Friends of Grasslands
supporting native grassy ecosystems
PO Box 440
Macquarie ACT 2614
Projects, Parks and Conservation Service,
PO Box 158,
Canberra ACT 2601
Molonglo River Reserve: Draft Reserve 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 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.
For more than ten years, FOG has been concerned about the impact of urban development on threatened communities and species in the Molonglo Valley, including along the River, and has made numerous submissions to both ACT and Commonwealth governments about these concerns.
The Molonglo River Reserve Draft Reserve Management Plan (the MRR MP) is sound as it stands, in providing high level aspirational objectives and actions. However, FOG is very concerned that it does not directly guide decision-making and that it is not compatible with the NES Plan in several ways. We address these concerns below. In addition we have provided specific comments in an attachment to this letter.
1. Outstanding planning decisions
FOG believes that the Management Plan omits many planning decisions that should be incorporated into the Plan and considered as part of the public consultation process. Particular omissions include:
- resolution of the buffer designed to protect Kama Nature Reserve (NR) from detrimental management, as well as protecting the urban area from bushfire;
- details of how Pink-tailed Worm-lizard (PTWL) habitat and Kama NR will be managed to ensure conservation attributes (biodiversity, function and resilience to climate change) are not detrimentally affected as a result of their inclusion as part of a Strategic Firefighting Advantage Zone (SFAZ);
- other planning decisions that are currently unresolved as part of the proposed exemption to an EIS for Stage 3; and
- resolution of future uses for the Coombs Peninsular.
2. Lack of detail
We are fully aware of the difficulties of managing this area for conservation of critically endangered ecological communities, threatened species and a highly diverse landscape, at the same time as catering for the inevitable high recreational demand that will be placed on the Reserve and the river. We are also aware of the high pressure to undertake fire mitigation actions within the Reserve, due to the high risk of fire through the river corridor. In order to address these, we believe the Management Plan must be far more specific in its recommendations for management of high conservation value areas. Without doing so, there is a danger that ad-hoc responses to issues will occur when they arise, as well as resulting in a high degree of confusion by users and managers as to what management and/or uses are appropriate in any given area. We recognise that there will be a need to modify how things are done over time, but this is not a reason to omit specifics in a plan that is supposed to identify and guide on-ground management over an extended period.
We refer you to the draft Ginninderry Conservation Area Management Plan, which contains a chapter that details strategies for managing specific parts of the Reserve, including practical and specific management actions, specific identification of short, medium and long term actions, and detailed methods to evaluate outcomes. In addition, actions are prioritised. We believe this is a model for the MRR MP.
If the MRR MP is not modified we believe there is another level of documentation that will need to bridge the gap between the Management Plan and the operational plans and recreational guidelines.
Examples where the MRR MP is not adequately specific include:
- While the Plan acknowledges that pressures of use are likely, it does not adequately address how management will minimise conflict and disturbance. We do not believe there is adequate guidance in the Plan to identify whether the objectives defined in the Management Plan will be achieved.
- The Plan does not distinguish between the different uses to be made of the urban areas adjacent to reserves, rural areas (mostly downstream from Coppins Crossing), smaller disturbed areas and the high value conservation areas. With the exception of PTWL habitat, specific areas in which recreation will not be allowed are not identified. Only generalised principles are presented to indicate how conservation areas will be managed to retain their conservation values. Operational Plans are used to guide short-term management and are not subject to community scrutiny – it is not adequate to identify the location and management guidelines for those discrete areas (objective 5, P. 86) in these lower level documents.
- On-ground (as opposed to aspirational) targets or desired outcomes are not identified, nor are methods identified as to how they will be evaluated.
- There are no clear and achievable mitigation plans identified in case of disturbance to the Reserve or to species within the Reserve.
3. Lack of protection of Kama Nature Reserve from urban disturbances
A major flaw in the Plan is the omission of a defined buffer zone for Kama NR, including its width, management, and the land uses that will occur within the buffer to mitigate against disturbance to the Reserve. The ACT Bushfire Management Standards define the width of bushfire asset zones depending on the vegetation type and likelihood of wildfire, and the current Strategic Bushfire Management Plan has been available for some years. Given that these documents should define the buffer requirement for Kama NR, we do not understand why this is not specified in the MRR MP.
The NES Plan states that there is to be a Management Plan for Kama NR; if the MRR MP includes that plan it is significantly inadequate to guide management of this important reserve.
4. Fire protection and conservation within the Reserve
The NES Plan identifies that no fire fuel actions that may have adverse environmental impacts or that may damage to habitat for threatened species or fire-sensitive species are to be undertaken inside Kama NR.
