Works Approval Report.pdf - the National Capital Authority

Campbell Section 5 - Works Approval Project Ref: 110029Prepared for the Land Development AgencyAGENCY NO COMMENTS PROPONENT’SRESPONSEdevelopment is likely to result inboth the loss of the naturaltemperate grassland and goldensun moth population. Thus, impactshave not been avoided or mitigatedagainst, nor have the conservationvalues of the site been integratedinto the development. It can beargued that the small size andisolation of the site and the natureof development makes avoidanceand mitigation of impact unrealisticand that grassland and golden sunmoth conservation efforts are betterfocused elsewhere.DATERECEIVEDCPR considers that the referraldocument understates the value ofthe development site in terms of thegolden sun moth. It utilises the2007 and 2009 surveys results ofRowell to conclude that the site onlysupports small numbers of moths.However a 2008 survey, conductedas part of a community monitoringprogram, recorded 38 moths withinthe mapped Natural TemperateGrassland area and 105 elsewhereacross the site. This is a relativelyhigh number and places the sitewithin the top 20% of all of ACT’s72 known GSM sites in terms ofmaximum moth count. In terms ofsize, the proposal area is the 36 thlargest of the 72 GSM sites. Thus,although small, the proposal areadoes represent the median size ofhabitat for the moth in the ACT.Within the proposed design the lossof natural temperate grasslandseems inevitable. However, theproposed landscaping of the sitecould be better planned to provideand maintain golden sun mothhabitat, and at least improve theprobability of a viable mothpopulation existing on the site intothe long term. It is also essentialthat an offset package is developedfor the proposal. In this regard theACT Government agreed with afurther recommendation of theCommissioner’s that if the NaturalTemperate Grassland within theproposal area was developed, anoffset should be required. ThroughNovember 2012 Cardno 90