Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....

Dear Sir/Madam


Draft ACT Trails 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.


In reading the Summary of Draft ACT Trails Strategy, FOG notes that acknowledgment is made of the need for the Trails Strategy and its implementation to remain consistent with plans of management for areas of high conservation value. However, FOG considers that the Strategy needs to ensure all potential impacts from Trails are avoided in high conservation areas such as those containing endangered grassy ecosystems or threatened species. In FOG’s view, only trails that are unavoidably required for fire fighting should be placed in such areas, with ultimate care taken to reduce their on-going impacts (e.g. weed spread).


FOG sees value in trails that raise public awareness of the value of conservation areas, with part of that process being able to appreciate the beauty of such areas, e.g. a trail that provides visual access to conservation areas without going too close to (and certainly not going through) them. An additional point should be added to the list of key strategic priorities on page 15:

FOG supports environmental aspects of the Strategy, such as the Natural Cultural Heritage criterion on page 47, the proposed information on the TAMS website concerning out of bounds, protected areas necessary to preserve ecological or heritage values, and the reference to monitoring of weed occurrences along trails. However, FOG does not think that they go far enough in a number of ways.


One concern of FOG’s is interpretation of the criteria table on page 47. What is an area of “significant natural or cultural heritage”? Does it refer to areas with high ecological values? If so, what is the situation with moderate value areas that have the potential to be rehabilitated to higher conservation values, particularly those that adjoin and buffer high value conservation areas? We note also that areas of high conservation value occur outside reserves as well as inside, and these also need to be protected from unnecessary impacts.


FOG has concerns about the scoring system proposed. We believe that there are significant flaws in the values given to various attributes. Our interpretation of it as it stands is that, if a trail will have minor impact on a high conservation area of endangered Box-Gum Woodland or Natural Temperate Grassland it will attract a score of minus 20. This is easily offset by the several recreational value and maintenance scores. A proposed trail of local recreational value that can be maintained effectively will attract a higher score than 20, and offset the negative environmental impact score. FOG’s view is that there should be no impact on any grassland or grassy woodland area with a conservation value – this precludes minor impacts, particularly as the scale of the “minor” impact in the long term is uncertain. A case in point is the recent large cycling event through the sanctuary area of Mulligan’s Flat Nature Reserve – a highly inappropriate activity in a high conservation area that occurred because of the existence of the trail through the area. In addition to this we understand that some riders rode off-trail, which may have caused damage to the surrounding vegetation. In other words, not having any impact on any area with high conservation values should be a necessary condition of any new trail. Similarly, we would have thought that providing access for emergency services should simply be a necessary condition and not part of any score card. Having said this, the existing criterion for natural and cultural heritage could remain and hopefully help capture impacts on areas of potentially high conservation value, i.e. areas of lower value that might be able to be restored to higher value. It needs to be recognised by Government that for endangered communities and habitat for threatened species it is not good enough to protect areas of highest value, but it is critical to restore more degraded areas, to reduce the level of threat to these systems.


Another concern is that cultural and natural heritage values are rolled together into the one criterion. These are completely different values, and should be separated out into two criteria. The criterion as it stands implies that a proposed trail going through an area containing both natural and cultural values will have the same impact as a trail going through an area containing either natural or cultural values.


In section 1.33 Impacts on ecological and cultural values (page 36-7), there is reference to “the need for an appropriate balance to be formed … between the provision of recreational opportunities and the need to protect ecological and cultural values across the ACT”. As already stated, FOG believes that some areas should be “no go” and that this should be stated explicitly in this section of the Strategy.

FOG believes that the monitoring of weed occurrence referred to in action 25 (page 55), while an essential task to understand and preserve our biodiversity, does not go far enough. There is no mention in the document of any steps that might be taken to deal with increased weed occurrences in higher conservation areas (or in areas such as Canberra Nature Park overall), or changes that might be made to redress such occurrences. Given the limited resources available in the ACT for management of both weeds and of existing trails, FOG has no confidence that any increased occurrence in weeds, damage to native vegetation or erosion problems due to establishment of new trails or preservation of existing trails will be dealt with adequately.


In summary we recommend that:

  1. The scoring system is modified to adequately reflect the true conservation values that may be impacted by trails.
  2. Natural (ecological) and cultural heritage values is scored separately.
  3. No recreational trails beyond existing walking tracks are built in areas of high ecological value.
  4. No high impact recreational activities are held in areas of high ecological value.
  5. Monitoring is regularly implemented and mitigation adequately resourced, for all potential impacts including weed invasion, erosion, damage to vegetation or other key habitat features and development of unofficial tracks.

Yours sincerely





Sarah Sharp



31 December 2013