Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Environment, Planning and Sustainable Development Directorate
Conservation Research
GPO Box 158
Canberra    ACT    2601

Dear Sir/Madam

Reference: Draft ACT Native Grassland Conservation Strategy and Action Plans, March 2017

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-east 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.

FOG welcomes the release of the Draft ACT Grassland Strategy and Action Plans March 2017 as it demonstrates the ACT Government’s commitment, now over twenty five years, to maintaining and sustaining Canberra’s grasslands. FOG also applauds the inclusion of rocky, sub-alpine and montane grasslands within the scope of the Strategy and Action Plans. The document illustrates to some degree ongoing research, improved mapping, better grassland management and documentation, and community involvement.

FOG believes that Canberrans can be proud of their achievements in their conservation and management of ACT grasslands. A high level of resources has flowed to support these grasslands from the ACT and Commonwealth governments, and many other stakeholders, including community groups such as ourselves, have provided extensive in-kind and voluntary resources to improve the ACT’s natural grasslands. FOG particularly applauds the recent collaborative work between ACT Government and other organisations such as Greening Australia to enhance habitat and initiate management practices based on the recent research.

However, FOG believes that the Strategy and Action Plans could be significantly improved, as follows:

1.       Definitions: Clarify and define the terms used for the different types of grassland identified in the Strategy, including the endangered community ‘Natural Temperate Grassland’, identify how they are related and use terminology for these types of grassland consistently. In FOG’s view the terminology should clearly state how the term used in the Strategy and Action Plans may differ from that used in the EPBC Act.

2.       Current situation: Update and broaden the description of the current situation on which the future actions in the document are based by

·         including a summary table of sites and key attributes such as size, Conservation Significance Category and presence of endangered species. To the extent that information is not known, this should be a research priority;

·         including more recent findings of research, surveys and on-ground activities that has taken place at ACT government management sites;

·         including findings of the same undertaken by other stakeholders such as universities, other Government agencies (both State and federal), community groups, Canberra Airport Group and rural lessees and in accordance with traditional Aboriginal land management practices, both locally and in the broader Canberra region; and

·         reflecting adequately on the enormous efforts and achievements to date by universities, research organisations, not-for-profit and community groups.

3.       Expand the scope: Expand the actions in the Strategy and Action Plans so that it has a wider focus and is more aspirational, for example:

·         include further actions that are not identified or not elaborated in the document, so that it reflects what all stakeholders can achieve and includes actions that might enhance restoration of grassland vegetation or expansion of dependent species across the broader landscape;

·         recognise that many stakeholders will be involved in implementing the Strategy and Action Plans and that the actions identified will guide those groups, for example in identifying research projects, opportunities for on-ground work, or facilitating educational opportunities; and

·         ensure the document is sufficiently comprehensive so that the information it contains can be used to lobby for resources to ensure priority actions are undertaken.

4.       Conserve all sites: Ensure conservation and protection of all sites that meet the criteria as the endangered community under the Nature Conservation (NC) and EPBC Acts, regardless of tenure – including Category 3 sites. The aim should be to protect and manage all existing sites so that they never deteriorate to the point that they no longer are classified as Natural Temperate Grassland (NTG) sites.

5.       Collaboration: Encourage a collaborative approach between government and community by identifying specific areas in which the conservation community may be involved beyond the provision of labour for weeding, for example by establishment of ParkCare groups, workshops, educational opportunities, and by providing support to community groups undertaking such actions. Also expand on ways information is provided to the general public.

6.       Management and operational plans: Identify the need to develop and implement site management plans and operational plans for all sites, both in reserve and off-reserve.

7.       Pink-tailed Worm-lizard: Include the Pink-tailed Worm-lizard Action Plan, as it is a threatened grassland species

8.       Document presentation: Edit the document for clarity and consistency, including insertion of a summary of key actions and guidelines up front, and removal of repetition between the Strategy and Action Plans. Relegate much of the detail to background sections so that the core Strategy and Action Plans could be more concise, without losing information that will be valuable to some.

In Attachment A elaborates on these points and included a number of other concerns with the document. We have also attached a table of specific comments (Attachment B).

FOG is disappointed with the lack of community consultation to this point, and recommends that a workshop or series of workshops with stakeholders be called to expand on the Strategy and Action Plan objectives, actions and proposed outcomes.

Many people have devoted many hours in the preparation of this submission and I would like to acknowledge their dedication and commitment to ACT's grasslands.

Yours faithfully


Geoff Robertson
11 May 2017

Attachment A: General FOG comments

FOG is recommending that a workshop or series of workshops with stakeholders be called to expand on the Strategy and Action Plan objectives, actions and proposed outcomes, as occurred during development of the 2005 Strategy and Recovery Plans.

Our rationale for this is that we believe that, to achieve a stronger foundation for best management of ACT native grasslands into the future, what is needed is involvement of all grassland managers (including private lessees and government), organisations involved in grassland management in the region and community, and community groups which play an active role in grassland education and advocacy. All stakeholders should be involved in reviewing the draft Strategy guidelines, with more specialised stakeholders also involved in the review of the Action Plans. The result will be better guidelines and a stronger commitment by stakeholders.

This may require more time before the Strategy and Action Plans are finalised, but the outcome will be a far more endurable and useful document. Many of those recommendations will be equally relevant to development of the proposed Woodland Strategy.

FOG believes the following key matters should be discussed as part of a review of the Strategy guidelines. As well as these, there are a number of other issues that FOG thinks need to be included or covered more fully in the Strategy and Action Plans.


There is a number of definitional and terminology issues with the document, relating to:

·         ACT and Commonwealth legislative requirements

·         Terminology

There is a need to clarify and define the different types of grassland identified in the Strategy, including the endangered community, identify how they are related and use terminology for these types of grassland consistently (in both text and maps).

One suggestion is to modify Table 2.1 in the 2005 Strategy to relate the different types of grasslands.

ACT and Commonwealth legislative requirements

There is inadequate explanation of how the Strategy fulfils legislative requirements of the Commonwealth and the ACT listings, and whether indeed the Strategy is based on the largely non-quantified ACT criteria or the revised listing of Natural Temperate Grasslands of the South Eastern Highlands (NTG_SEH) under the EPBC Act (that has quantitative criteria that can be used to determine whether a site meets the definition as critically endangered).

Are the Strategic actions identified for remnants identified as Natural Temperate Grassland based on the EPBC listing, the Nature Conservation Act listing (earlier and elsewhere, this was referred to as NC), or a bit of both? It is unclear what types of grassland are covered in Section 2, and there is considerable repetition of information in Section 8 –Background and again within the Action Plan for NTG. The Background section gives important information on which S2-7 is based. In particular Figure 5 (P. 75) is important to give relevance to parts of Section 2. Consider combining Sections 2 and 8, or better setting out of the information concisely.

