Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Macquarie ACT 2614
Re: Urban Open Spaces Land 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 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.
Friends of Grasslands welcomes the creation of a management plan for Urban Open Spaces (UOS), and supports the aspirations of the Plan. However, the UOS contains areas of extremely divergent use and environmental significance, which inevitably require different management strategies to manage them. Of concern to FOG is that there are a large number of sites within the areas designated as UOS which contain significant environmental and cultural values requiring require protection and scientifically informed management.
Friends of Grasslands do not believe this plan, as it is currently written, can be used to “guide the management of ACT Government’s public urban open space network” (Purpose of the Plan, pg. 4) when it does not provide the information that will enable protection of “natural features, ecological systems and cultural heritage” within UOS (Introduction, page 3).
This submission provides the following recommendations to assist this plan in meeting its goals in regard to protection of natural features, ecological systems and other significant values including cultural heritage. Each is explained in further detail below.
1. Use the ‘Canberra Nature Park Reserve Management Plan 2021’ as a reference for the refinement of this plan for areas of environmental significance.
Scope and vision of the plan:
The creation of land management plans for large areas of the ACT is not unprecedented. Both Namadgi National Park (106,095 ha) and Canberra Nature Park (11,400 ha) have existing plans of management, which seek to balance social, cultural, environmental, and economic factors. Of the two documents, The Canberra Nature Park Reserve Management Plan 2021 is likely the most suitable for providing guidance on environmental management strategies within the urban interface. For example, the Canberra Nature Park Reserve Management Plan 2021 pgs. 25-43 specifically describe the ecosystem, flora and fauna, and habitat connectivity values that occur within the reserve estate. Pages 44-61 of the plan then outline the management strategies and considerations. Comparatively, the Urban Open Spaces Land Management Plan pgs. 14-19 only provide broad information on the environmental actions undertaken within the UOS estate.
Given the current size of the UOS estate (>6,800 hectares), it is good to see that the environment is acknowledged in the vision statement. However, the first point under Benefit 2 (pg. 3) makes it clear that this plan effectively only considers a narrow scope of environmental factors. For example, the environmental factors listed to be ‘preserved’ fail to include fauna directly, and do not list specific ecosystems or threatened species.
- Friends of Grasslands recommends that refinement of the Urban Open Spaces Land Management plan be informed by the structure and details of the Canberra Nature Park Reserve Management Plan 2021 in regard to UOS that contain significant conservation values, particularly those that contain threatened species and/or critically endangered communities, or where processes may cause loss of mature native trees or create unnatural fragmentation (both listed key threatening processes).
- Friends of Grasslands recommends that the definition of ‘environment’ within the Urban Open Spaces Land Management Plan by broadened to include fauna that occur within the UOS estate, as well as other ecological functions and values that have not been accounted for in the current version.
The section ‘Achieving the Vision’ states that the strategies in Table 5 form the actions related to this plan. Of the 84 strategies listed within Table 5, only 8 appear to have a direct relationship to on-ground environmental management activities that support biodiversity. Some of these are very broad (e.g. “Prepare and maintain management plans for areas of environmental significance”) and contain no timelines or guidance for implementation. Considering these strategies form the basis for the monitoring of this plan (Evaluation, reviewing and reporting, pg. 8), it is difficult to see how adequate metrics can be constructed from such ill-defined strategies.
- Given land managers will likely refer to these strategies when determining appropriate land management activities, Friends of Grasslands recommends that these strategies are redefined to include metrics that can be measured to improve the effectiveness of ecological monitoring in the UOS estate.
The Urban Open Spaces Land Management plan contains no information regarding the current condition of the environment within the UOS estate, or how this would be assessed. Friends of Grasslands believe that benchmarking of ecological condition is necessary to determine whether land management activities are having the desired effect. This issue is compounded due to the lack of assessment of the effectiveness of past environmental management strategies within the Urban Open Spaces Land Management plan.
