Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Macquarie ACT 2614
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601
City to Commonwealth Park Light Rail 2a
Referral no: 2019/8582
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.
FOG notes that this proposal will impact on the critically endangered golden sun moth (GSM) by a partial loss of a small and fractured population of the species plus removal of supporting habitat. FOG recognises that the project is proving transport infrastructure so likely to obtain approval despite this impact. However, we would like to put on record our opposition to any development impacting on a threatened species, and also raise two concerns if the project does go ahead.
The first is that of offsets. There is no indication of what offsets might be offered, and no opportunity for public scrutiny of the offset proposal. In light of continuing impacts on GSM in central Canberra, offsets need to take into consideration that the end result is likely to be a complete loss of the species throughout this area.
The second is the piecemeal nature of development proposals and approvals in relation to impacts on GSM in central Canberra. In the last three years we have seen the following referrals come through:
- 2019/8582 City to Commonwealth Park Light Rail 2a (December 2019)
- 2019/8490 and 2019/8491 ACT City to Commonwealth Park Light Rail and Commonwealth Park to Woden Light Rail Projects (July 2019)
- 2019/8449 City Hill Section 63 Redevelopment Project, ACT (May 2019)
- 2017/8028 Blocks 3 and 15, Section 22, Barton, ACT Divestment (August 2018)
- 2017/8072 Canberra Brickworks Precinct access road and Dudley Street upgrade, Yarralumla, ACT (November 2017)
- 2017/8074 Canberra Brickworks, Yarralumla, ACT (November 2017)
- 2017/7813 and 2017/7812 Development of Part Block 20 Section 86 Yarralumla, ACT and Block 18 Section 86 Yarralumla, ACT (June 2017)
While we accept that the offset and mitigation for the Dudley Street upgrade (2017/8072) is reasonable, the same cannot be said of the Barton divestment referral (2017/8028). The long term result of this piecemeal approach is likely to be complete loss of GSM through the central Canberra area, with a net loss across the landscape due to not all offsets resulting in increases in GSM population on the offset sites. FOG is of the view that, before any further developments impacting on GSM are approved, there should be a strategy developed to guide Golden Sun Moth conservation in the ACT. This strategy should:
- Put the conservation status of existing GSM populations into context with losses of populations and habitat in the past 25 years as well as proposed and likely future losses
- Include any evidence of increases in GSM habitat and/or populations in offset sites or as a result of offset actions.
- Provide a context for the significance any particular population such as the central Canberra populations, to assist in decision making about developments impacting on the population.
16 December 2019