SFAZ actions that will be undertaken in Kama NR need to be identified, including whether any of these actions will or may impact biodiversity, and, if they are found to impact biodiversity, what will be done to alleviate those impacts.
In addition, parts of the reserve south of the river in various locations, including high quality PTWL habitat, are defined as Outer-Asset Protection Zone. This is incompatible with the NES Plan statements for protection of habitats of threatened species.
5. Dogs and protection of conservation are incompatible
FOG believes that dogs should only be allowed (on-leash) in the Reserve in recreational hubs along the river, and not allowed at all in conservation areas. Alternative areas should be utilised outside the Reserve to exercise dogs and to provide opportunities for bike-riding and walking, to prevent damage to the landscape and biodiversity.
6. Out of date references and material
The Plan was drafted in 2014. Since then significant publications and research have become available that require the plan to be updated. These include the 2017 Native Grassland Strategy and Action Plans and draft Riparian Strategy, more recent studies including habitat use of the Little Eagle and Superb Parrots within the Molonglo corridor, and fire regimes for biomass management in native grasslands (see Land of Sweeping Plains, for example).
7. Lack of knowledge gained from management of the Molonglo River Reserve
The Reserve has been managed for conservation since before 2014. The Plan does not reflect knowledge gained as part of that process, for example the habitat restoration trials that have successfully increased habitat for the PTWL.
22 March 2018
Attachment: specific comments on the Molonglo River Reserve Draft Management Plan
Page 11 - 17, summary table:
1. Land designations, management zones and boundaries
The lack of determination regarding the width and use of the eastern buffer to Kama gives no surety that this objective, policy and actions will be met
Are any proposals for lands bought up by ACT government (LDA) going to compromise this objective, policy and actions in any way?
2.1.1. (Geology) Avoid significant….. but if unavoidable….
This is a weak action when the objective is to conserve the condition of the heritage geological site
4.2.1. Select a set of views….
FOG believes that the Coombs Peninsular would be an ideal place to meet this objective and action. It would then serve a dual purpose: to meet this objective and to continue to be a fire asset zone that mitigates against having to utilise the river corridor (and PTWL habitat) as an outer asset zone. This would minimise impacts on other parts of the river corridor.
An additional way to achieve this objective is to create an elongated park above the reserve that includes extensive dog off-leash areas as well as providing picnicking, cycling and other recreational activities.
5.1.4. Implement the adaptive management strategy for the NES areas….
Add an additional statement in the above action or a new action: document requisite changes in management to ensure management actions are well understood and consistently applied.
6. Raise the ecological condition in the river and riparian zone to support the recovery of native fish in the river.
FOG recommends an additional action: undertake programs and projects to educate the community and involve the community in actions to reduce degradation of habitat
7. Achieve fire protection for people and property in ways that also effectively protect threatened habitat and other ecological conservation values.
FOG recommends an additional action: Need to identify an action that relates specifically to fire protection that does not compromise Kama as an EEC, nor threatened and other species
18. Achieve productive working relationships with neighbours that contribute to maintaining Reserve values
FOG recommends an additional action: establish and support a Friends of/Parkcare group
20. Inform future decision making with a structured, evidence-based process
Given management has been undertaken now for approximately four years (in line with the earlier drafts of the plan and the then unpublished management guidelines, it is probably relevant to undertake a review of progress against objectives now, not waiting for five years from when this management plan is completed and published.
Page 33, Table 3.1 and page 35, Figure 3.1
Although criteria are included in Table 3.1 to guide the identification of a buffer that will mitigate against edge effects on Kama NR we believe it is a critical omission not to identify the boundary of the buffer and its management within this plan. The criteria are not specific enough to ensure that Kama is adequately protected from actions that may compromise biodiversity condition and integrity in the reserve. It is imperative to apply the precautionary principle. In the Plan the buffer should not be identified as urban area (Figure 3.1). The buffer should not determined in-house without public consultation.
Pages 34, 35, Figure 3.1
Does this map reflect changes potentially identified in the Application for an exemption of an EIS for Molonglo Valley Stage 3 urban development? We believe there are modifications identified in the application for an exemption that are not consistent with the NES Plan, about which FOG has considerable concerns.
See also comments on Summary 4.2.1 above – as the future has not been determined for Coombs Peninsular we believe it is misleading to identify it as urban land. We believe the peninsular would be an ideal and very popular recreational area.
