Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Referrals Section (EPBC Act)

Approvals and Wildlife Division

Department of the Environment and Water Resources

GPO Box 787



Dear Madam/Sir


Project ref no. 2007/3531, ACT Dept of Territory and Municipal Services

'Site preparation of IAPZ in three Canberra Nature Reserves'


This project, referred under the EPBC Act, proposes to create an area, within the Inner Asset Protection Zone (IAPZ) at 39 sites within three Nature Reserves (NRs) of Canberra Nature Park (CNP), to enable mowing with a slasher 'to protect adjacent assets by maintaining bushfire hazards at an acceptable risk level'. Some of the sites are adjacent to or may include potential habitat for the pink-tailed worm-lizard (Aprasia parapulchella) which is listed as vulnerable under the EPBC Act; and some include remnants of the White Box - Yellow Box - Blakely's Red Gum Grassy Woodland and Derived Native Grassland listed as critically endangered under the EPBC Act. The pink-tailed worm-lizard has 'special protection status', and Yellow Box / Red Gum Grassy Woodland is listed as an endangered community under the ACT Nature Conservation Act 1980. Friends of Grasslands (FoG) and the ACT Herpetological Association recently made a submission to the ACT Flora and Fauna Committee to list the lizard as vulnerable, because of ongoing urban development pressures.


FoG is a community group dedicated to the conservation of native temperate grassy ecosystems, such as grasslands and woodlands. FoG is based in Canberra and its members, numbering about 200, include professional scientists, landowners, land managers and interested members of the public. FoG advocates, educates and advises on matters to do with conservation of grassy ecosystems, and carries out surveys and other on-ground work.


FoG believes that this proposal warrants further investigation prior to any approval under EPBC (either the works as proposed or modified) as it may have significant impact on a threatened species (at least) under the Act.  FoG's reasons for believing that the proposed works may have a significant (but avoidable) impact are as follows.


The level of fire risk. The referral implies that the sites carry uniformly 'high fuel load'. This is unlikely to be the case given growing conditions at the time of inspection, and given that some areas may have been burned in 2003. Contribution of the reserve edge to the 2003 fires is also implied, which does not take into account either the exceptional circumstances of those fires, or the relative location/contribution of CNP to properties lost. The referral makes no reference to the responsibilities of adjoining land owners to also manage risk on their own properties.


The extent/location of works and of impacts on habitat. The referral is unclear on what basis a slashed width between 4-30m is determined, e.g. scope for a conservative (minimum) width in high value areas. The potential for impacts is increased with greater width; but any preparation for, and ongoing, slashing is likely to lead to replacement of existing vegetation with weedy species (such as Chilean needlegrass, African lovegrass and serrated tussock) which will degrade remnant habitat values.


Impacts on a vulnerable species. Although rock removal is proposed to be timed to avoid the pink-tailed worm-lizard breeding season, the long term impacts of loss of habitat structure on the species is not considered.  There is inconsistency in reference to disposal of removed rock - about whether/how it will be reused or redistributed on site, orremoved from site. Stockpiling should be minimised - especially to avoid it spilling beyond work sites, and covering/damaging vegetation/habitat sites of value, even temporarily.


Alternatives to slashing. The alternative of 'annual burning in unslashable areas' and grazing are stated as unacceptable to the Canberra community, but burning and grazing as management options are not addressed from an ecological/functional perspective, and should be so considered and discounted as appropriate (they may well still be unacceptable). 


Quality of sites.  Site inspections were in March 2007, during a very dry period, and are likely to have understated the quality of vegetation at least. Although Tuggeranong Hill NR may be of less concern than other proposed work areas, given the level of disturbance and lack of known pink-tailed worm-lizard occurrence, both Urambi Hills and Cooleman Ridge NRs would appear to have significant values for this species and the 'Box Gum Grassy Woodland and Derived Native Grassland'. Although there were 'no comprehensive botanical surveys' at Urambi Hills NR, 'a large number of native forbs were observed' and a survey at a better time is expected to confirm the occurrence of the critically endangered ecological community - whether or not this occurs on the works sites is not confirmed. An area to the south east of Cooleman Ridge NR does contain the community. The detail provided on quality of vegetation/habitat (e.g. at 4.2(h)) is uneven and seems insufficient.


Impacts of tree removal. Generally, the details about tree management would seem to be marginal to this referral as beyond EPBC interest, except to the extent of designated area in Cooleman Ridge NR, or where the EEC woodland elements remain; much of the detail is beyond that and confusing, and the ecologically significant impacts of tree removal are not well considered.  The removal of non-local species plantings is supported where this assists with fire management.


Status of tenure for habitat protection. The referral is not clear that the Nature Reserves are reserved under legislation for conservation with a primary management objective 'to conserve the natural environment', rather than simply recreation or public use.


Rehabilitation after works. Text about  'rehabilitation plan'  (p.19), includes a reference to revegetation (with groundcover species) but no detail. A Site Rehabilitation Plan, stated to be at 'Attachment 5', was not found. Any rehabilitation, including with vegetation, would have to be very carefully implemented to recognise the woodland/grassland values of the site, protect pink-tailed worm-lizard habitat, and select species to prevent future management problems.


Adequacy of mitigation. Careful management of site works and mitigation will be critical.  The proposed use of strategies such as clear marking on ground and fencing near special sites must follow from sufficient on-site briefing of all site workers (including all contractors), with a site manager in charge and responsible and on site at all times (this is separate from the ecologist role specified).  


FoG has been unable to locate the Preliminary Assessment under ACT planning legislation that is referred to in this referral, and is concerned about the relationship between this referral and formal, broader local community comment on what is proposed, given the protection provided under ACT environmental legislation, including relevant conservation strategies (and within the context of current consideration of the conservation status of the pink-tailed worm-lizard). Further, FoG is concerned about impacts of past fire risk management approaches in other areas of CNP by the referring agency.


FoG believes that the conservation values of the proposed work sites across the three NRs - as pink-tailed worm-lizard habitat and remnants of an endangered ecological community - should be adequately assessed before any action is taken that may degrade those values, with an aim to recognise and protect those values (e.g. in minimising vegetation/habitat removal and disturbance) as far as possible within a fire risk management approach for CNP.   


Yours faithfully





Geoff Robertson

Vice President

19 July 2007