Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....


Mr Andrew Smith

A/g Managing Director, Planning, Urban Design & Projects

National Capital Authority

GPO Box 373

Canberra ACT 2600


Dear Mr Smith


Submission: Lake Burley Griffin and Adjacent Lands Draft Heritage Management Plan


I am writing to submit comments on the Lake Burley Griffin and Adjacent Lands Draft Heritage Management Plan, March 2009.


Friends of Grasslands (FOG) is a community group based in Canberra and region that aims to:

FOG represents more than 200 members that include professional scientists, landowners, land managers and interested members of the public.


The relationship of FOG to the lands concerned


FOG is especially concerned to see the restoration and conservation of the nationally threatened species and grassy ecosystems that exist on the shores of Lake Burley Griffin. In our view the Federal Government through the National Capital Authority (NCA) has a particular responsibility and opportunity to demonstrate excellence in its management of these biota on lands under its jurisdiction, including best practice in achieving the objectives of the Environment Protection and Biodiversity Conservation (EPBC) Act 1999 for the conservation of attributes of listed national environmental significance and other values on Commonwealth lands.


On 4 February 2009, a partnership agreement was formed between FOG and the NCA that focussed on FOG’s support for NCA conservation of grassy ecosystem lands with appropriate expertise, volunteer labour, and public awareness activities. Thus far in 2009 volunteer work parties have been held to commence fine-scale weeding of ecologically significant portions of major grassy ecosystem sites at Yarramundi Reach and in Stirling Park. A further four volunteer events to help conserve these sites are planned later in 2009, and more in 2010.


FOG’s comments here on the draft plan are based on our concern for conservation of the significant natural values of these lands, our partnership with the NCA, and practical actions to enhance management.


General comments


FOG welcomes the preparation of this Heritage Management Plan (“the Plan”) as a key tool for enhanced management of the Lake and adjacent lands. Such a plan is a key pre-requisite for considered, long term and efficient conservation of the values concerned, and we support the NCA in this endeavour.


We believe that this draft plan could be enhanced by more fully (than the simple listings in sections 2.4) explaining its relationship (in terms of precedence, implementation mechanisms, work plans and funding) to a number of institutions as detailed here:


a)        National Capital Authority Environment Policy 2003. We consider that the Plan should refer to the Policy. Further, given the heritage values detailed in the Plan, the Environment Policy should be amended to more explicitly refer to conservation of the heritage values detailed in the Plan, such as the significant natural values that are currently not cited;


b)        National Capital Plan. We consider that the relationship between the Heritage and the National Capital Plans should be explained in greater detail given a number of apparent conflicts. In particular, we believe that the National Capital Plan should be revised to better incorporate conservation of the natural and cultural heritage values identified in the more recent Heritage Plan, including more appropriate land use zoning for sites with grassy ecosystems;


c)        1998 Memorandum of Understanding between the [then] National Capital Authority, Department of the Environment, and Environment ACT for consistent and co-ordinated conservation management strategies for threatened species and ecological communities;


d)        Conservation Management Plans prepared by Sarah Sharp in 2009 sites managed by the National Capital Authority:  Yarramundi Reach Grassland; Stirling Park Woodland; Guilfoyle St Grassland; and Lady Denman Drive Grassland; and the


e)        Annual NCA work planning and budgetary processes structured yearly over the next 5 to 10 years.


We note that government decisions in past years appeared to have resulted in changes in the financial and human resources available to the NCA to effect its management of these lands, and that in a number of instances, such as the 1998 Memorandum, previous commitments to enhance management of heritage values have not been fully implemented. FOG urges the NCA to consider how to secure a more consistent approach to conservation of these values. Two options that the NCA could consider are:


a)        Including in the Heritage Plan more detailed work schedules and cost estimates to underpin the Federal Government’s budget decisions, including the employment of dedicated land management staff; and


b)        Entering into long-term contracts for the management of key sites with third parties, such as ACT Government agencies or private contractors.


Lastly, we note the National Capital Plan’s policy to “create a diversity of landscape and use zones which are integrated into the landscape,” and consider this policy should be advanced by designating particular areas where exotic vegetation is to be systematically removed and indigenous flora restored to conserve natural values. These should include:

General Conservation Policy comments:


Rowing course, Westlake. FOG notes the proposal to extend the rowing course at Westlake. We urge the NCA and Federal Government to rule out support for any development that would result in changes to the Lake’s edge at Yarramundi Reach (consistent with Policy 1.6.4) that impacted on the grassy ecosystems at this site. If such a development were to be formally proposed that impacted on the grassland site, FOG would take all appropriate third party measures to promote conservation of the site under the EPBC Act 1999.


