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Red Hill Bush Regeneration Group

16 Nelson Place

Curtin ACT 2605

The Office of the Commissioner for Sustainability and the Environment

PO Box 356

Dickson ACT 2602



envcomm@act.gov.au
Dear Commissioner
INVESTIGATION INTO CANBERRA NATURE PARK (nature reserves); the MOLONGLO RIVER CORRIDOR (nature reserves) and GOOGONG FORESHORES
Thank you for this opportunity to provide input into the above investigation. Red Hill Bush Regeneration Group (known also as Red Hill Regenerators) is an incorporated association and an ACT Landcare/Parkcare group, comprises about 30 active members, and has been active for 21 years. Collectively the Group has spent tens of thousands of hours surveying, regenerating, monitoring and striving to protect the Red Hill woodland remnant. This submission is based on the Group’s experience and thus only has direct relevance to the investigation into Canberra Nature Park as it applies to the Red Hill Nature Park. It is relevant that much of the Red Hill woodland remnant is within designated land and that it extends over nature reserve, public open space, concessional leases, road reserves and land for which utility leases or utility land zoning apply.
This submission addresses the terms of reference. However above these matters of detail, the Red Hill Regenerators consider that there are fundamental management issues that your Investigation will need to identify and seek to redress. It is likely that these issues apply across most, if not all of Canberra Nature Parks.


  1. Nature Park management has generally not been undertaken in accordance with the Natural Heritage Charter, in that management has not been based on sound knowledge of conservation values.




  1. The Red Hill Nature Park and wider woodland remnant has been a favoured site for infrastructure development, rather than a location of last resort, and development actions have only been subject to minimal and inadequate impact assessment.




  1. Despite numerous, repeated and ongoing illegal activities resulting in degradation of significant conservation values, compliance and enforcement action by appropriate regulatory authorities has been limited and virtually non-existent in recent years.




  1. There has been a constant turnover in ACT Government staff directly responsible for management of Red Hill Nature Park (6 – 9 months is the average). Corporate knowledge and working relationships therefore suffer greatly from this “churn”.

In relation to what has worked well in the past and what should be continued in the future, the Red Hill Regenerators consider the following are key points.




  1. Involvement of the community in management through Parkcare groups has been well supported by the Government and resulted in many conservation benefits.




  1. Weed (and to a lesser extent feral animal) control programs, involving both Parkcare and Parks, Conservation and Land Management (PCL), have been maintained and assessed over many years and have resulted in dramatic declines in the extent of weed cover.




  1. Long term woodland bird plots (Canberra Ornithologists Group (COG) and PCL), regular counts of threatened and rare plant species (Red Hill Regenerators) and basic mapping of weed cover (Red Hill Regenerators and PCL) provide a basis for monitoring the ongoing health of the Red Hill woodland remnant.


Recommendations of Relevance to the Investigation (See submission for rationale)




Assessment and monitoring of on-park development activities (Term of Reference 4)


  • Developments on-park by agencies, other than PCL, should only be located on the park when it has been demonstrated that there are no other prudent and feasible alternatives. They should only be a last resort option.




  • Any such developments should be subject to mandatory and adequate impact assessments, similar in scope to the Review of Environmental Factors, required for developments within the NSW reserve system. These should allow for public scrutiny. A condition of development approval should be appropriate supervision, with any input from PCL funded by the proponent. It is relevant to this and the preceding recommendation that most of Canberra Nature Park is not subject to the ACT’s Planning and Development Act 2007.




  • Activities on-park undertaken by PCL that could have a significant environmental impact, such as creating new fire trails, widening fire tails or extensive fuel reduction activities, should also be subject to impact assessments similar in scope to the Review of Environmental Factors, required for developments within the NSW reserve system.




  • Guidelines should be developed to assist in determining when it is appropriate for such impact assessments to be required.



Compliance enforcement (Term of Reference 4)


  • Active law enforcement should commence, which is likely to require enhancing the capability within PCL. If the appropriate legislation is not enforced there is little value in having enacted it.



Additions to Canberra Nature Park (Term of Reference 2)


  • A review of currently undeveloped gazetted road reserves should be undertaken across Canberra Nature Park. As part of this review the two undeveloped gazetted roads that exist within Red Hill Nature Park (one joins the summit road to Strickland Crescent and one connects the northern part of Hughes to the summit road) should be
    de-gazetted and subsumed into Red Hill Nature Park.




  • Woodland with high conservation value that is contiguous with the Red Hill remnant should be added to the Red Hill Nature Park including Open Space in north-west Hughes, public land between Rusden Street and Hindmarsh Avenue and about 17ha of wooded land that occupies the north, north-western and eastern portions of the Federal Golf Course concessional lease.


Park Planning (Term of Reference 4)

  • A specific management plan should be developed for Red Hill Nature Park (the Red Hill Regenerators would be happy to assist in its production). Its structure should reflect the steps of the Natural Heritage Charter and it should contain a thorough documentation of Red Hill’s natural heritage values. There would seem to be significant value in applying this recommendation to other major components of Canberra Nature Park.



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