Friends of Grasslands
supporting native grassy ecosystems
PO Box 987
Civic Square ACT 2608
Phone: 02 62.. ....
Mr John Stanhope
ACT Legislative Assembly
GPO Box 1020
CANBERRA ACT 2601
Dear Chief Minister
Friends of Grasslands (FoG) is writing to congratulate you and your Labor colleagues on your success in the recent ACT election. FoG notes that you held the balance of power in a minority Labor government, with the support of the ACT Greens. FoG understands that this is in the context of an agreement with the ACT Greens including a parliamentary reform agenda that we hope will lead to good governance in favour of our local environment.
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 200+ members include professional scientists, landowners, land managers and interested members of the public. FoG has a long term interest in the conservation and management of remnant natural temperate grasslands and grassy woodlands in the ACT. FoG is a member of the Conservation and Wildlife Stakeholders' Forum, which provides a regular opportunity to be briefed on a range of land management and biodiversity issues. FoG is a founding member of the Southern Tablelands Ecosystems Park, and is encouraged by your ongoing support for this project.
FoG notes that ACT Labor's election policy on the environment recognised the 'bush capital' values of Canberra; these values are to a large extent based on grassy ecosystems. As you know, FoG has been concerned over the years that development has continued to happen at the cost of grassy ecosystems, and remains concerned. For example, while some woodland was conserved at East O'Malley, a significant amount was lost to suburb. FoG is pleased with the outcome, so far, in protecting woodland in the proposed Molonglo and North Weston development, but reservation of some critical areas is still not secure (as outlined by FoG in its submission to the SCPE's DVTP281 inquiry in June). FoG welcomes: proposed funding for reserve establishment and management, including of grassy ecosystems; dedication of additional personnel to reserves at Gungahlin; and funding for strategic off-reserve conservation. FoG has been working cooperatively with the ACT Commissioner for Sustainability and the Environment. An absence in Labor's policy is commitment to an improved Nature Conservation Act 1980, including effective protection for native vegetation through evaluation and offset provisions, as already exists in some other states. FoG would welcome emphasis on protecting existing remnant vegetation rather than revegetation, and looks forward to an opportunity in the not too distant future to comment within a legislative/policy review framework.
As we hope you are aware by now, grassy ecosystems are cryptic and dispersed and particularly vulnerable to poor processes and decision making. FoG has been active in recent years in participating in opportunities for input to planning and decision making processes. As a summary of our ongoing concerns, I have included some points below that I hope you and your Government keep in mind over the coming years.
Good policy and good legislation go together. As already mentioned, FoG is keen to participate in a review of the Nature Conservation Act but notes it is a slow process. FoG is keen that the reviewed act is brought up to date with approaches from other jurisdictions e.g. biodiversity accounting and offset provisions.
Effective conservation requires both protection and management. FoG recognises the Government's efforts to give a high profile to protection and management of grassy ecosystems. However, FoG remains concernedthat recommendations in relevant conservation strategies (Action Plans 27 and 28) for reservation, or secure arrangements on private lease, of key remnants have not been implemented, and urges such protection immediately. Sites include (but are not limited to): grassy woodlands in the Molonglo valley and at Kinlyside, and natural temperate grasslands in the Majura and Jerrabomberra valleys, and at Lawson. FoG notes that some of these at least are identified as commitments in Labor policy.
Development impacts need to be managed. As stated recently 'Development (at all scales from intensive built environment, to utilities and rural residential), places ongoing stresses on grassy ecosystems. All proposals with potential risk on grassy ecosystems, especially where threatened species or threatened ecological communities are involved - that cannot be avoided altogether - should include comprehensive mitigation that is implemented, and compliance monitored with real disincentives attached for non-compliance. We need to keep what is left, what little there is, and keep/restore its condition.'
'While environmental concerns are considered in assessing development proposals in the ACT (particularly major ones such as Molonglo/North Weston and Gungahlin town centre), there is still continual loss of grassy ecosystem remnants through development, and incidental or accidental loss or damage from related construction activity. The few percent of original extent that remain are under ongoing and increasing risk, because of where they are in the landscape - too easy to get at, and convert to other uses. The problem is that decisions tend to made site by site (fragment by fragment) as each is assessed individually - a "tyranny of small decisions", often leading to irreversible loss.'
Government needs to 'Be strategic in decision making, rather than reactive and in short term interests of a few. Ensure that decisions, especially on threatened ecological communities/species are considered cumulatively, across the landscape (and across jurisdictional boundaries) and time, so that national protection policies and local conservation strategies are pursued practically and effectively.'
Good management requires adequate resources. FoG members have ongoing formal and informal contact with land managers, researchers and policy makers from the relevant areas of the previous Parks, Conservation and Lands Branch, and have the highest regard for their openness, professionalism and cooperation. FoG appreciates that you, as Chief Minister, encourage an open approach. However, FoG is concerned that staff carry heavy workloads, and suggests that workloads and responsibilities are kept under review, and that a case can be made for increasing the current capacity. FoG also has some specific concerns:
- ACTPLA planning processes do not pay sufficient heed to ecological assessment and advice, and fail to involve environmental planners
- there is a strong perception that ACT weed management is inadequate; more needs to be done to promote a greater understanding of the current weeds strategy, to ensure that it continues to be appropriately resourced, and to evaluate its implementation
- there have been anecdotal examples of over-zealous fire risk mitigation works; advice from Parkcare members and environment staff should be heeded in drawing up work plans
- it appears that research staff numbers need to be boosted, as important tasks such as efforts to describe and classify ACT vegetation, and to draw up protocols to plant, are slow to be completed because staff workloads are too heavy.
As stated to OCSE, the Government needs to: 'Set an example as effective land managers of grassy ecosystems. Require land managers with conservation or land management agreements to comply with such agreements, and take action if they do not.' and 'Make best use of community resources in managing land. Work cooperatively with communities, including to encourage and support volunteer effort - for long term outcomes.'
Social inclusion requires credibility and response. FoG, and others, struggled through the planning process for Molonglo-North Weston earlier this year. FoG provided a comprehensive response on the inadequacies of the process, together with comments to improve the proposal. As stated to OCSE, the Government needs to: 'Require/establish/run effective community consultation processes (e.g. credible, inclusive, transparent, responsive) to improve proposals and increase acceptability for communities. Community participants generally participate in good faith and with very limited resources and do not like being ignored.'
Further, FoG also stated to the OCSE, that the ACT Government should:
'Fulfilcommunity expectations of ecologically sustainable development.
Follow processes and policies under legislation, including cooperatively across jurisdictional borders i.e. ACT/Cth/NSW.
Believe, share and seek to protect the value of the 'grassy ecosystem story' as part of the ACT's unique appeal - a capital 'in the bush'. Build community awareness and support.'
A full copy of FoG's submission to OCSE was copied to you, and is also available on the FoG website, as are all FoG submissions of recent years. FoG looks forward to the Government's responses to inquiries into community consultation, and to effective processes in future.
While FoG notes that the recent ALP/Greens Parliamentary Agreement includes encouraging content (e.g. Assembly/Committee collaborative processes, engagement with civil society and access to advice from public servants), FoG is concerned that none of the stated policy program addressed threats to our local biodiversity.
19 December 2008
cc Mr Simon Corbell, Environment Minister
Mr Shane Rattenbury, ACT Greens environment spokesperson
Mr Hamish McNulty, ACT Conservator of Flora and Fauna
Dr Maxine Cooper, ACT Commissioner for Sustainability and the Environment
 FoG's submission to the inquiry into an expanded role for the Office of the Commissioner for Sustainability and the Environment (11/08)