Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Macquarie ACT 2614
Environment, Planning and Sustainable Development Directorate
Namadgi National Park Plan of Management Review
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.
Namadgi NP is a wonderful and complex environmental asset that provides a host of services to multiple stakeholders. We wish to limit our comments to four matters, as follows.
1. Inclusion of biodiversity indicators
Recommendation: Biodiversity indicators are required to measure changes over time to vegetation communities and plant and animal species and to evaluate ongoing management.
Appendix A makes a number of suggestions about what those indicators might be. It should be possible, with a little research, to include biodiversity indicators in the next plan and provide regular updates. Such indicators would be based on existing data and “expert" judgement (of professional staff and researchers).
2. A stronger focus on conserving species diversity and conservation values
a) The rare plant list, not only of those plants that occur within Namadgi, needs to be revised so that conservation effort is directed towards those species within Namadgi and conservation of their habitat.
b) The list of life forms of the 2010 PoM should be updated and made more comprehensive, especially as many new discoveries have been identified in the park. Species listed in Appendix B have been located since 2010.
Since 2010 Citizen Scientists and others have identified and located many previously under-recorded biota; no special management consideration has been given to these species in the plan. These biota need to be documented, outlined in the new plan and specific management aims and directives provided were this is appropriate.
For example, until two years ago, when it was first reported on Canberra Nature Map, it was not known that the nationally vulnerable Purple Copper Butterfly (Paralucia spinifera) occurred within either the ACT or Namadgi. A follow up survey by citizen scientists quickly determined that Namadgi actually contains over 98% of the known global habitat of this species. Further survey of this species within Namadgi is warranted. This butterfly has a complex relationship with a native ant and Blackthorn (Bursaria spinosa), which can be impacted both positively and negatively by fire, so it is important that fire management is beneficial to this species. Similarly, ten years ago the Long-nosed Bandicoot (Perameles nasuta) was thought to be extinct in the ACT and Rosenberg’s Monitor (Varanus rosenbergi) was considered to have a sparse and localised distribution. Both are now known to have significant populations in Namadgi, while citizen scientists have determined that the monitor has key summer, over-wintering and breeding areas. Protecting key populations of the Bandicoots and Rosenberg’s Goanna must be a key consideration of the location, timing and effort given to fox-baiting.
In 2013 the ACT Scientific Committee came up with a list of 318 species considered to be rare in the ACT or which were crucial for maintaining rare animal species. By 2017, as many new records of these 318 species had been collected via Canberra Nature Map as had been collected in the previous 110 years. This led to the recommendation that 58 of the species should be removed from the list as they weren’t rare, but another 18 species (previously unknown in the ACT) should be added. Since 2017 there have been many more rare plant records added on Canberra Nature Map, with a focus of species that occur within Namadgi over the last two years.
Some of the key species and species group that need to be considered (and weren’t included in the background papers) are listed in Addendum B. There is also a need to consult the recent Namadgi orchid survey report by the Canberra Orchid Society and the hundreds of significant sightings recorded on Canberra Nature Map within Namadgi National Park. See https://canberra.naturemapr.org/locations/sightings/62?filter=significant.
Experience with Canberra Nature Map volunteers suggests that monitoring of some species with single or few populations might be undertaken with the assistance of volunteers.
3. Management of all invasive species with potential to establish and spread within Namadgi
Recommendation: The management planning process should involve a consideration of all invasive species that pose a significant risk to Namadgi.
In addition to the priority species mentioned on Page 18 of the review report, the plan needs to consider and address the management of Tarweed (Madia sativa) which has become well established in the south of the Park, as well as giving priority to new weed incursions of Broom (Cytisus scoparius), Yarrow (Achillea millefolium), African Lovegrass (Eragrostis curvula), Birdsfoot Trefoil (Lotus corniculata) Sulphur Cinquefoil (Potentilla recta), Serrated Tussock (Nassella trichotoma) and Coolatai Grass (Hyparrhenia hirta). The plan also needs to be responsive to new threats.
4. The possible impact of the Uluru Statement from the Heart.
Recommendation: the referendum on the Voice should be flagged as a major opportunity and challenge for Namadgi, and an important focus of the plan.
Assuming that The Uluru Statement referendum is successful and followed up by treaty and truth telling, there is likely to be major impact on many aspects of the ownership and management of natural areas such as like Namadgi.
Members of FOG are happy to provide further input.
