Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


City Renewal Authority
PO Box 158
Canberra, ACT, 2601


Dear Sir/Madam

EPBC Referral 2019/8449 - Public Comment

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 responding to the Preliminary Documentation for referral 2019/8449, FOG notes that Golden Sun Moth (GSM) offsets for this project and the light rail project have been combined, and that the City Renewal Authority (CRA) and Major Projects Canberra (MPC) propose to coordinate their approaches to delivery of the offset. FOG has been arguing for a more landscape approach to impacts on and offsets for MNES and, while regretting the loss of 1.46ha of GSM habitat, is in support of this coordinated approach.

FOG notes that the ACT Government is confident that there are sufficient credits available in the NSW BioBanking scheme to offset the impacts on the GSM. As said in our submission concerning referral 2019/8582 (City to Commonwealth Park Light Rail), while not asking for disclosure of sensitive material, FOG strongly urges that 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.

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

20 June 2021