Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


The Commissioner
ACT Emergency Services Agency
GPO Box 158
ACT 2601


Dear Sir/Madam

Strategic Bushfire Management Plan Exposure Draft – comments

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia, included related fauna species. 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 updated Strategic Bushfire Management Plan (SBMP) and the Regional Fire Management Plan (RFMP) that flows from it. In general, FOG is supportive of the approach outlined in the documents but has the following comments:

Strategic Bushfire Management Plan

Action 7.5 2 in the SBMP targets research into post fire vegetation response, fuel age distributions and associated fuel loads. Action 9.2 targets research and monitoring to target biodiversity conservation and understanding of appropriate fire regimes. FOG considers that the research should include the impact of cultural burning (as part of traditional Aboriginal management) and ecological burning practices as fire management tools as well as their role in managing and enhancing our biodiversity assets.

FOG notes that the Strategy mentions other fuel management treatments, such as slashing and grazing as possible important fuel reduction tools. The decision as to which tool to use such as fire or another treatment is often complicated by a number of factors, including what the best treatment is from the viewpoint of preserving and enhancing biodiversity. It is essential that research activities include measurement of the effectiveness of each tool in terms of both fuel reduction and enhancement of conservation values, so that the best method can be selected for each site each year. Again this should be more explicitly stated in the Strategy.

FOG strongly supports some of the new initiatives in this strategy, such as Action 12.4 and the inclusion of the “Aboriginal Fire Management Zone” in both the SBMP and the RFMP. FOG understands that newly forming Traditional Custodians Advisory Group will play a major role in determining the fire management in the Zone. FOG considers that this is a good first step to allowing greater direct control and management by Traditional Custodians of areas within the ACT.

With action 11.2, there is a possible conflict between this action and the need to retain mature hollow bearing trees for species such as the superb parrot. There needs to be recognition of the importance of retaining hollow bearing trees (the removal of which is listed as a threatening process), and some discussion or guidelines as to how this might occur while still mitigating the fire risk to Canberra residents by managing the government tree canopy.

FOG notes that in the text of section 11, it is stated that “As a standard approach, any intensively managed Inner Asset Protection Zone required to achieve that level [BAL<29] must be located within the footprint of the area to be developed”. However, this is not entirely reflected in the actions – edge roads are a good start but may not always be sufficient to ensure no bushfire management is needed in adjoining reserve areas. To protect the conservation values of our native grasslands and grassy woodlands as Canberra expands, text along the lines of “… the development, and that all IAZ are within the development footprint when adjoining areas of conservation value,…” should be added to Action°11.6.

Regional Fire Management Plan

FOG sees the RFMP map as a very useful tool, as it allows everyone to be able to easily access the proposed fire management approach recommended for each forest, woodland and grassland site.

FOG notes that many areas, including many grasslands reserves and open spaces are listed for “optional prescribed burning areas”. FOG would generally encourage a more flexible approach to burning of natural grassland sites, ensuring frequency is based on best available knowledge, and recognising that important research is currently underway that may guide future utilization of burns in natural grasslands, aimed at enhancing native diversity and resilience. There are many issues that relate to this, including community awareness, application of ecological burns and/or cultural burning practices, herbage mass management, alternative forms of biomass management including grazing and mowing, and research. FOG welcomes the flexible approach set out in the strategy which, through the preparation of annual operation plans, will allow our understanding of ecological and cultural burns to evolve within the ten year period encompassed in the strategy.

FOG generally supports the statement “Some locations are currently excluded from prescribed burning programs until at least 2033. These locations are typically fire sensitive ecosystems such as alpine bogs, wet heaths, Cypress woodland, or areas still recovering from bushfires.” However, some careful research/experimentation of use of fire in these ecosystems may prove to be enlightening.

Yours sincerely


Geoff Robertson
President, Friends of Grasslands

31 May 2019