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


Throsby multisport complex

Reference Number: 2010/5456


FOG’s main concern in relation to this development is the presence of the endangered Golden Sun Moth (GSM) (Synemon Plana) in this area.  The GSM is listed as critically endangered both nationally and New South Wales, Victoria and the ACT.  Both the Ecological Assessment and the recent report “Community Monitoring of Golden Sun Moths in the Australian Capital Territory Region, 2008-2009” note the presence of GSM in this area, albeit in low numbers, and that the moth has been present at the site for some time.


The argument that the GSM is in low numbers in Throsby is not, in FOG’s view, sufficient to justify downgrading significance of this species in considerations about developing the area.  The Ecological Assessment notes that the level of GSM activity may vary within the precinct at different times of the season, and may vary from year to year.  The recent report “Community Monitoring of Golden Sun Moths in the Australian Capital Territory Region, 2008-2009” found that the GSM was only present as small or medium-sizes populations at most locations where it was found, and only high abundances at a few sites, not surprising given that the GSM is critically endangered.  WWF has nominated the GSM as one of the ten Aussie battlers, species that are at great risk of extinction and require urgent help to survive.  The argument, that the impact of developing sites with low GSM numbers is minor in the wider context of golden sun moth conservation in the ACT, if repeatedly accepted, could result in the loss of most or all such sites to development over time, with the net effect of an ACT-wide impact on this endangered species – a point that is pertinent given two development proposals at the moment making the same argument (for North Forde and Throsby).


Because the GSM is a critically endangered species, any site at which it is present should not be developed until the species has recovered.  At this stage we lack information about the moth’s ecology, the importance of sites where there are low populations of GSM, and how they might move into new areas and become more abundant (which may be what is occurring on this site).  FOG has been studying the GSM and can provide a copy of the report “Community Monitoring of Golden Sun Moths in the Australian Capital Territory Region, 2008-2009” if desired.  At the very least, a more strategic approach to the conservation of this species is needed before any development of sites such as Throsby occurs.


The Ecological Assessment notes that “a large proportion of the native pasture, which is potential habitat for the golden sun moth, would be removed by the development.  Much of the area where the highest concentration of golden sun moths was recorded in the surveys does not appear to be affected directly, however, and it may be feasible to retain and improve this habitat patch. This would require some amendments to the current landscape plan for the precinct, and may create a conflict with other landscape objectives.”  In FOG’s view, these amendments are the very least that should occur to this plan, particularly given the proximity of this area to Mulligans Flat.  Such an area would need to be fenced to avoid impacts from the development and operation of the sports complex.


Before this development (and other developments in Throsby) proceeds, FOG recommends that better data is collected about the GSM in the area and about the moth’s ecology and distribution patterns generally.  FOG also recommends that a strategic approach to GSM conservation applied across the ACT, one that takes into account both the low populations of this species on many sites and its critically endangered status.


If, despite this, the development goes ahead, FOG recommends that alternative landscape plans be considered to minimise the impact on the GSM, and that potential offsets be identified and delivered.  As it stands, the Ecological Assessment raises some possible modifications to the master plan for the site, but the actual development proposal does not commit to any of these or indicate how they might be implemented, and also contains no discussion of offsets.  Preferably these issues should be determined before public consultation, but definitely before any final consideration of the proposal.


FOG’s understanding is that native pasture could meet the EPBC criteria for threatened ecosystem if it adjoins high quality box woodland, which is the case in part of Throsby.  The area has been fairly heavily stocked and is somewhat over-grazed, but with little weed.  If it has recovered a little, (quite likely given the good season so far in 2010) the quality may be somewhat higher than stated in the Ecological Assessment.


FOG is concerned about potential impacts on the Mulligans Flat Nature Reserve.  While the Ecological Assessment discusses these and rates most of them as being low, it does suggest a number of measures to mitigate these possible impacts.  The proposal itself makes no commitment to some of these (e.g. those relating to bushfire management and weed control), and, while stating that “there would be value in reviewing the current layout for the precinct to determine whether there are ways in which such impacts could be reduced”, makes no actual commitment to conducting this review or implementing any recommendations from it.


FOG notes that this is the first part of developments proposed between the Mulligans Flat and Goorooyarroo Nature Reserves.  This is another example of piecemeal development proposals – it would be better to be able to consider the implications of all of the developments planned for Throsby at the one time, particularly given the presence of the Golden Sun Moth (GSM) (Synemon Plana) in this area. 


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



3 May 2010