Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


c/- Park Planning and Policy
Environment Planning and Sustainable Development Directorate
P.O. Box 158
Canberra ACT 2601


Dear Sir/Madam

CNP Draft Reserve Management Plan

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.

The proposed Reserve Management Plan is a vast improvement to the one produced in 1999, being far more informative and directive in its approach. The plan is well structure and argued, the maps are appropriately set out and linked, and the tables well constructed. The draft plan includes many powerful images of landscapes, plants and animals that illustrate the beauty of Canberra Nature Park (CNP).

However, while the draft plan is meant to set out a ten year plan, it largely describes what is the current practices and not what might be achieved within a next ten years. We note and acknowledge that such a plan is not the place in which to have specific actions that change over time, but we urge commitment in this Plan for Government to prepare and publish work plans for every reserve, that contain information for all stakeholders of those reserves, including ParkCare volunteers, research scientists. Development of these work plans should be in consultation with all stakeholders.

Particular improvements FOG would like to suggest include:

More information about these, and our detailed comments, can be found in the attachments.

Yours sincerely


Geoff Robertson

16 December 2019

Attachment A: Detailed comments

P xiii. The Ministerial statement could refer to the Traditional Custodians and mention how CNP can provide an opportunity to all visitors to learn about the importance of their culture and the importance of their land management practices.

P 1.  FOG suggests that the last dot point under Canberra Nature Park be expanded to include “and an experience of nature to local residents”

P 2. 1.2: Add a reference to biodiversity offsets likely to be one reason other areas are added to CNP, e.g. Franklin Grassland. And that such additions will have an offsets management plan associated with them.

P 4., p.181 etc Why isn’t Jerrabomberra East listed as a nature reserve? If an offset site, and thus not part of Canberra Nature Park, can this be explained somewhere?  

Chapter 1 Introduction: It would be useful to have a section in this chapter that relates CNP to the broader conservation estate and to the general landscape in the ACT. This section could both place CNP in context with other important conservation areas and discuss generally cooperation and actions with adjoining land managers (currently only mentioned under specific management topics). Information FOG thinks would be useful in such a section includes:

P 5. Nature-based experience and dog walking. A distinction should be made between experiencing nature and nature-based experience such as walking which are activities within a natural area but are not necessarily part of experiencing nature.

P 8. 1.6: At the end of the section, add text about some parts of reserves in CNP are offset areas and have their own offsets management plan, available in the ACT’s Offset Register

P 15. References to 10% and 33% are unclear and should be explained a little better.

P 16ff. As well as Figure 2.1, it may be useful to include a table that shows areas of each ecosystem in ACT and what portion is included in CNP, other ACT reserves and land, Commonwealth lands, rural leases, roadsides and private lands.

P 17. Text box. Can we say anything about the success of the project?

P 19ff, 2.1.2. References to plant names, should use the common name referred to in the Census of Vascular Plants in the ACT (v.4.1, 2019), as the definitive authority. Use of local traditional names, where available, should be in addition to but not in place of commonly accepted common names. Where names in CNM differs from the Census it would be helpful to note these. Regarding the references to the Monaro sub-region and Murrumbateman sub region, it should be explained how these intrude into the ACT.

P 19. The reference “The following four grassland communities fall within the definition of Natural Temperate Grassland (at an ACT and Commonwealth level) and are protected within Canberra Nature Park.” It would be useful to quote the source of the classification. Are there other grassland communities in the ACT that do not fall within Canberra Nature Park? Or provide a reference to the Grassland Strategy.

P 20, textbox. Reference to fire, should this mention traditional aboriginal fire practices? Should it include a reference to the Ginninderra catchment project?

P 21. The reference, “The forests on Black Mountain and surrounding areas have developed over millions of years …” seems somewhat odd. While it is true that eucalypt forests have evolved over millions of years, Black Mountain was likely covered by grasslands during recent ice ages.

P 22. Tableland Aquatic and Fringing Vegetation - should be in bold.

P 23. Re statement “Franklin Grasslands supports one of only three known populations of Ginninderra Peppercress (Lepidium ginninderrense).” We think that Ginninderra Peppercress is now known at four sites (see the Draft Variation to the Territory Plan 366: Franklin Grasslands Environmental Offset Site) - this needs to be checked.

