Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Chief Planner
National Capital Authority
GPO Box 373
Canberra, ACT 2601


Dear Sir/Madam

Reference: Draft amendment 88: blocks 3 and 15, section 22, Barton

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia, included related fauna species. 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.

FOG has had a long standing interest in the site concerning this amendment, i.e. York Park. We have, for instance, responded to several proposals concerning development impacts to the Park in the past, e.g. EPBC referrals 2010/5548 (5 July 2010) and 2012/6606 (19 November 2012 and 21 March 2013 – reconsideration request), and to the NCA’s development application concerning Block 14 Section 22 Barton - Redevelopment of 21 National Circuit - Stage 1 Works. FOG has visited the sites on multiple occasions, and undertook monitoring for the Golden Sun Moth (GSM) (Synemon plana) there in 2008-2009. In Jan 2013 FOG also wrote to the Department of Finance concerning deficiencies in management of the site, in particular weed control.

FOG is appalled by Draft Amendment 88 to the National Capital Plan and the accompanying EPBC referral, and is completely opposed to both proposals.

Under section 1.3, there is no mention of a third MNES involving York Park. A Striped Legless Lizard (Delmar impar) was recently captured on the site, and surveys are needed to understand the population and extent of area occupied by the Striped Legless Lizard at York Park and in adjacent areas.

FOG notes that the report “Proposed Amendment to the National Capital Plan: Block3 3 and 15, Section 22 Barton” (July 2017) briefly outlines, in section 7.4, the main thrust of the EPBC referral document. This section acknowledges the loss of Natural Temperate Grassland (NTG) and of GSM habitat, but does not mention the loss of an actual GSM population that has been reasonably stable and persistent over many years. FOG takes issue with the Umwelt conclusion cited on pages 26 and 30 of this report, that the GSM population is not viable in the long term. Evidence supporting this is not presented in the EPBC referral, and any recent decline in the population is most likely due to poor management of the site.

FOG also takes issue with the statement in the report (p30) that there is an appropriate offset available – in our view the offset is inadequate.

A summary of our reasons for opposing the EPBC referral, and hence this amendment is:

We can provide more information, or a copy of our submission concerning the EPBC referral, if needed.

In conclusion, FOG recommends that draft amendment 88:

Yours sincerely


Geoff Robertson

10 September 2017