The definition given on P. 113 is neither that under EPBC or NC Acts – it is a mix of both. Again, as per above, There is a need to sort out the relationship between these two acts.

Table 2 (P. 119) only talks about the below 625 m sites, although the context is up to 1200 m. Shouldn’t something be said about the montane and sub-alpine sites too? If sites above 625 m are not the endangered community, then explain; also explain why this discrepancy with the ACT legislative definition.

Should consideration be given to making the ACT definition more consistent with the EPBC definition?


The terms grassland, other grassland, and what grasslands meet criteria as NTG are very unclear, used very loosely. Grassland includes native and exotic; native grassland ecosystems also include by default secondary/derived grasslands; natural temperate grasslands under the NC Act do not include the montane and sub-alpine grasslands. Figure 1 uses Conservation Significance Cat. 1 grasslands and ‘other’ grasslands. What are ‘other’ grasslands? They may include other NTG, depauperate grassland, montane and sub-alpine grassland, secondary grassland, exotic grassland. They need defining and placing in a glossary. It might be better to refer to what is covered in this Strategy generically as ‘natural grassland’, the NTG as only those sites that meet the NC Act (or EPBC Act, depending on what is the definition of the threatened community), and then define other types of grassland that may not now be considered native (e.g. depauperate or exotic grassland) or secondary grassland. There was a table in the 2005 Strategy (p. 21) that provided information about the relationship between grasslands. Perhaps a modified version would be warranted.

Current situation

FOG considers that the draft Development of a Strategy and Action Plans has inadequately covered certain information required to have a comprehensive understanding of the current situations, including:

·         A review of achievements

·         A summary table of sites

·         Recent findings of research, surveys and on-ground activities

·         Updated references

Review of achievements

The document should include a concise review of the current situation against the vision, goals, objectives and actions identified in the 2005 Strategy (Table 4.1). In particular, review what actions identified in the 2005 Strategy have been achieved and, for those not achieved, the reasons why.

Summary table of sites

The document needs a summary table of sites and key attributes such as size, Conservation Significance Category and presence of endangered species (as per Table 3.8, 2005 Strategy). FOG suggests this information be combined with that in chapter 2 and placed in the background section to provide context. o the extent that information is not known, this should be a research priority

Recent findings of research, surveys and on-ground activities

FOG considers that the draft Strategy and Action Plans understate what has been achieved both in research and community participation which often work hand-in-hand. Much has been achieved since the last Strategy well beyond what was envisaged at the time. In fact, some of what has been achieved was considered implausible or impossible then (for example, the development and role of the Canberra Nature Map in tracking species and providing educational, monitoring and participatory outcomes). Other work includes:

·         Significant advances in grassland management as a result of research and trials), aided more recently by considerably increased Government support for ambitious research projects (such as those being undertaken at Molonglo in landscape restoration at Barrer Hill and for Pink-tailed Worm-lizard habitat).

·         On-going collaboration between community/other not-for-profit groups and Government (ACT and Commonwealth) in restoring of native grasslands and grassy woodlands. Examples include FOG, working with the National Capital Authority at Yarramundi Grasslands and Stirling Park Woodlands, with the ACT Cemeteries Trust at Hall Cemetery, with Snowy Monaro Regional Council at several large Cooma grasslands, and with Bush Heritage at Scottsdale, while other groups work in many grassy woodlands in the ACT as well as NSW. Community groups have achieved a high level of expertise in grassland management.

·         Strong institutional and community education and advocacy for grassland conservation through the three ACT Catchment groups, the Conservation Council, FOG, Kosciuszko to Coast, NSW agencies such as Office of Environment and Heritage and Local Land Services, regional NSW local governments, the ANU and Canberra University and many community groups. The Commissioner for Sustainability and the Environment has been a strong advocate to ensure government supports continues. This illustrates that that there is strong public support for continued government finance, which is therefore unlikely to falter, and also illustrates that there is a large resource commitment flowing to grassland conservation coming from outside the ACT Government.

Other information that should be included is:

·         Identification of existing important weed trials and research and where to get relevant information (for example, off-label use of herbicides to treat African Lovegrass, Chilean Needlegrass and Serrated Tussock; information from trials of treatment of African Lovegrass by Bush Heritage at Scottsdale Reserve at Bredbo)

·         Information about work undertaken on native grasslands throughout the region. This would include various trials to establishing grasslands using scraping soil and other methods. GR

·         Research at the Australian National Botanic Gardens that has trialed the use of seed orchard techniques to create large stocks of plants for selected threatened plant species (e.g. Ginninderra Peppercress).

·         The Canberra University’s Grassland Earless Dragon captive breeding program and Tim McGrath’s extensive surveys in the Cooma-Nimmitabel-Bombala region of Grassland Earless Dragon as part of his masters’ thesis.

·         The Strategy should reflect on the commercial production of grass seeds, such as that of Ian Chivers, Native Seeds Pty, where there have been major developments leading to extensive use of suitable native grasses in pastures and in other applications such as work site remediation. This and other horticultural is making many more grassland species available and at a cheaper price.

·         Translocation as an important conservation Strategy. The Strategy mentions the translocation of golden sun moth, although fails to come to any clear view on its success. FOG has been involved in translocation of a peppercress, previously thought got be extinct, organised by Rainer Rehwinkel. These matters need to be considered more fully in the Strategy and recommendations.

·         The use of indigenous grasses and forbs in home gardens, roadside landscapes, and commercial premises and public places. Horticulture of indigenous plants plays an important role in understanding grassland plants and in our understanding of their conservation and reintroduction into remnant vegetation. They also provide the basis of the food chain and habitat for many small and declining species.

This information needs to be presented concisely to avoid lengthening the document excessively, but should be included for completeness.

Updated references

Numerous publications and brochures have been produced on flora and fauna associated with grassy ecosystems. Two of just many examples are Grassland and Woodland Flora. There are numerous other books and brochures on various flora and fauna and groups participating grassland conservation also available. Proceedings of numerous conferences have been published. The role of publications in creating an understanding of grasslands cannot be understated.

The Myer Grassland Project carried out by Kosciuszko to Coast and several Victorian institutions and involving many grassland researchers-participants produced a number of grassland products, including the Land of Sweeping Plains which includes much material on the latest thinking on grassland management and restoration. Older, grey references (e.g. reviews) should be replaced by these more recent references. Some of these are identified in the table in Attachment B.

We suggest reviewing the Natural Temperate Grasslands section of the Management guidelines for Molonglo (Sharp, Osborne, Taws and Eco Logical), prepared for TAMS but never published. This is moderately up to date (2015) and covers many of the factors in the Strategy. Many references in this may be useful to review older references in the draft Strategy.

