Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
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

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.

Yours sincerely


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:

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. 

Vegetation communities

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.

Community descriptions

Descriptions of each vegetation community should include:

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:

Biodiversity indicators for individual communities

Five to seven broad measures are suggested for each vegetation community, namely:

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:

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:

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 staff salaries and staff hours
  • Contractors fees and contractor hours
  • Other expenditure.  

Frequency of data collection, analysis and publication

Vegetation surveys

There are a number of options here. Concerning surveys of community vegetation, these could be:

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.