Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Dr Maxine Cooper
Office of the Commissioner for Sustainability and the Environment
PO Box 356


Dear Dr Cooper


ACT Lowland Native Grasslands Inquiry by the
ACT Commissioner for Sustainability and the Environment


Friends of Grasslands (FoG) is writing to provide a submission to your investigation/inquiry into ACT's Lowland Native Grasslands (LNG). As you are aware, 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 conservation of grassy ecosystems, and carries out surveys and other on-ground work. FoG is based in Canberra and its more than 200 members include professional scientists, landowners, land managers and interested members of the public.


FoG welcomes the CSE's inquiry, as deterioration of significant LNG in recent years - particularly through overgrazing during the prolonged drought, at Majura, Belconnen, Jerrabomberra and Gungahlin - has been a real concern of FoG members and other environmental groups, shared by others within the ACT community. As you know, in 2007 FoG met with you to discuss related matters and also attended the roundtable for stakeholders in November, and then provided a submission on the Belconnen Defence site in December. These actions, the current submission (attached), and the ongoing activities of FoG, indicate our serious commitment to the conservation of ACT LNG.


FoG also emailed a comment on the scope of the inquiry after the roundtable (in response to your invitation): this expressed our concern that it is difficult to look at LNG out of context of the conservation arrangements (e.g. policies, action plans, recovery planning, reservation, management resources, decision protocols) for grassy ecosystems generally, as LNG grades into related ecosystems such as grassy woodlands, also under threat, e.g. from ignorance, development and poor management. FoG's comments are against the terms of reference provided, most recently with your media release of 30 November, and we note and welcome your comment re inclusion of 'associated threatened communities and species', as well as threats to them and measures for protecting them, in the investigation.


FoG looks forward to your consideration of these matters. We acknowledge that we have raised a lot of issues in our response, and welcome your further questions if necessary to elaborate on or clarify anything included here.


Yours sincerely




(Mr) Kim Pullen

25 January 2008




Friends of Grasslands submission to the ACT Lowland Native Grasslands Inquiry by the ACT Commissioner for Sustainability and the Environment, addressing terms of reference provided


1. Review existing management arrangements ... identify comprehensive conservation management principles and immediate actions ...


As noted in the terms of reference, 'the ACT Government has prepared a number of significant strategies for the conservation of grasslands and woodland'. FoG's view is that, while Action Plans (APs) provide a good basis for protecting and managing grasslands, they are clearly not whole-of-government policy (e.g. concerns re the current ACTPLA proposal to develop Molonglo and North Weston, including as outlined in FoG's submission on the Draft Variation 281 to the Territory Plan and related Preliminary Assessment of November 2007). FoG is keen to consider progress reporting on implementation of APs, and notes that an implementation report on AP27 (woodlands) is available (dated March 2007, although we did not get a copy until last November and have not yet responded on it), but that the report on AP28 (grasslands) is not yet available. It is critical that the CSE consider any implementation reporting available on AP28 in this investigation. Working from the report on AP27 (at section 3), it is likely that a report on AP28 will have highlighted issues such as the need to: protect key habitat, including to prevent intensive grazing; to 'monitor fauna, particularly threatened ... to determine their long-term trend and status ...'; and to 'participate in national recovery efforts ...'.


Further to the APs, management guidance is provided through documents such as the 'Grassy ecosystem management kit'[1]. FoG questions whether: the planning for management of LNG remnants of concern (e.g. at Majura), meets the standard as outlined in the kit; whether plans are adequately agreed for implementation/review through memoranda of understanding or similar with critical landholders such as the Department of Defence and Canberra Airport Group; and whether such management is adequately monitored and steps taken where management is not sufficient to conserve LNG and its threatened species. Perhaps some light was shed on this matter through vegetation condition assessment by ACT Government, as reported by Sarah Sharp in 2006; FoG is not in a position yet to have a view on that. Ideally, implementation of management plans should be made a requirement of MoU/lease and should have specific penalties/remedies for non-performance.


A specific aim should be to improve the status of grasslands across the ACT. Issues relevant to adequate grassland protection/management in the broader landscape include the following.

2. Identify the causes of the deterioration ... [explicitly addressing] the impact of eastern grey kangaroos


APs and recovery plans identify threats to LNG and associated species. FoG is concerned about a range of causes of deterioration including the following.

3. Identify any impediments to implementing short/long-term management practice for conservation ... identify any deficiencies ... to be remedied


Resources are not currently sufficient, or perhaps not well enough targeted, to ensure grassland management and protection. An ecologically sympathetic and realistic approach by government will require much better (sufficient, targeted) funding and organisation, including cooperative funding/management arrangements where appropriate. Priorities need to be established and reviewed; e.g. recent vegetation classification/condition work (Sharp 2006) should inform management and protection strategies - however, its application is yet to be seen.


