The following ACTEWAGL Corporation work practices have been observed within the Red Hill Nature Park by the Red Hill Bush Regeneration Group. These practices are considered to be contrary to good management of the Nature Park and may contravene relevant legislation. It is suggested that enhanced consultation mechanisms are established between PCL and ACTEWAGL officials to help minimise these types of practices.
Replacement of power poles within endangered woodland, resulting in bare areas up to 10m x10m, in which there has been no active rehabilitation measures, and consequently the area of disturbance has become a major site of weed establishment and hence a source of weed invasion beyond the initial area of disturbance.
The placement of overflow pipes from water tanks into drainage lines, with no erosion control measures put in place has created gully erosion.
The control of trees under powerlines by broadscale spraying of a non-specific herbicide that not only killed tree saplings, but native shrubs and a diverse understorey of native grasses and herbs, leaving a degraded area subject to sheet erosion and weed invasion.
Repairs to pipelines being undertaken in such a way that soil piles have been left for months and when finally levelled no other rehabilitation measures (such as planting or seeding with native species) were undertaken. This left bare disturbed areas colonised by weed species.
Vehicle hygiene within Canberra Nature Park is frequently not observed. Trucks and heavy machinery have entered the Reserve caked in mud and most are unclean. Weeds, such as Chilean Needlegrass or Nodding Thistle that otherwise are not present within a reserve or are located many hundreds of metres away have been observed soon after ACTEWAGL activity.
Screen plantings of some water tanks have used species that are not indigenous to Canberra Nature Park and some have become invasive. ACTEWAGL may not have been the original planters in many of these cases, but ACTEWAGL has not removed invasive species or controlled the invasive offspring.
Excessive clearing in the vicinity of powerlines. Trees in excess of 30m from a power line have been cut. In other cases woody shrubs and small trees that were near their maximum height and width were felled and yet were tens of metres away from any power lines. It would appear that those doing the work were unaware of the growth characteristics of the plants they were removing and that nobody explained these characteristics to them.
Heavy machinery operating, after periods of heavy rain, resulting in degradation of native vegetation and tracks within Red Hill Nature Park.
Work done in ignorance of local values so that the access route selected to work sites have needlessly destroyed plants of rare and threatened species, or machinery has been parked on top of diverse native understorey rather than nearby exotic grass.
Maintenance around some of the fenced water tanks seems to consist solely of slashing. Given the disturbance that occurs around these tanks, much of the vegetation is made up of weeds, such as thistles, wild oats or St Johns Wort, slashing may not be the best management practice. Without weed control or management to encourage native species these areas become a focus of weed invasion into the surrounding bushland. To compound matters, in at least one case, slashed weedy material from within a fenced area was raked and strewn over neighbouring bush.
Methods employed to control wattle growth under powerlines, has included bulldozing and baring of soils. This has only resulted in thickets of wattles - much of it non-local or weedy plants such as Cootamundra wattle. The practice has not controlled the target plants and has resulted in reduced biodiversity.
Attachment B: Examples of ACTEWAGL apparently illegal activities in Red Hill Nature Park
The following ACTEWAGL Corporation activities, which may contravene relevant legislation, have been observed by the Red Hill Bush Regeneration Group.
