Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Major Projects Canberra
PO Box 158 Canberra ACT 2601


Dear Sir/Madam

EPBC Ref: 2019/8582 (City to Commonwealth Park Light Rail)  – Preliminary Documentation

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 commenting on the preliminary documentation for stage 2A of the light rail network extension, City to Commonwealth Park, FOG notes the actions taken to avoid additional impacts on the Golden Sun Moth (GSM), and the proposed mitigation and restoration activities.

In principle FOG opposes the use of offsets to allow destruction of Matters of National Environmental Significance (MNES), such as the GSM. However, it recognises that projects involving infrastructure deemed important are likely to go ahead. With this proposal the offset requirements are being met by the ACT Government purchasing and retiring 82 species credit biodiversity credits in accordance with the NSW Biodiversity Offsets Scheme (BOS) prior to the commencement of construction. FOG is concerned in general about whether or not offsets are truly effective or if the result of offsetting developments is a net loss of the particular MNES in question. This is the first time that offsets via the NSW BOS has been proposed, and that, while a list of potential GSM biobanking credit owners is given, details are not provided. While not asking for disclosure of sensitive material, FOG requests that some information about the GSM offset credits are included on the ACT Government’s Offsets Register in such a way that we can understand how the credits are ensuring no net loss of GSM across the landscape.

As the GSM only disperses short distances, the success of recolonization by the moth in the southeast cloverleaf post-restoration would be more likely if a small area (preferably one where the surveys indicate that GSM occurs) of this cloverleaf could be left undisturbed during the whole construction phase. This would provide a founder area from which the rest of the cloverleaf could recolonize more easily.

Yours sincerely


Geoff Robertson

10 September 2020