Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614



Mr N Lhuede
Risk and Planning Group
ACT Emergency Services Agency
GPO Box 797
Canberra    ACT    2601


Dear Nick

Strategic Bushfire Management Plan Review

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.

FOG is very aware of the need to plan and prepare for bushfires and the priority of public safety in terms of managing the reserves and other green spaces around Canberra, and recognises the work done to date to minimise the impact of bushfire prevention operations on high value conservation areas. We also recognise the increased consideration of ecological values in hazard reduction burns, in particular the need to contain fires outside fire sensitive habitats such as drainage lines, and we acknowledge the skills being applied by fire teams to achieve more strategic burns. Despite this, we feel that there are some areas where the Strategic Bushfire Management Plan (SBMP) could strengthen its consideration of conservation matters without having a deleterious effect on its overall aims.

In reviewing both the Core Principles and Core Strategies documents provided at the information sessions, FOG noticed no distinction is made between high quality conservation areas and other areas of natural or semi-natural communities. We believe that the SBMP should acknowledge the existence of several native communities listed as endangered both in the ACT and nationally (of which Natural Temperate Grasslands and Box-Gum Grassy Woodlands are two), and include some commitment to implement strategies to maintain these communities as well as meet bushfire management needs. The Core Strategy document is particularly weak in this regard: it refers to a need to “…identify the potentially competing objectives for development and conservation…” but makes no mention of actually implementing suitable approaches that would maintain biodiversity. There is later mention (in the Core Strategy) of “Where appropriate, planned fire will be used to maintain or improve ecosystem health and resilience”. Of course FOG supports this, but it is not clear what determines appropriateness or whether the conservation status of the land in question would play any role in consideration of selection of management activities.

Another concern of FOG’s relates to Inner Asset Zones (IAZs) and new developments. Fire management practices in IAZs are generally incompatible with enhancing biodiversity and conservation status. With older developments we now have the unfortunate situation where houses are too close to reserves, and management not appropriate for conservation is needed around the edges of these reserves – Mulligans Flat Nature Reserve is a case in point. There is more recognition of the need for buffers between housing and reserves in more recent planning processes, but there is still a major conflict between commercial interests wanting to maximise land available (and hence have buffers inside reserves rather than within the development footprint) and conservation interests. FOG thinks that all new developments should have any asset protection zones that are incompatible with optimal conservation practices located within the development footprint, and would like to see this included in the SBMP. We do believe that there are many land uses related to urban development that are totally compatible with the maintenance of the outer asset zone, which would minimise loss to developers. Such uses include parks, playing fields and specialist sports facilities with minimal assets such as model aeroplane areas or dog exercise areas.

Other issues we believe are missing and wish to see reflected in the SBMP are:

  1. Clarification of the requirements of inner and outer asset protection zones. We believe there are advantages in increasing the flexibility of the sizes of the IAPZ and OAPZ, as long as a default standard achieved. This may assist in meeting the recommendations of the ACT Bushfire Council that OAPZ should not compromise biodiversity or fire-fighting safety. As already mentioned, FOG does not support OAPZ being inside areas of identified conservation value, whether they are in or out of reserve, where this may lead to any loss of those values.
  2. A more flexible approach to the width and size of Inner and Outer Asset Protection Zone areas complemented by a transparency of such decisions, with public disclosure of the issues, responses and outcomes of these decisions. This in particular should relate to decisions that may potentially compromise biodiversity values on reserved or unreserved land. Such a flexible approach may include actions undertaken on the far side of areas of conservation value, reducing the risk or impact of wildfire moving through and out of conservation areas.
  3. The inclusion, as part of the SBMP, of control burns that are undertaken for ecological outcomes. Such fires frequently have two-fold effects – achievement of biodiversity benefits and reduction of fire fuel.
  4. Consideration of the impact that bushfire management practices may have on vegetation other than native vegetation, in particular those which encourage the spread of weeds. As a case in point, Fisher Parkland has two types of bushfire management applied – control burns in the area immediately adjacent to the houses, and grazing in the rest of the open space. After control burns, a number of native forbs were evident in the Themeda patches. By contrast, in the areas grazed by cattle the only grass not eaten down was African Love grass, which by autumn was setting copious seed. This management practice is likely to result in African Lovegrass, a declared noxious weed, dominating the Parkland in years to come. There needs to be some recognition in the SBMP of the impact of bushfire management practices on the spread of weeds, and strategies (and resources) in place to counteract this.
  5. Enforcement of legislation with infringement notices if required.

There are also several issues that we believe need to be strengthened in this strategy:

  1. Increased community engagement and education to focus on raising public awareness of the risks of wildfire and promoting actions to reduce the risk. The Government’s program for providing advice and incentives to residents on what can be done around the home to reduce energy use might be a useful model to apply to reduction of bushfire risk. A similar scheme for residents in at-risk areas could be developed, whereby there is some provision of bonus payment for works achieved.
  2. Further support is needed of Community Fire Units in their communication role in education of householders in fire-prone areas.
  3. Ensuring that all burns are undertaken at low intensity and are compliant with ecological guidelines where at all possible.

Yours sincerely



Sarah Sharp

30 April 2014