Page 68, figure 6.1
The key for the pink area Grassland supporting pink-tailed worm-lizard (incl. buffer in the urban section) should also indicate that this grassland contains areas of the Critically Endangered Natural Temperate Grassland (Rocky Grassland) as identified in the recent ACT Native Grassland Conservation Strategy and Action Plans.
Pages 12, 75, 80, 86
References to ACT Aquatic Species and Riparian Zone Conservation Strategy ‘Ribbons of Life’ should also include (or be replaced by) the ACT Aquatic and Riparian Strategy and Action Plans, a draft of which was recently released for comment.
Pages 73, 74
Update reference from Action Plan 27 to the recently released ACT Native Grassland Conservation Strategy and Action Plans.
Also, in relation to Action Plan 28, make reference to the Woodland Strategy Review, which, we understand, is expected to be finalised later this year.
Page 74, section 6.3.2
The management plan should include management objectives and actions for the Natural Temperate Grassland (NTG) remnants occurring in the Reserve, especially those areas forming part of PTWL habitat. In particular, it would be worth including text along the following lines: “Knowledge of grassland management is developing rapidly and, as appropriate, lessons learnt will be applied to improve the functioning and diversity as grasslands during the life of the plan”.
Page 74 section 6.4, Dryland Mix
Although these areas are disturbed, there are significant advances in revegetation techniques that could be used to improve condition. However, we are supportive of the identification of these areas to be utilized for a higher level of pressure from recreation. Recent trials have resulted in improvement of PTWL habitat leading to repopulation by PTWL.
Pages 80 - 85, section 6.7
This entire section is very general and does not help guide on-ground actions. Far more specific actions should be described for on ground management. These should be based on the identification (in this Plan) of areas of conservation significance and of recreational hubs.
Ensure an adaptive management approach is identified, and ensure research is incorporated, including opportunities to trial and/or incorporate traditional aboriginal fire management practices.
Page 83, 6.7.4
It is not clear what management will be undertaken if the proposed measures are not sufficient for fire mitigation, and/or have a negative impact on the values of Kama. The paragraph reads that management will be consistent with guidelines for conservation of Box Gum Woodland (BGW) and NTG, and if these cannot be met, then the actions need to maintain fire protection requirements consistent with the Ecological Guidelines for Fuel and Fire Management Operations and the Molonglo River Reserve and Offset Areas Ecological Management Guidelines (insert ref Sharp et al., 2015). Because the fire guidelines and management guidelines are based on the guidelines for conservation of BGW and NTG they will not differ. This needs far better clarification, not only because the argument in the paragraph is circular, but it also does not provide any guidance as to how Kama NR will be managed, or any assurance that the ecological condition of Kama will be adequately maintained. While monitoring is imperative, it takes years before changes can be confidently identified as significant. The Precautionary Principle must be applied, and this includes ensuring there is a significantly wide buffer between the reserve and urban areas where high level fire fuel management can occur without any compromise of values within Kama and very clear and specific guidelines for management within Kama NR.
Page 102, 9.4.1
“If there are no other alternatives for routes, raised walkways that minimise impact on habitat will be used”. High quality habitat areas and areas that are known to contain PTWL should not have any trails going through them. Trails should be routed through the urban fringe in these areas. Again, if recreational hubs are identified the location of trails can be defined.
Page 102, 9.4.2 and page 104, Figure 9.1
Figure 9.1 is of “indicative trails”, but the text implies that a number of other bridges and trails will be added to the river reserve in the future. Clarification of the number of trails envisaged is needed, where they will be situated and why they are required, together with some limitation on the number of trails to be added in the long term. FOG recommends that a statement be added that route design will not impact on high quality habitat or known PTWL populations, and will avoid fragmentation of habitat.
This is another example of the short-comings of having an aspirational document with continued bets each way in case situations change – there is no clear identification of what will occur where in the reserve and how disturbance and damage will be prevented.
Page 144 (appendix 6)
Do the statistics for NTG include the rocky grassland identified in figure 6.1 (page 68) as PTWL habitat?
Page 147, Appendix 8 table 2.7
In relation to fire management of grasslands, it states “There is (sic) currently insufficient data to estimate the maximum interval, but some evidence indicates it would be approximately 10 years.” This statement requires further elaboration, to ensure it reflects the need for updating ecological burning intervals if research and other evidence suggests a change to the maximum (or minimum) interval; FOG understands that there is research suggesting that burns should be undertaken more frequently in native grasslands. FOG recommends that a flexible approach needs to be taken in terms of location, season, intensity and frequency.