ACT lowland native grasslands investigation:
Belconnen Naval Transmission Station

Discussion and Commissioner's recommendations

On 19 February 2008 the expert panel submitted its report which is at Attachment G (342 kB pdf). The expert panel’s report, submissions listed at Attachment E (10.5 kB pdf), and material provided by the Department of Defence and Territory and Municipal Services have all been carefully considered in developing the recommendations presented in this report.

In forming my recommendations the intent of all the recommendations made by the expert panel is respected as has been the advice received from the ACT’s Conservator of Flora and Fauna, Territory and Municipal Services (TAMS) Attachment H (513 kB pdf).

1. Should the natural temperate grassland and the threatened species within the grassland at BNTS be conserved?

Reasons for conserving the natural temperate grasslands and the threatened species within the grassland at BNTS are presented in the expert panel’s report (Attachment G (342 kB pdf), pages 1 and 2). Many of the submissions made to his investigation argued the importance of conserving the grassland at BNTS.

As previously mentioned in this report (page 8), the natural temperate grassland is one of the ACT’s most threatened ecosystems with only 1000 hectares remaining. The grassland at BNTS (approximately115 hectares) accounts for 12% of the remaining grassland and importantly this is also considered to be of high botanical significance. This site is important due to the grassland and also the presence of threatened species. Species, by their very categorisation as threatened are ones that are offered legislative protection. Accordingly, the answer to question 1 is a categorical yes and is reflected in the first recommendation on page 13 of the printed report.  

2. What is the current state of the natural temperate grassland at BNTS?

The expert panel undertook a field assessment of the site on the 25 January 2008 and concluded that despite recent rains the condition of the native temperate grassland over much of BNTS is still poor. Their analysis of the site is presented in some detail in their report (Attachment G (342 kB pdf), pages 4 to 7). I also visited the site with the panel and concur with their analysis.

The affect of over-grazing by kangaroos is well illustrated by photographs in the expert panel’s report.

Figure 1. Kangaroo enclosure on right showing response to resting over the spring and summer of 2007–08. Area on the left continues to be grazed. In the centre of the picture is an eroded area with scalding between the tussocks. Note the growth response of this patch is limited even with grazing removal. This is due to the condition of the soil restricting rainfall infiltration and the phenomenon that short-growing, low productivity species are most persistent in eroded areas (January 2008)

Kangaroo enclosure on right showing response to resting over spring/summer 2007-08

Figure 2: Historical grazing pressure at the BNTS has resulted in dominance by low-growing species. Combined with continuing grazing pressure, these small plants have failed to produce good grass cover despite favourable growing conditions January 2008).

Historical grazing pressure at the BNTS has resulted in dominance by low-growing species

Figure 3. Evidence of soil erosion: bare scalded areas between tussocks, individual tussocks remain raised while surrounding soil has washed away, leaving a lowered soil surface (January 2008).

Evidence of soil erosion: bare scalded areas between tussocks, individual tussocks remain raised while surrounding soil has washed away, leaving a lowered soil surface (January 2008)

Given the importance and condition of BNTS the expert panel recommended that urgent action be taken to protect the grassland and threatened species.

The expert panel's recommendation regarding this issue (Attachment G (342 kB pdf), page 8) is fully supported and is adopted as my first recommendation. 
  • Recommendation 1: Urgent action is to be taken to restore the ecological condition of the Grassland, and provide opportunities for the Perunga Grasshopper, Golden Sun Moth and Ginninderra Peppercress to survive and thrive at BNTS.

3. If the current state of the natural temperate grassland at BNTS is less than optimal, what is the cause?

The expert panel concluded that the cause of this is grazing pressure by eastern grey kangaroos (Attachment G (342 kB pdf), pages 7 and 8). They concluded that the current dense kangaroo population is preventing recovery of the Grassland by impeding biomass accumulation, preventing re-colonisation by less grazing tolerant, more productive Grassland plants and preventing the re-establishment of a soil crust of cryptograms (mosses, algae and lichens) on the bare ground between the tussocks&As the current growing season tapers into autumn then winter, the impact of kangaroos on the Grassland is expected to increase substantially (Attachment G (342 kB pdf), page 8).

