Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Conservation Research
Environment, Planning and Sustainable Development Directorate
GPO Box 158, Canberra City ACT 2601


Dear Sir/Madam

Draft ACT Native Woodland 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.

FOG welcomes the release of the Draft ACT Native Woodland Conservation Strategy and Action Plans April 2019 and is pleased that the strategy includes “lowland and subalpine native woodland communities across all tenures and land uses” and “in all conditions”, including the Endangered YB-BRG Grassy Woodland.

However, FOG believes that that there are broader issues that the Strategy fails to recognize sufficiently and that the Strategy and Action Plans could be significantly improved, as follows:

1.       Expand the scope: Given that this is a ten year strategy, there should be a greater focus or vision of what might be achieved ten years from now. This includes identification of specific outcomes to be achieved if all stakeholders work together, and the inclusion of indicators that express success in the strategy’s aims and achievements. A strategy should be encouraging a wider range of thinking and be ambitious and aspirational in its approach, so that it generates ideas and reflects potential achievements of the broader community, not just government.

2.       Stakeholders: Acknowledge that many people and organisations are undertaking conservation actions and/or influencing conservation outcomes, and that much that is happening is not under the auspices or control of the ACT Government. This strategy needs to encourage the involvement of all stakeholders in achieving the objectives, not just listing those actions that ACT Government is responsible for. True collaboration is not controlled by one, albeit important, stakeholder.

3.       Woodland decline: There needs to be greater recognition that, while YB-BRG Grassy Woodland is declared threatened, other woodland communities are in at least the same state of decline, especially Snow Gum Woodland, and all require a high level of preservation.

4.       Off-reserve woodlands: There needs to be full recognition and acknowledgement that much of the remaining woodland is outside the reserve system and is on unleased or leased Territory land or on Commonwealth-managed land, so that the requirement for collaboration is critical.

5.       Rural landholders: Following on from the previous point, there is a critical need to work with lessees in a positive manner to encourage stewardship and support rural lessees who want to retain and conserve areas of woodland, such as introducing conservation covenants, Land for Wildlife, undertaking joint projects and sharing management knowledge.

6.       CNP management plan and site operational plans: It is essential that the Canberra Nature Park management plan be completed and associated site specific operational plans be developed. It is also essential that operational plans are available for all unleased sites, whether in reserve, in urban open areas, along roadsides and so on, since these that provide a guide to government, community and other stakeholders of priority actions for each site.

7.       Traditional custodians and land management: The strategy should acknowledge that the traditional custodians of this country have the primary role (inclusion and autonomy) when making decisions about conservation of areas, including in utilising traditional management practices. The broader aboriginal community has an important role, but not superimposed over the role of the traditional custodians.

8.       Threats and management: This area of the document needs some restructuring and renaming of sections to both highlight the most significant threats and acknowledge that disturbance is a necessary part of ecological diversity, function and resilience and should be identified as such. Specifically, we draw your attention to the fact that some factors (such as fire) can be both a threat and a management tool.

9.       Linkage of issues: the document needs to better link the impacts and management of identified issues, for example invasive plants and climate change.

10.   Summary statistics and indicators: It is essential to identify what it is that is trying to be achieved (i.e. a benchmark) against which to measure change in condition.

11.   Enhancing woodland condition: Overall there should be more emphasis on enhancing condition to increase resilience and functionality (and identifying what would be considered good condition) over all land tenures, not just in reserves and other ACT Government open space.

12.   National Recovery Plan for White Box - Yellow Box - Blakely’s Red Gum Grassy Woodland and Derived Native Grassland (2011): There is no reference to this document, and how ACT conservation actions relate to this plan.

Attachment A elaborates on these points and includes other concerns with the document. We have also attached specific comments (Attachment B).

Many people have devoted a great deal of time in the preparation of this draft strategy, and, on behalf of FOG, I would like to acknowledge their dedication and commitment to the conservation of the ACT's woodlands. I would also like to thank the Directorate for the opportunities through the Woodlands Stakeholder Group to provide input during the development of the draft. Finally, I would like to acknowledge those other people, including members of FOG, and organisations who have contributed to woodland conservation to date, including the significant input into submissions on the draft document.

Yours sincerely


Geoff Robertson

23 May 2019


Attachment A: General FOG comments

Introduction and Part A The strategy

Scope of the strategy

Given that this is a ten year strategy, there should be a greater focus or vision of what might be achieved ten years from now. In particular, this relates to the actions in the Strategy and Action Plans. This includes more specific outcomes rather than the very general indicators currently in the document, and indicators that can be used to effectively identify the success, or not, of the strategy. The strategy should be more visionary and ambitious, identifying what the ACT Government commits to doing and what may be achieved by in collaboration with the broader community. This has the potential to:

This also applies to subalpine woodlands, about which little is said in the strategy.

