Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


The Conservator of Flora and Fauna



Draft Action Plan to Prevent the Loss of Mature Native Trees


Dear Sir/Madam

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 native 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.

1. Recommendations to strengthen the action plan to reduce the threatening process

FOG is pleased that the Action Plan is close to finalisation and implementation, particularly as FOG was extensively involved in the preparation and submission of the nomination to the Scientific Committee. The importance of the listing as a key threatening process is strongly supported by the report that over 6% of mature native trees (MNTs) were destroyed in the landscape over a five year period, particularly as a result of greenfield development. And this is in the context that more than a quarter of all bird species recorded at trees of varying sizes were exclusively recorded in trees with girth greater than 80 cm diameter above breast height (DBH) (Le Roux et al.(2014). The current clearance rate of MNTs in the ACT is clearly ecologically unsustainable.

The stated objectives explicitly identify the key processes required to protect MNTs, their habitat and to ensure recruitment. However, we do not believe that the actions are adequate to ensure the objectives will be fulfilled. With no timelines or priorities provided in the plan, there are few standards or targets to ensure and monitor implementation.

FOG believes the following actions, together with timelines for their completion, need to be included:

1.       Within a defined period of time (e.g., within one year for unleased urban land), identify, measure and describe habitat and register mature native trees with 50 cm DBH or greater on leased and unleased land. Include roadsides and institutions such as the universities, schools and hospitals. See also recommendation 7, to involve community in achieving this action.

2.       Register all naturally occurring trees over 100 cm DBH as ‘exceptional’.

3.       Ensure all registered and exceptional trees and their habitat are protected prior to any planning proposals for greenfield or other development.

4.       Identify transparent criteria to value MNTs to ensure the penalty cost of illegal removal of such trees is prohibitive to achieve compliance.

5.       Develop conservation management plans and ensure they are implemented to protect MNTs and their habitat and their context within the broader natural landscape. 

6.       Provide financial and logistical assistance (including expertise) to lessees (urban and rural lessees) to ensure areas are managed to improve recruitment and protect existing mature trees and associated biodiversity.

7.       Involve community in citizen science actions including survey (identification, condition and habitat attributes) and monitoring of threats and recruitment and ensure that the data are collated and maintained for regular analysis of change.

2. Specific comments

The preamble is an excellent section that elucidates the ecological basis for the importance of mature native trees, including recognising that abundance and diversity of those values increases with size/age and habitat complexity (e.g. foraging substrates) and senescence (e.g. development of tree hollows). However, the ecological principles are not adequately reflected in the actions, that such trees require additional protection under all but exceptional circumstances.

There needs to be more reference to the importance of connectivity between trees, not as single entities. While single mature native trees (MNTs) have important biodiversity values, groups of MNTs have a higher ecological value, and are more resilient to stressors. The values of mature trees that provide linkages within and across remnants of trees across the landscape need to be.

Protection of trees

Disincentives must be strengthened, to significantly reduce the clearance of MNTs and regenerating trees. Given only one in 10,000 trees reaches a size of 100 cm DBH (and these are likely to be of the order of 200+ years old), all trees of this size should be retained, and only under exceptional circumstances permission given for their removal, with a high penalty value placed on their removal, to mitigate against their destruction. The next generation (50 cm DBH and larger) need to be recognised as providing the hollows of the future. To achieve this will require strong facilitation and cooperative agreements between government agencies, landholders, developers and utility companies.

Protection of key trees and their habitat needs to be assured before planning decisions are made, not as an afterthought or being viewed as an impediment to development. These actions should be available to provide guidance to all stakeholders, including community, government and any on-site workers.

Protection of individual trees and clumps should extend beyond the canopy edge, for safety, and to reduce damage to the trees, and to facilitate natural regeneration. Offsetting must not be used without considering the age cohorts of trees. For instance, it should not be possible to remove most adult trees (>50 cm DBH, which will become MNTs) and replant with saplings, thus creating a demographic gap. Management actions need to be defined for these areas, such as optimal herbage mass management, that retain the groundlayer, and prevents compaction and erosion. 

We support the inclusion of dead or dying trees, and to utilise the definitions of a regulated tree and exceptional trees to protect and retain mature trees within in the urban landscape. The same categories need to be applied to MNTs across all tenures. We anticipate that listing trees as regulated or exceptional would assist in any deliberations as to their value(s) and ensuring they are not destroyed.

Lessees and other agencies should be informed about the values of their trees, and logistical and financial resources provided if required - the burden of retention of these trees rests with society as much as individual lessees.

Infrastructure management: include how this will be managed and tree clearance or excess lopping significantly reduced. This includes not sacrificing biodiversity of mature native trees for other environmental assets such as solar farms.

