Office of Nature Conservation
City and Environment Directorate

Re. The draft ACT Nature Conservation Strategy 2026-2036 (the Strategy)

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.

Thank you for the opportunity to comment on the Strategy. FOG has assisted in the preparation of the submission of the Conservation Council of the ACT (Council). FOG supports the Council’s submission. Recommendations included in the Council’s submission are not repeated here.

FOG consider the grassy ecosystems in the lowlands of the northern ACT to be of the highest priority for conservation given their historic very severe decline in extent and condition, and given this is where rapid urban expansion is expected to continue over the next decade. We refer here to the two ecological communities already protected from loss to highest possible degree, i.e., Natural Temperate Grassland (NTG) and Box‑Gum Woodland (BGW). Both are listed as threatened under the Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act) at the level critically endangered.

If implemented, the management planned in the Strategy will be robust. FOG commend the plans to:

• complete value and threat assessments, to guide the prioritisation of management interventions, improve understanding of ecological processes and to assist in evaluating the effectiveness of management interventions
• emphasise standardised data collection with protocols and standards for data capture, storage and management
• complete the spatialised community conservation guide to ‘prioritise threat management and ecological restoration’
• review the Biodiversity Sensitive Urban Design guideline
• adopt the Resist Accept Direct Framework which we believe will help to promote a shared language on climate change and make trade-offs clear in decisions on a wide variety of matters.

FOG and the Council have been promoting landscape scale planning via our ‘Biodiversity Network’ initiative for years, so of course we are delighted a Nature Conservation Network (NCN) will be established. Our proposal has called for the identification, permanent protection and coordinated management of all high value grassy ecosystem sites, on any tenure, outside the ACT’s protected areas.[1] A few points follow concerning how the two proposals relate.

At the next level down, FOG is open to supporting the establishment of Priority Conservation Areas within the NCN, including within the ACT’s protected areas. Outside protected areas, it is our hope every portion of the NCN will be ‘provided legislative protection’ and contribute ‘to ensuring the long‑term persistence of priority conservation values under current and future climate.’[2]

At a time when we are encouraging the ACT Government do more to protect and support grassy ecosystems, our doubt relates to the wisdom of focusing resources on reduced areas; this makes sense for some aspects of management but not others. The Strategy needs to demonstrate establishing PCAs will result in greater efficiency and effectiveness overall, and that focusing resources on less area (in hectares) is not an abrogation of responsibility.

Realising Nature Positive outcomes will depend on gains exceeding losses over time. While for grassy ecosystems the impacts of losses will be immediate and permanent, the outcomes of restoration works are not expected in the Strategy’s term of influence. The NCN will need to be retained and managed effectively over time.

FOG hold three primary concerns about the way the Strategy presents this bargain. First, resourcing. The Strategy is clear. The implementation of planned actions, and therefore the achievement of planned targets and outcomes, will depend among other things on ‘new financing mechanisms’ and ‘the ACT Government’s appetite for needs beyond business as usual’[3]. Relevantly:

• ‘Business as usual’ has seen grassy ecosystems continue to decline in extent and condition recently.[4]
• The only new financing mechanism mentioned is ‘restoration contributions’, i.e., offset funding. In our view, funds from offsetting alone will not be sufficient to enable the level of restoration needed to sustain let alone improve grassy ecosystem extent or condition in the northern ACT.
• There is no evidence of a strong commitment to resource the implementation of this Strategy. The achievement of its Nature Positive ambition is therefore extremely uncertain within, let alone beyond, the Strategy’s term of influence.

In FOG’s view, a significant uplift in recurrent funding is needed to ensure the Strategy is properly implemented, including for the Parks and Conservation Service who we hope will be custodians of the NCN outside land leased to private interests. Given the scale of the historic decline in grassy ecosystem extent and condition, and the many pressures mounting on the ACT’s environment, there is a clear need for more recurrent funding.

Second, the Strategy gives FOG no sense of whether the PCAs that will be identified outside the ACT’s existing protected areas will be ‘adequate’, sufficient to provide ecological viability and integrity of populations, species and ecological communities at a bioregional scale, where adequacy is taken to incorporate ecological viability and resiliency for ecosystems.[5]

Third, the Strategy gives FOG little confidence the NCN including PCAs identified outside the ACT’s existing protected areas will be permanently protected, meaning there is no assurance gains made there will endure through time.

FOG urge the ACT Government to permanently and securely (legally) protect the NCN. If outside the ACT’s protected areas the NCN is given no more than conserved area recognition, the NCN will be at perpetual risk of complete loss. The National Other Effective area-based Conservation Measures Framework is very clear on this, stating:

Consent for a site to be recognised as a Conserved Area can be withdrawn at any time, including after a site has been recognised. If consent is withdrawn, a site would no longer be recognised as a Conserved Area.[6]

While commitments to manage areas for conservation are always welcome, intentions change.