Expand the scope

FOG believes that the Strategy and Action Plans are too narrowly focused and the recommendations lack inspiration and ambition. In addition analysis could be more complete and the Strategy should encompass a broader range of issues that ultimately encourage community support for the grassland estate. Areas the document could be broadened include:

·         Scope of the Strategy

·         Action Plan recommendations

·         Resources

·         Traditional land management

·         All land tenures

Scope of the Strategy

A key FOG concern is that the document has presented an unambitious and narrow view of the future of ACT grasslands, which does not match well with the enormous efforts and achievements to date by Government (ACT and Commonwealth), research and educational institutions, not for profit organisations and community. FOG believes that similar achievements will continue as long as these various parties continue to work together, and recommends that the Strategy reflect what can be achieved, rather than a sub-set of actions that, we believe, reflects only what ACT Government may be expected to achieve with little involvement by other organisations.

It is important to recognise that many stakeholders will be involved in implementing the Strategy and Action Plans and that the actions identified will guide those groups, for example in identifying research projects, opportunities for on-ground work, or facilitating educational opportunities. The Strategy should reflect what all stakeholders can achieve and include actions that might enhance restoration of grassland vegetation or expansion of dependent species across the broader landscape. It should open the door for implementation of potential but as yet unknown, projects that will enhance grassland conservation.

Action Plan recommendations

FOG considers that the recommendations in the Action Plans also lack inspiration and ambition. The actions plans should state the aspirations for the future conservation and management of ACT NTG and threatened grassland species. Possibly a range of prioritised options should be included.

The recommendations in the Action Plans concerning individual species are little more than a set of cut and pasted generic recommendations. As an example, in the case of the Baeuerlen’s Gentian, the recommendations do not even seem to be appropriate. They seem to take no account that the gentian is a single population that may have gone extinct (it is not clear from the description, whether any plants in the single population, have been rediscovered since 2014).


It is important to ensure the document is sufficiently comprehensive so that the information it contains can be used to lobby for resources to ensure priority actions are undertaken, i.e. that its breadth includes what we really need to fully conserve and protect our grasslands, not just the current situation that is being funded.

Traditional land management

The use of traditional Aboriginal land management practices is highly relevant to the future management and restoration of ACT grasslands. FOG believes that conservation management needs to be based on a clear understanding of traditional land management values and practices and that the adoption of those values and practices – aided by science – will lead to cultural healing and provide a stronger basis for our conservation efforts. The Strategy and Action Plans recommendations need to reflect upon traditional land management and formulate suitable recommendations.

All land tenures

The document needs better inclusion of native grassland in all land tenures. In particular, the Strategy and recommendations fail to report on the management and aspirations of all native grassland managers including ACT and Commonwealth government managers, the Canberra International Airport, and rural lessees.

Conserve all sites

There are two areas where the document falls short of providing guidelines to protect all of our endangered grassland communities:

·         Category 3 sites

·         Rocky, montane and subalpine grasslands

Category 3 sites

Given there is so little NTG left, consideration needs to be given to whether and how the ACT may sustain all the current native grassland sites. The Strategy identifies that effort will not be put into retaining those sites that that have a Conservation Category 3, even though the majority meet the criteria as NTG under the EPBC Act (a Floristic Value Score over 5 and over the minimum size). These sites are therefore remnants of the Critically Endangered Ecological Community under the EPBC Act, but are considered redundant in the Strategy. While this may reflect current budgets, there are many breakthroughs in the science of restoration that make it feasible to improve their condition, and some reflection of whether these sites have become more degraded over time or not, as well as their role in providing marginal habitat, buffers, seed resources and so on.

Rocky, montane and subalpine grasslands

Despite the inclusion of rocky, montane and subalpine grasslands in the Strategy and Action Plans, they receive little attention and do not appear to be reflected in the recommendations.


Collaboration and community engagement have been factors in protecting our grasslands to date. FOG’s view is that a collaborative approach between government and community needs to be continued to be encouraged beyond the provision of labour for weeding, for example by establishment of ParkCare groups, workshops, educational opportunities, and by providing support to community groups undertaking such actions. Some suggestions follow:

·         Parkcare groups

·         Citizen science

·         Education, public awareness and advocacy

Parkcare groups

A useful action is to establish and support of Parkcare groups in grassland reserves. This action, not identified in the current draft Strategy, was included in the 2005 Strategy as well as earlier Action and Recovery Plans, but not implemented by the ACT Government.

Citizen science

The contributions of citizen science are underplayed in the Strategy and recommendations. In 2008-09 FOG conducted a major survey of Golden Sun Moth. This is referred to in the document as Annett Richter’s research but it was a major citizen science project involving a partnership of FOG-Canberra University-Annett Richter and was funded by WWF.

Canberra Nature Map is a major advance that will assist in our understanding of grassy ecosystems and their flora and fauna, including rare and not so rare native plants and weeds GR, fungi, herpetofauna, birds and invertebrates. This is particularly important as many reptile species, in addition to the few highly studied ones, are likely to have been severely affected by loss of habitat and fragmentation. Distribution of many species is unknown and their habitat requirements poorly understood; this is even truer of invertebrates.

Working with researchers in the ACT government, paid researchers and volunteers have participated in plant and Striped Legless Lizard surveys in ACT grasslands and kangaroo counts.

Scientist-cum-community partners have done much to develop techniques for monitoring vegetation condition (e.g. the MCG Vegwatch program). These need to be commented upon in the Strategy and considered in the recommendations.

Education, public awareness and advocacy

FOG believes that the importance of community education is understated and is not properly considered in the recommendations in the Action Plans. Well focused education may lead to support for conservation, changes in behaviour (e.g. better compliance with conditions of entry in reserves or compliance with management guidelines such as mowing regimes), involvement in on-ground work, advocacy and community adoption of sites.

The future of grasslands also relies on the efforts of community and groups who may organise support for grasslands through advocacy, education, on-ground work, and visiting such sites. Advocacy has played a significant role and, without the ongoing advocacy work by groups such as FOG (which has prepared numerous submissions on issues affecting ACT grasslands), the Conservation Council and others, ACT grasslands would likely be in a dire state in terms of size, amount and condition.

There are numerous professional and amateur people who are highly skilled in plant and fauna identification who have been involved in voluntary surveys and monitoring, including providing assistance to government programs. Many are involved as reporters and moderators in Canberra nature map

The importance of the work of the Commissioner for Sustainability and Environment cannot be overstated. The Commissioner’s two major reviews on ACT grassland management helped to focus attention on the inadequacies on the management of ACT grasslands and lay the foundation for Canberra’s current management.