Given that woodlands cover a third of the ACT (woodlands cover 34% of the ACT’s landmass, of which subalpine woodland accounts for 21%) and are a major part of the conservation estate, this should be emphasised. Equally, the very high percentage of woodland that occurs outside the ACT Government’s conservation estate (61% is on rural lands, national lands or other), with 29% in reserve and 10% in other ACT land, the roles, responsibilities and opportunities for those other land managers, especially rural lessees, needs to be better considered. This is within the context that much of those lands outside reserve have multiple uses, including providing an economic return from agricultural practices.

Objectives of the strategy

Leaving aside specific comments made in our submission, FOG generally supports the objectives of the strategy. However, as well as issues raised elsewhere, we have the following comments on the objectives:

On P. 5 Protect, the text indicates that threatened species (and other flora and fauna) are protected under Commonwealth and ACT legislation, but makes no mention of the fact that threatened ecological communities are also protected. Protection of the critically endangered YB-BRG Grassy Woodland community should be explicitly stated as an objective of the strategy.

Maintain. Ongoing intervention is required to mitigate the impacts of a range of threats (e.g. invasive species, loss of mature trees) to woodland communities and associated flora and fauna. Management practices must adhere to best practice and be informed by an adaptive management system.

On P. 5 Improve, we think Enhance would be a better heading for this objective, and one that reflects what we believe should be the aspirational approach for the strategy, and implies direct actions being required.

Local, regional and national cooperation (P. 9). There is no reference to the National Recovery Plan for White Box - Yellow Box - Blakely’s Red Gum Grassy Woodland and Derived Native Grassland (2011), nor any indication here or elsewhere of how ACT conservation actions relate to this plan. In particular, are there actions in that plan that are not covered by this strategy and associated YB-BRG Grassy Woodland Action Plan and, if so, what is the reason for excluding them?

Improving woodland condition/Enhancing woodland condition

Overall there should be more emphasis on enhancing condition to increase resilience and functionality. We know much about the elements required for woodlands to have resilience and functionality. These elements and attributes need to be clearly identified in benchmarks. Then management should be aimed at enhancing some of these attributes (such as species diversity) and controlling others (such as invasive plants and pest animals). Development and subsequent monitoring of such benchmarks should be included in the objectives of the strategy.

P. 17 Conservation objectives There needs to be greater recognition that while YB-BRG Grassy Woodland is declared threatened, other woodland communities are in at least the same state of decline, and all require a high level of preservation. In particular, Snow Gum Grassy Woodland is under threat (see table 2), having been heavily cleared. Within the ten years of this Strategy, an action should be to consider this particular community for listing as a threatened ecological community.

Off-reserve woodlands

Table 1 on P. 15 shows quite clearly that almost half of the ACT’s woodlands are on rural lands, more than is in reserves. There needs to be full recognition and acknowledgement in the document that much of the remaining woodland is outside the reserve system so that the requirement for collaboration is critical. This relates not only to land under leasehold or Commonwealth government management, but is particularly important on unleased Territory land,as there are a number of threats unique to ACT Government woodland that is out of the reserve or open space system as a result of conflicts for road maintenance or widening, infrastructure or development.

For example, on P. 6 Collaborate mention is made of woodland reserves only. This objective should include not only promoting and managing the sustainable use of woodland reserves, but also off-reserve woodland, including rural properties and urban open space and other unleased land (e.g. roadsides). In the same section, collaboration with other entities that manage woodlands should include the Commonwealth Government (NCA, Defense, etc.), commercial landowners other than rural land holders and land managers of lands bordering on the ACT. This is stated better on P. 8, but it is important in the summary to identify sustainable use and management of not only reserves but also other land uses. There is also considerable woodland in other arrangements, e.g. Ginninderry Conservation Area.

Section 2 Collaboration with the community

While FOG supports much of the content of Section 2 Collaborate with community, FOG has some issues, both with the terminology used and with some specific details.

While technically all ACT land is leased rather than owned outright, the document should identify that traditional custodians, rural lessees, ParkCare volunteers and others all have a deep affinity with the land they care for, albeit in different ways. The role of stakeholders in cooperatively managing woodlands needs to be recognized. Additionally, the Strategy should recognise that much woodland conservation is undertaken by bodies other than government, as different parts of the community link and interact outside government initiatives (and off reserve). This is particularly the case with rural lessees and traditional custodians, whose relationship with the land they care for goes back to earlier generations.

In this regard, we have some specific comments about the document:

P. 43 Collaborate with the community

While the ACT Government is the primary manager of ACT Government lands, it should be recognized that responsibility is spread across a number of administrative units within government and often management arrangements are complex. Are there protocols and guidelines that govern these arrangements to ensure there is collaboration between government units as well as with the community?

Where lands containing woodlands are managed by the Commonwealth Government, commercial or other similar organizations, there should be formal agreements that establish strategies and plans for co-operative land management.

