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

ACT City to Commonwealth Park Light Rail and Commonwealth Park to Woden Light Rail Projects

Referral nos: 2019/8490 and 2019/8491

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.

In looking at these referrals, FOG notes that the areas of Golden Sun Moth (GSM) population and habitat to be impacted are relatively small and, it could be argued, should not get in the way of the project going ahead and only need a relatively small offset. However, they are nearby other areas subject to EPBC referrals in the past two years, namely the City Hill Section 63 Redevelopment Project (2019/8449), Blocks 3 and 15, Section 22, Barton Divestment (2017/8028) and Canberra Brickworks Precinct access road and Dudley Street upgrade, Yarralumla (2017/8072). Each time one of these referrals appears, the argument is that the impact is small so the development should go ahead, with a correspondingly small offset. However, this type of piecemeal approach ends up with the whole area being developed, since the overall cumulative impact is never considered. As well, offsets on such an ad hoc basis are likely to result in net loss of GSM over the landscape. As we have stated in the past in relation to other areas, FOG is opposed to such a piecemeal approach since it generally results in environmental losses. FOG’s view is that these areas should be assessed on a strategic basis, and if development is approved, an offset be provided, that is larger, that might have a chance of delivering improvement in protection as well as condition

As far as FOG is concerned, the jury is still out on the effectiveness of biodiversity offsets in preventing net loss of the relevant MNES. We are aware of some examples where offsets have clearly resulted in improvements in conservation values at the offset site so do constitute a valid offset. On the other hand, there are examples where there is no improvement in conservation values for a range of reasons. These include the improvements being what would have occurred in the absence of offsets, the offset delivery being delayed and is yet to occur (despite the associated development proceeding), compliance delays, or no information available to community groups about the current condition of the offset area. Our concern with piecemeal approaches to urban development impacting on MNES within the same area is that the resultant offsets are small and likely to fall in the latter category of a net loss in the MNES in the long term.

A second concern with this referral is that the development corridor adjoins a high quality Natural Temperate Grassland (NTG) area in Guilfoyle Street. The reports state that, because the development corridor does not intrude into this area, there is no need for concern. FOG considers it essential that there be a fence to ensure that there is no construction impact on the Guilfoyle St grassland, and that this should be a condition of approval if the development goes ahead. . In addition there should be no potential for any impacts on any remaining areas of GSM habitat outside the construction area, including ensuring no car parking occurs on the roadsides.

A final concern is that of run-off from the light rail development onto the remaining GSM habitat, particularly in the Dudley Street area. The design needs to ensure that there is no run-off that might change the micro-climate in any NTG or GSM areas.

In conclusion, FOG considers it important that an EIS be done for this project to determine the impact on MNES and to ensure that these are avoided where possible, and minimised otherwise.

Yours sincerely


Geoff Robertson

27 July 2019