Manager – Natural Environment
Environment and Sustainable Development Directorate
ACT Government
GPO Box 158
Canberra ACT 2601
email: environment@act.gov.au

 

 

Dear Sir/Madam

 

Re. Draft Nature Conservation Strategy

 

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 members include professional scientists, landowners, land managers and interested members of the public.

Thank you for the opportunity to provide feedback on the draft Nature Conservation Strategy (NCS). We have separated our comments into a general section followed by specific comment on the five themes of the strategy.

 

General

 

FOG supports the five strategies proposed and the broad actions that have been identified to achieve the vision and long-term outcomes. However, we believe the draft NCS appears to be is very general and largely aspirational and lacking detail on how the strategies are to be achieved. Its targets are broad lacking clarity as to how the actions will occur and how success will be measured. We believe that, based on the identified targets, it will be extremely difficult to argue in ten years time whether these strategies have been successful or not in protecting biodiversity.

 

In contrast, the 1998 NCS, which this document will replace, identifies specific objectives, actions to achieve those objectives and performance indicators or targets to measure whether the objectives and actions have been met. We are extremely disappointed that this document does not build on the previous NCS. We believe the 1998 NCS was well-developed and comprehensive in approach and direction, and are disappointed that its format and vision has reflected in this update. Has there been a review of how well the 1998 performance indicators were met, and for those not met, why not? Such a review would strengthen the next ten-year Strategy and with setting new directions based on review findings.

 

The Strategy lacks context – in relation to national strategies and ACT legislation, policies and recommendations and in relation to research findings. There have been two key inquiries in the ACT over the past five years by the Commissioner for Sustainability and the Environment, but there is a singular lack of reference to key recommendations in those reports, including the recommendation for operational plans to be developed for each nature reserve. The lack of detail in the strategy allows ACT Government to avoid commitments outside current practice (or resources). There is little mention of how offsets will be applied in the ACT and the role of offsets to achieve no net loss – land development decisions are already being applied based on the draft ACT offsets policy that has not yet been made public, but in the ACT there is still significant loss of areas of conservation value every year – surely this should be addressed by the NCS.

 

Restoring the ACT’s focal landscapes

 

The draft NCS is supported for its focus on a landscape approach. We welcome the recognition of the nature reserves as a backbone for conservation, and the acknowledgement of other areas important for conservation. However, what is presented is very broad in its context, and omits significant issues. This includes the incorporation of Canberra Nature Park within both rural and urban landscapes; lack of recognition of the Molonglo River and Lake Burley Griffin as part of the River Corridor Landscape and omission of the rural landscapes and wilderness areas that are lumped, together with e.g. Pine Forests, in the ‘Other’ category.

 

In particular we are concerned about significant areas of grasslands and woodlands that are not in nature reserves, but occur across the urban environment. Many of these are managed by Commonwealth government agencies or in private leasehold. There is no indication of how the ACT Government will work with the other entities to manage these.

 

Strategies and actions

 

Strategy 1. Enhance habitat connectivity and ecosystem function

 

This is an important strategy. The continuation and expansion of the ACT woodland restoration program and the Greater Goorooyaroo Project are strongly supported.

 

However, except in regards to birds, there is still inadequate information relating to which groups of species are advantaged by corridors, which may also include pest species. If major resources are to be expended in this area it is important to establish targets set according to groups of species. As this program is rolled out, data is needed on fauna and flora using the corridors, and how this can be enhanced most effectively (see Role of research under Implementation below).

 

Connectivity is not the be-all and end-all for many ecosystems and species, especially fragmented grasslands remaining within the urban or rural landscapes, and effort needs to be put into managing small isolated remnants to strengthen their ability to resist weed invasion, human disturbance and threats of climate change.

 

Strategy 2. Manage threats to biodiversity

 

Aquatic ecosystems have not been included in this strategy yet biodiversity faces many threats here especially from low water quality. 

 

Strategy 3. Protect species and ecological communities

 

We support the proposed review of the Action Plans every 10 years (albeit we understand this is already undertaken by the Flora and Fauna Committee more frequently). In addition to protecting listed threatened species and ecological communities there needs to be consideration of managing to prevent others from becoming threatened. Previous work in the ACT (Sharp et al., 2007) identified several vegetation communities at risk, for example.

 

Re; “Monitoring of threatened species and communities will be an important action...” (s. 3.5, p. 15): programs have been in place for some years, but are generally woefully under-supported by government. To imply that monitoring will be introduced as a new initiative is very frustrating to read and reflects a lack of understanding of what is already occurring.