Many community groups including ACT catchment groups, and Landcare, ParkCare and other volunteer groups take responsibility for managing aspects of the ACT conservation estate. Consideration could be given to entering into formal agreements (e.g. NCA has a formal agreement with FOG for the latter’s work on national lands, see case study P. 47). The ACT Government should review the resources supplied to voluntary groups in a way that recognizes the costs of providing managerial assistance. Possibly the appropriate wording here is shared management. This matter also relates to the need for management plans and operational plans so that community and government can truly collaborate to meet commonly understood and developed actions and better understand outcomes in relation to those actions.

P. 45 Support community participation and raise community awareness

The role of volunteers is often undervalued. The voluntary effort requires much organization and, while voluntary groups raise awareness of woodland values, some assistance is needed from government, e.g. for training, or to cover of out of pocket expenses. Catchment groups are not receiving adequate government support and may not be able to continue to support important monitoring projects (e.g. Waterwatch, Frogwatch, Vegwatch). Data on the number of volunteer hours and the financial value of those hours should be included as part of the data monitoring of the implementation of the strategy.

Rural landholders

There is a critical need to work with lessees in a positive manner to encourage stewardship and support rural lessees who want to retain and look after areas of woodland, such as instigating legislation to facilitate conservation covenants, supporting joint projects or sharing management knowledge.

P. 43 Collaborate with rural landholders

We think that this section should be titled “Rural landholders”, in respect of the connection they have with their land.

While mention is made of prioritising the ongoing management and enhancement of woodland outside the reserve system (P. 17 dot points 6, 7), it isn’t clear anywhere if government is considering incentives for rural landholders such as conservation covenants, grants for specific improvements or management actions, or assisting a rural lessee group interested in woodland enhancement. Further mention of the five year program being undertaken with Commonwealth funding to enhance liaison, information and data and on-ground liaison between government and rural lessees could be held up as an example (see comments also on the YB-BRG Grassy Woodland Action Plan).

Traditional custodians and land management

P. 49 Enhance the participation of Aboriginal people

Looking forward ten years, we need to have a vision of the place of Indigenous people in woodland management and conservation. By then, we may have: a First Nation’s Voice in the Constitution and Makarrata (treaty and truth telling). The strategy, in our opinion, should mention:

P. 49-52 Enhance the participation of Aboriginal people

It is important to provide specific support for the traditional custodians of the ACT country for employment and provision of advice, not just support for the broader Aboriginal community.

We are concerned about the recommended action to identify and map cultural values. Control of knowledge and who has that knowledge must remain with the traditional custodians. FOG’s experience is that there are real concerns amongst Aboriginal elders about some locations and their values becoming publicly known. Several FOG members (and individual NCA staff) have worked with Elders to identify locations of important areas within NCA land, and have produced maps with limited distribution and used this information to ensure on-ground activities in those areas are compatible with those values. However, these values and associated maps remain intentionally confidential, as per advice provided by Elders.

Threats and management

Chapter 1 Protect and manage woodland and component species

We question the order of the threats in section 1.2 Reduce threats to native woodland biodiversity. It isn’t clear why Invasive plants is so far down the list of threats when it is amongst the most damaging of the listed threats, nor why it has been separated from the conceptually similar Pest animals section. We suggest re-ordering the sections in 1.2 so that the most significant threats come first. The orders and categories of threats in the YB-BRG Grassy Woodland Action Plan look much better; we suggest consistency in the ordering throughout the document.

Disturbance is a necessary part of ecological diversity, function and resilience and should be identified as such. Specifically, we draw your attention to the fact that some of the listed threats can be both positive and negative in their impact on woodland biodiversity. For example, while intense or overly frequent fire is in general destructive, an ecological fire regime can be a useful tool in promoting biodiversity (and possibly may become the most important tool). The same can be said of grazing. Pulse grazing using domestic stock is used successfully as a management tool to control biomass in some areas. As well some woodlands on rural leases have retained their structure in the presence of grazing – this should probably be acknowledged on P. 41. The use of “overgrazing” as a heading carries an implication that grazing is negative at the top level (the contents page) of the document. It might be better to:

(a)    replace “overgrazing” with “grazing”; and

(b)   have similar sub-headings under section 1.3 Implement ecologically appropriate biomass management; or

(c)    group these two sections together under a heading similar to that used in the ACT Native Grassland Strategy, e.g. Ecologically inappropriate disturbance regimes, which captures the essence of the problem, including that these are frequently utilised complementarily.

While aware that the Strategy is meant to have a broad scope, we think that this whole chapter is too general and needs to provide some more detail, reflecting more recent scientific literature.

Addressing each of the threats in turn, our comments are as follows:

P. 18 Dieback

In addition to dieback apparent in E. blakelyi trees, there is considerable dieback of many E. melliodora trees across the rural and urban landscape. This is arguably the key tree species in the YB-BRG Grassy Woodland community as it has lower natural regeneration rates than E. blakelyi, and because very old trees in these woodlands are most frequently E. melliodora specimens. For this reason, the issue of dieback on E. melliodora should be highlighted in this section, and included specifically in the conservation objectives. E. viminalis dieback also requires identification, as do whether any other species may potentially be affected. While dieback, particularly of E. blakelyi, has been an issue for decades, the potential for it to affect a great many more species is of critical concern.