Also, Franklin Grassland is in the process of being changed to a nature reserve – it is mentioned here but is not currently part of CNP. What is the process for adding such reserves and offset sites to the Management Plan in the future?

P 24. Spelling: Rutidosis leptorhynchoides, etc (see the Census v 4.1)

P 24. Reference to dingoes suggests that it may be found at Rob Roy and Mount Majura. Is this in fact the case?

P 26. Reference to Grassland Earless Dragon (Tympanocryptis pinguicolla), should be (Tympanocryptis lineata) following split of the former into four species. ( T. pinguicolla is now only confined to Victorian and is likely extinct.

P 26 GSM. While GSM is found in areas dominated by spear grasses, FOG is not aware of any evidence that GSM feed on these grasses. It seems more likely that these grasses often grow with wallaby grasses on which GSM feed. Possibly it should be mentioned that CNG is a major weed which complicates management of GSM.

P 34: Dogs are non-native animals but don’t need a licence to take them into a designated dogs-on-leash reserve.

P .34, 35: Information on the values of the Eastern Grey Kangaroo, reasons for culling and results of monitoring of the benefits of culling kangaroos to biodiversity should be included or at least referenced

P .35: State that timing, intensity etc. of ecological burning is based on research

P 38: Distinguish the differences between transformer, invasive and other introduced species in order to prioritise control of particular species.

P 40: Distinguish between wild dogs and dingos.

P 41: Isn’t dieback of E. melliodora also an issue?

Pp 46, 209, 217. Action 25. Since urban open space surrounds most of the 37 listed parks, mowing, invasive control, dumping and rubbish removal are all enormous problems along this huge interface. To acknowledge this, change “control of disease with adjoining land managers” to “control of disease and species invasions with adjoining land managers”, and boost priority from low to high in the action tables.

P 47. Re statement, “Ngunnawal people manage cultural landscape for over 25,000 years”, is problematic. We know that aboriginal people were in Australia at least 60 to 65,000 years ago, and archaeological evidence shows the presents of indigenous people in Canberra at least far back as 25,000 years. Likely aboriginals were in this region prior to that time. However, during the last ice age, it is likely there were few people in this region and those that are here now probably descended from people who lived well below the current east coast of Australia. Without trying to undermine the concept of traditional custodians, we need to accept that there was much more fluidity in aboriginal society. Possibly the statement could be modified to say “Ancestors of the Ngunnawal, Ngunawal and Ngambri people managed cultural landscape for over 25,000 years”.

P 53, chapter 4. There are five references to “Representative Aboriginal Organisations and Traditional Custodians” in this chapter. The use of capitalisation implies that this an organisation. If so, an explanation of what it is would be helpful.

P 55: Elsewhere in Australia, there is Indigenous Land, i.e. where land is owned and directly managed by Traditional Custodians, instead of Shared Custodianship as we have in parts of the ACT. Should some areas be set aside for exclusive use by Indigenous Custodians?  Mention could be made of exploring the possibility of doing this.

P 60. Suggest addition of a section titled “Learning from traditional custodians” – see attachment B for details

P 102: The research identified in the draft plan essentially focuses on larger plants and species. In future, a greater focus is required on the relationship between soil, fungi, soil biota, etc on the one hand and higher life forms on the other. More emphasis needs to be given to understanding and measuring the populations of invertebrates, especially given concerns that invertebrate populations have fallen worldwide by up to 40%. Invertebrates perform many ecosystem functions and are an important part of the food chain. Equally, a greater understanding of smaller reptile species, likely to be undergoing serious declines, is required. Since settlement, poor water management practices, including allowing water to run off quickly, has led to deterioration of water retention in landscapes. Reversing this and keeping water on site and within the soil needs research. Regenerative farming practices may provide important insights into many of these issues.

Each of these elements of research and the application of their findings becomes more urgent in the context of the growing impact of climate change and related drought, catastrophic fire threats and likely occasional heavy rain falls. Hence the final plan should highlight that each of these elements needs to be researched and their findings applied in the management of CNP  

P 104, S9.1.3 Citizen Science: Citizen science ‘activities’ have proven to be effective, not “are proving to be effective”. As well as gaining new information etc., they are also a means to gain important information guiding adaptive management. More direct support could be given to other citizen science programs as well as Canberra Nature Map, for example Waterwatch and Frogwatch initiatives.