FOG has played an important role over many years: leading many field trips to ACT grasslands; holding major conferences (e.g. Glass half empty, Glass half full, 2014 Canberra, celebrating FOG’s 20 years of advocacy for grasslands) and workshops on all manner of topics related to grasslands; publicising many elements about them in its News of Friends of Grasslands in many publications by other organisations and in the public media. Many other groups in the Canberra region also conduct such programs related to grasslands . The importance of this work cannot be overstated and should be reflected in the Strategy and recommendations.

Conservation Management Networks (CMNs) have played an important part in creating a greater awareness of and better conservation outcomes for grasslands. Two in the Canberra region, the Monaro Grassland CMN and Southern Tablelands Grassy Ecosystems CMN, played an important historical role and provided a good model for grassland conservation. These networks bring together grassland owners and managers with scientists, community and usually a facilitator. In many ways FOG is an example of a CMN. Kosciuszko to Coast has undertaken several funded programs promoting grassland conservation and restoration. Currently Kosciuszko to Coast has a large landowner network to which it regularly distributes information and for whom it holds workshops. ACT Catchment groups and other local regional groups perform similar functions.

Work on grasslands in south east Australia has also played an essential role in our understanding of the ecology of grasslands and their most appropriate management. The Strategy should reflect on this work and the recommendations should support building stronger links with work taking place in Melbourne and other parts of Victoria, other regions in NSW, South Australia, Tasmania and Queensland.

Management and operational plans

There is a need for site specific management and operational plans for every grassland site, not just those in reserves. Individual site management plans are vital and need to be reviewed on a regular basis, partly to take advantage of developed understanding of management for promoting native flora and fauna. They need to be developed with input from, for example ParkCare groups, to work cooperatively towards common goals. Management Plans have been developed for all sites managed by the NCA and by the Department of Defense and in preparation for offset sites under ACT Government. They are sadly lacking or desperately out of date for many ACT Territory sites.

FOG supports the use of expert bush management teams, which may operate in a form similar to Indigenous management teams, to implement specialized conservation management.

Pink-tailed Worm-lizard

FOG believes that the (existing) Pink-tailed Worm-lizard Action Plan should be included in this document for clarity and ease of reference (i.e. including all Action Plans for threatened species that are ‘grassland specialists’). The Pink-tailed Worm-lizard is dependent on native grassland (Rocky Grassland, R8) in the ACT; its occurrence in woodland (and forest) is only where there are open grassy, probably natural, rocky outcrops. In S.4, we note inclusion of PTWL in discussion of management requirements (e.g. p. 38) and in Table 1 p. 115.

Document presentation

FOG has a number of comments on the format and presentation of the document. Specific comments are provided in Attachment B, while the following general comments relate to the:

·         Underlying data and analysis

·         Presentation of information

Underlying data and analysis

·         Past strategies have served as useful reference documents, providing both comprehensive analysis (showing aggregate statistical data) and lists of sites comprising the analysis. The analysis in the draft Strategy is patchy and inconsistent and useful summary information on the characteristics of each site is missing.

·         Maps are incorrect and misleading, with different groupings being used, and definitions of the groups not provided.

·         No information is provided as to how data are stored, accessed and reviewed.

Presentation of information

·         The Strategy and Action Plans contain a lot of detail that is difficult to read and absorb:

-   There is considerable repetition, both within the Strategy, and between the Strategy and the Action Plans. Removing this repetition will improve the readability and usability of the documents.

-   Relegating much of the detail to background sections would enable the Strategy itself and the Action Plans to be more concise, without losing information that will be valuable to some.

·         The Contents requires a list of figures and tables.

·         It is not easy to find key information, including: maps, definitions, key actions, principles. The major guidelines and key actions in the Strategy need to be summarized and presented up front, together with key maps, so that the Strategy and Action Plans are briefer and more cogently argued.

·         Ensure maps are consistent in colours used and differentiation between types of grassland. Identify sites by name where possible.

·         The use of links needs careful consideration. For example, there are many references in the document to ‘ACTmapi’ ( While ACTmapi is a powerful tool, the reader is not given directions about how to use the map, and the end result may be more confusing than enlightening.

·         Develop and use a style sheet for the document, which includes terms, to ensure consistent use throughout. Activate the language with verbs and clear statements of intent.

·         Include a glossary of terms (to help general readers).

Other issues

There are several other important issues not addressed fully in the document, including:

·         The requirement for consistent and adequate funding over longer periods to support long-term projects.

·         Related and broader issues that affect grassland management. These may include urban design and planning, tourism, traditional Aboriginal land management, balancing production and conservation, the availability of new technology and developments in citizen science.

·         Outlines of future research possibilities, including further work on burning, restoration, and reduction of nutrient levels

·         Requirements to ensure all fire asset zones are outside conservation areas.

·         Guidelines to clarify relationships between conservation of grassland and other land uses such as livestock production, recreation, tourism (including promotion of grasslands). There is a chapter outlining excellent guidelines on promoting sensible public access to grassland reserves in the Land of Sweeping Plains, referred to later in this submission.

·         Although the ACT Government has a database of existing information on grasslands and other vegetation, there is a need for a comprehensive database containing information – kept up to date – on land managers, site management plans, survey data (all species) for all sites (all government and non-government managers, including rural lessees). GR

·         Ultimately, as we continue to learn how to conserve, manage and restore grasslands that large parts of the landscape may be restored to natural temperate grasslands. GR



Attachment B: Specific FOG comments

Page and para reference




p. 4, 1.1


Consistency with later content (p5)

Clarify in first para that it’s about grasslands ‘regardless of tenure and land use’

p5, 1.3


No objective for the Strategy to identify sites for protection, but there is a whole section on protection

Include objective that the Strategy will identify sites/criteria for protection

p. 6, 1.4


Relationship between woodland/grassland strategies

Is there a need to state (and ensure) that derived grasslands are managed consistently with this strategy?

p. 7, 1.5.4

ACT policy on environmental offsets

The wording of the two dot points about the policy objectives is not the same as in the policy. The first is missing a crucial phrase, and the second one implies that EECs can be offset in any situation

Replace the wording of these dot points with the exact wording from the offsets policy

p. 8, 1.6.1

Rutidosis leptorrhynchoides

Earlier conversations with Brendan Lepschi at the ANH is that the spelling has been modified to only one ‘r’: leptorhynchoides.

Confirm with Brendan Lepschi

p. 8, 1.6 …


Ref to ‘Table 1’, and text about ‘action plans’ repeated in 1.6.1 and 1.6.2

Avoid repeating text (confuses readers); careful final edit required

p. 8 and elsewhere

Placement of figures and tables

Conventionally figures and tables follow as close as possible the first mention in the text. In the draft they are frequently numbers of pages removed,

Either place closer to the text or give the page number in the text next to reference to the table/figure

p 12, 2.1


Other significant ‘urban edge effects’ are fire and slashing.

