Department of Climate Change, Energy, the Environment and Water [Commonwealth]

Re. draft Recovery Plan for the Golden Sun Moth (Synemon plana)

Friends of Grasslands (FOG) is a community group dedicated to the conservation of grassy ecosystems in south-eastern Australia - natural temperate grasslands and grassy woodlands. FOG advocates, educates and advises on matters to do with the conservation of these ecosystems, and carries out surveys and on-ground work. FOG is based in Canberra and its members include professional scientists, landowners, land managers and interested members of the public.

FOG is responding to the public invitation by DCCEEW to provide feedback on a draft National Recovery Plan for the Golden sun moth (Synemon plana) as published here: https://consult.dcceew.gov.au/draft-national-recovery-plan-for-the-golden-sun-moth

Whilst FOG applauds the creation of this plan, we strongly encourage the adequate resourcing of this and all recovery plans to enable their timely and thorough implementation.

The draft Plan summarises well the pertinent information and addresses the key threats facing the Golden Sun Moth (GSM). The main changes we recommend are:

• Wording to better communicate that Wallaby Grass is vulnerable to any herbicide targeting perennial grasses
• elaboration of the limitation of counting pupal cases as a survey method

Attachment1 provides specific suggestions for change to the plan, section by section, and references.

If you would like more detail or clarification on any points, please email advocacy@fog.org.au.

Yours sincerely,

SIGNED

Professor Jamie Pittock
President, Friends of Grasslands
2 October 2025

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Attachment 1

Section 2.6 | Survey Methods | Para 1

Regarding the counting and sexing of pupal cases as a survey method, the following limitation should be included in Para 1:

Other possible limitations of this approach may be difficulties in finding and counting pupal cases in differing conditions, e.g. in non-drought conditions where grass may be taller, that pupa cases deteriorate faster under wet conditions and that predation or scavenging of cases by birds, such as magpies or ravens, may occur unevenly across years or between sites.

Table 1 | Application of chemicals | Evidence | Para 1

We recommend the following wording which describes the rationale and method for herbicide use in maintaining golden sun moth habitat.

Wallaby Grass has been shown to be detrimentally effected by Glyphosate and Flupropanate but has tolerance to other chemicals such as diclofop-methyl, simazine, fenoxaprop-ethyl, and diuron, which target broad-leaf weeds and annual grasses (Lodge & McMillan 1994). The specific herbicides to which Wallaby Grass is tolerant should be used when spraying for herbs or annual grasses in GSM habitat. There are no herbicides that kill perennial grasses, which don’t impact on Wallaby Grass, so careful application such as spot spraying needs to be utilised. Care needs to be exercised as well to prevent spray drift.

Section 3.6 | Strategy 3 | 6^th dot point

Add a sentence:

If necessary to kill perennial weed grasses then careful application such as spot spraying needs to be used.