Professor Jamie Pittock
8 May 2023
Appendix A: Biodiversity descriptions and indicators for Namadgi NP - vegetation communities, species and expenditure
Prepared by Geoff Robertson, May 2023
In developing the PoM, a major step forward would be to provide a framework to monitor biodiversity within the park. We assume that the Conservation Effectiveness Monitoring Program (CEMP) has been implemented within the Park. However, what we are advocating is a framework, that could rely on CEMP, but would provide broader, simpler, fewer and more aggregate measures, and would require an element of expert judgement, to provide:
- measures of the health of each vegetation community,
- measures of the overall health of the vegetation communities by combining the measures of the individual vegetation communities,
- measures for individual species, and
- measures of related government expenditure and resource use.
These measures should be published regularly (annually, or every two or three years) as a time series. They can be developed using existing data, based on vegetation, plant and fauna surveys, but would require a degree of expert judgement. The published measures could be regarded as “interim measures” as they are likely initially to be somewhat experimental but would be improved over time as better data and greater insights come to hand. The publication of measures should be accompanied by an explanation of the sources and methods used to prepare them so that users of the measures are informed of the strengths and limitations.
Such measures, if they prove robust, could be extended to all of Canberra’s parks and reserves where vegetation plant and fauna surveys are undertaken and likely to be copied by other jurisdictions.
The framework would need to include descriptions of each vegetation community and describe and evaluate management priorities. These were included in the previously published Namadgi PoM but some suggestions are made below for their improvement.
Factors like drought, temperature, rain and fire are all likely to impact the measures suggested. Measures are likely to decline in drought and bounce back with a lag after fire and heavy rains. Going forward the measures suggested are likely to assist greatly in our understanding of these impacts.
Appendix 2 of the 2010 PoM includes six broad vegetation classes, which account for nineteen vegetation communities, namely grasslands (2), forbland-sedgeland-mossland complex (3), shrubland-heathland complex (3), wetland complex (1), woodlands (3) and forests (7). For each community we would urge that the plan include updated and include more detailed community descriptions, management priorities and measures of biodiversity health.
Descriptions of each vegetation community should include:
- Community title, description & area (hectares).
- Patchiness and patch size - some communities are naturally contiguous while others naturally patchy. However, patchiness can also be due land clearing. Mention should be made about the number of patches and the size of patches, and the potential to increase patch size and connectivity.
- General community health and threats (taking account of weeds, dieback, invasive animals, erosion & other natural threats, and the impact of tourism and other human traffic).
- Weather and its impacts (temperature, drought, fire, flood and abnormal rain).
- General management strategies (to manage biodiversity and the impact of human traffic).
- Conservation status (critically endangered through to not threatened).
Management priorities for individual communities
This would include planned and contingent management plans and reports on their implementation and success or otherwise, and may include:
- Impact of tourism and other uses and their management.
- Responses to weather and natural fire events.
- Management of weeds, erosion and feral animals.
- Restoration through increasing patch size and connectivity, increasing plant diversity and ecological function, and flora and fauna re-introduction.
- Ecological burns and other fire management.
- Creation of exclosures and other infrastructure.
- Captive breeding programs.
Biodiversity indicators for individual communities
Five to seven broad measures are suggested for each vegetation community, namely:
- Total area (hectares).
- Area of high quality, medium and low quality vegetation (or simply the area of high quality vegetation).
- Floristic value score”, “native plant richness” and “weed value score” for high quality areas, or the total area.
These measures are well known and are regularly calculated in current vegetation surveys by the ACT government. A useful description of these measures is found in recently published paper Environmental Offsets Ecological Monitoring Program Report 2018–19, February 2020 found here.
It would be possible to publish many more measures for each community, but it is highly desirable to publish fewer rather than many measures.
A number of elements of judgement is required in the measures suggested - this may cause some to question whether it is premature to publish such data. However, we should “not let the perfect crowd out the good”. It will be possible to revise the methodology in future, provided there is some degree of robustness in the underlying data used to compile them. Also, the sooner that such measures are published, the more likelihood that will be strengthened sooner. The reality is that most economic, social and other scientific statistics are based on a large degree of expert judgement - this does not lessen their value.
Vegetation assessment across all communities
Part of the framework would be to combine data for all communities into a single set of measures for “all communities”. The recommended measures are those described above.
The question arises: how to combine measures across individual vegetation communities. Here are some suggestions:
- Total hectares of the combined communities. The residual would be the area of the park that is built and the area not covered by indigenous vegetation;
- Each of the other measures would be the sum of the weighted community measures - the sum of the weights would add to one, and weights could be calculated by assigning each community an equal value - each community would receive a weight of 1/19;
- Assigning each community a weight based on their area; or
- Assigning each community a weight based on some other basis, e.g., threatened communities may be given a weight based on a combination of their conservation status (critically endangered being given a relatively higher weight) and area. The weights should be based on some form of expert consensus, but in any case the weights used should be published so that analysts may experiment with different weights. Before determining what weighting system to adopt, some analysis should be undertaken comparing how different weighting approaches may impact the combined measures.