P. 20-23 Pest animals

We support recommendations in this section but don’t think that they go far enough.

Ten years from now we will have hopefully a better understanding of ecology and its management so that we may be seeing a reversal of the decline in threatened species and ecological communities. One barrier to this happening is the impact of some native fauna whose numbers are possibly too high, leading to overgrazing, competition for nest sites, competition for food, predation, and so on. Interestingly, overgrazing by Eastern Grey Kangaroos is not mentioned here – perhaps a link to the section on overgrazing by this species should be added. Noisy Miners are mentioned, but other birds such as many larger native birds are not mentioned. While Currawongs are an obvious example, there are other larger birds with the potential to be problematic. Research is required to identify what are the appropriate population targets for different native species. As per the comment above, there is much research published (e.g. that by Karen Ikens) that would strengthen this section on the impacts of invasive urban adapted fauna, invasive exotic pest animals such as the Common Myna, and on the other side, urban avoiding species such as sensitive woodland birds. In addition, more and continuous education of the general community is required to understand why we need to manage populations of some native species. For example, even with the ACT’s Kangaroo Management Plan and its implementation, FOG is concerned that current kangaroo numbers remain too high, possibly in order to appease anti-kangaroo cull advocates.

We recommend the inclusion of how predator-prey relationships may be improved. The place and protection of the dingo needs consideration. The reference to dingo-wild dog hybridization should be deleted as, according to Dr. Don Fletcher, there is no evidence of this occurring. Within the next ten years research is required that provides a better understanding of the roles and place of the Dingo in the landscape and that may support landowners to adapt management methods to protect domestic grazing animals against predation from Dingoes and wild dogs.

P. 23-26 Fire

The material on fire is unduly negative and seems to be too strongly influenced by the trauma of the 2003 wildfire. The critical regenerative impacts of fire need further elaboration. The aim of the strategy should be that in ten years best practice ecological fire regimes would be a major form of management of biomass and biodiversity in our woodlands. Cultural burning practices that apply cool mosaic burns seems to be relegated to an afterthought. This section could include a discussion of consideration of incorporating indigenous practices, and also give this approach to fire management a higher profile in the conservation objectives.

We have several observations concerning fire:

a)      Fire, since the arrival of the first Australians, has been a key management tool. Most grassland ecologists now are strong supporters of cool burning techniques. There are a number of studies underway that can be drawn on to improve the implementation of ecological burns.

b)      While subalpine areas may not have experienced fire for some years and litter load may not be large, the litter load would actually vary from place to place and litter and other biomass reduction would be appropriate in some areas. Trials of cool burns should be supported.

c)       The comments about fire compare areas recently burnt with long unburnt areas and say that the former are more likely to contain a diversity of fauna. However, this does not discriminate between the impact of high intensity and widespread fires and controlled cool burns undertaken over smaller areas. The utilization by kangaroos and other herbivores of fresh green grass after burns is well documented.

P. 26-28 Urbanisation

We support the recommendations, but think that they could be strengthened. In particular, many areas off-reserve are particularly vulnerable to disturbance and loss related to the establishment of infrastructure associated with increasing urbanization and population growth. This includes road widening, loss of small patches of woodland within the urban area that provide links between larger habitat, and development of former rural land. The width and use of buffer zones designed to protect threatened species and ecological habitat need to be determined by evidence based research.

P. 28-30 Overgrazing

P. 28. See earlier comments. Suggest the heading Overgrazing is changed to Herbivore management or Ecologically inappropriate disturbance regimes – it is not just overgrazing that is the issue but general impacts, which may for example be stock grazing at certain times of the year that limit plant regeneration, especially of palatable species. Also, the strategy should better integrate threats of grazing with the benefits of grazing, recognising that grazing at certain times of the year/season may encourage plant regeneration (e.g. by creating gaps in the groundlayer) and may control some invasive species. This is particularly important in the context that much of the ACT’s woodland is grazed commercially, and the role that livestock can play in reducing biomass quickly for wildfire control (refer to Morgan in chapter 8, Williams et al., Land of Sweeping Plains for more information on the role of grazing in grassy ecosystems).

P.28. Eastern Grey Kangaroo: the influence of grazing is also on the soil and ground cover. Under high numbers kangaroos create bare ground in camps and tracks, and consequently cause erosion. It’s also important to recognise the role of kangaroos in biomass reduction.