Greenfield development: the majority of tree destruction is the result of greenfield development. Encouraging developers or planners to undertake mitigative measures is manifestly inadequate. The priority needs to be to identify and protect mature trees prior to planning and development options are considered. Clear and explicit actions need to be identified to reduce the threat of clearing as a result of planning that compromises the future retention of MNTs in the urban landscape.

Non local native species: Not all mature native trees are equal. There is a need to identify that some mature native tree removal may be required, for example the removal of introduced Blue Gums which have very high fire risk, high regeneration rates and invade native remnants. Other trees clearly at times require removal or pruning due to safety concerns. Some trees, for example, Silky Oak (Grevillea robusta), grow very quickly above 12 m in height, and may be planted in or on the verge of residences where they cause significant problems with utilities. Proactive planning should ensure that trees in the urban landscape are retained within a site in such a way that they are not later identified as causing safety concerns. As identified above, this should include ensuring an area larger than the canopy projection is protected from disturbance and compaction, and may include additional plantings.


p. 26. update reference to the CNP mgmt plan: ….the 2020 draft management plan t for Canberra Nature Park includes a commitment to…. “

p. 30.  “Prescribed burns is a valuable area for future research” – Change to active tense: Research relating to frequency and effectiveness of prescribed burns should be implemented.

Offsetting: An existing 100 centimetres DBH tree should be considered to be ‘worth’ more than 20 trees with 80 centimetres DBH, based on likelihood that only one in 10,000 trees reach that size. This should be the value against which the monetary compensation should be calculated.


FOG is concerned that the majority of the actions require the development of actions (e.g. develop policy, identify criteria etc.), and omit identification of specific guidelines (actions) that will achieve those aspirations. We urge that more emphasis be given in the action plan on how and when the actions to mitigate against their loss will be undertaken, including timelines and priorities and how government will facilitate this across all tenures. The implementation section may be strengthened by linking it to other existing plans, strategies and programs that help achieve the actions for MNT, particularly the Woodlands Strategic Plan and associated action plans. Stakeholder input into the development of criteria for the classification of exceptional and registered trees is recommended.

Action 7. Include ‘monitor to ensure that reparations for tree damages are completed’

Action 11.  Actual standards and targets are needed for both retention and recruitment in greenfield sites.

Action 15. Mature trees need to be mapped and protected, so that planning is undertaken to ensure their retention, so that only in very rare and unusual circumstances would they be removed. There need to very explicit criteria and targets for both retention of mature trees in a biodiverse, connected manner, and explicit criteria for areas of recruitment into the future.

Action 21. Increased planting of trees is encouraged, but needs to be kept out of inappropriate habitats, including in natural grasslands or particularly diverse secondary native grasslands.

Losses need to be offset by planting local native species characteristic of the particular habitat type and appropriate to the site, particularly those that provide the highest level of habitat value, and following other ecological principles (associated plantings, weed control etc).  

Financial and logistical assistance: We urge that government provides financial and logistical assistance (including expertise) to volunteers, agricultural managers and all relevant government and non-government land managers, as well as residents of urban properties. A change of language from should be provided into Provide financial and logistical assistance… will promote retention and condition of mature native trees.  Extend facilitate expert staff to assist volunteer groups in preparing applications for .. funding ‘and providing expert advice on best practice management of weeds and other issues’.

Identify that fallen timber should be retained and cut timber added as habitat wherever possible.

The cross references to other key action plans or strategies are very useful inclusions, however, we would hope that these would be applied consistently across all the actions. For example, Action 16 is a key factor in the Native Woodlands Conservation Strategy. This would help with understanding the links between different documents, as well as ensuring correlation between reporting and implementation of similar actions across multiple documents.


The draft action plan is very comprehensive, in terms of ecological information, threats and actions, however, there is very little information provided in the implementation section to guide how the plan will be implemented. It will be therefore very difficult to assess whether it is achieving the objectives. Proactive planning and protection, compliance checking, active management and enforcement of non-compliance are critical. We recommend the inclusion of information on priorities for implementation, including provision of timelines. Disincentives need to be effective in preventing noncompliance. These all need specific actions identified in the plan as to how they will be undertaken.

Implementation will require cooperative land planning and management to take into account the conservation requirements of MNTs, both within and outside the reserve system.

The data in Table 1, p. 14 paint a significant level of clearance of MNTs, particularly but not only, in the urban environment. A 6% loss in a five year period between 2015 and 2020, given the context of the woodland strategy and listing of Box Gum Woodland as critically endangered, is unacceptable. Unless the actions are strengthened and implemented, these clearance rates will not decrease.

FOG representatives are happy to discuss our concerns further if required.

We thank you for the opportunity to provide input into the draft Action Plan to Prevent the Loss of Mature Native Trees.


Yours sincerely



Professor Jamie Pittock

27 May 2022