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

Submission on draft Caring for Dhawura Ngunnawal – A natural resource plan for the ACT 2022-2042

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 native 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.

We write with strong support for finalisation and adoption of this natural resources management (NRM) plan for the ACT. The draft proposes a great many strategic measures that are vital for the conservation of endangered grassland and grassy woodland biota. Finalising and implementing the plan is critical for the future well-being of the ACT’s people and environment. FOG is committed to contributing to implementation of the plan through the full spectrum of our activities in the ACT.

We write here to make some overarching suggestions to enhance the draft strategy, as well as to make some specific points on the draft measures.

Overarching suggestions

1.       Vision

We note that the draft vision (pg. 5) emphasises “Rewilding Canberra”. This is an admirable and engaging objective but wonder whether a broader framing is needed. Canberra city is only 17% of the land area of the ACT. Further, while the vision leads with rewilding, relevant measures are actually a minor part of the subsequent text (pgs. 34 and 64).

Does “nature” adequately reflect the full range of NRM values, involving our land, water, biodiversity and cultural assets? We wonder if rewilding could be misinterpreted as focussing too much on restoration of very degraded urban lands in place of the higher priority that we would place on restoration and conservation of existing natural habitats? For example, in the context of grassy ecosystems where 70% of Natural Temperate Grassland communities are not protected in reserves, we consider that restoration, conservation and connectivity of existing natural remnants is the priority.

2.       Context of NRM with respect to land tenure and agencies

The draft plan is presented as being tenure blind and engaging all relevant government agencies and stakeholders. This is appropriate. Yet, in practice the 60% of the ACT that is in reserves is managed by ACT Parks and Conservation Service. Consequently, the key focus and added value of this NRM plan is the 40% outside the formal reserve network, in particular, the 80% of natural grassland and grassy woodland that is outside the reserve system. In this context, a number of ACT Government directorates have greater responsibility, in particular, Planning, Transport Canberra and City Services, and well as EPSDD. It would be helpful if the draft plan could provide greater detail of the roles and responsibilities of these directorates with respect to each other and how their capacities to aid NRM will be enhanced.

As an example, FOG leads volunteer work to restore the grassy woodland site on urban park land recognized as a priority by the ACT Government at Blue Gum Point in Yarralumla. TCCS is responsible for and acted to minimize mowing when we asked, leading to extensive regeneration of grassy woodland vegetation. However, we have been unsuccessful in having TCCS control major environmental weeds (like African Lovegrass) in a regular and timely manner. The site is also in need of periodic ecological burning to manage biomass but the resources and processes between TCCS and Parks for achieving this are labyrinthine. Greater clarity on how TCCS, EPSD and Parks collaborate to deliver these critical management actions in a regular and timely manner is crucial for conserving grassy ecosystems.

Additionally, leased urban and rural land also require assistance; 70% of Box-Gum Grassy woodland is within rural leases. Currently, urban lessees with remnants containing MNES (for example, St Marks Grassland in Barton, one of the most iconic remaining natural grassland remnants) receive little or no management advice or other assistance.  

3.       Relationship to Commonwealth Matters of National Environmental Significance

The draft plan thoroughly identifies and gives appropriate priority to conservation of threatened biota and other matters of environmental significance. In so doing the draft does not always distinguish between matters of national significance versus those additional values identified through ACT processes. In our view it would be helpful for the plan to identify as an early action the mapping of irreplaceable habitats needed to conserve all Matters of National Environmental Significance within the ACT and those not on the MNES that are identified as threatened under the Nature Conservation Act. This would have three advantages: a) informing the ACT’s NHT funding request to implement the plan; b) defining the no go zones for a regional plan likely to be required under the Federal Government’s impending reform of national environmental legislation (announcement expected in December); and c) informing the ACT Government’s planning reforms, so as to better protect values upfront and direct developments to sites without conflicting values. This proposed mapping would integrate NRM, planning and environmental regulation.

4.       Establishing progressive output and outcome targets

The outcomes described in the draft plan are admirable and presented in qualitative terms. We ask if the plan could be amended to provide more measurable outcomes and quantified, progressive output targets? For example, for the threatened grassland species, a more measurable outcome would be their conservation to the point where their populations increase, and they are no longer listed as threatened by 2042. Progressive outputs may then be practical measures such as the numbers of hectares of habitat restored and occupied by the species concerned in the five years to 2028. Similarly, with only 30% of Natural Temperate Grassland communities protected in reserves, another progressive output target for the next five years could be a particular target increase in the area managed for conservation by effective means. This more quantified approach may aid efforts to secure funding to implement the plan.

