Ms Carma Sweet
Director, Policy & Planning,
Urban Treescapes Section
City and Environment Directorate

Carma.Sweet@act.gov.au

 

Re. Municipal Infrastructure Standard 25 Plant Species for Urban Landscape Projects (Ed 1 Rev 2)

Dear Ms Sweet,

Friends of Grasslands (FOG) and the Conservation Council ACT Region (Council) (together, ‘we’) appreciate the opportunity to comment on the above revised document (MIS 25).

MIS 25 includes objectives to:

We are concerned that inclusion of some species listed will likely continue to create future management problems, i.e., those species identified previously as “sleeper weeds” (identified in Attachment 1). These species are already invading public areas and nature reserves. It is highly likely plant species identified as sleeper weeds will become even more invasive in a changing climate.

We urge you and the ACT Government as a whole to demonstrate responsible ecological leadership by not using and promoting invasive species. Invasive species are already a resource drain for government staff and landcare volunteers managing nature reserves and landcare project sites.  It devalues their work as they battle weeds such as firethorns, Pyracantha spp., cotoneasters, Cotoneaster spp., as well as other invasive plant species commonly planted in Canberra’s urban open spaces and gardens many years ago, prior to their removal from government planting lists and nursery stocklists. 

We note with approval that MIS 25 now has a section on ecological landscape considerations, and that some of the sleeper weeds are now recognised as “species plants and restricted use plants” that will be “limited to particular applications and locations within Canberra’s environment and urban landscapes. All special plant species require written approval from CED prior to planting”. 

In our view, a better approach would be to phase out using sleeper weeds because of the ease of dispersal of their seeds, either by wind (in the case of the ashes, Fraxinus spp., and Chinese Elm, Ulmus parvifolius), or by fruit‑eating birds (especially the Pied Currawong), in the case of Callery Pear, Pyrus callereyana.  A large bird like a currawong can fly several kilometres with its crop full of seeds before it will disperse those seeds in an urban park or nature reserve; as a result, limiting the use of these plant species to particular distances from such areas (exclusion zones) is inadequate.

We note that the document states “all planting within, or adjacent to, high-value ecological communities should aim to utilise planting stock that is grown from Southern Tablelands provenance” (underline added). This requirement should be modified by adding that locally indigenous species should be carefully sited to ensure that they are appropriate to the topographical position.

We reiterate our concern that the sleeper weeds, particularly the ashes, Fraxinus spp., Chinese Elm, Ulmus parvifolia, and Callery Pear, Pyrus callereyana, should be phased out of use via MIS 25. Of concern too is Pittosporum tenuifolium (for more information, please see Attachment 1).

We note that a number of previously identified sleeper weeds are now on the “Deleted Species List”, including Agapanthus africanus, Arbutus unedo, Fraxinus angustifolia subsp. oxycarpa, and two other Fraxinus cultivars, Nandina domestica, Pyrus ussuriensis, two Ulmus parvifolia cultivars, and Viburnum tinus.

We urge the ACT Government to consider this submission seriously and trust the above-listed sleeper weeds will be removed from the recommended lists and join the deleted species list.

Yours sincerely,

SIGNED

SIGNED

Prof Jamie Pittock

President, Friends of Grasslands

13 July 2026

Dr Simon Copland
Chief Executive, Conservation Council ACT Region

13 July 2026


Attachment 1


About us

FOG is a community group dedicated to conserving grassy ecosystems in south-eastern Australia, including natural and temperate grasslands and grassy woodlands. Our members include professional scientists, landowners, land managers, and members of the public, all committed to protecting these landscapes for the long term.

The Council is the peak non-government environment organisation for the Canberra region. Since 1981, we have spoken up for a healthy environment and a sustainable future. We campaign for a safe climate, to protect biodiversity in urban and natural areas, to protect and enhance waterways, reduce waste, and promote sustainable transport and planning for our region.