Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....




Dr Maxine Cooper

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



Dear Maxine


Investigation into the Canberra Nature Park (nature reserves); the Molonglo River Corridor (nature reserves) and Googong Foreshores


Friends of Grasslands (FOG) is responding to the request for comments on the three papers “Managing Rabbits in Canberra Nature Park” (by Dr Kent Williams), “Impacts of Climate on the Canberra Nature Park: Risks and Responses” (by Dr Bob Webb), and “Funding options for protecting the environment through enhanced management actions” (by Ms Lisa Miller).


In general, FOG supports the recommendations of the report “Managing Rabbits in Canberra Nature Park”, particularly in those parts of Canberra Nature Park (CNP) that have high conservation value (such as the Mulligan’s Flat and Goorooyaroo Nature Reserves). As you identified in your “Report on ACT Lowland Native Grassland Investigation”, grazing by rabbits has had a detrimental impact on many of the natural temperate grasslands and grassy woodlands in the ACT. In particular, we consider that resourcing of maintenance of the high conservation areas of CNP is inadequate, with rabbit control being one component of this maintenance that needs an ongoing commitment of additional funds.  We also think that rabbit control is best considered as part of a bush management approach rather than a single management issue.


The one small concern we have with the report is the statement:

“On the basis of knowledge obtained in exclosures studies, such as those at Mulligans Flat, consideration should be given to establishing exclosures in other parts of CNP to promote recovery or restoration of suppressed species of plant and animal. Such exclosures may qualify as biodiversity offsets.”

In principle, FOG’s view is that there should be no development that impacts on vulnerable or endangered species habitat or ecosystem communities, and consequently no need for biodiversity offsets. However, recognizing the reality of the current situation where offsets are mandated by government, our view is that offsets should be aimed at “net gain” (rather than maintenance of the status quo), and that they must be supplementary and not substituting for already existing commitments, e.g. they should not replace existing government funding to maintain reserves. From that point of view, the suggested exclosures should be part of current ongoing maintenance of the relevant reserves. If they were proposed as a biodiversity offset, there needs to be long-term commitment to their maintenance and to ensuring that they achieve the desired effect of enhancing conservation of native grasslands. Any research component using such exclosures should be specifically directed at species or ecosystem recovery, and obtaining good management outcomes leading to enhanced conservation of grasslands and grassy ecosystems, with longer term commitment to using the results more widely in ACT grassland reserves.


In considering “Impacts of Climate on the Canberra Nature Park: Risks and Responses”, FOG supports the key strategy (covered by recommendation 4.1)

“Enhancing the resilience of ecosystems and species through maintaining diversified habitats and refugia and improving connectivity on a ‘whole of landscape’ basis”

We have been arguing for a ‘whole of landscape’ approach to grassland and grassy woodland conservation for some time, and continue to be dismayed by development proposals that appear to ignore this concept. One factor that mitigates against a ‘whole of landscape’ approach in reserves is the lack of resources for our current reserves (and consequential loss of biodiversity and conservation value), leading to a reluctance to add areas to these reserves that would enhance landscape connectivity. While off-reserve management can be effective, it can also leave particular sites open to ongoing demand for development.


In response to the paper “Funding options for protecting the environment through enhanced management actions”, FOG in principle supports a levy such as is proposed in this paper.  FOG has been arguing for an expert bush management team in the ACT for some time.  As we are aware that this will require additional funding, a levy seems to us to be a good way to go about this.  We do not have specific comments on the details of such a levy, but it would need to be sufficient to adequately cover the cost of the bush management team and the list of defined projects that it should undertake. This might mitigate against the concept of starting low and then increasing it.  Alternatively, another approach might be a staged one, with stage 1 a less ambitious list of tasks for the bush management team and stage 2 a bigger list.  In terms of a sunset clause, we would not that bush management is an ongoing task that needs continuing resources, although the tasks of the bush management team might vary over time.


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.


Sincerely yours





John Fitz Gerald



8 April 2011