Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


EPBC Public Portal

RSPCA facility in Pialligo - EPBC referral

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 native 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.

The proposed location for the new RSPCA facility is within an area that has been used for grazing for a long period of time, but once formed part of the naturally treeless grassland that occurred throughout the Majura valley. While many of the native grassland plant species have been replaced by introduced species, there are patches of natural grassland within the development area and patchy native grasslands are extensive throughout the area of grazed land, linking to more intact areas of natural grassland and grassy woodland to the west. The Golden Sun Moth is found throughout the valley in native grassland. Much of the area is also potential habitat of the Striped Legless Lizard as this species is known to utilise exotic pasture provided it is in or close to an area that was previously natural temperate grassland.

FOG is concerned that, as presented, the proposal may have a significant environmental impact (and hence be a controlled action), but believes that the development should, and can, take into account the small areas of natural grassland, which are the core habitat for Golden Sun Moth (Synemon plana) and Striped Legless Lizard (Delma impar), without compromising the development. We recommend planning effort be applied to avoid unnecessary loss of these habitat areas, particularly in the context that the development site is part of a larger and important threatened species habitat area. We consider that it should be possible for the RSPCA to at least maintain the north-east patch of Natural Temperate Grassland as part of the paddocks that will be part of the development, and that the southwestern patch (recorded Delma impar habitat) and a connection (perhaps via the drainage line) to the south-east grassland should be retained in the development design.

Survey results

The ecological report concludes that Golden Sun Moths (GSM) are not present on the block as no individuals were observed during surveys undertaken between October 2021 and January 2022. While the timing for the surveys was ideal, surveys during the 2021 season in other known habitat areas indicated that numbers of GSM across all populations in the ACT were extremely low, presumably due to the abnormally wet conditions. As stated in the ecological report, Golden Sun Moth is known to occur within the Duntroon horse paddocks and has consistently been recorded in all Natural Temperate Grassland areas within a kilometre or so of the proposed development. Thus, it would be surprising if the native grassland patches in the development area don’t contain Golden Sun Moth habitat. The precautionary approach would be to assume its presence unless, or until, the area is surveyed at a time when moths are observed to be emerging at nearby known habitats.

FOG therefore considers this conclusion downplays the potential significance of impact of the development on Golden Sun Moth.

The ecological report correctly notes that the Striped Legless Lizard (SLL) may utilise the surrounding exotic paddocks and will certainly move through the habitat in the proposed development area. In the past overgrazing during drought years has probably fragmented habitat. The south-western patch may actually be a refuge area from which the lizard can disperse as numbers build up, following drought years. Probably in the past grazing pressure has limited the extent of the SLL within the horse paddocks, but, given that there are high densities of the species recorded in exotic pastures at Gungaderra (Gungahlin), Woolshed Creek and elsewhere, it could be argued that the precautionary approach would be to consider the whole of the development footprint as Striped Legless Lizard habitat.

In conclusion, FOG does not oppose the development but believes it is feasible that the use of the site by RSPCA can incorporate protection of the Natural Temperate Grassland areas and habitat for a range of threatened and other native species, as well as connections between them as part of paddock and “landscaping” features within the site.

FOG representatives would be pleased to meet with landscape planners to discuss ways to maintain, and ideally improve, habitat for native fauna and flora.

Yours sincerely


Professor Jamie Pittock

10 August 2022