Covered later in detail, but could mention here.

p 12, 2.1 …

Use of ‘etc’, throughout

Adds nothing; don’t use

Begin bracketed example strings with ‘e.g.’

p. 12, 2.1 …

Need to define some terms

A glossary, and clear coding in text of words included (e.g. use bolding), would help readers understand technical terms

Include/indicate technical terms in glossary, e.g. ‘natural-patch-dynamic processes’. Or avoid overly technical terms.

pp. 12–13, 2.1 – last para on p.12

Statement not followed up

Raises a significant issue (viability) that deserves to be covered elsewhere and cross-referenced

Check that this is covered later

p. 13, 2.1, last para


Paragraph is too complicated (and it’s not alone in this)

Clarify unnecessarily complicated writing (throughout)

p. 13, 2.4.1; p. 88, 8.5.4

Floristic Value Score

We believe the FVS version that is applied in ACT is based on the EPBC listing for NTG in the S-E Highlands, that is modified from Rehwinkel 2007, 2014 (applies a score to common). Also provided as an update in Rehwinkel 2015 (unpublished report circulated). S8.5.4 needs to identify that the FVS is key to identifying NTG SHE.

Need to fix referencing. The EPBC listing is a primary reference, particularly as the Rehwinkel references are unpublished.

p. 13


If assessment of the FVS is to be undertaken for sites, who will be undertaking it, and when?

New text to address this; also relevant to 2.6 text

p. 13, 2,2

Protection goal

How does “moderate to high ecological condition” relate to conservation categories

Define “moderate” and “high”. In particular, some indication of which of the Category 2 sites are covered by this protection goal.

p. 13, 2.4.1


Identified in the text as Endangered under EPBC

Modify text: Grasslands are Critically Endangered under the EPBC Act

p. 13, 2.4.1, para 2

Native grassland

Terminology: The EPBC Act does not refer to native grasslands but to a subset, i.e. NTG.

Suggest referring back to the EPBC listing and use the exact criteria and terminology specified in the listing.

p. 14 2.4.2



Change cruicial to crucial

p. 14, 2.5

Use of short forms

Once the CSC term has been spelled out it needn’t be reused in full – it’s clunky and intrusive in the text

Prefer ‘CSC’. Suggest shorten text as appropriate, e.g. ‘CSC sites meet the following …’ to lead in sections, in text and headings … Also add CSC to a glossary

p. 14 2.5, last para, column 1

Best quality

Best quality in comparison to what?

Explain, reference as required

p. 14, 2.5; p. 156

St Marks Cathedral, St Mark’s site

Outdated name – the grassland is on the originally proposed cathedral site which will not be built. It is mostly within the lease of CSU

Check with CSU/ACCC (Stephen Pickard) to find out what they call the grassland.

p. 14, 2.5.1

CSC1 sites

It would be useful to note in the listing which are protected

Code CSC1 protected areas, e.g. bolding in list

p. 14, 2.5; P15, 2.6

Refer to the ACTmapi for locations of grasslands….

It would be very useful to include a table listing all the NTG sites, and their key characteristics, including conservation categories, presence of threatened species and current land use and management responsibility at this point in time, as per the 2005 Strategy, noting that the ACTmapi website will change over time if the condition or assessment of individual sites changes.

Include table of all NTG sites and their key characteristics for ease of reference

p. 15, 2.6.1

Management of category 2 sites

Some of the category 2 sites are special cases and need conservation management without or with minimal other uses, e.g. York Park

Add reference to conservation management as the primary goal in such cases

p. 16, 2.6.1, last sentence; p. 44, 4.10 first dot point

National Land… MOU

MOUs are weak.

Consider other Federal conservation mechanisms that could be applied.

p. 16, 2.7

Repetitive text

Another example, after dot points

Simplify text wherever possible

p. 16, 2.7, 2.7.1, fig 1; p137 table 3

FVS 5-10 sites (category 3 sites);

These still meet criteria as the CEEC under EPBC. If they meet CEEC they need a higher level of protection than that recommended in 2.7.1. Confusion then in following maps where “other grassland” includes NTG and degraded or exotic grassland – i.e. see comment above on P12 S2 about sorting out differences between what is/is not threatened under EPBC and NC Acts. Why is restoration not identified to improve sites, especially those that are in Cat 3 but are still the CEEC? The Strategy should indicate that no NTG sites should be lost. See also p. 135, where there is no flag for offsetting or protecting Category 3 sites.

Need to indicate that they are the CEEC. Clarify NTG status for Cat 1, 2, 3 sites.

p. 16, 2.7, elsewhere

Spelling for common names, e.g. Chilean Needle Grass

For consistency, suggest using spellings for common names as per the ACT census.

Refer to National Herbarium’s ACT Plant Census, e.g. Chilean Needlegrass

p. 17, fig 1

Map of native grasslands has some details different to Figs 1-7 (pp 117-125).

Why not show Cat 2 and 3 sites too?

Part of this is that p17 shows ‘category 1’ vs ‘other’. Pp 117-125 show ‘NTG’ vs ‘native g/l’ and ‘exotic g/l’. This has the potential to be confusing as FOG didn’t find any text to help interpret this in a helpful way. See also comments on terminology above. The rocky grasslands on the Molonglo are not identified as NTG on p117 or 124. FOG is sure the majority meet the definition as NTG. See various Molonglo reports.

Use same classifications in all maps and clarify.

Would also be helpful to have an enlarged map of the central Canberra area and its NTG sites, as the yellow areas are barely visible against the grey background

p. 17, fig 1

Natural temperate grassland (Rocky Grassland) also occurs in Ginninderry.

Surveys and interpretation of the data from polygons in the conservation area in Ginninderry have identified that NTG occurs within Ginninderry (West Belconnen).

Refer to maps (SMEC 2016) and reports (SMEC 2016; Sharp 2016) provided to Riverview Inc.


Language style

Often too passive

Activate the language; move verbs up front in sentences (clarifies intent), especially for dot points

p. 22, 3.3


First two dot points are repetitive


p. 22, 3.3


Unclear what the references to imprecision (second dot point) and perception (third dot point) are about; perhaps perception is sometimes relevant – could the issue actually be about ‘precaution’ (i.e. perception of potential threats)?


p. 22, 3.3

Key principles

Are points six and seven separate?

Reconsider wording

p. 23, S3.4

Annual weeds

No mention of annual weeds that do need control and their influence on dynamics e.g. dry biomass in summer. In comparison, woody weeds are a doddle to control.

