Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


c/- Environment Division, Environment, Planning and Sustainable Development Directorate
GPO Box 158
Canberra City ACT 2601


Dear Sir/Madam

Natural Resource Management Plan

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of 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.

Our recommendations concerning the Natural Resource Management (NRM) Plan are that:

1.       A review of the previous NRM plan be prepared to determine to what extent it has been implemented (both intermediate (2015) tasks and progress towards long term (2030) tasks), and the reasons for unmet targets be identified so that elements with shortfalls can be enhanced in the new Plan.

2.       The NRM plan should:

3.       Protection should be given to all grassy ecosystem sites, not only those that are within the reserve system. This should include:

4.       Native grassland and grassy woodland should be restored by:

5.       The NRM Plan should include resourcing of robust and consistent citizen science programs such as Vegwatch.

6.       The following actions should be included to support Landcare and NRM volunteers:

7.       NRM policy should encourage the ACT Government to cement long-term opportunities and funding for the Catchment Groups as part of the mechanism to enable the community to better support what it values.

FOG’s views on all of the questions raised in the NRM Plan Discussion Paper can be found in Attachment A. Discussion supporting the above recommendations is in Attachment B.

We would be happy to talk further about these recommendations. We also would welcome the opportunity to work with Government to achieve the outcomes we have proposed.

Yours sincerely


Jamie Pittock

28 May 2021


Attachment A: Friends of Grasslands responses to the Discussion Paper questions

The following provides details of FOG’s views of each of the questions in the Natural Resource Management Plan Discussion Paper 2021.

Question (p8): do you agree with these principles? What other principles should guide the development of the plan?

We agree with these principles. Attachment B outlines in more detail how the FOG believes that these principles should be implemented.

Question (p13): are there other major focus areas in NRM planning we should consider?

We agree with the focus areas and consider them to be the most important areas to consider.

Question (p13): what are the species, communities, areas or issues that should be a major focus in NRM planning?

FOG has been concerned about the status and management of remnant Natural Temperate Grassland (NTG) and Box Gum Grassy Woodland (BGGW) areas for many years and agrees with focus being given to the three key threatened ecological communities in the plan. Protection and the application of conservation management of these will also protect and enhance all of the individual threatened flora and fauna species that occur within them. It is essential that management of these communities where they occur outside reserves be addressed, together with strategies that ensure their protection in the long term. There needs to be consideration of linkages between grassy ecosystem sites wherever possible. It is important to consider the areas containing these communities and the threatened species within them as part of the landscape scale, rather than just as individual patches, to ensure that we do not continue to lose patches in a piecemeal fashion.

Closely allied to the implementation of conservation management and legal protection of areas containing these threatened communities, is the protection of mature trees, clearance of which is identified as a key threatening process. Mature trees not only provide important habitat in themselves, but also provide an important link across the landscape for many native species, as well as other functions such as urban cooling and mitigation against climate change effects.

However, while significant focus should be on improving the status of threatened species and communities, there remains a legislative and social responsibility to ensure all biodiversity in the ACT are adequately protected and conserved.

As FOG has emphasized in other submissions, significant impacts remain a key issue in the maintenance of biodiversity and control of them must be adequately funded. One example is weed invasion, which needs consistent funding to ensure strategic and effective containment and control of existing, new and emerging weeds, both on and off reserve.

Question (p14): how can NRM planning best address the issues associated with a changing climate?

Biodiversity and landscape function loss is a major contributor to climate change and reversing it is an obvious step. Also see answer to next question.

Question (p15): how can the NRM plan best support the act farming community to maintain sustainable practices in the face of existing and emerging challenges?

There have been many innovations in farming practices and the NRM plan should be abreast of these and facilitate their adoption. This includes regenerative agriculture, no till farming and feeding cattle with appropriate supplements that will reduce methane production. The ACT Government should develop expertise, provide leadership, and offer incentives to farmers and others to adopt good practices.

Question (p15): how can NRM planning best enable the increase of the use of Ngunnawal knowledge and land management methods in the ACT?