In his review of national environmental law, Professor Graeme Samuel calls for Nature Positive outcomes and states offsets must be “ecologically feasible and deliver genuine protection and restoration in areas of highest priority.”[7] For FOG, this quote brings together key aspects of our concern.  

Absent detail about the adequacy of the NCN, absent detail about its protection, and absent detail regarding how restoration contributions and offsetting in general will work in the ACT, the feasibility of the Strategy’s Nature Positive promise is open to question.

If the ACT Government is serious about achieving Nature Positive outcomes, we urge you to improve the Strategy now. Apply the mitigation hierarchy fully, and with rigour. Propose and require adequate compensation for future losses of BGW and NTG, sufficient to genuinely contribute to Nature Positive outcomes overall. Provide detail about your environmental offsetting regime. Confirm it will be transparent and enforceable, giving civil society detail about how it will deliver accountable and measurable improvements in ecological outcomes, sufficient to demonstrate the achievement of net gains. Above all else, resource the implementation of the Strategy.

FOG see no good reason for delaying until 2029 the making of the conserved area and restoration contribution policies or the ACT Landscape Plan (or a Bioregional Plan if that is what the Landscape Plan becomes[8]). Equally problematic is the delay enacting complex amendments to the Nature Conservation Act. All these plans and laws are needed quickly to support the implementation of this Strategy.

Other points of interest and concern to FOG include:

• Recognising broad-scale planning, development and conservation decisions involve fundamental trade-offs that will shape the ACT for the long term, FOG seek an opportunity to at least observe if not participate actively in the PCA identification process described on pages 5-6 of Supplement B.
• The Strategy needs to consider providing for the enactment of different legal protection mechanisms needed for different purposes, i.e., different mechanisms to protect the relatively intact, i.e., the critically endangered grassy ecosystem remnants, and the less intact, the areas under restoration.
• The Strategy should confirm a presumption that, wherever leaseholders execute protective instruments using a secure mechanism, further leases will be granted for long periods.
• We would like confirmation the ACT Government will:

o   take action to resist and override for the ACT provisions in legal mechanisms that would otherwise enable lengthy ‘maintenance periods’ in the management of grassy ecosystem sites under rehabilitation, restoration or repair – periods which ‘begin when the outcome intended by an offset activity has been achieved’[9] – grassy ecosystems need ongoing management

o   continue the fight against weeds and pests with further investment in a specialist Biosecurity team, on-ground management by trained Government officers, adequate funding for weed contractors, and training and support for the volunteer workforce

o   establish the Parks and Conservation Service as the custodian of the NCN (outside land leased to private interests), and ensure it is staffed and resourced appropriately

o   establish the NCN (or PCAs) over more tenures than Urban Open Space and rural leases

o   increase collaboration with the managers of National Land to deliver outcomes needed across the ACT.

Yours sincerely

SIGNED	SIGNED	SIGNED
Professor Jamie Pittock President Friends of Grasslands 27 March 2026	Julia Raine Vice President Friends of Grasslands 27 March 2026	Matt Whitting Vice President Friends of Grasslands 27 March 2026

References

[1] Friends of Grasslands Inc & Conservation Council ACT Region (2022) Briefing: Building a Biodiversity Network Across the ACT, https://conservationcouncil.org.au/wp-content/uploads/BRIEFING_BIODIVERSITY-NETWORK-_Final_Version_December.pdf

[2] Strategy, Targets 5b and 5a, respectively

[3] Strategy, p. 24

[4] Conservator of Flora and Fauna (2024) ACT Nature Conservation Strategy 2013-23 - Progress Against Implementation Plan 2 (2019-23), https://www.act.gov.au/__data/assets/pdf_file/0009/2779344/act-nature-conservation-strategy-2013-23-progress-against-implementation-plan-2.pdf, pp. 7-8

[5] Natural Resource Management Ministerial Council (2009) Australia’s Strategy for the National Reserve System 2009–2030 www.dcceew.gov.au/sites/default/files/documents/nrsstrat.pdf, p. 10

[6] DCCEEW (2024) National Other Effective area-based Conservation Measures Framework, www.dcceew.gov.au/sites/default/files/documents/national-oecm-framework-2024.pdf , p. 16

[7] Samuel, G. (2020) Independent Review of the EPBC Act – Final Report, www.dcceew.gov.au/sites/default/files/documents/epbc-act-review-final-report-october-2020.pdf , p. 140

[8] Orr, S. (24 March 2026) Ministerial Statement Conserving Nature in a Growing City and Government Response to Special Report by the Commissioner for Sustainability and the Environment Close to the Edge, an Investigation into the effects of urban expansion on the environment of the ACT (2025)

[9] National Environmental Standard (Environmental Offsets) 2025 EXPOSURE DRAFT, https://storage.googleapis.com/files-au-climate/climate-au/p/prj38a8e553bef96ceb5490c/page/Draft_Offsets_Standard_legislative_instrument.pdf, s 9(5)