Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Senior Policy Officer (Natural Resource Management)

Sustainability Policy and Programs

Department of Territory and Municipal Services

GPO Box 158




Dear Madam/Sir


Draft ACT Weeds Strategy (July 2007)


Friends of Grasslands (FoG) is writing to provide comments on the above. FoG is a community group dedicated to the conservation of native temperate grassy ecosystems, such as grasslands and woodlands. FoG is based in Canberra and its members, numbering over 200, include professional scientists, landowners, land managers and interested members of the public. FoG advocates, educates and advises on matters to do with conservation of grassy ecosystems, and carries out surveys and other on‑ground work.


FoG supports the ACT Government in revising the existing (1996-2006) Strategy. Comments on the draft Strategy are attached. Many of the comments on text, and suggestions, seek to improve the clarity and coverage of the document. In summary, FoG's view is that:

Thank you for providing an opportunity for FoG to comment.


Yours faithfully





Kim Pullen


14 September 2007




FoG comments on draft ACT Weeds Strategy (July 2007)


General comment


The use of the terms 'weed control' and 'weed management' is both inconsistent and confusing throughout. 'Control' implies a high level of management (to eradication), whereas 'management' implies a broad range of activity. FoG suggests the use of the general term 'weed management' except where eradication/suppression/containment is considered.


Specific comments


1.1 Context and Purpose

Threatened ACT grasslands and grassy woodlands, in particular, are further threatened by existence and spread of weed species, with at least 14 relevant weedy grassy/herbaceous species declared under the Pest Plants and Animals Act 2005, not to mention woody species. Weed management in and adjacent to such threatened ecosystems should be a priority.


Continued and long term investment by the community as volunteers in weed management is unsustainable without considerable training, resourcing and retention of good will. One way to retain good will would be for the ACT government to show its commitment to weed management by increasing expenditure significantly, and to show success through management actions.


Details about specific success (or otherwise) against the previous Strategy would have been useful in commenting on its replacement, especially given the apparent lack of success, including on public land.


The unique position of the ACT as the 'hole in the doughnut' - within NSW - is an important issue in terms of responsibility, strategy, implementation and monitoring.


Somewhere early on in the Strategy it would be helpful to mention the need for restoration - especially of conservation sites - as part of weed management.


The initial mission statement is also included in the list that follows from the Australian Weeds Strategy (at point 3).

As well as 'authoritative guidance' the Strategy should also seek to provide leadership by the ACT Government, which should flow through to implementation.


1.2 Achievements

None of the achievements include a reduction in weediness. Although FoG realises that a strategy provides a framework and that actions are often about process (consultation, legislation, planning, coordination, priority setting, mapping, extension ...) towards outcomes, a decade of activity should have been able to deliver some advance in on-ground weed management. An ongoing concern is that some actions (e.g. mapping of species such as Chilean needle grass) will be wasted unless there is sufficient funding and willingness to manage weeds.


1.4 Support for ACT Weed Programs

Beyond its 'key role in guiding a strategic approach' FoG suggests that the ACT government should also lead by example through its weed management practices, on all lands where it has management responsibility including nature reserves, urban open spaces, roadsides, utility corridors, horse paddocks and pine plantations.


FoG agrees that effective coordination and integration, and cross-tenure/border approaches are critical for success in weed management.


One type of landholder that is not specifically identified in the Strategy is the householder. Weeds which threaten grassy ecosystems (e.g. Chilean needle grass and serrated tussock) are increasingly found on nature strips. Other weeds that overwhelm management in some seasons, and which may or may not be declared (e.g. Paterson's curse, cape weed), have almost replaced front 'lawns' in some places. This is a responsibility that may not be understood. There is an excellent opportunity to raise awareness and seek further support from the general community on weed management issues through encouragement to report concerns and 'do the right thing' at home; especially in suburbs adjacent to reserves. FoG notes that TaMS is already working cooperatively with Friends of Aranda Bushland on the 'Go Wild in Your Own Backyard' project; similar approaches could encourage informed householder weed management.


'Continuing support for on-ground weed management' is indeed a long term challenge. Engaging volunteer effort in particular will rely on a ready and willing 'workforce' - one that is trained, resourced and supported, recognised, used where there is some chance of success, and definitely not involved in areas that may be lost through later decisions e.g. road or other developments.


1.5 Weeds Working Group

FoG is keen to see CCSERaC at least continue to be represented on the appropriate Group. 


1.6 About Weeds

FoG suggests that the impacts on native animals (especially threatened species) of weed incursions is made clearer here; the last dot point in para 2 is not explicit enough.


1.7 Weed Spread Pathways

From FoG's observation (e.g. through weed mapping) apart from slashers, other local government related machinery/activity is also to blame for spreading weeds such as establishing fire trails, along pipelines, around street lights and weirs across water courses. FoG is concerned to have observed Chilean needle grass apparently being imported in seed mixes used in ACT Government landscaping (e.g. on roadsides).