Flora, fauna & other life species - lists, descriptions, management priorities & results of priority actions
Species lists & descriptions
The list of life forms recorded in Appendix 2 of the 2010 PoM should be updated and made more comprehensive. Special attention should be placed on identifying all species in Addendum B. The comprehensive list could included in the report or be published separately. It should be regularly (every one, two or three years) updated and published. The list should be extended to include all known species (including those on Canberra Nature Map). It should show separately indigenous and non-indigenous life forms, and in turn by fauna (shown separately mammal, bird, reptile, frog, fish, marine invertebrate, territorial invertebrates), plants (showing major families and family groups) and other life forms by broad category. For each species the following are suggested:
- Scientific and common name.
- For indigenous species, conservation status and abundance. Conservation status would state where species is extinct, critically endangered, etc., or may need further research. Abundance would state whether the species is very rare, rare, common, abundant, and over abundant - the latter would refer to species that negatively impact the abundance of other species.
- For non-indigenous plants, whether they are transformative, invasive, common or rare.
- For non-indigenous life forms, whether they are a major threat, common or rare.
- For all species whether population is stable, or rapidly increasing or decreasing.
- Statistics on the numbers in each category above.
Species of concern or watch and see status
This should include all indigenous species targeted for management or placed on a watch and see list because they a threatened, rare and seriously declining species, and so on.
It should include all a major invasive weeds, non-indigenous predatory species, or non-indigenous species that are a major threat to other species of ecological functions, or indigenous species that are overabundant and displacing threatened and rare species or causing ecological disfunction.
The population size of species of concern and on the watch and see list should be regularly reported as should actions taken to control them.
For the purpose of publishing indicators, species could be grouped into broader groups.
Use of resources and expenditure
To measure the success or otherwise of biodiversity outcomes, the use of resources and expenditure should be measured. These could include:
- ACT government expenditure at Namadgi on biodiversity research and management (excludes expenditure on water management and tourism), including Funding provided by Commonwealth government.
- Additional information on ACT government expenditure might include:
- ACT government staff salaries and staff hours
- Contractors fees and contractor hours
- Other expenditure.
- ACT government capital expenditure at Namadgi, including funding provided by Commonwealth government.
- Volunteer hours spent on managing and measuring biodiversity at Namadgi NP.
Frequency of data collection, analysis and publication
There are a number of options here. Concerning surveys of community vegetation, these could be:
- a full survey of each community conducted every year.
- a full survey of each community conducted each three years and partial surveys on the intervening years. These could be rotated so that a third of the full surveys are conducted each year.
Other variations are possible.
It would seem likely that surveys in consecutive years are likely to produce similar results unless there is a major weather event. In such cases, possibly complete surveys should be conducted after major events. On the other hand, after a major bush fire there may need to be a lapse of time before a survey should be carried out.
It would seem likely that grassland communities are more likely to change from year to year compared to forest communities.
Descriptions and measures of species
Concerning descriptions and measures of species, such data are likely to be updated as new data become available.
Government expenditure and resource allocation
These are likely to become available annually but with a lag.
There are several options here. Likely the best option is that there is a publication (that could released on a website) annually. As it is largely an updating process, putting the release together is unlikely to require a major effort, once matters settle down.
Appendix B. Key species or species groups that need to be incorporated into planning
The following species were largely unknown to occur within Namadgi in 2010. Many of the records about these species are from NatureMapr.
- Alpine Redspot Dragonfly (Austropetalia tonyana) is a rare dragonfly species, with only 31 recordings in Australia since the 1950s. A few older records are known from Gilbralter Falls but it was thought to have become locally extinct until it was photographed in December 2017 close to Corin Road. This dragonfly breeds in the splash zones of creeks and falls and protection of this habitat at all times and of surrounding vegetation during the October to January adult flying period is important.
- Swamp Blue Damselfly (Austrocoenagrion lyelli) is only known from Grassy Creek within the ACT. This Creek was impacted by silting resulting from poor erosion control during upgrade works along Boboyan Road.
- Iota Ringtail Damselfly (Austrolestes io) has rarely been recorded in the ACT or NSW but is also known from Grassy Creek along with Naas Creek.
- Alpine Darner Dragonfly (Austroaeschna flavomaculata) is a rare species occurring along Ginnini Creek and associated alpine swamps.