Include a para on the more significant impacts of annual grasses including Wild Oats and Bromes

p. 23, 3.4.1

Use of terms

Re weeds, need to be clear between use of terms such as ‘manage’, ‘control’ and ‘eradicate’

Check use of terms - prefer ‘manage’ as general term; define in glossary if used according to the pest weeds declaration

p. 23, 3.4.1, third dot point

Early response

Need to report and act

Reword to indicate early action/ immediate intervention required.

p. 23, 3.4.1, fifth dot point

Spot spraying

See 4.6.2 re spot spraying prior to mowing

Reword to add

p. 24, 3.4.1, dot points 6-8

Active language

These provide another example of the need to bring verbs up front


·         Take care when applying …

·         Avoid herbicide drift …

·         Take appropriate action …

p. 24, 3.4.1, dot point 8

PPAA 2005

Are ‘importation, propagation, commercial supply’ relevant here?

Consider rewording

p. 24, 3.4.1, dot point 9


Should ‘records’ be ‘sightings’?

Consider rewording

p. 25, 3.5.1

European Wasps

No mention of why European Wasps are a threat in grasslands, let alone a major threat

Omit or explain why they are a threat in grasslands

p. 26, 3.5.1

Passive language

Another opportunity to bring verbs up front


·         Manage the major pest animals: …

·         Use [relevant plans/policies] to guide feral horse and wild dog management ..

p. 26, 3.6, third para

Cascading detail format

Avoid use of (a) … (b) … within sentences [see also 4.5.2]

Use colons and semicolons (or dot points) to include strings of detail

p. 26, 3.6


‘Exogenous disturbances’ is not a common term

Reword or include in glossary

p. 27, 3.7


Could include drought as an influence on kangaroo density

Consider rewording

p. 27, 3.7

Last para

Is this in the correct section?

Reconsider placement

pp.27–8, 3.8

Urban pressures

Paragraph 1 could also mention that management as fire buffer (e.g. slashing) is often a factor.

In paragraph 2, another risk is inappropriate disturbance (e.g. too frequent slashing).

Consider rewording

p. 28, 3.8.1

Urban impacts

Earlier mention of Marshall 2015: excellent planning ideas to protect grasslands in urban areas – edge design can reduce impacts on grasslands as well as improve aesthetics and care of grasslands, by facilitating attractive surroundings – i.e. turn a negative impact into something positive.

In guidelines add point to look at urban design in key sites

p. 28, 3.8.1

Passive language

Another opportunity to activate language

Bring verbs to the front of dot points consistently …

·         Incorporate fire fuel …

·         Manage sites adjacent …

·         Enhance ongoing …

Avoid ‘…tion’ words, e.g. ‘… provide adequate buffer areas and create hard urban edges …’

p. 28, 3.8.1

Reverse errors

Are there any areas of grassland where unsympathetic plantings have been done which could benefit from their removal? [see 5.5]

Consider issue and reword if appropriate

p. 28, 3.8.1

Infrastructure – dot point five

If works are required in a grassland, there is a need to manage traffic (vehicles, equipment), on-site storage of materials/equipment, and the site requires rehabilitation to an agreed standard afterwards

Consider added words

p. 28, 3.8.1

Infrastructure – dot point six

Other significant disturbances that could be mentioned are parking and storing of stuff on sites by adjacent neighbours, and driving through sites for access.

Consider added words

p. 29, 3.9, third dot point

Climate ready

Should perhaps be

‘Monitoring and recognising climate change’

Consider rewording

p. 29, 3.9.1

Precautionary principle

Another word needing explanation

Include in a glossary

p. 29, 3.9.1

Initiatives – third dot point

Participation should also include ‘implement and evaluate’ initiatives (i.e. more than ‘promote’)

Consider rewording

p. 29, 4 – heading

‘Natural’ vs ‘native’ grassland

Are these interchangeable terms? If not, the term ‘natural grassland’ is not explained

Consistent use of terms, or explanation of the differences between them in a glossary

pp. 32 – 44, 4

habitat features

It’s not just grass that provides structure to g/l Rocks, spider burrows, wet and damp areas and sometimes scattered trees etc all need to be maintained

Add sub-section on maintenance of habitat features

p. 32, 4.1

Some grasslands not managed primarily for livestock

Are there more than a very small number of remaining natural grasslands managed primarily for grazing? Again, a table of sites to refer to for basic data (land use and management, size, condition etc.) would be very helpful to be able to see how many are managed primarily for livestock

Change some to almost all? Or modify sentence

p. 32, 4.1 second para

Higher areas

Altitude or on hills????


p. 32, 4.1

It may not be possible to maintain habitat heterogeneity

Grasslands appear to be remarkably resilient; few have been lost other than through human influence. Small sites already have lost heterogeneity. If it has heterogeneity now it is possible to retain it, if not, then likely can’t bring it back, except through restoration if warranted. If they contain threatened species then the habitat is retained for those threatened species, unlikely to be more than one anyway in small sites (GSM or BWW?)

This does not seem to be based on knowledge of actual sites in ACT, but a generalised statement

p.33, 4.3, dot point 4


Not sure what ‘mostly intermediate grass biomass’ means


p. 33, 4.4 para 1

Significant advances

We would contend, given that 30 years ago their location wasn’t even known, no management applied for their conservation or recognition of grasslands for their conservation values, that there have in fact been substantial or major advances


p. 33, 4.4, para 5

‘best practice management’

Text here could go in a glossary instead

Move to glossary entry

p. 34, 4.5

Grass biomass

Grass isn’t just grass – it includes both native and exotic grasses, needs some explanation, esp. as they can have important differences in biomass, fire dynamics etc. (Phalaris, ALG, Wild Oats for example). Although it is identified in S4.8 more or less as if it is one thing or the other – exotic grasses are present in all sites

Clarify; add point in 4.5.2 as to how exotic grasses affect biomass removal

p. 35, 4.5, second column


Habitat requirements for PTWL needs a reference

Include reference

p. 34, 4.5, paras 3-4

‘biological crust’

Description could be in a glossary

Move to glossary entry

p. 35, 4.5.1

‘grass height’

Description could be in a glossary

Move to glossary entry

p. 36, 4.5.2

Slashing waste

Is the need to remove grass dealt with sufficiently later? Should it be mentioned here too - see 4.6.3.

Check related wording

p. 36, 4.5.2

‘Kangaroo Grass’ vs Themeda triandra

Need to use terms consistently – after introduction (in each chapter perhaps) should be able to use common name

Check use for consistency

p. 36, 4.5.2, dot point 8

Coded terms

The (apparently) sudden use of codes (r# and a#) is confusing – are these described and/or mapped somewhere in the document?