 

Strategy 4. Enhance biodiversity value of urban areas

 

There are several issues we would like to raise:

• Residual and fragmented areas: See earlier comment about connectivity, and the residual fragmented areas that still require adequate protection. Several areas of note that are not part of the reserve system but merit consideration for consideration for reservation under the Territory Plan are Mt Rogers, North Mitchell Grassland and Umbagong Grassland. We recommend that consideration be given in the strategy to identifying how best to protect all vulnerable remnants.
• New urban development: We are concerned that there is no strategy for new urban development, given we are continuously losing areas of biodiversity value. ACT Government agencies are currently undertaking studies and have involved the Conservation Council and FOG in discussions about criteria for assessing an approach that aims to achieve optimal conservation benefits, whilst providing surety for planning and development. Such an approach should be implemented for all development areas, including Molonglo, Majura, Jerrabomberra and Kowen.
• Fire reduction activities: Fire fuel reduction activities within the urban and peri-urban areas may conflict with conservation outcomes (biodiversity values). While there are few alternatives to Outer Assets Zones in nature reserves abutting existing residential areas, this is inexcusable in all new developments. Where biodiversity management may be compromised by fire mitigation activities and fire fighting (or vice versa) Outer Asset Zones need to be placed within buffer zones outside areas of conservation value.
• Legislation: Although as the NCS states, there are a range of legislative measures to protect biodiversity (s. 4.1 p. 16) past performance makes it clear that legislation has been inadequate. A simple tally of areas developed would clearly indicate serious net loss of biodiversity value.

 

Strategy 5. Strengthen community engagement

 

The ACT does have very strong community engagement in conservation management, advocacy, citizen science and education. Commitment to develop new Parkcare groups is welcome, so that the majority of nature reserves are supported by such groups. However, there is no mention of resource allocation so that Government can support and equip these groups. The community’s role should not be to undertake work that is the responsibility of government, including significant weed control. It is not an infinite resource, either.

 

Monitoring and review

 

A statement about resources is provided below, but in the context of monitoring, there is a significant lack of bureaucratic support for existing monitoring to be undertaken regularly, to provide important information to guide conservation management actions.

 

We do not accept that the monitoring outlined in Section 5 will provide useful data to determine progress against actions (p. 25).

 

“The assumption ... that habitat connectivity provides an appropriate surrogate for overall species health” (S.5.1, p. 21) must be questioned. We are not aware that this is actually correct. For some ecosystems at least connectivity will not lead to an increase in ‘species health’ For example, tree plantings in either naturally treeless grasslands or some derived grasslands will disadvantage particular species through shading.

 

Fire is identified as a key threatening process (p. 22). There are no threatening processes listed in the ACT. Fire has an extremely important role in the maintenance of biodiversity, which needs to be recognised in the strategy to determine how it can be better applied for ecological outcomes. 

 

Is it intended to wait until national standards are developed in 2015 or later (S 5.1, p. 21) to implement condition monitoring of vegetation communities? There are already measures available to undertake condition monitoring, even if subsequent modifications prove necessary in 2015 or later.

 

Three monitoring sites will be inadequate to measure impacts of climate change in the three identified ecosystems (p. 22).

 

Volunteer effort should not only be measured in terms of numbers of groups, hours spent and area treated but much more importantly, by the effectiveness of what is being done. We need to see results of what is achieved, and determine the most effective ways of utilising that most precious resource, ‘volunteer labour’. The inclusion in particular of a series of actions that the Bush on the Boundary group will achieve is of concern – the Strategy is hardly the place for government to be directing what the essentially volunteer group will do.

 

Implementation

 

Resources

 

Resources remain a significant issue in ACT Government’s role in undertaking environmental conservation activities. FOG is well aware of the difficulties faced by ACT Government, with fluctuating operating budgets that are not conducive to undertaking well-planned, strategic long-term programs designed to both protect biodiversity and to measure whether it is adequately managed and protected. The draft NCS does not address how this will change to achieve biodiversity outcomes – indeed it says “Prioritising overall investment efforts across landscapes will be dependent upon the availability of funding” (p. 24), which does not give any confidence that anything will change. Many of the new strategies are extremely ambitious, for example, to develop a hydro-geological profile of the ACT (p. 10), when existing programs, especially monitoring, are not currently being done adequately or meaningfully.

 

To effectively implement the Pest Animal and ACT Weed strategies the funding base needs to allow for planned, comprehensive treatment co-ordinated across land tenure. Resources also need to be available to control isolated outbreaks of new or existing invasive weeds to prevent their spread into key habitats or areas (e.g. to control the existing isolated patches of African Lovegrass in Gungahlin before it becomes established). The cost of preventative treatment is a fraction of the cost of containment.

 

Vague statements such as ‘Investment will be sought through a variety of mechanisms, including Government, private enterprise and in-kind contributions’ are entirely weaken the strategy. How? When? Who will seek it? In identifying sources of funding the role of offsets is noticeably absent.