4. What action is necessary to conserve the natural temperate grassland and threatened species that have the grassland as their habitat?

The expert panel recommended that there be immediate removal of all kangaroos from the BNTS and that this removal be completed before impacts on pasture biomass occur during the dormant winter growing season (Attachment G (342 kB pdf), page 9).

The ACT's Conservator of Flora and Fauna (TAMS), has advised that complete removal of kangaroos is not considered necessary to facilitate grassland recovery, particularly if an adaptive management approach is used. This approach would involve the number of kangaroos being adjusted according to prevailing conditions. The Conservator also indicated that the site is likely to recover if kangaroo numbers were at a level of approximately 1 per hectare (Attachment H (513 kB pdf), page 4). Currently the density of kangaroos is approximately 5 per hectare (588 kangaroos).

The Conservator highlighted the role of some kangaroos at BNTS regarding fertility control research. He argues that the BTNS site, particularly by being enclosed, offers opportunities not readily available at other sites (Attachment H (513 kB pdf), page 2). Research on kangaroo fertility is critical if kangaroo populations are to be managed so that ecological systems are protected concurrently with achieving a high level of animal welfare. The results of the research may provide all land managers with alternatives for managing kangaroo populations.

The option of accommodating research kangaroos on land immediately adjacent to BNTS was explored. These animals could have then been re-introduced to BNTS when the grasslands had recovered. As mentioned above, the Conservator did not consider it necessary to remove all kangaroos and was also of the view that such an approach could compromise research programs (Attachment H (513 kB pdf), page 5).

Taking into account the intent of the expert panel's recommendation and the information from the Conservator, the following recommendations are made:
  • Recommendation 2: Kangaroos are to be removed immediately from BNTS to achieve a stocking rate of 1 kangaroo per hectare or less. This is to be done by the land manager, preferably before the end of April 2008, to prevent impacts on pasture biomass occurring during the dormant 2008 winter season.
  • Recommendation 3: Kangaroo population numbers are to be maintained at the targeted level for the foreseeable future using fertility-controlled kangaroos only. A program to maintain this situation is to be implemented as needed. (This recommendation is made on the assumption that all remaining kangaroos at BNTS will be part of fertility control research programs.)
  • Recommendation 4: Further reductions in the number of kangaroos at BNTS (i.e. even below the proposed sustainable stocking rate of 1 kangaroo per hectare) is to occur if recovery of the grassland does not improve over the next growing season even if research projects are compromised.

The expert panel made a recommendation that all kangaroos re-introduced or dispersing into the BNTS must be subject to known and established fertility control measures and be incapable of breeding (Attachment G (342 kB pdf), page 12). This only applies if all kangaroos were to be removed from BNTS. However if the site were to accommodate kangaroos other than those part of a research program, I would agree that those animals must be subject to known and established fertility control measures and be incapable of breeding.

5. If action to conserve the natural temperate grassland requires removal of some or all of the kangaroos, what is the most humane method of removing the kangaroos within the constraints of the BNTS site?

Submissions from the community indicated that this issue was of great concern to several groups. Accordingly, the expert panel's membership was biased towards people with animal welfare expertise.

The expert panel considered non-lethal and lethal methods (Attachment G (342 kB pdf), pages 9 to 11). They found that shooting is the most humane method. However, the Australian Federal Police will not allow this method to be used at BNTS due to public safety concerns. The expert panel therefore  recommended that the kangaroos be removed from BNTS by sedating by darting followed by euthanasia by lethal injection. The Department of Defence (Defence) has advised that their contractor will be required to develop a specific method for capture darting. As part of this method, the contractor will be required to address animal welfare concerns including stopping work immediately if the kangaroos become stressed and there is to be a review of procedures if any kangaroos are injured during any stage of the procedure. I am also advised that there will be supervision by a qualified and experienced veterinarian at all times.