5.       Biodiversity network

Along with the Conservation Council, FOG is proposing the establishment of a biodiversity network to ensure conservation and restoration of linking habitat corridors to support bigger populations of flora and fauna. Such a network is critical to conserve bigger, minimum areas of the fragmented habitat of grassy ecosystems in the ACT. We particularly welcome the proposal (pg. 30): “Introduce new land use zone development controls in the Territory Plan, with protection of areas of important landscape setting or nature conservation values or areas of value for connectivity corridors or as buffers to adjacent areas with greater values.” The (pg. 36) Urban Connectivity Project is an important start to implementing this measure. FOG further suggests that the reserves and linking off-reserve corridors are formally designated by applying the IUCN World Commission on Protected Areas’ standards and guidelines for protected area categories, “Other Effective Area-based Conservation Measures”, and “Guidelines for conserving connectivity through ecological networks and corridors.” Just as the ACT was a world leader on climate change mitigation, we can also be an exemplar for world’s best practice in biodiversity conservation by systematically applying IUCN standards in our planning system and land management across tenures.

FOG has a particular concern to ensure that the methods used in the ACT to identify corridors are attuned to the needs of grassland ecosystems and not the mapping methods used thus far that are based on tree dominated ecosystems.

6.       Trade-offs between trees and grassy ecosystems

The ACT Government has rightly adopted policies to increase the urban forest in Canberra to generate many ecosystem services. However, the settled area of Canberra prior to British occupation was primarily grasslands and grassy open woodlands. Planting trees can very negatively impact key remnants of grassy ecosystems by shading out the groundcover species, introducing weeds and providing perches for raptors to more effectively hunt threatened grasslands fauna. In the past year at a number of sites FOG has had to ask TCCS to remove their poorly located tree plantings to protect significant remnants of grassy ecosystems.

The ACT Government and this NRM plan can promote a better balance between planting trees and conserving grassy ecosystems by adopting four measures:

  1. Not enabling planting of trees in urban areas within 100 metres of native grassland  remnants;
  2. Further removing invasive tree species from the City Services list of approved species;
  3. Requiring that planning for all tree plantings considers the opportunity to plant appropriate understory species, including indigenous grasses and wildflower species; and
  4. Working with relevant community organisations and government agencies to develop a guide on better practices for habitat restoration in Canberra.

7.       Further enabling community volunteers

The draft plan recognises the significant role of community organisations and their volunteers (including FOG). We welcome this partnership with the ACT Government for the benefit of the people and environment of the ACT. There are elements of this government – community partnership that could be enhanced:

  1. ACT agencies prohibit volunteers using power tools in on-ground activities leading to longer and less effective work. This policy applies to even the most innocuous of tools, such as line trimmers. We suggest that rules for volunteers are reviewed periodically so as to broaden the range of activities that volunteers can undertake, with appropriate training where relevant.
  2. In many cases, volunteers are applying for ACT Environment Grants to subcontract work for conservation of significant sites on public land. For example, FOG is currently contracting for weed spraying at one grassy woodland site, work that should be the core responsibility of the ACT Government land management agency concerned. This has high transaction costs. Further efforts are needed by the ACT Government to coordinate its agencies to deliver timely, basic land management activities to conserve sites of high conservation value on public land. This would free the time of volunteers to undertake activities where they add particular expertise.
  3. Strategies for recovery of grassy ecosystems include recommendations for the application of best practice management. In order to do so, the strategies identify the need to develop and implement management plans and more detailed operational plans. Their absence leads to volunteers and land managers potentially working in conflict, including for bushfire management. NRM has a role to play to ensure management plans are developed in consultation with all stakeholders and implemented under agreed operational plans.

8.       Weed control

We wish to see the NRM plan enhance the emphasis on control of environmental weeds. While ACT Government agencies employ expert staff, we are concerned that this has not translated into more regular and effective weed control on the public land sites that we help manage. Some of the issues include:

  1. The recent increase in weed control funding not translating into more hectares of control on the ground;
  2. Volunteer mapping of weeds on Field Maps not translating into control activities;
  3. Changes in weed control funding from year to year meaning that a weed sprayed one year is not controlled the next year resulting in reinfestation and loss of any benefits;
  4. Frequent changes in priority species identified for control.

FOG is concerned at reports that the list of species prioritised for control has been further reduced in past months. FOG does support priority control of new weed incursions. However, the conservation value of grassy ecosystems is being degraded by transformative weeds, such as African Lovegrass and St John’s Wort, and these need ongoing control.

Specific points (not already covered above):

Pg. 9 Land use. A key issue for conservation of the lowland grassy ecosystems is the uncertainty over future land use. The NRM plan could encourage strategic environmental assessments to identify high conservation ecosystems for protection. For example, the mooted Eastern Broadacre Strategy should clarify the status of many of the highest conservation grassland remnants. The District Strategies should be at a scale that identify all areas of conservation status and the Territory Plan identify a classification of such areas as Other Effective Area-based Conservation Measures (OECMs) to quarantine them from development or other damaging actions.