P.28 last para, first sentence: Replace “vegetation” with “grass” in “Preference for new grass growth” (we suggest this be checked against Fletcher and Howland papers, aren’t kangaroos largely grass eaters, while wallabies and other native herbivores more generalists)? This strategy is an opportunity to compare the role of kangaroos at lower densities in maintaining biomass control – a preferred option to domestic stock grazing in reserves -and the increases in populations as a result of the creation of grass and water sources in the urban as well as rural landscape – i.e. there are far less restrictions on food supply now, hence leading to the need to cull under certain circumstances. We presume much of this is ably covered in the Kangaroo Management Plan, but could be included in the strategy.

An additional recommendation for this section is to state government support to continue to pursue a range of methods of limiting effects of high populations of kangaroos, with non-lethal as the preferred option (but currently not feasible). Is there a word is missing here?

P. 29. Livestock. The impacts are considerably greater than for kangaroos. For example, many native forbs are eaten preferentially by livestock, and the increased soil compaction and disturbance also destroys cryptogams, which play an important part in nutrient recycling and hydration of soils.

More detail in this section would be useful. The issues raised are important matters for understanding of the need to both utilise and control kangaroo and stock grazing, and the more information available to inform stakeholders of possible impacts the better the outcomes are likely to be.

A general comment that applies to this section is the need to identify the links between issues, for example, that overgrazing frequently results in invasion by introduced plants.

P. 31-33 Invasive plants

While the statement “A number of species, including African Lovegrass and Chilean Needlegrass, have become so abundant and widespread that eradication is not feasible” (top of P. 31) is true, the implication of such a bold statement is that nothing can be done to control it. It might be helpful to qualify this statement along the following lines “However, given their ability to transform habitat, their spread needs to be contained and control undertaken as a priority in high conservation value woodlands.”

The reference to novel ecosystems (Stagoll et al., 2010) should be followed by a sentence “Hence removal of some woody weeds needs to be accompanied by a sound habitat replacement strategy”.”

Give reference to other highly invasive species that occur in woodlands (Steve Taylor has recently circulated a list of species that identify the degree of invasiveness of a range of naturalized species, including species not listed as Declared Pest Plants: Steve Taylor Dec 2018.doc)

Either in this section or in the section titled Urbanisation (P. 26) more should be said about community education regarding the biosecurity risk that people and vehicles pose to woodland values, and the need to utilise appropriate hygiene measures to reduce the likelihood of species being unintentionally introduced.

As well, there needs to be much more stringent policy and compliance to ensure vehicles and persons are not infesting areas this includes accessible and identified appropriate wash down facilities (and better access for non-government vehicles to be able to use these). Vehicle hygiene is a major issue in control of invasive plants, especially African Lovegrass.

Another consideration is the potential for non-indigenous native species to become invasive, to monitor their abundance and range within woodland areas and to develop treatment strategies accordingly, especially in light of the existing changes to weather patterns in ACT.

P. 33-36. Climate change

P. 34 Climate change: dieback may be linked climate change, so there should be a reference back to the dieback section, possibly with particular mention of E. melliodora and E. blakelyi.

The paragraphs on lowland woodland (e.g. most of P. 34) need more detail on the impacts of climate change. We think that it could have massive impacts on trees in YB-BRG Grassy Woodland. In this regard there should be a link made to the recent listing of removal of mature trees as a threatening process.

Another linkage that needs to be made in this section is to invasive plants. With the effects of climate change there are inevitably going to be new species becoming naturalised as well as increasing invasion by existing naturalised species. The conservation objectives should include research on the potential for increases in invasive species.


Woodland offsets are discussed under Urbanisation, with supporting their identification, establishment and ongoing management being a conservation objective. Government and stakeholders may not agree as about the role of offsets (or the loss of the area to be offset). In part this comes down to concepts of net loss. The community often sees the loss of acreage, i.e. destruction of a YB-BRG Grassy Woodland area, as a net loss, and are convinced that neither restoration or enhancement of another area adequately compensates for the loss of a patch of YB-BRG Grassy Woodland. Supporters of offsets, however, believe that offsets are successful if the restoration work delivers improvements in woodland habitat or species condition. Either chapter 1 or chapter 3 should address this, with clear information about the effectiveness or otherwise of the various woodland offsets either in place now or that emerge during the life of the strategy, and a way forward if offsets do not deliver the promised “no net loss”. The Strategy should identify that offsets are not a panacea, but may be utilized where there are no other options to the loss of an area of woodland, but that offset areas are to be enhanced (albeit this should be occurring anyway).

CNP management and operational plans

P. 8 Implementation, P. 38 Conservation objectives

This section states that the Woodland Conservation Implementation Plan will be developed from a range of sources including existing reserve management plans. However, the lack of ecological management plans for the majority of woodland sites in reserve, open space or other important woodland in unleased land (for example woodland that borders roads in the rural and urban environment and woodland in Travelling Stock Reserves) is a critical failing by government to date. It is essential that the Canberra Nature Park management plan be completed and associated site specific operational plans be developed.