The expert panel also considered the alternative option of moving the kangaroos. The expert panel rejected this option because they did not consider that dart capture followed by release into the wild to be a better option. 

In light of the opinion of the expert panel that dart capture followed by release into the wild is not a preferred option, it would therefore not be appropriate for any export licence to be granted to the Department of Defence.

Furthermore, it is understood that the Conservator of Flora and Fauna does not intend issuing  translocation licences for the movement of kangaroos and that this is consistent with the policies stated in the first and third Kangaroo Advisory Committee reports. The Conservator has advised that the policy stated in these reports is as follows:
First Report: that translocation is not an appropriate management strategy for free ranging kangaroos in the ACT; and
Third Report: that although translocation can play a role in the conservation of threatened fauna, it is neither a humane nor an appropriate management technique for abundant species like eastern grey kangaroos in the ACT.

From discussions with officers in Defence it is understood that the option of moving the kangaroos to New South Wales is being explored.  It would seem that this could not occur unless the Conservator of Flora and Fauna granted an export licence to the Department of Defence (see sections 48 and 104 of the Nature Conservation Act).

The panel's recommendation and the Conservator's policy regarding this issue (Attachment G (342 kB pdf), page 11) are supported.

Recommendation 5 : Kangaroos are to be removed from BNTS by the most humane method suitable for that site having regard to advice from the AFP that firearms are not to be used at BNTS. (The Expert Panel has recommended sedating by darting followed by euthanasia by lethal injection.)

  • Recommendation 6: The policy of the Conservator of Flora and Fauna, to the effect that translocation of eastern grey kangaroos is not an appropriate management technique, is to remain unchanged and that this policy position be confirmed to the Department of Defence immediately.

The above policy includes the movement of joeys. However, I understand that a case can be, and in the past has been, put forward for exemption in exceptional circumstances. I therefore propose that the Conservator, on a case-by-case basis, consider any requests for exemptions.

6. How should the natural temperate grassland be managed in the future so that it and the threatened species are conserved?

From meetings with officers in Defence and TAMS, it is understood that Defence is currently developing a new management plan in consultation with TAMS, to protect the natural temperate grassland and threatened species at BNTS (grassland management plan). It is also understood that Defence, in consultation with TAMS, is also developing a kangaroo management plan for BNTS. The management plan will be designed to provide a management strategy for the on-going management of the key natural values, in particular the natural temperate grassland and the threatened species. The kangaroo management plan will be integrated with the grassland management plan to ensure that on-going management of the natural values are sustainable and complementary.

It is also understood that Defence plans to divest itself of their 143 hectares of land at Lawson, including BNTS, around June 2009, and that the grassland and kangaroo management plans currently being developed are focused on assisting Defence in their land management activities primarily until that time. It is understood that these plans will not address issues such as community access or give guidance on the appropriate forms of abutting urban development. As the Lawson site is proposed for urban development in the short to medium term it will be important that a long-term management plan (incorporating a range of issue including kangaroo management and research) be developed as well as the shorter-term plans currently being prepared by Defence. This longer-term plan could cover all temperate grassland areas.

The expert panel has recommended that an adaptive management approach based on clear management objectives, expressed in a long-term management plan, be taken to protect the natural temperate grassland, perunga grasshopper, and golden sun moth and ginninderra peppercress at the BNTS. This plan would therefore be an extension of the plans that are currently being developed by Defence.

I strongly support the development of the grassland management plan and the kangaroo management plan for BNTS currently being prepared by Defence. These management plans are essential for ensuring that a holistic approach is taken to managing the kangaroos and conserving the natural temperate grassland and threatened species within the secure area at BNTS. However, they should be considered as interim plans and incorporated into a long-term management plan that explicitly addresses issues such as the role of BNTS in the long-term with respect to kangaroo research, community access etc. This should be done prior to the development of the Lawson site so that there is a clear understanding of the role and purpose of BNTS and the opportunities available to the community to support the protection of BNTS. Accordingly, the following recommendations are made.

