Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Referral Entry Business Point

Environment Assessment Branch
Department of Sustainability, Environment, Water, Population and Communities
GPO Box 787



Dear Sir/Madam


Canberra Centenary Trail Project

Reference number: 2012/6645


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.


Timing of the Referral


FOG is concerned that comments on this Referral have been requested before targeted surveys of some listed species are completed. Any decision about the Referral should not be made until all relevant information is available. While there are pressures to complete the Trail in time for Canberra’s Centenary, there has been sufficient time to do such work during the life of the project (FOG’s original submission to TAMS on this Trail was dated 21 Nov 2011 and questioned its environmental impacts), and decisions about listed species should not be 'fast tracked' because a celebratory deadline is now drawing very close.


Potential for Misuse of the Trail


FOG submits that the current lack of resourcing to ensure compliance to usage rules across all ACT nature reserves gives no credibility to the claim that prohibition against dogs in the nature reserves and illegal trail and mountain bike use will be controlled. Providing and publicising the Canberra Centenary Trail (CCT) will probably result in more breaches of the restrictions in using the Trail. As FOG pointed out in its 2011 submission to TAMS, there is already a serious problem of inappropriate use by trail bikes in other nature reserves and open spaces around Canberra, and FOG considers that broadening and extending trails through these nature reserves will most likely increase unauthorised entry and damage to surrounding vegetation.




There is a strong likelihood of passive spread of weeds into the nature reserves. There are areas that the Centenary Trail goes through, particularly in the south of Canberra, where there are extensive populations of grassy weeds (such as African Lovegrass, Serrated Tussock and Chilean Needlegrass) alongside walking tracks and fire trails, e.g. along trails between Urambi Hills and McQuoids Hill. While one of the major vectors for weed spread is by mowing, inadvertent transfer by walkers (and their dogs) and cyclists carrying the seed further along the trail also occurs. Increased use of the tracks through Mulligan’s Flat Nature Reserve and Goorooyaroo Nature Park is likely, over the long term, to increase the spread of weeds through these areas.


Impacts on listed species and communities


The proposal will impact on 0.49 ha of Box-Gum Woodland. FOG’s view is that this is unacceptable, especially as the majority of this (0.38 ha) is planned for completely new track segments. FOG submits that no development should occur in high-conservation-value areas. While FOG acknowledges that in an exceptional case (e.g. where vital Territory infrastructure cannot be rerouted) an impact on endangered Box-Gum Woodland would be unavoidable; we submit that this Trail designed for recreation is not vital, and arguably not exceptional. The primary objective under the Territory Plan for Nature Reserves such as Mulligan’s Flat is to protect biodiversity. Recreational opportunities are a secondary objective. FOG considers that the CCT should, at the most, only make use of existing trails in Reserves and in high quality areas linking them.


FOG notes that the Trail will be 'micro-aligned' to minimise impact on Pink-tailed Worm-lizard habitat and Hoary Sunray population, and, if the Trail goes ahead, requests that this become one key component of the conditions of approval. Further, FOG recommends that removal or disturbance of other habitat features such as rocks, logs or fallen timber also be prohibited.


Finally, FOG points out an aspect that also bears directly on enhanced spread of weeds:- FOG calculates that, although fragmented, 0.38 ha of new track with a corridor 1.5 m wide (page 4) corresponds to an actual route 2.5 km long. FOG submits that this poses a risk for ecological damage that is far too high.


Construction and post-construction impacts


In the Referral there is mention of contractor induction and of a CEMP, but no indication of process to ensure that these are adhered to, of limiting accidental damage in high quality areas by use of temporary fences, or of how breaches would be dealt with.  This is of serious concern to FOG since commencement of planned construction could be just a month or so away.


FOG argues that the Referral understates the impact of the Trail on existing Box-Gum Woodland as analysis is confined to construction impacts. There will be long-term impacts due to the increased use of the existing and new trails in our high-conservation-value nature reserves, including more weeds being carried in and more people straying off the Trail and disturbing the surrounding woodland, particularly as the Centenary Trail would be wider than the existing tracks.


There is mention of post-construction management and monitoring to ensure that the Trail achieves its aims, which are to “showcase the true ‘Bush Capital’, taking you on an exploration of the national capital’s natural areas and iconic landmarks”. There is also mention of identifying areas of ecological sensitivity (although surely these should be known before track construction), of developing management plans about Trail actions, and of how these will be managed to avoid impacts to matters of NES. However, there is no mention of monitoring the post-construction impact of Trail use on the environment and managing of any problems that might arise, e.g. with weeds and improper recreational usage. Given the time this project has been under development, it is disappointing that the Referral offers only general statements about monitoring and management. Since no long-term funding has been identified for essential ongoing management, FOG is left with no confidence that the Trail’s impact can be monitored or that problems can be resolved in a timely and effective fashion.



While acknowledging the worthy intent of the CCT (to showcase Canberra and some of its hidden treasures), FOG is concerned that the Trail planned could degrade some of those treasures. At the very least, a Trail should be confined to existing tracks through high-conservation-value nature reserves. Improved consideration needs to be given to potential long-term impacts of the Trail on our endangered grassy ecosystems.


Sincerely yours



John Fitz Gerald



10 December 2012