 

Role of research

 

What is the intended interrelationship between ACT Government, research institutions and other land managers to achieve “better management of native vegetation, .... refugia ... and better management of threatening processes” (p. 22)? Ecological burning, grazing, habitat requirements for threatened and other species to enhance recruitment, effective restoration of habitat and vegetation, effective weed control and the role of corridors are all issues that need to be addressed to achieve ‘better’ management (which needs to be defined to have any meaning).

 

Conclusions

 

There is little in this Strategy that is new or innovative it is disappointing that such an important document will do little to guide and direct effective programs of conservation of biodiversity at this challenging time.

 

FOG would welcome a revised NCS which would become a document against which future successes or failures in conserving biodiversity in the ACT could be measured.

 

References

 

Sharp S., Macdonald T., Kitchin M. and Dunford M., 2007. Setting Conservation Targets for Vegetation Communities in the ACT. Report to the Natural Resource Management Committee, ACT. Parks, Conservation and Lands, Canberra.

Sincerely yours

 

 

 

 

John Fitz Gerald

President

 

10 December 2012

 

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Addendum

 

Manager – Natural Environment
Environment and Sustainable Development Directorate
ACT Government
GPO Box 158
Canberra ACT 2601
email: environment@act.gov.au

 

 

Dear Sir/Madam

 

Re. Draft Nature Conservation Strategy

 

Friends of Grasslands (FOG) made a submission on the draft ACT Nature Conservation Strategy on Monday 10 December. Unfortunately, some of FOG’s comments were inadvertently left out of that submission. The following is an addendum to that submission containing these missing comments, which we hope you will accept at this late date.

 

Strategies and actions

 

Strategy 1. Enhance habitat connectivity and ecosystem function

 

Strategy 1.2 is very brief, and it is not entirely clear what is meant by “fine scale assessment” – is it “fine scale assessments of all habitats lumped together”, or “assessment of different habitats and types of ecosystems”. Who will undertake this fine scale assessment? Will the community be advised as to the results (or consulted during the assessment)? How will it fit in with the offsetting occurring as part of the EPBC process? Does the current North Gungahlin Strategic Environment Assessment fit into this (and if not where does it fit in the Strategy)?

 

As well as its support for the continuation and expansion of the ACT woodland restoration program and the Greater Goorooyaroo Project mentioned in our original submission, FOG also thinks that there is an opportunity to improve grassland connectivity across the border in the vicinity of the Majura and Jerrabomberra valleys. Development in the Eastern broadacre area is a possibility within the lifetime of this Strategy, so the importance of such connectivity should not be underplayed in the current document.

 

One gap in the draft Strategy is mention of the involvement of the private sector in grassy ecosystem rehabilitation. FOG is aware of Natural Temperate Grassland rehabilitation work being undertaken by Canberra Airport Group and Greening Australia as part of biodiversity offsets under the EPBC Act. The private sector is part of the ACT community and, at times, has both interest in and responsibilities for rehabilitation or care of grassy ecosystems and dependent species. Such efforts need to be acknowledged and encouraged by the Strategy.

 

Strategy 4. Enhance biodiversity value of urban areas

 

FOG is perturbed by the brief mention of “environmental offsets” in the last paragraph of this section. The text, by implication, assumes that offsets are a standard part of the development process. Offsets are not a way for developers to buy out the impact of their projects on the environment. In fact, offsets should be a last resort where all else fails. The aim should be to avoid impact as far as possible, then to mitigate impacts, rather than to need to offset the impact of a development proposal. This needs to be clearly stated as part of the Strategy.

 

Other key points about offsets that need to be made clear are that:

• they are biodiversity offsets, not carbon offsets;
• some of our highest quality areas should be considered “no go” zones, with the aim of no development being allowed that will impact on them;
• the aim of offsets is, at the very least, no net loss of the relevant species or ecosystem in the long term. In fact, we should be aiming for net gain, given that offsetting is not proven in terms of its long term effectiveness, and that climate change is likely to increase impacts on our endangered ecosystems and species;
• offsets are not actually proven to be effective in achieving no net loss of endangered grassy ecosystems or dependent species in the ACT. Monitoring their effectiveness should appear somewhere in the Strategy, as should monitoring adherence to offset conditions;
• the effectiveness or otherwise of biodiversity offsets in preventing net loss of our grassy ecosystems and endangered species should be apparent before the end of the life of this Strategy. A true strategic approach should include alternatives if offsets prove ineffective in preventing the decline of these ecosystems and species.

Another area of concern is that, despite not having articulated its biodiversity offset policy to the community (although FOG is aware that this policy has been in draft form for two years), decisions are being made about offsets as if this policy were in place. While this situation is better than no offsets being made available at all, the community is left uncertain as to the grounds on which offsets are chosen. This situation is not helped by negotiations occurring between the ACT Government, the Commonwealth Government and developers behind closed doors. The Strategy should include the principle of and commitment to clear articulation to the community of all policies that affect nature conservation in the ACT.

 

Sincerely yours

 

 

 

John Fitz Gerald

President

 

17 December 2012