P 104. S9.2. Cultural heritage research – here or elsewhere, ensure it relates to current practices: facilitate use of and encourage cultural practices overseen by traditional custodians

P 104. S9.3. FOG supports the longitudinal data being collected and hopes that it will be used to create biodiversity indicators over time.

There is other information that should be collected, although this Management Plan may not be the appropriate place to specify such information. This includes the total cost of managing CNP, indicators of the benefits and cost of CNP management, costs broken down by type, and estimates of the number and hours of volunteers who contribute to CNP

P 116:  FOG considers that an extra reserve complex should be created in this Plan for the southern grassland reserves, initially comprising East and West Jerrabomberra. Jerrabomberra West has little in common with the other reserves currently assigned to that Woden Woodlands and Grasslands complex. The Southern Grasslands Reserves are likely to increase as the lands in that vicinity, acquired as future grassland offset sites, are likely to be added to the CNP.

P 134 etc. The proposed Franklin NR will need to be incorporated into the document

P 134. Add: “promote ParkCare” into the first sentence under “Future directions” (about grassland reserve management)

P 136 etc: ParkCare: Friends of Grasslands is not a ParkCare group; maybe add a statement on 134 to replace this throughout the grassland Nature Reserve entries. Although FOG also promotes conservation of grassy ecosystems.

Appendix 1: Table of Actions

P 208. Add another action “Prepare and implement works plans in conjunction with stakeholders (ParkCare groups, neighbours etc.) on a rolling three year program (or whatever)”

P 208, action 1: add text “Prepare and implement management guidelines….”

P 209: Fire: add another action: “Support collaborative research into the different outcomes of cool burns (often called cultural burns, but this has a different connotation) with more generally applied higher intensity burns”

P 201, action 35. Add text “Rehabilitate damage to creeks …. and protect creeks … from overland flow which leads to further erosion” (see Sharp, report to the CSE e.g. Callum Brae NR)

P 210, action 42. Add text: “support existing cultural practices” (i.e. not just the development of policies)

P 213. Add action: “Commitment to prepare and implement works plans – prepare all within 3 years.”

P 225. Glossary. It might be useful to include an explanation of the term IUCN and the relevance to the protection and management of units within CNP. Also a definition of the terms “ecosystem” and “biodiversity”.

Attachment B: Learning from traditional custodians

We suggest that an additional section be added Chapter 4 titled Learning from traditional custodians or similar, giving an emphasis in the plan on how non-Indigenous people can gain from learning from Traditional Custodians. Text that might appropriately be included in such a section includes the following:

CNP offers opportunities to learn about the Ngunnawal, Ngunawal and Ngambri and other traditional custodians, their culture, lore and spiritual beliefs. In 1911 Aboriginal people were expelled from Canberra, but now many Indigenous people live here and have a strong connection with their land. More and more their traditional land management practices, in particular their use of cool burning, are being used to manage CNP More importantly for the broader community, their sharing of their language and culture gives non-Aboriginal people many insights into nature but also a greater understanding of non-Indigenous culture. 

In particular, many professional land managers and voluntary land carers have had the opportunity to receive knowledge from traditional custodians. They have reported that this has given them greater ecological insights and helped them to understand the importance of fire and other forms of traditional land management. In addition, they reported that contact has enriched their understanding of Indigenous culture, lore and spiritual beliefs and allowed them to reflect more deeply on their own cultural and spiritual beliefs.

This section should refer to the Uluru Statement from the Heart which will likely highly impact on the place of Indigenous people in our community and in particular on CNP where there remains a strong traditional connection with land. CNP may provide ways to explore how a voice, treaty and truth telling may play out.

Another area that could be covered in this section relates to signage promoting greater understanding of traditional cultural and spiritual beliefs. A very powerful addition would be create signs that make liberal use of local traditional languages, e.g. Ngunnawal, Ngunawal, Ngambri and Ngarigu.