Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Applications Secretariat

Customer Services

ACT Planning Authority

PO Box 365



Dear Madam/Sir


Comments on three Preliminary Assessments - Site preparation of the Inner Asset Protection Zones of three southern Canberra Nature Park Nature Reserves: Cooleman Ridge, Tuggeranong Hill, Urambi Hills


The project works in these three PAs propose to create areas within the Inner Asset Protection Zone (IAPZ) at 37 sites within three Nature Reserves (NRs) of Canberra Nature Park, to enable mowing 'with a slasher to protect adjacent assets': 'Site preparation activities will involve removing dispersed rock, stumps and dead vegetative debris and clearing native vegetation (largely regrowth) and levelling uneven ground.'


Some of the sites are adjacent to or include potential habitat for the pink-tailed worm-lizard (Aprasia parapulchella) which has 'special protection status' under the ACT Nature Conservation Act 1980, and some include Yellow Box / Red Gum Grassy Woodland, listed as an endangered community under the NCA. Friends of Grasslands (FoG) and the ACT Herpetological Association made a submission to the ACT Flora and Fauna Committee in June 2007 to list the pink-tailed worm-lizard as vulnerable, because of ongoing urban development pressures.


FoG is a community group dedicated to the conservation of native temperate grassy ecosystems in south east Australia, such as grasslands and woodlands. FoG is based in Canberra, is well known to the ACT Government, 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 would have liked to have been consulted, with other stakeholders, in preparation of the PAs.


FoG's comments on the PAs are attached. Despite the recent decision after referral of these proposed works under the EPBC Act, FoG's view is that the proposed works may well have significant impact on a 'special protection status' species at least, probably on occurrences of an endangered community, and also other native vegetation and fauna habitat.


FoG's view is that the conservation values of the proposed work sites across the three nature reserves - in particular 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 as far as possible. 


Any works should seek to avoid or minimise negative ecological impacts through

  1. integrating nature conservation with fire risk management
  2. recognising nature conservation as the primary management objective
  3. not carrying out the proposed works in occurrences of an endangered community, or in locations where a threatened (rock reliant, ground dwelling) species is known or likely to occur
  4. designing the area to be slashed to minimise width and disturbance in areas of high value
  5. minimising the need for rock removal and related disturbance
  6. getting experts to assess the proposed works areas as potential/actual habitat for the pink-tailed worm-lizard and occurrence of the endangered box/gum woodland
  7.  retaining mature and significant vegetation
  8. implementing adequate erosion controls, and rehabilitating/revegetating sensitively and appropriately using local grassy woodland species, and avoiding introduction and spread of weeds
  9. implementing effective mitigation strategies both in the short term on site, and the long term; any future slashing regime needs to be funded to include an ongoing weed monitoring and management program, and protocols to use clean equipment.

As a final comment, it would have been more straightforward to comment on these proposals if the proposed work areas on the three NRs had been included together in one document, as with the EPBC referral. FoG noted that much of the information was reused, but that involved a lot of checking.

Yours faithfully





Kim Pullen


17 August 2007



Friends of Grasslands (FoG) comments on three Preliminary Assessments - Site preparation of the Inner Asset Protection Zones of three southern  Canberra Nature Park Nature Reserves: Cooleman Ridge, Tuggeranong Hill, Urambi Hills


FoG's comments on the three PAs (and on the works as understood from the EPBC referral where that is relevant) are generally dealt with together.




FoG commented on the recent referral of the proposed works under the EPBC Act and notes that the Australian government Department of Environment and Water Resources (DEWR) has decided that the proposed action is not a 'controlled action', because [emphasis added in italics]:

FoG agrees with DEWR's further statement that 'Although a decision has been made that the proposed action is not likely to have a significant impact on matters of national environmental significance, the site may contain important local, regional or State environmental values.'.


FoG notes that the PA documents do not deal with the significant flora and fauna information and impacts as comprehensively as the EPBC referral. Work areas are not mapped (of interest, as the referral dealt with 39 sites, and the PAs with 37). Appendices are not included (these are referred to, but have to be obtained via the Shopfront, and are said to be 'large'). This lack of detail detracts from the PA as a consultation tool.


Specific comments


1. Responding to fire risk.

While FoG recognises a need to manage fire risk, and that there is efficiency in implementing 'uniform fire management standards', the risk to adjacent suburbs is not uniform along reserve edges. Adjoining land owners also have a responsibility to manage risk on their properties. FoG and others are becoming increasingly alarmed at the measures taken or proposed since the 2003 fires, and the potential for them to harm biodiversity values initially and in the long term. The proposed slashing regime will 'move back the bush', introduce or spread weeds (such as Chilean needlegrass, African lovegrass and serrated tussock) and degrade biodiversity (including habitat) values. FoG suggests that the ACT can afford to integrate managing such risk with ecological conservation in nature reserves.


2. Status of tenure for habitat protection.

While the PAs note that the NRs are 'Hills, Ridges and Buffer Areas' under the Territory Plan, they do not state that the NRs are reserved under legislation for conservation with a primary management objective 'to conserve the natural environment'; i.e. more than as visual backdrop or for recreation.