- Friends of Grasslands recommends that an evaluation of the current environmental condition, and effectiveness of past strategies to protect ecological systems, in the UOS estate is provided within the Urban Open Spaces Land Management plan.
Mapping of plant community type within the UOS estate is currently limited and very localised, preventing staff and volunteers from constructing environmentally relevant management plans. It is important to note that where vegetation mapping has been used extensively (e.g. within the Canberra Nature Park estate), there has been the opportunity to effectively monitor the condition of ecological communities.
- Friends of Grasslands recommends that the scope of vegetation mapping within the UOS estate be expanded to align with the 2018 Vegetation Map (available on ACTmapi).
Areas of environmental significance
Conservation areas that are within urban open space are part of a broader landscape of protected and currently unprotected land containing conservation values. Therefore, urban open space should be managed for conservation of biodiversity, in cooperation with other land managers. The ACT Government has a mandate to conserve areas that contain threatened species and ecological communities, regardless of tenure. The conservation areas may have multiple land uses as long as they are compatible. For example, recreation in urban parks may be the major land use in one area, and a conservation area within that park may be used for more passive recreation.
- The plan needs to include much more information to identify what ‘areas of environmental significance’ are, and how the management of these areas is undertaken.
It is difficult to determine if ‘areas of environmental significance’ are the same as the land typology ‘Natural Open Space (Grassland or Woodland)’. This issue is further confounded by the reference to ‘sensitive areas’ on pg. 19. Despite the various names for areas that may contain important ecological values, there is very little information regarding management activities.
Given the intention of this plan to be a guiding document for land managers, there is an opportunity to provide principles for a ‘whole-of-estate’ approach to the management of ‘areas of environmental significance’. These could then be referred to when addressing the strategy ‘Prepare and maintain management plans for areas of environmental significance’ under the ‘Sustainable’ principle in Table 5. This would further work being undertaken currently through the Connecting Nature Connecting People program in Environment, Heritage and Water, to which FOG is contributing.
- Friends of Grasslands recommends that ‘areas of environmental significance’ are identified within the plan and encourages the development of guidelines on how these will be managed at the whole-of-estate level.
Preparing and maintaining management plans for areas of environmental significance can be a challenge for government agencies with limited resources.
- Friends of Grasslands recommends that TCCS look for ways to do this efficiently to increase effective coverage quickly. Some options include:
a) Collaborating with adjacent land managers (e.g. Parks and Conservation Service, National Capital Authority) to prepare cross-tenure plans;
b) Preparing plans for multiple or large areas at once; and
c) Providing guidelines and processes for community or other organisations (like FOG) to draft plans for TCCS review and adoption.
- TCCS should make these UOS management plans public accessible to inform actions by TCCS staff, contractors, community groups and others.
- As knowledge of the biodiversity on UOS lands changes, Friends of Grasslands recommends that TCCS to establish a formal process and guidelines whereby community organisations or other experts can nominate areas of habitat for transparent assessment and designation as an ‘area of environmental significance’, after which ecological management guidelines should be implemented. This may include incorporating such areas into Canberra Nature Park.
For example, the Ainslie Volcanic grassland site might logically be incorporated into the adjacent Mt Ainslie section of Canberra Nature Park for more efficient biodiversity management.
This plan notes identifies that there are a large number of volunteer groups operating in the UOS estate (“At the time of writing, over 87 volunteer groups are active…” – Executive Summary, pg. 1). It also states, under the ‘Roles and responsibilities’ subheading, that the TCCS directorate is responsible for the “delivery of community programs including volunteer programs”. Throughout the plan, it is mentioned that volunteers “play a critical role” (pg. 17), “support the preservation and maintenance of Canberra’s urban open spaces” (pg. 21), and form a key element of the plan’s goal of ‘activating urban open spaces’. It is therefore surprising that this document contains no details as to the support mechanisms and strategies that will be provided to volunteer groups. For example, there is currently only one TCCS staff member to support these volunteer groups compared to the four attached to the Parks and Conservation Service volunteer program. As such, increasing staffing for volunteer programs could be a tangible way of increasing the knowledge, resources and support available to volunteers in the UOS estate. This can be a cost-effective way for TCCS to improve the management of the UOS estate.
