Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Mick Welsh
Commonwealth and Territories Section
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
Ph: 02 6274 1692



Dear Mick


Mirrabei Drive Extension, Gungahlin, ACT

Reference Number: 2010/5412


Friends of Grasslands (FOG) notes that “the design of the road has been developed with a view to minimizing the impact on healthy remnant woodland trees, consistent with acceptable road design standards”. However, the proposed road will have some impact on habitat of the golden sun moth and on an area containing White Box – Yellow Box – Blakely’s Red Gum grassy woodlands and derived native grasslands, both listed as critically endangered.  While this area is small and, according to the ecological assessment, “is unlikely to cause an impact of such significance that the conservation status [of the golden sun moth] is reduced”, the proposal still represents a net loss of golden sun moth population and habitat. For this reason, FOG is disappointed that, if the development is regarded as necessary, there is no mention of offsets in the proposal. Surely, with any critically endangered species or community, any loss is important and attempts need to be made to either avoid the loss altogether or to provide offsets to ensure long term continuation of the species or community?


FOG is also concerned about the piecemeal nature of development proposals occurring in this area. With each proposal being submitted and assessed at different times, there is potential for developments being allowed because the impact of each is not regarded as significant, whereas in fact the overall impact of the series of developments is substantial. This view is supported by the statement in the Ecological Assessment that “In terms of achieving beneficial environmental outcomes, however, an EIS would be more effective if undertaken in the context of the development of the broader area”. FOG’s view is that the environmental impact of all proposed developments in this area should be considered at the same time, so that the best outcome for all of the endangered and vulnerable species and communities affected is achieved.


FOG is disturbed by the implication that native grasses are of little value, as implied by the underlined words from the statement in the proposal that “The proposal would result in the removal of approximately 1.8 ha of moderately modified box - gum woodland that is in a generally degraded condition, although the vegetation to be removed consists predominantly of grasses.”  While specific grasses and forbs can be replaced, the ecosystem of which they form a major part can never fully regenerate once it is lost.


In the proposed landscaping along the road edges, FOG supports the use of species selected from the original woodland community, particularly in those sections adjoining golden sun moth habitat.


FOG also supports the mitigation strategies proposed, but would also like the construction environmental management plan to be included in any contracts involved in the project, with penalties if the plan requirements are breached.


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 more than 200 members include professional scientists, landowners, land managers and interested members of the public.


Sincerely yours





Geoff Robertson



7 April 2009