Unfortunately weeds have also spread, at least in the past, from inappropriate but quite deliberate plantings - sometimes before potential weediness was understood.


2.1 Economy and 2.3 Health and Public Amenity

There is crossover between these two headings, and the latter could be titled 'Social' to be consistent with earlier text and more accurate. For example, recreation (currently at 2.1) should be at 2.3, and horse pasture weediness (at 2.3) could be at 2.1.


The point about active summer growth of ALG and need to manage biomass is not entirely clear; many species of native grass are also active summer growers.


3.1 Legislation and Policies

As already noted, some weeds of suburban blocks - e.g. Chilean needle grass and serrated tussock - which are both declared under the PPA Act (prohibited and must be contained) and are WoNS - should be being managed by householders. This would need very good public information and encouragement for action. Without care such weeds will get beyond management across the ACT.


Agreed priorities for weed management identified in strategies such as Action Plans (e.g. for grassland and lowland woodland conservation) should be built into weed management planning.


3.2 Weeds Management Roles and Responsibilities

An 'environmental duty of care' for all landholders is only of value if it is enforced. Roadsides often show where local governments do not lead by example, and this tends to 'let off' other land managers who are not managing their weeds. As already stated, the ACT government should seek to lead by example in managing weeds on its own lands. This will require adequate funding, in the long term.


3.3 Involvement in Collaborative Approaches     

Beyond 'Consistent weed control priorities and cross-border communication', the ACT government and other relevant stakeholders (e.g. land managers on borders) need to take cooperative action to manage weeds effectively, at the landscape scale.


4.1.1 Identifying Priority Weeds

Declaring a species (i.e. listing it) does not go far in assisting management, particularly given 'Weeds have variable distribution and impacts, and differing biological characteristics'. The Strategy should state clearly how management actions/responsibilities are identified and communicated for priority species.


'Risk assessment analysis' must also consider potential impacts.


4.1.3 Preventing Weed Spread                                           

Containment is a real challenge that needs to be addressed practically and effectively, e.g. of weeds spread by slashing of urban open spaces and roadsides.


Useful 'criteria' such as those included under 'Eradication', should be included also under 'Suppression' and 'Containment', with examples of species where these particular approaches would be applied. All such criteria will only be useful if there is a genuine commitment to follow through once a priority is established; e.g. eradication is a very serious intention.


4.1.4 Control Methods

'Rehabilitation' is finally mentioned here, but should be earlier as it is a key to not only preventing re-infestation but recovering site values, which is especially important in areas conserved for biodiversity. This is an example where weed management is usefully integrated with general management.


It is not clear what 'spray topping' or 'spray grazing' are, and perhaps these could be included in a glossary as there will be other terms not widely understood.


A further measure that could be listed in the dot points is withholding stock/recreational animals - where there is any chance that have eaten weedy feed -before they are allowed onto areas that are not already infested, to allow weeds seeds to pass into faeces and be disposed of.


4.1.5 Community Engagement

As already noted, involving the community requires good support and goodwill, in the long term. Most certainly 'weed problems cannot be solved over night'.  Volunteer programs need to be resourced beyond short-term funding cycles, and their successes recognised, monitored and followed up. Results of short term episodes/enthusiasms exist as reminders in the landscape to individuals, groups and communities that their efforts were not valued, and their time wasted.


4.2 Monitoring and Evaluation

M&E are necessary and supported if they lead to priority action; e.g. as noted under 1.2, it is no use mapping spread without effective management follow up, and this means resources. FoG suggests that (re dot point 2) success is also reported on.


FoG also suggests that fetes might be worth visiting (dot point 4); or perhaps schools/groups could be targeted with information about species to avoid if they are intending to include a 'plant stall' in their fund-raising event.


The matters to be determined re effectiveness (a-f) could perhaps be clearer and better structured.


In the second last para, of the three dot points FoG suggests that 'attribution' is perhaps the first thing to be considered - i.e. how successful were planned actions?



Obviously, success will depend on how well the Strategy is resourced for practical implementation. As well as process steps, Strategic Actions should seek to pursue and support on-ground action.


The ACT government is not included under 'Responsibility for Action' in some places (e.g. Strategic Action 1.1.1, 1.1.2 and 1.3.1) where it should be. Similarly, 'all stakeholders' could be included elsewhere where they have not been (e.g. at 2.2).


Sometimes difference between state Performance Measures are a bit subtle (e.g. at 2.3.1), or perhaps not quite in the correct place (e.g. second one at 1.3.1 maybe should be at 1.3.2) or are not quite specific enough (e.g. perhaps include one at 2.1.2 on the level of community participation). It will be important that the PMs are sufficient to drive objective reporting via the LMWWG and the WAG.