Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614



Mr Peter Beutel
Asset Manager
National Capital Authority
GPO Box 373
Canberra ACT 2601


Dear Peter, 

Submission on the NCA’s draft 2014-2016 Bushfire Operations Plan (BOP)

Thank you for the opportunity for Friends of Grasslands (FOG) to comment on the NCA’s draft 2014-2016 Bushfire Operations Plan.

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 supports the management of environmentally significant national lands through volunteer ecological restoration work under a partnership agreement with the NCA that was renewed in 2013.

FOG fully supports the NCA for its ongoing efforts to undertake professional fire management on environmentally significant national lands. In addition to managing the socio-economic risks from wild fires, a well conducted planned burning program may have significant ecological benefits. In particular, in native grasslands and woodlands the ‘intermediate disturbance’ of a low-intensity fire is important for reducing grass tussock dominance so as to maintain inter-tussock gaps vital for many indigenous herb species (including the endangered Button Wrinklewort) and wildlife. Such ecological burns are also important for thinning eucalypt and wattle regrowth so as to maintaining a more open woodland vegetation structure. Key to positive ecological outcomes from planned fires are timing outside of plant flowering and animal breeding seasons, as well as low burn intensity, as is proposed in the draft BOP.

In fully supporting the draft BOP we ask that the following elements are considered or enhanced:

  1. Preventing weed spread. Mowers and other vehicles track the seeds of highly invasive weeds, especially of African Lovegrass, into high conservation value areas. As noted in the ecological guidelines, we ask that all slashing equipment and vehicles are washed down before entering and upon leaving each site.
  2. Coordination with weed control efforts. FOG agrees with references in the plan to coordination of our weed control works with NCA burns. Where FOG can undertake woody weed control work first the subsequent fire may have lower intensity, remove left cut material and kill any weed regrowth. For control of grassy and herbaceous weeds (e.g. St John’s Wort), contract sprayers should be scheduled for early spring (September - October) following each burn, that is, when the weeds have resprouted but before the indigenous plants are active. This may enable highly targeted spraying of weeds.
  3. Aboriginal sites. FOG cooperates with the Ngunnawal traditional owners. They have made us aware of many more culturally significant sites, especially in Stirling Park, than are noted in Federal Government reports. Ideally the NCA and the Ngunnawal traditional owners would identify and conserve sites of cultural importance. Key measures to conserve sites may include protection of scar trees from fire and care to avoid disturbing rock arrangements. A number of the Ngunnawal traditional owners have expressed to FOG a desire to be involved in ecological burning on national lands.
  4. Hollow trees. Hollows in dead or alive trees are particularly important for wildlife, and can take upwards of 120 years to develop in eucalypts. As noted in the ecological guidelines, we ask that particular care is taken to protect hollow trees from destruction.
  5. Vegetation of ecological importance. At Scrivener’s Hut and Stirling Park there are particularly fire sensitive species that are considered to be ‘keystone’ plants supporting higher native bird diversity, beyond the species listed in the ecological guidelines. Mistletoe is a very important source of fruit, nectar and cover in tree canopies. It is particularly sensitive to scorching and efforts should be made to avoid burning close to low hanging specimens (see: Watson, D. M. (2002). Effects of mistletoe on diversity: a case-study from southern New South Wales. Emu, 102(3), 275-281. doi: Cherry Ballart trees form dense habitat for nesting and roosting as well has having edible fruit (see: Loyn, R., Faragher, J., Coutts, D., & Palmer, G. (2009). Bird Responses to Targeted Revegetation: 40 Years of Habitat Enhancement at Clarkesdale Bird Sanctuary, Central-Western Victoria. Australian Field Ornithology, 26(3), 53). They are readily killed by fire and this should be avoided with rake hoe lines around major specimens, e.g. those in FM 4 and 7. If desired by the NCA, FOG could consider GPS mapping of major specimens of both species to enable their protection during burn operations. We also note that the endangered Button Wrinklewort may grow close to major trees at Scrivener’s Hut and Stirling Park and, as noted in the ecological guidelines, care should be taken to avoid damaging these plants through rake hoe use.
  6. Scale of burning. We appreciate the NCA’s plan to burn sites in multiple blocks in rotation so as to retain cover for wildlife and develop different aged blocks of vegetation. While understanding the operational difficulties, we are concerned that Stirling Park block FM7 is particularly large and ask if further consideration could be given to dividing it in two for burning in different years. There is an existing walking track midway along this unit that would require removal of only a small number of eucalypt saplings to provide light unit access. Similarly FM8 is large and could be divided in two by reopening the access track along the power line.
  7. Weed trees. We encourage the NCA to continue to use the planned burn program as an opportunity to fell and burn non-heritage listed, non-indigenous trees on environmentally significant national lands (e.g. pine, poplar and willow wildings in FM 4, 7, 8, 12 and 13). There are Bluegums in FM6 that could be felled similar to those that were in FM5.
  8. Scrivener’s Hut. FOG particularly supports the proposal to burn the Scrivener’s Hut FM36 block in autumn 2016. In February 2014 FOG completed the first cut over of woody weeds on the site, reducing the mid-story biomass. However, we are concerned that eucalypt and wattle regrowth on the site is overly dense and will shade out the endangered Button Wrinklewort population. Hence a burn on the site would be ecologically beneficial. Further, we suggest that this could be an opportunity to fell and burn the Poplars, Ash and Willows invading the creek line at the north end of the block.

9.       Stirling Park units. In FM4 coppicing Bluegums may need retreatment if not killed in the upcoming burn. We hope to undertake further plantings in the southern end of FM4.1 in the coming year, which may reduce the area that can be slashed. FM5 is now effectively clear of woody weeds apart from some Ash saplings at Westlake that will be felled next spring. FM7 has significant woody weed infestations that are unlikely to be cleared before autumn of 2015, delaying recommencement of weeding in FM8.

Thank you again for the opportunity to contribute. FOG supports this excellent NCA program.

Yours sincerely



Sarah Sharp

30 April 2014