Check explanation or cross-reference

p. 37, 4.5.2


Fourth last ‘guideline’ dot point, last sentence – this presumes the past practices led to good condition?


p. 39, 4.6, last para


Should wording be ‘vulnerable’ rather than just ‘sensitive?

Consider rewording

p. 39, 4.6.1

Repetition, and absence

Some things are said over and over, e.g. preference for native herbivores: emphasis or unnecessary repetition? However, is there a preference for cattle over sheep, and should this be stated?

Remove repetition, and consider extra text

p. 40, 4.6.2, first para


Another example of need for editing

Consider: ‘To promote native plant diversity, fires …’ instead

p. 40, 4.6.2


There is more specific information about preferred burn patch size (10x10m) at 4.5.2; text needs to be consistent, and best placed

Consider where prescription is best included

p. 40, 4.6.2


End of third para – ‘good ecological reasons’ such as?


p. 41 S4.6.3

Slashing guidelines

Best practice also includes order of mowing areas in sites, clean to weedy, as per Michael Mulvaney guidelines

Add info

p. 41, 4.6.3, fourth para

Slashing guidelines

Suggest this needs stronger wording about removal of slashed material


p. 41, 4.6.3

Slashing guidelines

Cross-reference to 3.4.1 should go earlier, in para above

Move reference

p. 41, 4.7

Buffer placement

Could note that it’s ideal that such buffers are not within the grassland areas (cross-reference to earlier text about good urban planning)


p. 41, 4.8


All grasslands contain exotic grasses. The section only includes perennial grasses; either identify that or else include annuals

Maybe: Manage habitats that contain high abundance of (perennial) exotic grasses

p. 42, 4.8.1 and Fig 4


Need text description to flow consistently with summary in the flow diagram

Reorder text for consistency. Don’t need to describe Fig4 in the text, just refer to it. Remove duplication (about ‘significant’ habitat’ description).

p. 43, 4.9


Need to define ‘ex-situ’ and ‘extant’ would seem a tautology in para 1

Add to glossary and/or simplify wording

p. 44, 4.10


Another method could be: Liaising across NSW border regarding SE LLS weed management approaches (in process of being updated), including hygiene protocols

Consider new text

p. 45

Photo: spelling



p. 49, 5.4.1


Meaning of ‘hard boundaries’, and ‘nationally alien species’?

Consider glossary entries

p. 50

CAR principles

Seems odd that this is the first reference to these in the Strategy

Consider earlier coverage of CAR for conservation of grasslands

p. 51, 5.5, third para

Native perennial species tend to lack..

Many perennial species do have, however, persistent underground bulbs, stems or roots. It’s amazing what will come up after many years in the right conditions

Consider reviewing sentence.

p. 51, 5.5, third last para

Text clarity

 ‘… and so refuges for this predator should be destroyed (e.g. rabbit warrens) or not created (e.g. wood piles).’

Suggested rewording

p. 51, 5.5.1 first dot point

Sites that are in moderately good condition

How does this relate to CSCs and to the terms in 2.2?

Clarify what “moderately good condition” means

p. 53, 5.6.1, dot point 3

Text clarity

Suggest should be ‘Avoid further fragmentation of grasslands by infrastructure …’

Check meaning

p. 53 table 2

Last row

Hard to read

Change table to landscape format

p. 59, 6.2.1


Citizen science? Incorporate monitoring undertaken by community where it overlaps. Canberra Nature Map, Vegwatch?

Add dot points about community involvement and contributions (existing and future) and how to integrate it.

p. 59, table 3

NTG metrics

What does “NTG rated grassland” mean? How does it relate to EPBC or NC Act definitions or to CSCs?

Metric C7.1 include how much area by quality of grassland, e.g. by CSC

p. 59, table 3

NTG metrics

What about NTG areas on ACT public land but not in reserves?

Add a metric for these areas. Possibly also separate out the broad categories of NTG in the metric (e.g. lower and higher elevation grasslands)

p. 61, 6.3.1

Mapping methods used to date…

If you cannot distinguish primary from secondary grasslands then a comment needs to be up front that the Strategy may include some secondary/derived grasslands.

Add point on p. 5 for what is in the Strategy.

p. 66, 7.1 …


‘Grassland’ is used extensively throughout here, but elsewhere in doc ‘native grassland’ is usual

Adopt a style sheet for the doc which sets rules about use of terms for ‘grassland’ (general and community specific)

p. 66, 7.1 and 7.1


Here, as elsewhere, there is unnecessary repetition (e.g. second para of Overview and first dot point of Key Principles)


p. 66, 7.2

Redundant actions

Volunteers also need to know that their work won’t be undone (e.g. bulldozed for development)

Consider additional text

p. 66, 7.3


Amazing, almost unbelievable

Need to check 1/20 and 29%!!?

p. 66, 7.3

FOG statement

Seems to have been plonked into the text; could do with introduction or neater placement (and following para could go above it)

Add FOG undertakes on-ground work and monitoring at several sites in ACT, including Yarramundi Grasslands

p. 67, 7.3.1

Continue to support

Support and training for what?

Provide training for grassland-specific monitoring and on-ground work?

p. 67, 7.4

Citizen science examples

FOG was heavily involved in the community GSM report of 2009. This is referenced on p. 130 but could also go in here

Add in the grassland-specific example of the GSM report

p. 68, 7.5

Build indigenous engagement

Very weak. Add 7.5.2 – Guidelines…. Talk to people such as Karen Williams (MCG) and Wally Bell to strengthen this section.

Add guidelines, e.g. learning from indigenous culture, use of local language names in interpretation materials and activities …

p. 69, 7.6.1


Shouldn’t this be 7.7? nothing to do with recreation etc.

Check placement of 7.6.1 – and introduce it

p.69, 7.6


No Guidelines yet for appropriate recreation/tourism

Include Guidelines

p.72, 8.1.1, 8.1.2

Eddy ref

This is a weak reference.

Use the NC Act definition or EPBC

p. 72, 8.1.1

110 grasses in the ACT

How many occur in grasslands? No value in identifying how many grasses in ACT. How about how many native/exotic species have been surveyed in ACT grasslands?

Modify or omit

p. 72, 8.1.1

Species rich

The data are there: how many species recorded overall; what sorts of no. of species/area in the best sites?