3. Conservation status.

Although the PAs note the status of a threatened species and ecological community under the EPBC Act (hence referral) they do not state that the community is also listed under the Nature Conservation Act 1980 and that the species has 'special protection status'. This is relevant, as such status conveys protection in the ACT and also coverage by strategies such as Action Plan No. 27[1]


4. Extent/location of works and of impacts on habitat.

The PAs are unclear on what basis a slashed width between 4-30m is determined. While any preparation for, and ongoing, slashing will have impacts (e.g. weediness, habitat loss), the potential for impacts is increased with greater width. FoG suggests preparation of a conservative (minimum) width in high value areas. 


5. Impacts on a 'special protection status' 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. FoG supports the intention to retain 'sheet rock, and discreet rocky outcrops' wherever possible, and suggests that embedded rocks should be disturbed as little as possible. Any stockpiling should be minimised - especially to avoid it spilling beyond work sites, and covering/damaging vegetation/habitat sites of value, even temporarily. FoG would be interested in hearing more about the proposed 'trial artificial habitat site' for the pink-tailed worm-lizard in the Cooleman Ridge NR.


6. Quality of sites.

FoG notes DEWR's view that the degraded condition of each of the NRs means further impacts will not be 'significant'. This misses the point that such disturbance may further threaten an already threatened species and community.


Each of the PAs addresses either existing, or the potential for, pink-tailed worm-lizard habitat adjacent to or within the project areas, including within or adjacent to proposed work areas. FoG is concerned that recent assessment was based on what seems to be limited (and not particularly scientific) effort in 'visual survey' and 'some rock rolling' (under permit, FoG presumes). FoG's view is that the likely occurrence of the species and its habitat is worth serious consideration in undertaking works and mitigation across many work areas, and that these should be identified carefully by experts prior to any works, including using the most recent records; FoG notes that records mapped in Action Plan No. 29[2] may include the project areas.


The PAs state that assessment of and reporting on habitat values occurred in October 2006; the EPBC referral also noted site inspections in March 2007 (but see below). These inspections/assessments were 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 project areas, both Urambi Hills and Cooleman Ridge NRs would appear to have significant values for pink-tailed worm-lizards and the Yellow Box / Red Gum Grassy Woodland. The EPBC referral noted that there were 'no comprehensive botanical surveys' at Urambi Hills NR, but 'a large number of native forbs were observed'; a survey at a better time is expected to confirm the occurrence of the woodland community; the PA indicates that proposed works areas are likely to form part of the EPBC listed critically endangered Box-Gum Grassy Woodland and Derived Native Grassland ecological community. Although the PA for Cooleman Ridge NR also notes 'the absence of extensive surveys', an area to the south east is considered to contain the community.


7. Impacts of tree removal.

Generally, FoG supports the removal of non-local native vegetation where this is required, but the retention of local species especially in Yellow Box / Red Gum Grassy Woodland remnants; FoG suggests that the ecological impacts should be well considered before removing mature and significant trees. For example, where such woody vegetation may be thought to impede use of a tractor slasher, as an alternative it could be retained in high value areas and slashing done with a smaller machine. Sensitive restoration of Yellow Box / Red Gum Grassy Woodland remnants could be achieved by management - e.g. to replace introduced (and fire supporting) grasses such as Phalaris spp. with native understorey species, and by encouraging existing understorey species and regeneration.


8. Potential for erosion and proposed rehabilitation. Each of the project areas has potential for sheet erosion with soil disturbance. While mitigation and rehabilitation are proposed, detail is not included in the PA. Similarly, EPBC referral text about a 'rehabilitation plan' included reference to revegetation (with groundcover species) but no detail. FoG suggests that it will be critical to avoid impacts such as use of inappropriate species for soil stabilisation, and introduction of weeds in mulches. Any rehabilitation, including revegetation, 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/techniques to prevent future management problems. Any rehabilitation seeding/planting should use species (and preferably seed or propagules) local to the site.


9. Adequacy of mitigation. FoG is concerned that the PAs each state that 'the potential impacts are all considered to be minor and short-term'; which is not the case. Preparation for slashing has initial impacts as discussed above (e.g. loss of habitat, loss of significant vegetation, site erosion, moving back of the bush edge, increased weediness ...), but the impacts will have longer term effects (e.g. absence of habitat, some of which will never return and some will take a long time to regrow, further weed spread, questionable survival of removed individual threatened animals) and slashing itself will continue and will have its own impacts (i.e. compaction by vehicles, ongoing disturbance, later introduction of weeds on slashers). And there is no guarantee that fire will not carry - in the worst conditions - into adjoining backyards, e.g. previous fires spread from degraded horsepaddocks. 

Careful management of site works and mitigation will be critical. FoG is pleased to see a long list of mitigation measures at each PA's 3.3.1 (the same 'best practice' should be used at each site) including re use of clean machinery, but is concerned to read text such as '... is unlikely to be disturbed as a result of the proposed ... (works)' [PA Cooleman Ridge NR p.22 at 3.3.1]. The proposed use of strategies such as clear marking on ground and fencing near special sites prior to works commencing 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).  


 1] ACT Government (2004) Woodlands for wildlife: ACT Lowland Woodland Conservation Strategy, Action Plan No.27, Environment ACT, Canberra


 2] ACT Government (2007) Ribbons of life: ACT aquatic species and riparian zone conservation strategy, Action Plan No. 29, TaMS, Canberra