- Purple Copper Butterfly (Paralucia spinifera) is a nationally vulnerable species, and 98% of the known global habitat occurs in Namadgi. This butterfly has a complex relationship with a native ant and Blackthorn (Bursaria spinosa) which can be impacted both positively and negatively by fire, so it is important that fire management is mindful of this species.
- Spotted Trident-blue Butterfly (Cyprotides maculosus) is a newly described alpine species, first recognized after an image was posted on Canberra Nature Map. It has a restricted distribution of which ACT’s alpine grasslands are an important plant. The species is considered to meet the criteria for listing as endangered.
- Yellow Jewel Butterfly (Hypochrysops byzos) uncommon local resident with very localised distribution associated with Pomaderris species, and is susceptible to fire.
- Bank’s Browns Butterfly (Heteronympha baksii) is an uncommon local resident susceptible to fire. It was not seen in Namadgi for ten years following the 2003 fires.
- Silky Hairstreak Butterfly (Pseudalmenus chlorinda) is a regionally rare species with a restricted distribution. The species has particular habitat requirements with ribbon eucalypts, wattles and an attendant ant needing to be present. It is apparently very susceptible to fire.
- Bogong Moth (Agrostis infusa) has suffered a recent mass decline and is now considered nationally endangered. Its aestivation sites in Namadgi need particular management care and protection from pig predation.
- Striated Sun Moth (Synemon collecta) was recorded in native grassland in the Naas Valley – this sun moth is probably rarer than the nationally listed Synemona plana).
- Red-eyed Fire-tail Cicada (Yoyetta grandis) is a newly described species at its northern distribution in the ACT and rarely recorded in the region.
- The jewel beetle Castiarina attenuata is only known from one location in our region and its Bulls Head location is a northerly disjunct of other recorded locations. It is dependent on white flowering shrubs.
- The nationally endangered Key’s Matchstick Grasshopper (Keyacris scurra) is now known to have relatively large and widespread populations in the sub-alpine grasslands in the vicinities of Rendezvous Creek, Bogong Creek and Naas Creek. Maintenance of its grassland habitat is of importance.
- Harris’s Peacock Spider (Maratus harrissi) is only recorded from a few locations which tend to be high altitude woodland areas prone to fire, to which this species appears susceptible.
- Blunt-nosed Burrowing Crayfish (Engaeus cymus) is near its northern limit in the ACT and has been rarely recorded.
- South Toadlet and Brown Toadlet (Pseudophryne dendyi and P. bibronii) have both suffered population declines since 2010 and their ongoing existence in Namadgi may be perilous.
- Namadgi contains a significant population of Rosenberg’s Monitor (Varanus rosenbergi). Recent research has indicated that the Park contains one of the highest monitor populations anywhere in the world. The monitor can survive in the environment by having differing breeding, summer and over-wintering habitats.
- There are a dozen recent records of the nationally endangered Tan-backed Skink (Liopholis Montana) in the upper Cotter catchment.
- The Alpine Water Skink (Eulamprus kosciuskoi) is a regionally uncommon and restricted species that has been recently recorded in the upper Cotter Catchment.
- There is a recent record of the Glossy Grass Skink (Pseudemoia rawlinsoni) from the grassy flats below Mt Gingera. It is regionally uncommon.
- The Long-nosed Bandicoot (Perameles nasuta), thought to be extinct in the ACT, has recently become known to be quite widespread within Namadgi, where it utilises specific habitats. Fire management and fox control are of importance for this species.
- Feathertail Glider (Acrobates pygmaeus) - suitable habitat within the vicinity of Canberra Nature Map recordings from 2021 and 2023 needs to be appropriately managed.
- Brindabella Midge Orchid (Corunastylis ectopa) - a new population of the ACT endemic has been recently located. This new location needs to become a focus for weed control and other protective measures. The relationship to fire needs to be better understood, as does the impact of native grazers.
- Jean’s Leek Orchid (Paraprasophyllum jeaneganiae) is a newly described species currently only known from a small population at one location, which should be a high priority to protect and managed for this species.
- A newly described Leek Orchid (Paraprasophyllum stipatum) has a highly restricted distribution including Namadgi.
- Channelled Leek Orchid (Prasophyllum canaliculatum) is a critically endangered species, with one known population in Namadgi which is susceptible to pig damage.
- The regionally endemic and rare Charming Leek Orchid (Paraprasophyllum venustrum) and Stocky Leek Orchid (Paraprasophyllum viriosum) have both recently recorded at new locations in Namadgi, but not relocated at previously recorded habitat.
- Mountain Spider Orchid (Caldenia montana) is a nationally rare species that appears to be in decline in the ACT. Poor rates of pollination and grazing from native animals seem to be key issues that need further research and action.