FOG has had an interest in cultural indigenous burning techniques as part of grassland management for some time. Applying cultural burning techniques support the ecological resilience of native plant communities and their capacity to preserve soil and fuel moisture, and should be considered for integration into ecological burn methodology. As we stated in our recent submission to the draft Regional Fire Management Plan 2019-2028, ongoing monitoring, evaluation and application of these techniques should continue to inform Government-led bushfire fuel management practices.

Question (p16): what do you think needs to be included in the NRM plan for the ACT?

FOG believes the update of the NRM Plan provides the opportunity for ambitious moves forward in regard to implementing and documenting significant enhancement of natural resource management to achieve high conservation outcomes. We have provided a number of recommendations concerning inclusions to the Plan, together with supporting discussion, in attachment B.

Question (p16): what challenges do you see for natural resource management in the ACT over the next decade?

In our submission we have placed a strong emphasis on the collaborative approach between Government and community to implement the vision identified in the discussion paper, that of having the ‘best managed natural resources in Australia’. Means to work towards this are set out in attachment B. A major challenge is to ensure that there is sufficient ongoing funding to support NRM and related matters.

Question (p16): how would you like to be engaged through this planning process?

We would be happy to talk further about our proposal.

Attachment B: Friends of Grasslands recommendations for implementing the new Natural Management Plan for the ACT

The following provides details of FOG’s response to “Question (p16): what do you think needs to be included in the NRM plan for the ACT?”

1.      Overall statement

FOG stresses the need to prepare a review of the previous NRM plan to determine to what extent it has been implemented: intermediate tasks (2015) and progress towards long term (2030). If the targets have not been met, then it needs to be identified why not. The new NRM plan has to proceed from the basis of the previous plan, which is broad and aspirational, but the degree to which it has been implemented is questioned. It is recommended that particular elements in the previous plan are further enhanced, based on shortfalls identified from the proposed review and on SOE recommendations that apply management guided by more recent research and information. The discussion paper gives the impression that this NRM Plan is starting from scratch.

The ACT Government’s ‘Vision in the City’ report has many excellent recommendations that need to be drawn upon in preparing the NRM Plan. The Plan needs to be aspirational in its extent but achievable, and Government needs to commit to it, including providing adequate budget to do so, supporting and respecting the role of volunteer groups and individuals, and providing adequate resources and involvement. While the ACT Government has responsibility only for ACT Territory lands, it is critical to ensure that biodiversity extends beyond the Territory border into NSW and onto Commonwealth land within and beyond the ACT border. Close collaboration is required to achieve conservation outcomes across the region.

Aspirations for consideration:

That remaining areas of grassy ecosystems, their associated threatened species and other biota (e.g. old-growth trees), including modified remnants, are protected across the landscape and managed for conservation outcomes, thus reducing the threat to those biodiversity elements.


A review of the previous NRM plan be prepared to determine to what extent it has been implemented (intermediate (2015) tasks and progress towards long term (2030) tasks), and the reasons for unmet targets be identified so that elements with shortfalls can be enhanced in the new Plan.

2.      Conservation of biodiversity across the landscape

While Government has a legislative as well as social responsibility to reduce threats to endangered and vulnerable species and ecological communities, it also has a responsibility to ensure all biodiversity are adequately protected and conserved. The NRM plan needs to recognise that resources need to be spent on other species and ecological communities, to ensure:

  1. Other biodiversity elements in the ACT are not threatened by extinction;
  2. The diversity of habitat and species is not reduced across the ACT (and across jurisdictional boundaries);
  3. Integration of conservation management across all bureaucracies and land uses (requiring better structures within bureaucracy to ensure appropriate skills and budget are available for management of all leased and unleased Territory lands); and
  4. Collaboration with Commonwealth land managers to enhance conservation across all of the ACT.