P. 67 Woodland management plans identifies the need for these plans to effectively manage our woodlands, but in addition there need to be site specific management plans for all woodlands within ACT Government tenure to provide a guide to government, community and other stakeholders of priority actions as well as defined proposed condition outcomes for each site. This should be a key action of the strategy, to ensure that all woodlands in CNP and other unleased land are covered by a management plan and/or operation plan. How does government expect to monitor change if it hasn’t identified the actions to be undertaken and outcomes to be achieved in particular areas? How can stakeholders work together to achieve outcomes if these are not specified beyond generalised statements such as manage native assets; control invasive plants – which species, how, follow-up etc. These plans are not difficult to prepare, and FOG doesn’t understand why they are not already available for all woodland areas within CNP, let alone other important woodlands. Examples of management and implementation plans for other areas include those for NCA conservation areas (Sharp 2016), plans developed by community groups for open space that they manage (e.g. Griffith woodlands, Bullan Mura Woodland, Justice Robert Hope Woodland) and ones developed and implemented with a great deal of success over 20 years ago for the four northern grassland reserves. It is recommended that simple plans like these be developed and implemented without delay.

A conservation objective should be added to the effect that management and operational plans have been (or would be) developed for all woodland areas, whether on-reserve or in other public land. Ideally, lease holders should be offered incentives to develop such plans.

P. 46 Support community participation and raise community awareness – conservation objectives:

Community actions on ground would be significantly improved by having site management or implementation plans that they collaboratively work to implement with government, so that everyone can work together strategically. A good example of where this is happening and the positive effects are illustrated in the case study of Stirling Park.


P. 52. There is no reference to how the actions identified in the Strategy will be provided to the Commissioner for incorporation in State of the Environment Reports.

P. 52. Monitoring: Ecological consultants, research institutions and various community groups also undertake monitoring of woodland condition and collect relevant information that is provided to government in order to inform management decision making. To ensure the best data are collected government needs to encourage such monitoring and work with these groups to provide opportunities for metadata analysis and sharing of resources to collate, store and access data, recognizing that not all useful data is government owned and controlled.

P. 52 second last para: “… CEMP for ACT woodlands that will, in addition to providing a framework to monitor changes in woodland condition over time and assess the efficacy of management actions, identify knowledge gaps and prioritise future research projects to inform woodland conservation.” We suggest that involving the community in this program will facilitate broader data collection and quality control of data to guide management of woodlands, and that the following conservation objective should be added to this section:

Collaborate with community groups to collect and use monitoring data systematically and effectively by providing support to enhance data integrity.

FOG is concerned about the long period of time it has taken to develop the CEMP for ACT woodlands and hopes it is published shortly. In the meantime, FOG supports the MCG’s Vegwatch program and COG monitoring programs implemented over the past decade. FOG members are involved in implementing the Vegwatch program in woodlands within the ACT.


While we agree in principle with what is stated, it is very frustrating to read paras like the following:

“A range of projects aimed at addressing knowledge gaps and monitoring woodland condition since the 2004 Lowland Woodland Strategy are published online (ACT Government, 2018h) and are outlined in Section 4.7. These projects, as well as evidence from other literature relevant to lowland and/or subalpine woodland conservation and management, guide the strategies and objectives outlined in this Strategy.”

when Section 4.7 does not provide any data in a statistical form. When one clicks on the “online” link, the page is not available. While the CEMP is often mentioned, the CEMP for lowland woodlands is not yet developed (or if being used internally has not been published for use or review by others).

P55 3.2 Address knowledge gaps in woodland conservation

Most research has concentrated on attributes relating to above ground activity, while little research has been done on below ground ecology. FOG recommends that the Strategy identify the need to undertake much more research on below ground activity, including bioturbation, soil biology, the relevance of new ideas such as rehydration and natural sequence farming.

Summary statistics and indicators

FOG recommends that, within ten years, statistics should be developed that quantitatively demonstrate, over time, changes of the area of woodlands under conservation, changes in condition including woodland biodiversity, and expenditure on woodlands. Such statistics would provide measures of the success or otherwise of the woodland strategy and fit within Economic and Environment Statistics being developed nationally and in each jurisdiction (in the ACT by the Commissioner for the Environment and Sustainability). Ideally, these statistics on woodlands would be part of broader biodiversity statistics that include woodlands, grasslands, riparian and other areas of vegetation.

Hence the statistics for woodlands would include time series for:

Ideally these measures would be integrated within a more comprehensive framework that measures similar statistics across all woodlands, grasslands and riparian areas and should be consistent with the statistics on Economic and Social Accounts being measured by the Commissioner for Environment and Sustainability. Many elements of these indices will already be available.

5.2. Management investment required to achieve conservation objectives

P. 83-89. Every action identified requires significant management investment in lowland woodland. Perhaps some other level of categorization is required that will provide a more useful guide to prioritising actions.


Part B. Action Plans

General comments

Many of the comments outlined above are relevant to the individual action plans, including:

Include measurable outcomes to identify success not of achievement of actions undertaken but the impact of those actions on conservation of woodland.

