Conservator of Flora and Fauna

Re. Draft Controlled Native Species Management Plan: Eastern Grey Kangaroo (Buru)

Friends of Grasslands (FOG) is a community group dedicated to the conservation of grassy ecosystems in south-eastern Australia - natural temperate grasslands and grassy woodlands. FOG advocates, educates and advises on matters to do with the conservation of these ecosystems, and carries out surveys and on-ground work. FOG is based in Canberra, and its members include professional scientists, landowners, land managers and interested members of the public.

Introduction

FOG fully supports the plan to control Buru populations, and the sensitive approach of the plan to balance the welfare of the animal and the ecological and human welfare issues created by the numbers of animals within the ACT urban, peri-urban and rural environment and concern expressed by many members of the community about culling per se.

In particular we support:

1. the protection of other environmental values, such as threatened species and plant diversity, from the impacts of Buru overgrazing;
2. the need to consider total grazing pressure, including from rabbits, in management decisions and actions;
3. the proposed culling methods;
4. the inclusion of the evaluation and reporting schedule, including transparency in the communication of the reporting;  
5. incorporation of Ngunnawal values and knowledge in terms of inclusion of cultural values and respect for cultural practices;
6. support for the cultural and other non-commercial uses of Buru carcases;
7. inclusion of background information on past culls, ecology and other key information; and
8. identification for the need to undertake surveys in conservation areas outside CNP and on rural land.

Recommendations

Our major recommendations are summarised below, not in order of priority, with more detail and inclusion of other minor points provided in the Attachment.

Recommendation 1: Integrate requirements identified in the plan for more than just economic viability in conservation areas that are in horse paddocks and on rural lands (p.44) and other land.

Conservation areas occur across the landscape – not just reserves but also other land managed by Parks and Conservation Service (e.g. Travelling Stock Reserves, other public land), City Services, and rural lessees are required under Land Management Agreements to conserve existing areas of Box-Gum Woodland and Natural Temperate Grassland and threatened species habitat.

Recommendation 2: In referring to managing Buru in an ecological context, identify that other forms of management are used to control biomass management and maintain ecological values.

Buru management of grassland structure (also grassy woodland) is only one means to control biomass for ecological outcomes (i.e., on or influencing nil tenure conservation areas) as well as biomass management. We disagree that the statement, ‘the preferred way of influencing grassland structure (ACT EPSDD 2019)’ is correct in the context of ecological outcomes.

Recommendation 3: Provide definitions either in the text or as a glossary.

Unclear terminology includes:

• P. 33, 34, 42 ‘the ‘safe operating environment’: is this just a grass height of 5 – 12 cm or does this have a wider meaning? Clarification is needed as to meaning: safe for who or what – culling exercises, for ecological outcomes for Buru or other native species? Interim Outcome H makes no sense without a definition of a ‘safe operating environment’.
• P. 41, SF.1: ’heterogeneity’: of what? structure, species diversity? Include diversity of species including fauna.
• P.30: ‘preferred way of influencing grassland structure’: preferred for what outcome, is it preferred over other management of herbage mass including cool burns or cultural burns?

Recommendation 4: Measures of ecological success should include the maintenance or improvement in species diversity and where appropriate the population numbers of rare or threatened species. 

p. 38: Measure of success of Buru management is defined as the desired grass structure and biomass. As described, the point step method does not measure ‘grassy layer composition’ as it does not measure native and introduced floristic or faunal ‘composition’. While grass structure and biomass are useful measures of success of control of Buru abundance, what is not indicated is compositional diversity (native/exotic, grasses/forbs and other non-grasses). This is a more important measure of ecological success.

Recommendation 5: Interim Outcome J.1, Re. incorporation of Ngunnawal values: Change the first statement to: J.1. Undertake consultation to discuss, develop and implement activities that will be implemented as part of this plan. Some key topics for agreement include….. 

We are disappointed that holding a meeting/s to discuss and develop activities will be identified as adequate to signify success of this five year plan implementation of Outcome 4, ‘Ngunnawal values and knowledge are incorporated into Buru management programs in the ACT’.

Recommendation 6: Evaluation and reporting (S. 5) must explicitly state that the reporting will be communicated to the public and ideally how this will be achieved. We endorse recommendations in the submission made by the Conservation Council relating to providing more conspicuous evidence to support the ecological and welfare considerations for culling.

Recommendation 7. Interim Outcome Q. Include serious injury to cyclists, drivers as a significant outcome of collisions with kangaroos. Include a mitigation measure to reduce speed limits on key roads during peak kangaroo times when kangaroos are that remain unfenced, eg Barton Highway.

Recommendation 8. In addition to the reference list, provide a list of sources of information and reports on the outcomes from the previous management plans.