The NRM plan should

3.      Improving the protection of all areas of conservation: proposal for a protected area network across the ACT and within diverse tenures

While the ACT overall has a high percentage of land in the reserve system, the significant majority of ACT land in reserves is within Namadgi National Park (47% of the ACT). Many remnants of lowland communities are outside the reserve system, without protection and not being managed for conservation outcomes. The lack of protection of many areas that remain outside the reserve system needs to be addressed as a priority.

The strategies and action plans for threatened communities and threatened communities use a classification system to categorise sites as having high, medium or low conservation value. Outcomes of these strategies is to protect and manage for conservation those sites of the highest values; this is despite both Box-Gum Woodlands and Natural Temperate Grassland being classified as critically endangered.

A review was undertaken of the current status and protection of grasslands, for which data were available from the Grassland Strategy (ACT Government 2017). Table 2, pp 19-21 in the Strategy identifies by site all the remaining remnants of natural grassland that meet the criteria as the critically endangered community. Land use as well as size classes of the remnants is provided in the table. These data have been used to identify the protection status of the remaining areas. It is assumed that mapping data to undertake a similar process for grassy woodlands held by ACT Government will indicate the percentages being probably similar as for grasslands.

Of the 48 sites remaining (one has been destroyed after the Strategy was published), 16 (33%) are in conservation reserves. Of the 12 sites (25% of the sites) under Commonwealth management, only one is designated as a conservation area (Yarramundi Grasslands). None of the other 31 remnants have any conservation overlay; included in this are sites with the highest conservation rating of 1.

Grassland remnants by land tenure and land use (from the ACT Grassland Strategy, Table 2, pp. 19-21)

Type of land use

Territory remnants


Commonwealth remnants







Nature reserve or proposed





Urban open space










Rural lease or agisted





Urban lease





Unleased, vacant










Road reserve










Airport and infrastructure





Territory totals






Protection should be given to all grassy ecosystem sites, not only those that are within the reserve system. This should include:

It is expected that legislative changes will need to be made to the Territory Plan to enable some of these outcomes.

4.      Restoration of grassy ecosystems

Restoration includes:

  1. Enhancement of habitat and plant species diversity within existing remnants, applying best practice management (frequency, methods and intensity of herbage mass manipulation, pest plant and animal control);
  2. Re-introduction of additional species into existing remnants (ecologically and habitat appropriate planting and fauna habitat enhancement); and
  3. Creation of new habitat to provide a more natural landscape that link remnants, provide opportunities for the more general public to appreciate elements of the natural landscape.

To achieve a reduction in the threat to grasslands and woodlands (a change of status from critically endangered) requires the expansion of natural resources into the modified landscape. In addition to improving management and enhancing existing remnants, new native grassland and grassy woodland sites can be established along major corridors, linking existing biodiversity nodes. Such sites would provide attractive borders to our roads, water courses as well as within the built environment, that accentuate the natural environment of the ACT and expand habitat.


Native grassland and grassy woodland should be restored by:

5.      Monitoring

As identified above it is critical to review the quantitative recommendations in the previous plan to identify what has been achieved to date. This will assist in what can be realistically achieved over a short, medium and long time frame under this plan, and enable better planning of budgets to achieve stated outcomes.

Expansion of the existing monitoring of key elements by Government is required. This includes monitoring ecosystem function, vegetation condition, selected biota and recovery of rare and threatened species. Elements of these monitoring programs should be undertaken together to enable better understanding of landscape condition change.

Existing Government programs such as that undertaken in the CEMP (which we note is progressing extremely slowly) need to continue to be enhanced by volunteer programs including Canberra Ornithologist Group monitoring, Waterwatch, Frogwatch and Vegwatch to ensure the most effective and best data are utilised to understand whole of landscape condition as well as guiding best practice management, particularly relating to resilience to climate fluctuations. We believe that robust and consistent citizen science programs such as Vegwatch that are implemented by community groups to measure and guide on-ground action are a critical component of NRM Plan implementation, and as such should be resourced through the NRM Plan.


The NRM Plan should include resourcing of robust and consistent citizen science programs such as Vegwatch.

