Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608


The Office of the Commissioner for Sustainability and the Environment
PO Box 356
Dickson    ACT    2602



Dear Maxine


Investigation into Canberra Nature Park, the Molonglo River Corridor and Googong foreshores

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.


FOG’s overall view is that:

Scope of investigation

The previous investigation focused on Lowland Natural Temperate Grasslands (LNTG), so grassland reserves are explicitly excluded from the current study.  However, FOG is concerned that grassy woodlands within these grassland reserves may be overlooked using this approach (e.g. at Gungahlin Hill in Gungaderra, much of Mulanggari, and part of Dunlop).  These woodlands were not explicitly considered in the previous investigation and yet are an omission from the current study.


The first Term of Reference (TOR) asks for assessment of the “forests, woodlands and grassy woodlands”.  Grassland vegetation structure is omitted, presumably because of the focus of the previous investigation.  However its focus was LNTG, rather than all grasslands.  There are excellent native pastures and grasslands in many of the reserves under consideration, e.g. at Farrer Ridge, Wanniassa Hills, Mt Taylor and Callum Brae reserves.  They have an ecologically important function, and their management is important for conservation (some contain threatened species such as Aprasia parapulchella), weed control, rabbit management and fire hazard management.  FOG suggests that the current investigation include grassland vegetation in these reserves that was omitted in the previous report.


From the first TOR it isn’t clear to FOG whether or not each area/reserve will be assessed as a whole, or with regard to each vegetation structure (“forests, woodlands and grassy woodlands”) within the reserve.  As the different vegetation structures can respond quite differently to the same pressures (whether they be grazing, weeds or vertebrate pests) and different management approaches may be needed across the different structures, it may be helpful to assess each type of structure separately and provide this information in the final report.


As was done for the grassland report, inclusion of any available information about how each area/reserve has changed over time would be useful, particularly in the context of ongoing management approaches for the different areas.  “Snapshot” information about the condition of a reserve does not provide a reliable basis for recommending management actions.


Finally, FOG suggests that all of the inquiry's recommendations need to be issued on the basis of the most reliable and up-to-date evidence.  The optimal actions on long-term management of weeds, pests and grazing critically depend on the ACT Government investing sufficient to facilitate high-quality and current scientific measurements.  All recommendations (and resulting decisions) need to be justified transparently by all means possible including distribution of clear and comprehensible information about the primary data upon which they are based.


Annual operational plans

Many of the issues identified in the CSE’s Native Grassland Investigation also apply to the high conservation lowland woodland areas of CNP and the Molonglo River corridor.  In particular, there should be annual site operational plans developed for all lowland woodland sites and these should be urgently implemented.  FOG believes that management of these sites, as in management of any actions, needs to be guided by plans that have a long-term view of what is to be achieved. While the Canberra Nature Park Management Plan gives an overarching strategy for management for land in nature reserves, it is not designed to provide guidance to ensure annual operational plans are undertaken strategically.


Resourcing issues

Coming from this, a major issue is the lack of adequate resourcing of TAMS to manage these areas adequately, particularly the high conservation value components.  Sufficient resources are needed to implement Action Plan no 27, with these resources being committed over the long term, not just for a year or two.  There needs to be established a long term system with appropriate expertise to undertake regular management activities (including weed control and pest management) in the high conservation areas, together with the necessary resources to undertake these activities in the long term.  As well, resources are needed for ongoing monitoring of the high conservation value areas and their biodiversity, and to assess the impact of different management strategies such as grazing and different weed control methods.  In general, the emphasis should be on maintaining and restoring good and natural woodland structure that is for the most part weed free, rather than an emphasis on particular weed species.


FOG suggests that an ongoing bushland management team (BMT) with specific expertise in bushland management principles and practice could be set up.  Such a team should be a professional team with a high level of skills in restoration and management that would work with government, non-government and community groups to help train and undertake work in sites across jurisdictions.  We believe such a BMT could undertake valuable work to improve the state of the sites over a few years so that fewer resources may then be required to sustain good ecological health in the long term. These teams could be hosted jointly by the ACT government and Federal Government agencies like the National Capital Authority to improve lowland woodland (and also grassland) sites across the ACT.  These teams could function separately from the existing TAMS structure while remaining under TAMS control.  This is likely to be more effective in the long term than attempting to add yet another layer of training (in bushland management principles) to existing staff who are already overloaded. [More information on bushland management teams]


The BMT should have influence over the management of Canberra Open Spaces in terms of drawing up mowing protocols and bushfire plans so that such areas may promote biodiversity health, ecosystems services and not be the source of weed spread (through inappropriate mowing management).  There is the possibility that the BMT could bid for works on non-ACT government land (e.g. high quality grassland or lowland woodland managed by the Commonwealth within the ACT).


