Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....




The Commissioner
ACT Emergency Services Agency
PO Box 104 Curtin ACT 2605



Dear Sir/Madam


Draft Strategic Bushfire Management Plan - comments


Friends of Grasslands (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 the 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.


While the draft Strategic Bushfire Management Plan is a general document and does not contain details of how the strategies might be implemented, we are uncertain as to whether or not there will be an opportunity to comment on detailed fire management plans for specific areas, and wish to provide some comments at this stage of development of the Management Plan.


While recognising that reduction of fuel loads around urban areas is a necessary part of the ACT bushfire management strategy, FOG has some concerns about the impact of such activities on high conservation areas if poorly managed. The first is the timing of fuel reduction activities, which can have a significant impact on the long term viability of high value conservation areas. Timing should be targeted at reducing or preventing seed set of exotic species while allowing native species to set seed. Examples of poorly timed grazing (in terms of seed set of the different species) have already been seen.


Slashing can transfer weeds from one area to another if equipment is not cleaned appropriately. Equipment should always be cleaned thoroughly before moving from a weedy area to a non-weedy area. It should always be cleaned after leaving an area infested with noxious weeds such as African love grass and Chilean needle grass.


The Plan indicates that control burning will be used in a number of areas for fuel reduction. Control burning, for safety reasons, is carried out in a season when wildfires are unlikely. In other words, it is done in a season when the flora is most definitely not adapted to fire. Repeated control burning will result in artificial selection within and between plant communities such as to favour rapidly growing, short lived plants (e.g. weeds). This is recognized in the comment that grasslands will need to be burnt more frequently than forests due to the shorter fuel reduction effect in grasslands. However, the frequency of burning in any high quality grassy woodland should not be such that the structure changes and becomes more like that of a grassland.


The macro-invertebrates, micro-invertebrates and other fauna that are essential in leaf letter breakdown in Australian forests are vulnerable to fire. The normal way that these invertebrates deal with fire is to repopulate from unburnt refuges following the fire. Consequently, if control burning is essential, then a micro-mosaic burn is preferable over large scale hit-and-miss practices. The information available in the Strategic Bushfire Management Plan seems to indicate that larger areas will be burnt in a particular period, with little opportunity for repopulation from neighbouring areas.


In reviewing the draft Strategic Bushfire Management Plan, we found it difficult to determine whether any high conservation lowland grasslands or grassy woodlands (as designated by action plans 27 ACT Lowland Woodland Conservation Strategy and 28 ACT Lowland Native Grassland Conservation Strategy) would fall into the Inner Asset Protection Zone (IAPZ) Treatment Standards. Since the targets for IAPZs in terms of fuel reduction are higher, maintaining the biodiversity in and environmental value of any high conservation areas in the IAPZs will be more challenging and may require a different strategy than that used for other IAPZ areas.


Other concerns of FOG are introduction of weeds to high quality areas by fire and other equipment, and disturbance to vegetation by construction of more fire breaks and trails.


As details of the bushfire management plan are developed, FOG would be happy to provide further comment on these matters.


Sincerely yours






Geoff Robertson



15 September 2009