Pg. 10 Climate change. Other impacts to note include declines in precipitation and stream inflows. Also, there is the growing issue of managing novel ecosystems.

Pg. 11 Fire. The plan could usefully highlight the need for more resources for timely ecological burns, especially outside formal reserves. These are critical for managing biomass in grasslands to enable a diversity of forbs and threatened fauna to thrive.

Pg. 12-13 Cross border connections. The ACT shares its grassy ecosystems with neighbouring areas of NSW. We believe there is less investment in conservation of grassland ecosystems in NSW despite the opportunities to greatly advance conservation. Some key grassy ecosystem sites are cross-border, for example in Jerrabomberra. The new cross-border NRM Regional Collaboration Committee could usefully have conservation of grassy ecosystems as a focus.

Pg. 16 Where have we come from. FOG strongly supports “the prevention of continued fragmentation and decline of important vegetation communities such as Box Gum Woodlands, Natural Temperate Grasslands and riparian areas (including the management of threats such as development, weeds, pests, climate change and fire regimes).” FOG notes: “the potential for carbon and biodiversity trading through the use of a system where land managers can collect credits for undertaking actions that reduce or sequester carbon or enhance biodiversity.” We are concerned that there are major problems with both existing markets nationally and in NSW. They are the subject of current inquiries. Professor Gibbons (Fenner School, ANU) and others have published extensive research on the failings of current ACT and Commonwealth environmental offsets programs. We urge the ACT Government to develop policies for biodiversity and carbon markets cautiously to ensure that they are transparent and credible, and genuinely represent an overwhelming net benefit for biodiversity conservation.

Pg. 17 Key focus areas. FOG supports the proposed key focus areas, especially “conserve, protect and restore the natural environment with a particular focus on threatened ecosystems and species.” We note that woodlands and grasslands are where these threatened biodiversity conservation efforts need to be focussed, and this requires improved governance.

Pg. 30 FOG strongly supports the proposals to “Introduce new land use zone development controls in the Territory Plan, with protection of areas of important landscape setting or nature conservation values or areas of value for connectivity corridors or as buffers to adjacent areas with greater values.” Also “Investigate opportunities for supporting the protection of important environmental assets on rural lands through land stewardship programs.” We urge the same level of support be given to those assets that are on urban leased land.

Pg. 31 Support “Support leaseholders to manage riparian areas and erosion via off-stream watering points, fencing, revegetation and other activities.”

Pg. 34 Urban landscapes. As discussed above, further clarification is needed on the need to better protect and link grassy ecosystems in urban areas, to use grassy flora more in plantings, and to be more strategic in selecting tree species and better targeting where to plant them.

Pg. 35 Offset land. There is a lack of clarity on when land designated for offsets is actually formally reserved.

Pg. 39. FOG strongly supports the Urban Connectivity Project, as discussed above. We strongly support “Progress work to ensure lands of high conservation value outside the reserve system are protected including voluntary stewardship or custodianship agreements.” And “Management of urban biodiversity” for assessment of off reserve land, cross-tenure biodiversity networks, reducing mowing and ecological burning.

Pg. 41 Natural landscapes. FOG strongly agrees that “Only 50% of the Box Gum Woodland communities and 30% of Natural Temperate Grassland communities are protected in reserves and therefore management of these communities outside conservation networks is paramount.”

Pg. 51 Woodlands and forests. FOG strongly supports the proposed targets and actions and suggests adding explicit reference to the need to conserve biodiversity corridors.

Pg. 56 Grasslands vision. FOG agrees that we need “healthy native grasslands supporting a diverse flora and fauna for now and the future” and suggest that the immediate priority is to protect and manage the remnants outside the reserve system.

Pg. 58 Grasslands pressures. FOG suggests adding the following pressures:

We strongly support the proposed actions. Particular attention is needed to assist TCCS to better manage remnants on their lands. Protection mechanisms for OECM sites is needed to be included in the Territory Plan.

Pg. 69 Governance. The recognition of “The silo approach of different directorates” is welcome. Consequently, FOG strongly supports the proposed targets and actions.

Pg. 72 Measuring the success. We welcome recognition of the need for “prevention of continued fragmentation and decline of important vegetation communities such as Box Gum Woodlands, Native Temperate Grasslands and riparian areas (including the management of threats such as development, weeds, pests, climate change and fire regimes), improved management of urban open space and protection of ecosystem services.” As discussed above, we would like to see consideration of more quantified progressive output targets to transparently track progress.

Pg. 87 Grassland Earless Dragon. Please note that recently four species of Grassland Earless Dragon are now recognized, meaning that out local species, the Canberra Grassland Earless Dragon, is critically endangered:

Thank you for this opportunity to contribute to the ACT NRM plan. FOG looks forward to contributing to its implementation.

Yours sincerely


Professor Jamie Pittock

17 November 2022