We are available to discuss this further if it would assist in the finalisation of the Plan.

Yours sincerely

 

Professor Jamie Pittock
President, Friends of Grasslands

8 December 2025

---

Attachment. Additional information relating to the recommendations, other issues and concerns

 

Plan	Comments
P. 5 -6 Aboriginal Kangaroo Management	It may be worth mentioning here, or elsewhere in the plan, that for millennia Aboriginal landscape management included actions that favoured the concentration and hunting of Kangaroos. These actions included cool burns and precisely fired landscapes (see work by Bruce Pascoe and Bill Gammage).
P. 11. (a) for nature reserves and adjacent land — the Nature Conservation (Buru — Eastern Grey Kangaroo) Conservation Culling Calculator	Include mention of TSRs and other unleased public land managed by PCS.
P. 18 Other land	It is discussed later in the plan, but it should be stated here that other lands can share a Buru population with conservation reserves, such as the Buru population across Red Hill and the Federal Golf Course and Buru management needs to be consistent with the environmental objectives of the wider area
P. 30: Buru are therefore the preferred way of influencing grassland structure (ACT EPSDD 2019). As an ‘ecosystem engineer’ Buru also alter habitat structure through their grazing in ways that affect many other species (Jones et al. 1997; Wilby et al. 2001).	The highlighted statement does not equate to scientific evidence that using fire in particular, is equally important in influencing grassland structure (and plant composition). The plan should identify that Buru management is one way of achieving ecological and fire management outcomes across the landscape. Include reference to the role of burning and other grazing in control of herbage biomass, which ultimately impacts how Buru are managed.  In this vein, the statement on pp.30 and 32, Buru are therefore the preferred way of influencing grassland structure is misleading: explicitly understating the role of fire and controlled domestic stock grazing to reduce herbage mass and as a means to retain ‘green’ pick for Buru and other native herbivores and on rural properties, domestic stock, as a way to retain native plant and therefore fauna diversity, and Buru are preferential grazers, particularly grasses and most particularly Kangaroo Grass, their grazing can leave almost bare areas dominated by Kangaroo Grass while swathes of other native and particularly introduced grasses remain.
P. 38: Grassy layer composition is surveyed using a step-point survey within each monitoring plot and quadrat-based data is collected about dominant grass species, average grass height and the percentage of grass that is green to determine the current amount and Recent reviews have determined that previous Buru management has been successful by enabling target Buru abundance to be achieved and that the desired grass structure and biomass has been maintained	As far as we are aware, grassy layer composition, i.e. understorey plant species composition, is not surveyed using the point step method. Plant species composition is an important measure of ecological condition. Has the desired compositional diversity been maintained? What data are available that have investigated this?
P. 41 F.1 Undertake annual field surveys of grassy ecosystem condition in priority sites to collect data about dominant grass species, weed density, grass height, structure, heterogeneity and percent greenness of grass.	Heterogeneity of what – structure, species diversity? Include diversity of species including fauna
P. 44: 4.3.2. Outcome 5. Buru populations on rural properties and horse paddocks are maintained at densities that do not seriously impact the economic viability of the land. P. 45: Several ACT Plans emphasise the importance of rural lands and contain objectives for protecting rural productivity and sustainability (The Territory Plan, Vol 1: ACTPLA 2008: s. 9.1) and to ensure rural lands ‘should be retained and utilised on a sustainable yield basis whilst providing a distinctive rural landscape setting for the National Capital	Multiple plans, strategies and legislation recognise ecological values that require the maintenance of conservation values on leased and contracted land. Include consideration of conservation values on rural properties and horse paddocks.
p.49. Outcome 7: The incidence of vehicle-Buru collisions is reduced in the ACT	It seems that Buru are more likely to be involved in collisions when they are fleeing in panic from perceived threats such as unrestrained dogs or people running in areas that aren’t usually frequented by humans, close to busy roads. Discussion and commitment should be made in the plan to increase education and legal enforcement of the consequences of unrestrained dogs within reserves and need for park users to behave in a way that does not drive Buru onto busy roads.
p. 64. S6.2. Biology, Ecology and Conservation of Buru	Our understanding is that Buru are primarily grass not forb consumers, and experience in the field is that they have a significant preference for Kangaroo Grass. We recommend information on diet be included. Also impacts of drought on the welfare of Burus: study of kidney fat of animals culled in Belconnen Naval Station undertaken in the 2000 drought indicated starvation despite there being pouch and joeys at foot. I.e. culling of animals may be considered for their welfare, especially of contained populations.
p. 67 Table 5. environment	The following should be added as an additional important impact: Direct grazing of threatened plants which may prevent or delay flowering, reduce plant health or vigour, or result in direct loss.