The complexity of planning and development approval processes between/within governments is a concern, and does not achieve grassland protection. FoG has raised this as a concern recently with both the Australian and ACT governments, specifically on the issue of administration of the EPBC Act (copy of correspondence already provided), but also in context of the need for a whole-of-government approach and adequate decision protocols within the ACT, to TaMS/PCL. For example, the conservation value of small grassland remnants, which often contain threatened species, may be (and have been, recently e.g. diplomatic developments in inner-south Canberra) dismissed as too small to be of concern (below 'threshold') at the project or development approval level; continuing destruction or degradation of small remnants is a real threat.


Grassland management is a relatively new discipline with a couple of decades of experience from a general conservation perspective. There is a significant need for governments to continue to fund/participate in management related research and monitoring, and to support site managers to understand options, apply what is known and to learn from mistakes. Failure of site managers to understand the complexity of grassland management - and to manage to existing agreements - is an impediment to good practice as well as a cause of deterioration (see ToR2). Further, the general lack of community awareness of (or interest in) grasslands fails to provide the 'watching' and expectation required to encourage good practice.


Key remnants need to be protected (e.g. reserved) so that organised management can follow. Other relevant remnants, less disturbed and rehabilitatable vegetation needs to be managed sympathetically (e.g. via lease, agreement) to buffer/connect the key remnants. Without a landscape scale approach to conserving grasslands - e.g. as expressed through a connectivity layer[2] in a new Territory Plan - they will continue to be threatened. Management at a landscape scale will rely on approaches such as a network of managers, such as the ACT's active participation in the NSW DECC led Southern Tablelands Grassy Ecosystems Conservation Management Network. The role of ACT grasslands within the broader tablelands landscape should be central to management approaches; there are challenges and opportunities provided by being located (physically) within, and in working with, NSW.


4. Identify ways for ensuring effective communication with stakeholders


Effective community involvement, and communication/cooperation between site managers, is critical.  Existing networks need to be worked with, and improved where necessary. For example, FoG encourages ACT participation in the Southern Tablelands GE CMN (see ToR3), which we are already a member of, and welcomes TaMS/PCL initiation of a series of stakeholder forums within their community engagement program, including a 'conservation and wildlife sector group' which FoG intends to participate in. Apart from communication/collaboration, such forums raise awareness about and expectations of good management, and encourage/support action over time. FoG suggests that the CSE consider whether such forums provide adequate communication mechanisms, or whether there is need for something more specific to conserve LNG (e.g. a site manager's forum?), or at least how the office of CSE could improve outcomes for LNG through the existing networks.


5. Determine whether any policy/legislative changes are needed


Existing Action Plans seem to exclude at least some reserved areas. Given that reserved areas are also under threat (e.g. from fire protection actions on edges), FoG suggests these too are included in the broader strategies for protection and management.


As already mentioned, FoG's view is that, despite existing nature conservation and threatened ecosystem/species related policy/legislation, LNG remains threatened, and this is partly because of a lack of a whole-of-government approach, i.e. part(s) of government(s) (ACT PCL, Cth Env Dept) understand(s) the need to conserve, while others (e.g. ACTPLA, Cth Transport/Infrastructure) approach development planning with little sympathy for nature. FoG is concerned that many environmental impacts are driven by government departments (e.g. infrastructure projects). Further, in the ACT the office of Conservator, while required to advise, is limited in vetoing poor decision making. There is much scope within governments to agree on conservation priorities and to seek them, and to integrate[3] that within future developments, consistent with principles of ecologically sustainable development. But such approaches need good leadership, and to be deliberate, consistent and strong. A good start would include clarifying and resolving conservation and planning issues in the Majura and Jerrabomberra (and Molonglo) valleys.


There is no ACT native vegetation legislation, as exists in other jurisdictions. The principle of 'no net loss' is an important principle that ought to be considered, but use of any 'offsetting' provisions proceeded with cautiously. The CSE inquiry should make recommendations to the reviews of the Nature Conservation Act (e.g. to protect native vegetation) and the Territory Plan (e.g. to provide a connectivity/conservation layer, to reserve key remnants, to ensure decision/advice protocols address conservation policy adequately).


FoG's view is that the ACT/Australian governments should seek to clarify planning/decision arrangements and to optimise funding arrangements, to ensure that both local/federal environment legislation and policy are implemented successfully. This should include measures to ensure effective (including both strategic and cumulative) assessment of potential impacts of proposals, and to target funding for protection of threatened ecosystems/species, at least to implement recovery plans.


[1] Sharp, S., Dorrough, J., Rehwinkel, R., Eddy, D. and Breckwoldt (2005). Grassy ecosystem management kit: a guide to developing conservation management plans, Environment ACT

[2] FoG notes that the Spatial plan addresses corridors at least in a section on biodiversity conservation

[3] noting that this is not about 'balancing' conservation and development, i.e. trading one off against the other, but rather about seeking to conserve while continuing to develop, without compromising the former beyond what is sustainable