Chief Planner
National Capital Authority
GPO Box 373
Canberra ACT 2600
email: draft.amendment@nca.gov.au

 

Dear Sir/Madam

Draft Amendment 95 - North Curtin Diplomatic Estate and Urban Area

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.

FOG’s concern in relation to draft amendment 95 relates to the possibility of the endangered Golden Sun Moth (GSM) occurring in the area that is subject to this amendment. We are aware of a persisting population of the GSM through the southern part of central Canberra which has been subject to actual or potential development impacts over the last few years. This includes the former (and now destroyed) population at York Park (EPBC referral 2017/8028), areas of GSM along the route of the proposed light rail from Civic to Woden (EPBC referrals 2019/8490 and 2019/8491) and the Canberra Brickworks and Dudley Street upgrade (EPBC referral 2017/8072 – the offset being in the Franklin Grassland (formerly North Mitchell grasslands)). As well, there is a GSM offset for the Campbell Section 5 development (EPBC 2012/6292) in the nearby Yarralumla equestrian park. More information about some of these is available at https://www.planning.act.gov.au/tools_resources/plans-registers/registers/offsets-register.

We have argued elsewhere that, while with each of these the areas of GSM population and habitat to be impacted are relatively small and so the developments are approved, this type of piecemeal approach ends up with the whole area being developed, since the overall cumulative impact is never considered. FOG is opposed to such a piecemeal approach since it generally results in environmental losses and considers that these areas of importance to the GSM should be assessed on a strategic basis.

We understand that there may be a small but continuous GSM population from the Dudley St site through to the North Curtin Horse Paddocks. This needs to be investigated and taken into account as part of such a strategic approach before DA95 goes ahead.

Yours sincerely

 

Geoff Robertson
President

6 June 2020