Give examples

p. 72, 8.1.1

Transient seed banks

True, but see above; many plants are extremely long-lived below ground. There are two factors: survival of existing plants (e.g. BWW is estimated to live for 40 years (Briggs), and regeneration

Add info

p. 72, 8.1.2

Walker and Hopkins 1994


Update reference to 2009 3rd edition

p. 74, 8.1.2


There’s a great photo in the Mildenhall collection that shows the intergradation in Majura Valley, or use a recent photo from Mt Pleasant

For your information, possible inclusion

p.79, 8.2.3 last sentence

Pasture improvement

Define what is meant by this and then implications for grasslands in ACT


p. 79, 8.3




p. 80, 8.3

Yarramundi Reach

NCA has advised to call this Yarramundi Grassland, as the reach is the water

Change here and elsewhere

p. 80, 8.3

Main areas

Rocky grassland at Molonglo is worth mentioning – large areas, new type of NTG in this area; assume the 880 ha includes this, but given it is identified as not NTG in fig 6 of the grassland Action Plan this is not clear


p. 81, table 5

NTG>625 m

I.e. NTG under the EPBC Act.


p. 86, table 9

 East Jerrabomberra (Committed to…what?

Text cut off in four rows

Turn on wrap text

p. 86

Belconnen naval transmitter station

Consistency with nameit

A table of all the sites would identify names correctly that can be then checked through the document.

p. 86, 8.5.2

Lowland natural temperate grassland

There is no such thing

NTG (NC Act or EPBC Act)

p. 87, 8.5.2

Rural culling would have benefits

Benefits or impacts? FOG suggests little, given there are few areas of rural land with grasslands or adjacent to grasslands where rural culling is allowed?

Review statement

p. 87, 8.5.3

Canberra nature map and weed mapping

Significant project to assist in distribution and abundance of species


p87, 8.5.3

Surveys for PTWL

Also surveys for vegetation in Molonglo and Ginninderry– id of R8


p. 87, 8.5.4

A variety of research…



p. 87, 8.5.4

Howland and Fletcher, Dimond etc.

Lack of referencing to identify dates and references to these studies

Provide dates and references to theses

p. 89, 8.5.6


Shouldn’t it be Osborne?


p. 89, 8.5.7

Friends of Grasslands

FOG is interested, but not collaborating; primarily the work of Ken Hodgkinson

Remove FOG; acknowledge Ken

p. 89, 8.5.8


The primary reference is Sharp S. and Gould L., 2010. ACT Vegetation Monitoring Manual. A step – by – Step Guide to Monitoring Native Vegetation in the ACT. Greening Australia (ACT Region), Canberra.

Refer also to Sharp and Gould

p. 89, 8.5.8

FOG forum


Include proper reference for the proceedings

p. 91

C3 and C4 species


Add to glossary

p. 92, 8.8

Kangaroo grazing

A great summary of role and impacts of kangaroo grazing


p.93-99, 8.9

Description of associations

It would be great to include examples of where these associations may be easily accessed. Otherwise it is very abstract

Include examples

pp. 113-4

Definition of native grassland?

NTG has been defined, but what is native grassland then? It is mentioned in the maps, but what is it? FOG suspects a lot has FVS>5, so therefore it may well be CEEC.


p. 114

Anthosachne scabra


Change to scaber

pp. 113-139


There’s a great deal of repetition from the Strategy to the Action Plan. As it is one document, can much of the background be dealt with earlier, and then get right into the plan?


p. 115, table 1

List of NTG sites

The information and presentation of table 1 is useful.

Also need a list of NTG sites, preferably with, for each site, an indication of the category of the site and which of the endangered species occur there

p. 117, fig 1

Map and grassland categories

The colours used for high value areas are different than for Figs 1 and 2 in the Strategy. The differences in the categorisations between the two sets of maps are confusing

Be consistent about the use of similar colours for high versus low conservation value areas. Provide definitions of the categorisation on both sets of maps so it is clear why there are differences between the two

p. 118




p. 126

Insert, Tuggeranong

Why put with the montane and sub-alpine sites?

Put as insert in one of the other maps, and leave F8 as only referring to the Namadgi NP sites.

pp. 134-135


There is no mention in this section of actions that might be undertaken for sites already identified as approaching critical thresholds

Add further information to identify what will be done for such sites

p. 135

Environmental offsets requirements

This section states that a proposed development on NTG will be flagged if it is on a CSC 1 or 2 site as per the Strategy. However, CSC 2 sites are not listed in the Strategy – instead a reference to ACTmapi is given

A list of all CSC 1, CSC 2 (and CS 3) sites be included in the Strategy, as well as other sites that contain threatened grassland species

p. 138 (also p. 8)

The Strategy document is referenced as 2016 (c) and also as Part A.

Is it self-referencing as it is in the same document?


p. 157 BWW info

NCA management. plan for conservation sites

There is a revised and updated plan, Sharp 2016. Note also, there are about 140 plants at B2S128 Yarralumla, ACT Govt land between the Chinese Embassy and NCA Stirling Park (contiguous with the latter). This is a doubling of the population since MCG’s weeding began in 2015. Note also, no plants were found despite significant searches at West Block in 2016, after extensive weed control (this site also has a management plan (Sharp 2016)

Update reference

p. 159

Environmental offset requirements

The use of the wording “offsets are appropriate” implies that it is acceptable to offset this species. The aim of both the Conservation Strategy and the Action Plan should be to expand the populations until the species no longer needs to be listed as endangered. While the Button Wrinklewort populations may be such that some losses may be possible without the species being in imminent danger of going extinct, offsets should only ever be used as a last resort for an essential (infrastructure) development.

Change wording to “The Button Wrinklewort has been determined as able to withstand further loss in the ACT. However, offsets should be avoided if at all possible to allow the species to recover sufficiently to no longer need listing as endangered.”

p. 161

Grazing and BWG?

The Crace population is in a paddock where cattle grazing occurs (or has it been fenced out?), but has obviously increased enormously since found in the 1990s, perhaps despite grazing, or perhaps because of managed grazing? There was clear evidence of cattle grazing the plants then; however grazing is also a way of keeping the canopy open.

This statement needs more consideration of the actual data, and then consideration of further actions, eg research or careful monitoring

p. 161

Heading ‘MANAGEMENT’ left hanging

This problem occurs in the electronic version but not the hardcopy

Ensure heading is linked to next paragraph on the following page.

p. 169


Conservation status only identifies one population

Confusion: There are two populations of the GP but only one is identified in the conservation status statement

Revise or add footnote if a definition (and give reference).

p. 171


This problem occurs in the electronic version but not the hardcopy

Ensure heading is linked to next paragraph at the head of the next column.

p. 192


York Park, while a small area, has a high population of the GSM and is an iconic, well-studied site. Protection of this population should be encouraged

Include reference to York Park in second para on p. 193

p. 194

Trigger for review of offset threshold for a species

Not clear who would make the observations. What is the purpose of the review of the threshold – presumably to raise or lower offset requirements? The review phrase is in several other plans (e.g. GED, SLL)

Clarify wording, intent and possible responses to population changes for all species for which this is identified