no: 2017/8072), that will impact the areas identified by Biosis, namely, the GSM population together with the Natural Temperate Grassland Critically Endangered Ecological Community between Denman and Dudley Streets (and south of Dudley Street). Both of these referrals are interconnected and should have been dealt with as one item. We will be responding to this referral separately, but emphasise that they are clearly related and losses to biodiversity are cumulative, not separate. An obvious offset for this referral that has not been identified would be to conserve the remaining Natural Temperate Grassland and Golden Sun Moth habitat on Dudley Street, through long-term protection and management.

In summary, FOG opposes this development proposal. It has been released for comment in an incomplete state, with no offset options provided, and in isolation to another related referral, and possibly others, dealing with the future of the threatened species and ecological community north of Dudley St.

Yours sincerely


Sarah Sharp
Advocacy Coordinator

1 November 2017