FOG is particularly concerned that unmanaged runoff from roads and lands outside NCA control at Stirling Ridge and Yarramundi Reach is causing weed infestations of drainage lines through these ecologically significant habitats. We urge that this Plan be amended to provide for appropriate, small retention basins to be constructed on disturbed lands (eg. on roadside verges) to trap and filter out weed seeds, silt and nutrients before runoff enters the ecologically significant sites. The priorities in our view are Haines Creek at Stirling Ridge and the two unnamed gullies at Yarramundi Reach either side of the Aboriginal cultural centre.


Policy 1.2. FOG strongly supports nomination of identified heritage values to the Commonwealth and National Heritage lists to formalize their conservation under federal law.


Policy 1.6.3 on maintaining the water level of the Lake we do not support if the opportunity exists to reduce Carp populations by seasonally stranding and desiccating their eggs.


Policy 1.6.6 (and C7-1.3) on conserving the “historic” plantings of deciduous trees around the foreshores we oppose in relation to the four riparian sites listed above, where we propose systematic removal of exotic vegetation. These sites are relatively small or obscure, and removal of deciduous trees in these places would not detract from the intention of this proposed policy, and would contribute to Policy 1.7.1 in enhancing “the contrasts between the formal and informal landscapes, and native and exotic vegetation.” There are very good reasons for removing this exotic vegetation at these sites (consistent with Policy 1.11):

We note in particular the detrimental impact of exotic flora at Attunga Point, where it is invading the Button Wrinklewort population, and at Yarramundi Reach, where extensive fallen timbers and thickets harbour pest animals and invasive weeds. Ornamental planting of willows at Yarramundi Reach in the small remnant of endangered Poa wet grassland ecosystem should be removed as a priority.


Policy 1.7.5 on managing new development at Stirling Ridge and Attunga Point (and other ecologically significant lands like the Yarramundi Reach and Guilfoyle Street grassland): we strongly support the conservation of the “natural values of the landscape, topography and vegetation”. We urge the Plan and the NCA to go further and rezone the ecologically significant portions of these lands, and those interconnecting areas that may reasonably be conserved, from “National Capital Purposes” to “wildlife refuge” under the National Capital Plan (consistent with Policy 1.11). “Wildlife refuge” is a slightly antiquated concept and a designation more akin to (and integrated with) the ACT’s “Nature reserve” designation would be more appropriate. In our view any proposed development of existing habitat of threatened species and ecological communities is unlikely to succeed under the EPBC Act, and it is now time to consider less ecologically damaging options for the site of a new Prime Minister’s residence.


Policy 1.11 on conservation of the natural heritage values of the study area is strongly supported by FOG. In our view Stirling Ridge and Yarramundi Reach should be restored by the Federal Government to be leading examples of the conservation of threatened species and grassy ecosystems. We offer more detailed comments on how this could be better achieved below. The first priority is to stabilize and restore the high quality remnant habitats and threatened species on these NCA lands. Subsequently, at these sites we urge the NCA to go further and consider reintroduction of locally extinct species to these sites, including, as appropriate, threatened grassland plant, insect and reptile species. We also urge that the scope of this Plan be expanded to incorporate the conservation of two other NCA managed natural temperate grasslands at Lady Denman Drive, and also at Kintore Street, both in Yarralumla.


Policy 1.11.3 needs to include conservation of aquatic fauna as an action, not just vegetation.


Policy 1.11.6 on managing contractors is urgent as FOG has observed actions on these NCA lands that do not fulfil the proposed policies. For instance, at Yarramundi Reach, a pipe installed from the Aboriginal cultural centre to an ecologically significant drainage line has become a corridor for Chilean Needle Grass invasion. In another example, at our recent working party at Stirling Ridge our volunteers removed Broom that was regrowing following previous, ineffective treatment. Management of these sites through contractors creates a higher risk of ineffective use of resources or damage through ignorance or inadequate supervision. One off interventions by contractors militates against the development of land management knowledge and expertise, and application of adaptive management, preventing the full evolution of a land stewardship ethic. FOG urges the NCA to consider all possible mechanisms to reduce these risks, such as through direct employment of land managers or long term contracting of management activities to an organization with appropriate expertise.


Policy 2. FOG urges the NCA to add additional actions for interpretation of the significant grassy ecosystem values of the NCA lands. These grassy ecosystem sites are some of the most accessible and rich in Australia and represent a key opportunity to promote the value of this flora and fauna. Further, we consider the current lack of signage at these sites contributes to their degradation. For instance, this month a FOG member observed a sporting activity occurring in part inside the fenced enclosure for the Button Wrinklewort at Attunga Point. When this was discussed with the organizer, she said she was not aware of the value of the site, and they had not been advised by the government agency that had approved their event to avoid the threatened species habitat. We consider that better interpretation could avoid unnecessary impacts like this.