- Friends of Grasslands recommends that further development of specific volunteer support mechanisms is required within the Urban Open Spaces Land Management plan.
- Involve Landcare groups in the development of site management plans; frequently such groups know the attributes of these sites better than anyone else.
While there are few explicit examples of the support that will be provided to volunteers in the UOS estate, the administration of grants is an exception. Grants are one mechanism that can be used to assist volunteer activities in the UOS estate, and the ‘Adopt-a-park’ and community gardens are good examples. However, there are also grant programs with specific environmental goals that are not mentioned in similar detail. A prime example is the ‘Connecting Nature, Connecting People’ program delivered by ACT NRM. The projects this grant program funds are exclusively within the UOS estate, yet it is only discussed briefly (pg. 17) with no indication of future funding or support.
- Friends of Grasslands strongly supports the Connecting Nature, Connecting People project and recommends that the Urban Open Spaces Land Management plan formally recognises it as an ongoing initiative.
Friends of Grasslands appreciates the inclusion of the ‘Shared Stewardship’ principle within the plan. This principle offers the opportunity to recognise the activities conducted by the many community organisations that work within the UOS estate. A key element of shared stewardship is the implementation of cooperative management, to achieve optimal outcomes. Community organisations have a significant role in keeping local community involved and aware of local concerns, and, with considerable experience in ecological management, can provide insights into best practice ecological management. One such example may be to identify where biomass management may be required for bushfire mitigation, and engage volunteer support to provide low impact assistance, rather than high impact responses such as mechanical removal of saplings or seedlings.
- Friends of Grasslands, as one of the organisations that has contributed considerable time and effort into land management activities within the UOS, would like to see the list of potential partners listed in the first strategy under ‘Shared Stewardship’ in Table 5 expanded beyond Landcare and the catchment groups. This will allow for recognition of more than only on-ground maintenance activities, given that citizen science, advocacy, and community engagement also contribute to environmental outcomes in the UOS estate.
Friends of Grasslands welcomes the inclusion of the habitat connectivity map (pg. 18), given our group’s interest in the establishment of a Biodiversity Network across all tenures. However, the habitat connectivity map on page 18 of the Plan, indicates that very few sites are identified within the UOS estate that could be managed to improve the habitat connectivity values. One example of this is the area surrounding Lake Ginninderra, where four habitat corridors appear to terminate at areas zoned as PRZ1. Environment, Heritage and Water are currently liaising with community and other organisations to identify conservation areas and corridors. that are outside the reserve system, many within UOS as well as other urban land. The Connecting Nature, Connecting People program is a great example of strategic restoration that is occurring on UOS that can achieve enhancements to threatened species and ecosystems.
- Friends of Grasslands recommends that TCCS should strategically target resources for ecological restoration to extend the habitat of threatened species and ecosystems listed under ACT and Commonwealth laws. In particular, resources should aim to consolidate and link such habitat to restore more viable species populations and ecosystems.
- Friends of Grasslands recommends that the habitat connectivity map be revised, given its value as a decision-making tool for strategic investment through programs like Connecting Nature, Connecting People.
The plan includes no further elaboration on the principles that informed the development of the habitat connectivity map it references. Given that habitat connectivity requirements are species-specific, the lack of ecological principles makes it unclear what is to be conserved and why. For example, the ACT Government is promoting extensive planting of trees. While this is often beneficial, if the wrong species are planted within or adjacent to areas of conservation value, or worse, planted in or next to a site containing Natural Temperate Grassland or important native grassland, they may serious degrade this listed critically endangered ecological community and associated threatened species.
