Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Customer Services
PO Box 365
Mitchell ACT 2911


Dear Sir/Madam

Canberra Brickworks EIS (reference number EIS201900047)

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 has had a long standing interest in the Golden Sun Moth (GSM) population in the area of the Canberra Brickworks and Dudley St, and has provided comments on previous proposals relating to the Brickworks (8 July 2014, 20 March 2015, 1 November 2017). In those submissions (and in submissions on other developments in the area) we asked that all impacts on the GSM in this general area be considered and a strategic approach to the species conservation be taken. We are disappointed that this has been repeatedly ignored and these proposals are still being evaluated in a piecemeal fashion.

In responding to this EIS, we note that the GSM habitat to be impacted is reported to be Chilean Needle Grass, and that the ACT Offsets Team has been consulted concerning the proposed offset site on Old Cooma Road, near Googong.

In principle FOG is opposed to any development that impacts on threatened species or ecological communities. While we accept that some developments, for example the widening of Dudley St, might be essential, the current proposal does not fall into this category. The fact that there are no suitable GSM offset sites available in the ACT that could be used by this development also raises the question of why the impacts are not being avoided.

On the assumption that the development will go ahead anyway, we reiterate the comment in our submission to the Commonwealth on EPBC Referral 2019/8449 last month, that the purchase of GSM credits from the NSW BioBanking scheme to offset losses in the ACT is of concern. How will a community organisation such as FOG have any surety that this offset will be effective? We again urge that information about the GSM offset credits are included on the ACT Government’s Offsets Register in such a way that we can understand how the credits are ensuring no net loss of GSM across the landscape.

Yours sincerely


Naarilla Hirsch
Advocacy coordinator
20 July 2021