Some of the action plans are “draft”, others are not. Are the ones not notated as “draft” meant to be commented on? As we were uncertain, we have provided some comments on these anyway.

Action plan indicators

Each of the action plans contains a table showing key objectors, actions and indicators. The indicators are expressed to demonstrate whether tasks outlined in the plan have been achieved or not. However, these measures of outputs do not measure whether the outcomes of the plans are successful or not in enhancing condition of woodland and/or particular species. FOG believes it is important that the publication of statistics shows the outcomes of actions identified in the woodland strategy and associated action plans, by creating time series statistics that aggregate the data from the monitoring and evaluating program. The statistics that could be measured are listed under the heading Summary statistics and indicators in the section on the Strategy above.

Yellow Box – Blakely’s Red Gum Grassy Woodland

In addition to the comments below, many of FOG’s comments or recommendations made in regard to Part A are relevant to the YB-BRG Grassy Woodland Action Plan, and are not repeated, except where specifically relevant.

The context of land use of YB-BRG Grassy Woodland

The critical factor for the conservation of YB-BRG Grassy Woodland in ACT is that less than half (41%) is in conservation areas, with the remainder in rural leasehold (43%), National land (9%) and ‘other’ (7%). The ACT Government has limited ability to control conservation of these areas directly other than through relevant legislation. Therefore collaboration of the highest level must be the primary objective before any of the other objectives may be met. For example, additional formal protection will only add a small proportion to the land within the reserve system.

As has been identified in earlier sections of this response to the draft Strategy, many of the actions identified are ACT Government-focused and only achievable within the conservation lands. There is little if any identification of how these actions can be achieved where the ACT Government does not have direct control. In addition, it is frequently not clear whether actions identified as occurring now or in future will be undertaken on land not managed by ACT Government. For example, it is not clear whether monitoring undertaken to improve management and understanding will or is occurring only on reserves, or also on unleased or leased land, and whether there is collaboration of results for other land, such as the monitoring that occurs on Commonwealth land.

Addressing actions across all land tenures by all stakeholders

FOG recognises that government will be called to account for implementation of actions identified in the Strategy. For example, in the section on collaboration the actions and indicators all relate to what the ACT Government will do to achieve collaboration. However, FOG contends that additional actions that may be initiated by community, research bodies, national government agencies or rural landholders, with which government may or may not collaborate, can be of significant value to meeting objectives. Several existing examples are:

We therefore recommend mention of actions that bodies other than the ACT Government may be able to achieve (albeit of course without being called to account for non-achievement), so that the actions are not solely ACT Government focused.

Providing opportunities for rural lessees to better conserve YB-BRG Grassy Woodland on their properties:

Conservation covenants

Legislative changes to enable rural lessees to seek protection for areas of land on which conservation will be the primary objective are important. This allows for more areas of land to be included into the conservation estate and also protects endangered woodland from unintended impacts (Objective 1). Such covenants rely on individual landholders volunteering, but resources from government can be used to improve the conservation of these areas (such as fencing, assistance with feral animal control) at a fraction of the cost of putting such areas into reserve. FOG suggests that such an approach is far better than government requiring actions to be taken or not taken.

Land for Wildlife

It is our understanding that surveys for Land for Wildlife are now being undertaken in ACT. Some information on how the results of these surveys will be used would be useful, in facilitating alternative ways of conserving woodland.

Application of domestic stock grazing

While research into the role of domestic stock grazing to achieve conservation outcomes is identified in the Action Plan, this explicitly or implicitly relates to grazing as an option for biomass control, i.e. on lands primarily managed for conservation. On rural properties in the ACT the primary objective is to utilise grazing for financial return. Therefore, studies need to be undertaken to better research and apply management that achieves both financial return and conservation outcomes.

The Protecting and Connecting Box-Gum Woodland Project

This project is an excellent example of what can be achieved with government and the rural community collaborating. However, it gets only one small mention, with no explanation of what it is about. FOG recommends that this be explained in a box, as it has potential for considerable improvements in woodland management outside the reserve system.

Kosciuszko to Coast

K2C comprises fourteen partners working together to deliver better natural resource management and environment services to and learn from land owners and managers, Landcare groups, and community. Projects include Land for Wildlife Assessments which are now available in ACT, and workshops focused on learning about and managing habitat for the Scarlet Robin and other vulnerable bush birds. One significant strength of this organisation is that it facilitates projects across the border between ACT and NSW.

Scarlet Robin Action Plan

Refer to the work being done through various programs including K2C to enhance habitat for the species.

The action plan appears to be the 2016 plan and has not been updated. For example, the first two indicators refer to end dates of July 2018, which is well past. Have these indicators been met and need to be removed, or updated? Should other areas of this action plan be updated to match current our current understanding of the threats to this species?