- Friends of Grasslands recommends ecological and other programs are compatible and work in synergy, for example, ensuring tree, shrub and understorey planting with ecologically suitable species is prioritised for where it will have greatest ecological benefit.
- Friends of Grasslands recommends that the principles of how an ecological network are applied in the UOS estate is provided for in the plan.
The difficulty associated with managing the competing priorities of the UOS estate is not lost on Friends of Grasslands. However, the current state of environmental management in the UOS estate, both through observation as well as review of this plan, indicates that an ecologically-informed review is required. To begin with, the term ‘re-wilding’ is not appropriate in this context and can be offensive to First Nations peoples due to the connotation that the environment was ‘wild’ prior to colonisation. Without this review, and the corresponding implementation of recommendations in practice, it is difficult to foresee meaningful and sustainable environmental change occurring. This will become increasingly more important as complex issues, such as maintaining appropriate habitat connectivity, are factored into land management planning.
- Friends of Grasslands strongly recommends that guidance be sought from experienced ecologists on best-practice environmental management and ecological restoration.
- Friends of Grasslands recommends that TCCS should employ at least two ecological restoration specialists to guide work on the UOS estate, including application of ecological management of areas of environmental significance to encourage natural regeneration.
Friends of Grasslands appreciates that the plan commits to “reviewing and updating mowing policies to ensure sensitive areas are identified and protected” (pg. 19). While mowing is important for bushfire protection, access and green space, mowing unfortunately results in the spread of weeds and creation of conditions in which they can flourish. It also stopping natural regeneration of locally-native trees and shrubs, which further increases the risk of weed invasion. On many occasions in the past, there have been conditions attached to mowing in sensitive areas of urban lands, but there has been limited success in their implementation (and little assessment of their effectiveness). We do recognise that mowing guidelines have been successfully implemented where mowing is excluded from marked conservation areas.
Additionally, there also seems to be a disconnect between mowing crews and wider plans and goals of UOS management. There are too many examples of new plantings being run over by the mower or mowers encroaching within agreed ‘no mow’ areas.
Fire management and ecological requirements may mean that a more nuanced management regime is required. This would consider other methods of understory/shrub biomass control such as cool burning and determining areas where regular mowing is not required.
- Friends of Grasslands recommends that further information on the considerations and potential negative impacts of mowing on ‘areas of environmental significance’ is provided within the plan to assist land managers when planning mowing activities.
A key omission of the plan, and a potential major cause of weed establishment and spread, is that the UOS estate is subject to regular disturbance through the installation and maintenance of major infrastructure, such as telecommunications, water, sewerage, electricity, and gas. The works associated with such infrastructure typically take little consideration of impacts to remnant vegetation or surviving elements such as patches of native grass, that are of importance for future enhancement activities. Furthermore, restoration of disturbed areas is often rudimentary, utilises exotic rather than local species, and is not monitored or maintained once work has been completed. It is important that restoration of a site not be considered complete until restoration targets have been met. For example, a target could be achieving control of ‘Weeds of National Significance’ and that the overall weed cover be below a certain percentage of ground cover (e.g. 10%).
- The plan needs to address management of infrastructure and provide clear guidance as to what needs to be considered prior to works commencing, with an emphasis on identifying key biodiversity areas and ensuring that all reasonable measures will be taken to minimise impacts.
- The plan should require all infrastructure works within the UOS estate to develop a restoration plan, with maintenance (especially weed control) to extend two growing seasons after completion of works.
- Friends of Grasslands recommends that regulations are developed in this plan for the protection of the environment from weeds introduced through disturbance associated with infrastructure.