One possible source of resources to operate such a BMT is offsets when loss of high quality areas is inevitable as part of a development.  While FOG would prefer that no high quality area is either destroyed or fragmented further, if it is deemed to be necessary by the Government, then offsets should include financing of rehabilitation work in other woodland areas within reserves.  Note that FOG only considers this appropriate if financing is offered over the long term, if the BMT or similar expert rehabilitation resources are used, and if rehabilitation is effective and monitored in the long term.


Another possibility is the potential to establish a botanical district combining the ANBG, Yarramundi Reach, Black Mountain and the two herbariums into a more cohesively managed entity.  While most of these areas are outside of the current review, lack of integration of management of adjoining areas is an ongoing problem in the ACT due to the different jurisdictions involved, and given the stage of development of the two herbariums and the current review of the ANBG, it may be timely to consider such a combination of these adjoining areas with similar yet diverse aims.  Alternatively, the concept could be broadened to that of an ecological district which also includes Sullivan's Creek, and the support of ANUGreen sought to assist in management of the larger area.


Connectivity issues

There are a number of areas outside CNP but adjoining it that have obvious biodiversity, connectivity and ecosystem services functions, e.g. Action Plan 27 identifies habitat connectivity for wildlife movement.  While components of the corridors are in CNP, these areas are often separated by public land outside CNP but still classified as “open space”.  Recognition of these other areas in development proposals and general management such as weed control and bushfire management is needed.  For example, if no weed control is undertaken in these intervening open spaces, they may become a source of weeds spreading into the adjacent nature reserves and negating the efforts of Parkcare groups and TAMS staff.  These areas should be either directly managed by the BMT referred to above, or the BMT should have a strong influence over their management.


Fragmentation of remaining lowland woodland in these corridors outside CNP is increasingly a problem due to urban development pressures.  This is a particular problem with the developments commencing in the Molonglo Valley.  There is also a need to integrate management of CNP and NCA lands, e.g. ACT and NCA lands at Stirling Park.  Fragmentation and weed introduction continues as service roads and urban infrastructure are placed and maintained through CNP and other reserve areas.  Activities such as mowing continue to spread weeds such as African love grass into areas adjoining these reserves.


In any management plans for CNP, the Molonglo River Corridor and Googong foreshores, there needs to be an emphasis on restoration of the natural habitat in all three areas.  Plans should also include long term strategies to upgrade existing areas that have good actual or potential connectivity.


Management issues

Recommendation 21 of the Report on ACT Lowland Native Grassland Investigation noted that overgrazing by kangaroos (as well as rabbits and stock) is threatening a number of the sites.  A similar situation applies to higher quality grassland and yellow box/red gun woodland areas of CNP, e.g. Conder 4A (part of Tuggeranong Hill Nature Reserve) and Mt Taylor.  Again, the problem has been exacerbated by the prolonged drought, and grazing pressure needs to be reduced in these higher quality areas by reducing the number of kangaroos, strategically managing stock and controlling rabbits.


Recommendation 32 of the same Report noted the need for increased community awareness of the importance of lowland native grassland.  Again, this recommendation needs to be extended to the higher quality grassland and yellow box/red gum woodland areas of Canberra Nature Park.  One action FOG believes could enhance community awareness is the placement of informative signs, both in some of the grassland sites in the Report (e.g. CC09 Guilfoyle St, Yarralumla and TU01 Isabella Pond, Monash), and in relevant parts of Canberra Nature Park.  Examples of sites in CNP that could benefit from such a sign are Conder 4A and Conder 9.  These high quality sites have been damaged a few times over the years by local youths building BMX jumps (a problem that occurs in other areas of CNP as well).  Lack of awareness in the community of the value of these grassy woodland sites contributes to the problem, and installation of signs may assist in addressing this.


Another problem subsequent to the damage to these particular sites has been attempts to restore the sites.  As already noted, TAMS staff lack the resources and, at times, the specific expertise needed to completely restore such areas to a reasonable condition. Restoration of the Conder sites after BMX-related damage has not been well done and, if such damage continues to occur, a different approach is needed.  Usually TAMS uses a large machine and, for the most part, spreads the dirt around the site until it is more or less level.  Additional damage to the site occurs because the machines are too big and awkward for the job, but if a much smaller machine was used, such secondary damage should be reduced.  Alternatively, use of a BMT to assist in restoration of such damaged areas would ensure that further high quality native grasslands and grassy woodlands do not deteriorate further. 


FOG has particular concerns that the ACT bushfire strategy will result in those parts of high quality woodland reserves adjoining urban areas being burnt more frequently than is desirable to maintain the existing structure, or subject to other actions such as rock and shrub removal and frequent mowing, with the net result of a change in both structure and biodiversity in the long term.  Future developments should ensure that bushfire buffer zones adjoining woodland reserves are included in the urban development and not in the reserve area, unlike what appears to unfolding in North Watson.


Further information

If you would like to discuss any of the issues raised above in more detail, please contact Naarilla Hirsch (FOG advocacy coordinator) on ........ or email ........ .


Sincerely yours






Geoff Robertson



22 February 2010