Superb Parrot Action Plan

Recent trends in Superb Parrot distribution have seen its range extend further into the ACT, a trend that is likely to continue as climate change continues. Consequently, it is important that we undertake proactive management for conservation of the species in the western rural areas of the ACT, and this should be included in the action plan.


Attachment B: specific FOG comments

In terms of general edits, there is a lack of consistency in some areas. One example is that both capitals and no capitals have been used for common names. Another is inconsistent use of terminology in lowland/tableland and upland/sub-alpine.

Another concern is keeping track of the objectives or recommendations. These are provided at the end of the relevant section, so are buried in the document. It would be useful if these could be drawn together in some sort of summary statement.

Possibly, the document could be tightened and improved by the employment of an external reviewer who is also a woodland ecologist.

P. 7-8 iv. Action plans and conservation advice The purpose and authority of a conservation advice (a statutory document?) is not explained, nor is any reason given for dropping a number of threatened species from an action plan to a conservation advice, apart from stating that action plans “were considered unnecessary for the persistence of these species”.

P.8 v Implementation

In paragraph 2, regarding “the development of the Woodland Conservation Implementation Plan (CIP) in 2019”, the document mentions a plethora of plans to be reviewed. However, it isn’t clear to us how this CIP will relate to either the strategy or the individual plans. And will the CIP provide case studies of how the recommendations in the strategy would impact individual sites?

As well, the terminology in paragraph 1 lacks recognition that the ACT Government is part of a network of stakeholders with an interest in ACT woodlands.

P. 9. para 3, As outlined….: Other land managers are also undertaking management using fire specifically to conserve key threatened communities and woodland species. For example, since 2011 the NCA has been implementing Bushfire Operations Plans for conservation areas that include YB-BRG Grassy Woodland in Stirling Park, State Circle Woodland and O’Malley. These are designed specifically to use fire for conservation outcomes. Refer to the case study of Stirling Park. Ken Hodgkinson’s research into the impacts of burning on grassland diversity is of direct relevance also.

P. 9: second last para: Daviesia is misspelt

P. 10. Third para: It is not only grazing that “has reduced …”, but also changed burning patterns, weed invasion, soil disturbance, clearing, and so on.

P. 11. Map: hard to follow: use more contrasting colours.

P. 17 Conservation objectives: dot point 5: The use of the term “unintended impacts” gives the impression that there will be no protection from any intentional impact. In fact, in the action plan for YB-BRG Grassy Woodland, a definition of “unintended impact” is given in Table 1. This definition should appear in the strategy itself.

From a stakeholder perspective, given the critically endangered listing of this ecological community, all attempts should also be made to protect ALL remaining areas from all unintended as well as “intended impacts”, not just those areas in reserve.

P. 17 Conservation objectives: dot point 7 should reference to the Commonwealth Government, commercial landholders, Traditional owners and Indigenous people.

P. 24. Great photo, but the fire is burning hot up the trunks of trees - does it show best practice burning?

p. 40. What does ‘natural’ grazing pressure mean?

P. 41 Fire management. What is meant by ‘traditional’ tool? Should reference to cool burning be made here?

P. 48 Enhance and promote citizen science: suggest change the last sentence in the first para to:

Programs developed and implemented by community groups (such as the Vegwatch Program for monitoring vegetation and habitat condition coordinated by the Molonglo Conservation Group (formerly Molonglo Catchment Group)) provide guidance to community members to undertake monitoring using consistent methodology.

Note that Molonglo Catchment Group needs to be changed to Molonglo Conservation Group throughout the document

P. 58: there are now two yam daisies recognised as occurring in ACT: Microseris lanceolata (sub-alpine) and Microseris walteri (tableland). Both are important as food plants. The one most people think about and record (probably including the photo on P. 60) is M. walteri.

P. 63. Rutidosis leptorhynchoides: one r –spelling updated as published by the National Herbarium in 2015.

P 72 4.8 Woodland conservation and research activities in the ACT since 2004

A useful addition to this section would be a case study showing how offset funds are being used in Molonglo to enhance woodlands – management, research, revegetation and rehabilitation activities, and spin-offs into management practices from these.

P. 74 Third dot point – expand point as follows:

On-ground management and engagement activities undertaken by ParkCare groups (including: weed treatment, grazing and erosion control, tree and shrub planting and interpretive walks for the public). Other activities include monitoring and surveys (rabbits, kangaroos), involvement in other monitoring programs such as Frogwatch, Waterwatch and Vegwatch, weed swap, and organising and running stalls, e.g. annually at the Jamison Centre.

P. 75, second dot point: Currently monitoring is occurring in ten woodland and derived grassland sites in the ACT as part of the Vegwatch program.

P. 79-82 Table 5.2: What is the significance of some of the table being highlighted and some not? It needs an explanation at the start of the table.

Objectives in the YB-BRG Grassy Woodland Action Plan (and probably elsewhere): the term “appropriate” used in Action 2a, 2d and indicator for 2c is very loose. Does it mean optimal? Suggest the term is replaced.