6.      Landcare and NRM volunteer contributions

Contributions by community are far more valuable than identified in the discussion paper (p12). In many cases (primarily but not only in TCCS lands) the volunteer contributions are actually key to driving the actions which identify and aim to achieve big improvements in conservation outcomes. Community volunteers are not just participants in the processes, but collaborators and stakeholders, alongside the research community, Government organisations and land managers.

In the case of FOG volunteer programs on public land, FOG plays a key role in planning, identification of issues, implementation of management actions, consultation and negotiation, and overseeing contractors. This role is undertaken because the group has high level skills and experience, strong networks, and recognises that conservation groups play an important role, together with Government, in achieving conservation outcomes. Examples of this are the work undertaken at Hall Cemetery (where FOG collaborates closely with the Cemeteries Board to improve conservation outcomes), involvement in the development and preparation of the ecological management plan at ‘Mugga Mugga’ Heritage Site, works undertaken on National Lands at Yarramundi Grasslands and Gurubung Dhaura woodlands (Stirling Ridge in Yarralumla), and the role in providing small incentive grants through our donation program to volunteer groups in local urban parks such as Bass Gardens and Griffith Woodland. Such assistance provides skills and resources not available within TCCS and other bureaucracies outside Parks and Conservation Service. To demonstrate that commitment and participation, in 2020, thirty-seven work parties were organised by FOG, involving 299 volunteers contributing 1,367 hours of their time. In total FOG contributed 9,748 volunteer hours were, with a financial contribution valued at $487,500 (FOG Annual Report, 2020: Annual report 2020). Other ParkCare and Landcare groups and NGOs in ACT could identify that similar levels of dedicated resources have been applied in NRM activities.

Many volunteers know and understand what is happening in particular remnant areas better than Government employees.

Undertaking more complex management to achieve restoration of habitat – volunteers and Government working together

Natural resource management has been greatly improved over the past 20 years. The role of volunteers has been greatly enhanced by their improved ecological understanding, skills and ability to undertake trials and monitoring. This allows them to undertake more complex and ambitious on-ground work, including more effective restoration, weed control and training of others. We encourage the implementation of programs in which ACT Government staff and volunteers work as teams to undertake joint planning, implementation of tasks, and introduction of adaptive planning principles (assessment, planning, implementing, measuring, monitoring, reviewing). In some cases, volunteers take a leading role, e.g. in FOG’s Blue Gum project with TCCS, the project is directed and supervised by highly skilled of volunteers.

We submit, however, that further work needs to be done to improve the application of the adaptive management approach to include all stakeholders.

Additional funding

Monitoring is identified in current grant application forms as a requirement for funding projects. Programs need to be coordinated to ensure that the monitoring (especially of projects aimed at improving vegetation and habitat condition) is effective, accurate and useful, and that measures are consistently applied across projects so that results can be compared across similar projects and used to guide further on-ground work.


a)       Increasing funding available under the annual ACT Environment Grants;

b)      Allowing ChemCert qualified volunteers to use the full range of selective herbicides for weed control;

c)       Coordinating ACT Government tree, fire and heritage approvals; and

d)      Stepping up City Services and PCS programs to maintain weed control at sites where volunteers have achieved restoration to 'care and maintenance' levels, e.g. African Lovegrass control along roads in and adjoining bushland sites.

7.         The roles of not for profit Catchment Groups

Unlike other NRM Regions, the ACT NRM is managed within Government. However, the three Catchment Management Groups in the ACT provide an essential and demanding role in planning, financial and reporting aspects of implementation of NRM projects undertaken by Landcare, Parkcare and other volunteer organisations. The Catchment groups and other NGOs provide invaluable roles in keeping many of the community's environmental activities running and facilitating coordination within and between projects and volunteers. Despite this, their funding remains insecure and low. NRM policy needs to pressure the ACT Government to cement long-term opportunities and funding for the catchment groups as part of the mechanism to enable the community to better support what it values (p12).


NRM policy should encourage the ACT Government to cement long-term opportunities and funding for the Catchment Groups as part of the mechanism to enable the community to better support what it values.