Policy 3.1. FOG supports public access to the Lake environs, but calls for action to channel this to appropriate sites (consistent with Policy 3.4). At Yarramundi Reach the grassland is being degraded through off-road vehicle access and this should be controlled as a matter of priority by restoring the fence on the western boundary. At Attunga Point we would like to see refocussing of public access to the more ecologically disturbed sites so as to restore and re-link the best remaining areas of natural habitat. On Stirling Ridge we call for a consolidation of pedestrian and cycle access tracks to reduce damage to indigenous vegetation. A policy on practices to reduce damage to the indigenous vegetation from public events (e.g. orienteering, lakeshore, and race events) should be developed so that event organizers receive consistent advice from different public agencies.


Policy 4.1.5 on site specific plans is confusing and should be reworded so that the preparation of these strategies is not contingent on “assessment of any proposed impacts.” To manage the natural heritage values detailed management plans are required now. The values of these sites face immediate threats, such as from weed invasion, and plans developed with technical experts are needed to direct urgent conservation actions. FOG welcomes the NCAs recent work to draft more detailed management plans for the Stirling Ridge, Yarramundi Reach, Lady Denman Drive, and Guilfoyle Street sites. We look forward to the NCA’s finalisation of these plans, their formal adoption and publication to guide investment and management actions to conserve these ecologically significant sites.


Policy 4.3 should be expanded to provide also for capacities to better manage natural heritage values.


Policy 5.2 on monitoring the effectiveness of the Plan is welcome, but we consider that it could be enhanced by suggesting effective mechanisms for this reporting. FOG would favour the inclusion of a section within the NCA’s annual report that details actions to conserve the identified heritage values. This may have the advantages of mainstreaming heritage management and consolidating the reporting work load of the NCA.


Policy 6.3 should also provide for engagement with organizations with expertise in natural values of these lands, such as FOG.


Policy 6.4 for regular collaboration between the NCA and ACT Government agencies is welcome and strongly supported by FOG. We note that the lands with natural values occur on sites with a mixture of ACT and NCA land tenures so that effective collaboration and consistent management is essential if the threatened vegetation community and species are to survive. We also observe that previous agreements for inter-jurisdictional collaboration do not appear to have resulted in effective on-ground conservation, as indicated by the weed infestations on both ACT and NCA lands in Stirling Park and between Lady Denman Drive and the Tuggeranong Parkway. The ACT Government has staff with extensive land, ecological, and fire management expertise that may complement the NCA’s strengths. FOG urges the NCA and ACT Government to consider how to better implement the 1998 Memorandum.


Where we have additional comments on the specific proposals in the contributing volumes we detail these below:


Volume 2 - Stirling Ridge and Attunga Point


Component 3. Westlake Settlement site.

Components 4 & 5. Button Wrinklewort habitat and grassy woodlands.

Component 6. Remnant grassland. We strongly support the conservation measures proposed and urge this Plan be updated with the more recent ecological management actions proposed in the management plan recently prepared for the site (see General Comments point d) above). We further urge that efforts are made to restore indigenous vegetation across broader areas of Attunga Point, including removal of exotic lake shore vegetation and reconnection to the grassy woodland on the other side of Alexandrina Drive to the extent that is feasible.


Components 4 - 6. Grassy ecosystem conservation.

Volume 3 - Yarramundi Peninsula


Component 4. Temperate grassland.


Volumes 1 & 4 - The Lake & Scrivener Dam


Section C, Component 1. Management Issues, Condition and Integrity. In our view this section misses two key issues.


1.      Aquatic biota. Although not strictly within FOG’s ambit, we are surprised that the Plan does not appear to consider means of enhancing the Lake as habitat for indigenous biota and discouraging weeds and pest animals. The Lake environment is in a very poor ecological condition as an artificial storage managed in a manner that does not encourage indigenous biota. The Federal Government has adopted a number of strategies and policies for the restoration of the aquatic environment in Australia, and the Murray-Darling Basin in particular, that should be reflected in this Plan, eg. Native Fish Strategy for the Murray-Darling Basin 2003-2013. Some obvious measures that should be considered include:


2.      Blue-green algae. Algal blooms are clearly a major issue in lake management and use and must be included in the plan. The advent of warmer temperatures and changed hydrology with climate change will only exacerbate the problem. The NCA should consider what role it can play in the management of the catchment to reduce the problem to the extent possible. Policies for reduction of diffuse nutrient pollution and greater use of artificial wetland filters may be two approaches that could help mitigate algal blooms.


Component 9. Spinnaker Island.


FOG strongly supports the proposed actions to manage the island largely as a grassland habitat. After securing conservation of the extant grassland flora, we urge consideration of the opportunities to use the island for reintroduction of locally extinct grassland flora and fauna species, where appropriate, given the opportunities to manage the site with minimum impacts from herbivores and visitors.


Thank you for the opportunity to contribute to development of the Plan. FOG would appreciate further participation in the development and implementation of these policies.


Any further correspondence should be directed to the President of FOG.  More information on the comments in this submission can be provided by Jamie Pittock (


Yours sincerely





Isobel Crawford

A/g President


28 May 2009