Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Fire Management Plan
Parks and Conservation Service
GPO Box 158
Canberra, ACT 2601

Dear Sir/Madam

Regional Fire Management Plan 2019-2028 - Draft

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 following comments relate to bushfire fuel management in areas where bushfire asset zones overlap or adjoin native vegetation areas with high conservation values, especially grassy ecosystems, and including areas both in reserve and off reserve (including urban open space, rural leases and road easements).

FOG generally supports the approach taken in preparing the latest draft management plan, especially the extensive consultation that has occurred and been incorporated in respect to ecological values and Indigenous fire management practices. FOG recognises that the plan is undertaken at a broad level and all the methods used have an appropriate application.

1.       Applying fuel reduction techniques in areas of high conservation value

Biomass reduction is a key management factor for fire management. It is also a key factor for retaining biodiversity in grassy ecosystems. Retaining outcomes for conservation and for fuel management are compatible when there is proper consideration of the requirements of both, in terms of how biomass reduction is undertaken and timing of biomass reduction. Continued research and monitoring of ecological outcomes of burning at different intensities and frequency is strongly supported. Bush fire fuel management techniques that support ecological resilience in native plant communities are more likely to support the retention of soil and fuel moisture in the landscape and reduce fire risk.

Therefore, implementation of the Draft Regional Fire Management Plan 2019 2028 should consider which bushfire fuel management techniques best support ecological resilience in native plant communities in high qualities conservation areas on a site by site basis. For example, how do individual methods affect the capacity of a site to retain soil and fuel moisture in the landscape? Loss of fuel moisture is recognised as one of the key determinants of fire risk.

Grazing by introduced herbivores may also detrimentally alter the structure composition and functions of native plant communities. These shifts may lead to weed invasion, loss of key native perennials and increasing probability that alteration of microhabitats will result in loss of soil and fuel moisture undermining ecological resilience and increasing fire risk. It is important not to re-introduce grazing into areas of native plant communities that have not been grazed by domestic stock for long periods of time.

Similarly, mowing may compromise ecological resilience and soil and fuel moisture retention in native plant communities through compaction, vegetation cut height, and weed seed contamination. This favors the establishment of weeds like African Lovegrass (ALG), an ecologically transforming weed and highly flammable perennial which poses a high fire risk. On the other hand, in some situations properly applied mowing may be ecologically very beneficial in controlling or containing invasive species and encouraging distribution and abundance of native species.

In addition, prescribed fuel reduction burning when it is not tailored to the ecological needs of native plant communities increases the probability of reducing the ecological resilience of native plant communities to fire.

On the other hand, ecological burns and indigenous burning practices are strongly supported by FOG enhance the ecological resilience in native plant communities. Current case studies that are exploring and applying these techniques in urban areas to grassy ecosystems should be encouraged and extended so they can inform wider use in regional areas at scale.

2.       ACT Bushfire Management Standards

FOG believes that it is critical to apply the recommended standards to strategic fire advantage zones to ensure there is full capability for bushfires to be extinguished without compromising people, infrastructure or conservation values. Ultimately review of successful implementation of the strategy needs to be based on how the strategy achieves the ultimate goals of fuel reduction, fire preparedness and protection of assets including conservation values within sites and across landscapes, particularly in any new development areas. FOG will continue to advocate for the highest standards to be applied to protect and enhance high conservation areas, such as Kama Nature Reserve.

3.       Application of adaptive management

Ongoing monitoring, evaluation and application of cultural indigenous burning techniques and ecological burning techniques which support the ecological resilience of native plant communities and their capacity to preserve soil and fuel moisture should continue to inform government-led bushfire fuel management practices. FOG urges that better resources be given to monitoring and evaluation as  part of the Regional Fire Management Plan.

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

5 May 2021