  • Recommendation 7: The interim grassland management plan and interim kangaroo management plan for BNTS are to be completed by the end of August 2008, by the land manager, in consultation with key stakeholders. These plans are to adopt adaptive management principles and be based on a stocking rate of 1 kangaroo per hectare or less prior to the 2008 winter.
  • Recommendation 8: Conditions at BNTS are to be reported on a quarterly basis to all relevant agencies and to the Commissioner's Office. The Commissioner is to establish an independent group to assist her evaluate progress and report on this in her annual report.

If Recommendation 8 is adopted the members of the expert panel could be part of the independent group.

  • Recommendation 9: A long-term grassland management plan covering BNTS is to be developed prior to the abutting Lawson lands being developed for residential purposes. This plan should incorporate clear management objectives and be based on an adaptive management approach to protect the Grassland, Perunga Grasshopper, Golden Sun Moth and Ginninderra Peppercress at the BNTS. (The interim grassland management plan and interim kangaroo management plan (Recommendation 7) should be incorporated into the long-term plan. This long-term plan could cover all ACT natural temperate grassland areas.)

Recommendation 9 respects the expert panel's recommendation on this issue (Attachment G (342 kB pdf), page 11). The long-term plan may require a cooperative effort between the current land manager and a future land manager given that BNTS may be under a different land manager as of mid-2009.

Given the importance of BNTS, the expert panel wished BNTS to be given a high level of legal protection (Attachment G (342 kB pdf), page 13). The panel understood that BNTS is to be transferred to the Territory. While this maybe the case I have worded my recommendation to accommodate a transfer to another entity.

  • Recommendation 10: The Territory is to ensure that legal measures are implemented to protect and preserve the high conservation value of the Grassland and its threatened species when the land at BNTS is transferred from the Commonwealth to another entity. (This recommendation is made on the assumption that Territory laws will fully prevail post the transfer.)

Memorandum of understanding

In September 1998 a memorandum of understanding between the Department of Defence, the then Commonwealth Department of Environment and the then ACT Department of Urban Services (the Memorandum of Understanding) was signed.  The Memorandum of Understanding appears not to have been terminated and therefore is still in operation.

Action Plan No. 28 called A Vision Splendid of the Grassy Plains Extended, made under the Nature Conservation Act, outlines conservation goals, objectives and actions for the natural temperate grassland and grassland dependent species including the threatened species of Golden Sun Moth, Ginninderra Peppercress, Perunga Grasshopper and Striped Legless Lizard. 

The Action Plan provides for the Commonwealth and the responsible ACT Department (namely TAMS) to keep the Memorandum of Understanding under review[1]. I understand from meetings with officers in Defence and TAMS that steps are currently being taken to review the Memorandum of Understanding.

I strongly support a review of the Memorandum of Understanding and encourage an emphasis on the coordination and sharing of research activities, monitoring results and evaluations. It may also be beneficial to ensure that senior management in both organisations are routinely briefed with the same information on site conditions, research, progress, and etc.

An up-to-date Memorandum of Understanding is essential for ensuring that in the future there is effective communication, cooperation and concerted action by the Department of Defence and TAMS to conserve the natural temperate grassland and the threatened species that depend upon that grassland at BNTS.

  • Recommendation 11: The review of the Memorandum of Understanding between the Department of Defence and ACT Government (TAMS) is to be completed by August 2008.

Notes:
[1] ACT Government, 2005 A vision splendid of the grassy plains extended: ACT lowland native grassland conservation strategy. Action Plan No. 28 (Arts, Heritage and Environment, Canberra), Table 4.1 under the heading Management

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