The UOS estate has often been an entry pathway for high-risk weeds such as Bridal Creeper (Asparagus asparagoides), Madagascan Fireweed (Senecio madagascariensis) and Feathertop Grass (Cenchrus longisetus). TCCS has placed a high priority on controlling these plants, among many others. The need to continue vigilant monitoring should be mentioned in the plan, including encouraging the reporting of possible new incursions by the general public via Canberra Nature Map. Additionally, there needs to be continued effort to identify potential new invasive species and develop a prioritisation framework together with other land managers in the ACT, ensuring that it is compatible with other governmental jurisdictions (both local and interstate). The development of appropriate treatment methods for these weeds, as well as guidelines for follow-up actions after treatment has been conducted, would greatly aid in the protection of the environment from invasive plants.
- Friends of Grasslands recommends that these elements of weed management be addressed within the Urban Open Space Land Management plan.
Weed management is also identified as one of the primary undertakings of volunteers in the UOS estate (pg. 21). The section on ‘Weed (pest plant) control’ states that both chemical and mechanical forms of weed control are used in the UOS estate. Despite this, it is ambiguous as to whether this extends to volunteers. Allowing volunteers access to chemicals and power tools, after completing mandatory training, would greatly assist in their undertaking of weed management activities.
- Friends of Grasslands recommends that guidelines are revised to expand volunteer use of chemical and mechanical weed management strategies.
Much of the UOS estate before the development of Canberra was grassland or grassy woodland. The health of these ecosystems depends on control of biomass to avoid accumulation of senescent grass tussocks that may smother forbs and create habitat unsuitable for many threatened fauna species. Cool controlled burning, generally in winter or autumn, is now recognised through scientific studies to be an important tool to maintain biodiversity. Such burning has additional benefits, especially for reducing wildfire risk and for weed control.
- Friends of Grasslands recommends that TCCS allocate resources and further collaborate with PCS fire staff to enable more strategic burning. The priorities should be the designated ‘areas of environmental significance’. The TCCS-PCS autumn 2022 burn at Blue Gum Point, Yarralumla is an example of best practice.
It is important to note that the draft Territory Plan recognises that the fundamental goal of the UOS estate is to provide an appropriate quality, quantity and distribution of parks and open spaces to meet the recreational and social needs of the community. This places environmental outcomes as secondary in the UOS estate, when in reality there are many biodiversity values that can be compatible with recreational and social outcomes. This is reflected in the typologies, with most ranking the environmental/ecological value as “Low”. However, the need to derive co-benefits for the environment and the community will increase in importance from a management perspective as the urban footprint increases, thus increasing the size of the UOS estate required to continue providing an appropriate quantity of parks and open spaces.
- Friends of Grasslands recommends that the Urban Open Spaces Land Management plan recognises that co-benefits for the environment, or the potential to create them, exist across all land typologies.
- Further, we urge greater recognition of the importance of areas of conservation value have significant benefits for wellbeing, and provision of functional roles.
Strategic and guiding policies
Friends of Grasslands welcomes the inclusion of the ‘ACT Native Woodland Conservation Strategy and Action Plans’ within the policies (pgs. 73-75) that have guided the development of the Urban Open Space Land Management Plan, and rightly recognises the importance of woodland areas of significance that occur in the UOS. Adherence to this policy will ensure that management of native woodlands will be conducted in an appropriate manner. However, Friends of Grasslands note the absence of other key strategies are omitted, importantly, the ‘ACT Native Grassland Conservation Strategy and Action Plans’, to ensure that grasslands will receive a similar level of appropriate management.
- Friends of Grasslands recommend that the following publications be explicitly included within the guiding policies to guide the plan:
* ACT Native Grassland Conservation Strategy and Action Plans,
* ACT Nature Conservation Strategy; and
* the notifiable instruments NI2018-536 (Nature Conservation (Loss of Mature Native Trees) Conservation Advice 2018) and NI2019-833 (Nature Conservation (Unnatural fragmentation of habitats) Conservation Advice 2019).
We can be contacted on the above email.
Professor Jamie Pittock
President, Friends of Grasslands
15/8/2023 Conservation Council and Friends of Grasslands, 2022, BRIEFING_BIODIVERSITY NETWORK _Final_Version_December (conservationcouncil.org.au)