The dumping of fill (or perhaps it has just been the storing of waste spoil) outside of ACTEWAGL lease areas. Some of these spoil dumps have covered tens of square metres. (Apparent offences against Section 67 of the Nature Conservation Act - Maximum penalty - 30 penalty points - Apparent offences against Section 86 of the Nature Conservation Act - Maximum penalty - 2000 penalty points or 5 years imprisonment or both)
The dumping of waste such as left over concrete, used tins and bags and power pole parts in Canberra Nature Park. (Apparent offences against Section 66 of the Nature Conservation Act - Maximum penalty - 10 penalty points)
Cleaning of equipment, such as concrete mixers and heavy vehicles in such a way that waste and polluted waters have covered and killed significant native vegetation, including rare plants and understorey of endangered vegetation, within Red Hill Nature Park. (Apparent offences against Section 77 of the Nature Conservation Act - Maximum penalty - 2000 penalty points or 5 years imprisonment or both)
The parking of vehicles and heavy equipment outside of lease areas. In many cases this has resulted in the destruction of significant plant species. (Apparent offences against Section 67 of the Nature Conservation Act - Maximum penalty - 30 penalty points)
The storage of pipeline sections, power poles or building materials outside of ACTEWAGL lease areas. (Apparent offences against Section 66 of the Nature Conservation Act - Maximum penalty - 10 penalty points)
ACTEWAGL vehicles driven off-track across parts of Red Hill Nature Park, without required approvals, resulting in the destruction of rare and endangered plants or significant disturbance to high quality understorey. (Apparent offences against Section 67 of the Nature Conservation Act - Maximum penalty - 30 penalty points)
Clearance of trees and vegetation along access tracks not owned by ACTEWAGL to allow ease of access to ACTEWAGL facilities, without receiving any approvals to do this work by Environment Act. (Apparent offences against Section 77 of the Nature Conservation Act - Maximum penalty - 2000 penalty points or 5 years imprisonment or both)
Some of the excess clearance done as part of maintenance activities could be regarded as reckless. (Apparent offences against Section 77 of the Nature Conservation Act - Maximum penalty - 2000 penalty points or 5 years imprisonment or both)
Some of the damage done to tracks and vegetation in the reserve by heavy machinery being operated during wet conditions could be regarded as reckless (Apparent offences against Section 77 of the Nature Conservation Act - Maximum penalty - 2000 penalty points or 5 years imprisonment or both - Apparent offences against Section 86 of the Nature Conservation Act - Maximum penalty - 2000 penalty points or 5 years imprisonment or both)
Attachment C: Letter sent by Red Hill Regenerators to ACT Department of Territory and Municipal Services in 2008 in relation to fire management activities
Recent Fire Fuel Reduction Activities on Red Hill
I write to express the frustration and disappointment of Red Hill Regenerators with recent apparently ad hoc and poorly planned fire management activities on Red Hill. Activities that have resulted in local extinctions, the destruction of rare and threatened plants, the encouragement and spread of weeds and exacerbated the decline in woodland bird numbers and diversity. The cumulative impact of tree and shrub removal, undergrowth slashing, trail construction and prescribed burning has been highly significant, while there appears to have been little effort of impact minimisation or mitigation.
Red Hill Regenerators is a voluntary Park Care group of about thirty members that has been active for 19 years. The group has been awarded ACT landcare group of the year and the National Bank ACT environmental award. The Red Hill Regenerators has spent 10,000s of hours (in partnership with Environment ACT), by which much of Red Hill has been restored from an environment dominated by weeds to a woodland of national significance largely dominated by native species. In terms of size, plant diversity and numbers of rare and threatened species supported, Red Hill is amongst Australia’s most significant temperate woodland remnants (Attached is background information on both the significance of Red Hill and the Red Hill Regenerators for your information).
Unfortunately fire management activities of the last two to three years has basically ignored the knowledge of Red Hill Regenerators and treated Red Hill as just another piece of bush.
Fire Fuel Reduction Zones
Red Hill Regenerators are appreciative and complimentary of the way small tree and shrub growth in the vicinity of neighbouring houses has been removed. It has been done in a way that minimised physical disturbance. Originally (around 2000) advice on the location of significant plants within the fuel reduction zone was sought from Red Hill Regenerators, while fuel reduction activities concentrated on woody weeds and removal of illegal ‘garden extensions’. However activities in more recent years have been less discriminating, removing young eucalypt seedlings and saplings and some of the significant plants (ie regionally rare species such as Native Tick Bush [Indigofera adesmiifloia] or species with restricted distribution on Red Hill such as Hop Bush [Dodonaea viscosa]).
The document Planning for Bushfire Protection (2001), by the NSW Rural Fire Service indicates that for residences that adjoin a bushfire hazard, an asset protection zone of 30m is required in situations where the vegetation is woodland and up slope of houses. In a few places on Red Hill, significant removal of mid-storey species has occurred in excess of 100m from the nearest house, while generally most of the mid-storey has been removed within 50m of any house. Paradoxically many of the gardens adjoining Red Hill have a continuous layer of fine fuel, wood sheds, overhanging vegetation and flammable shrubs and vines hugging the house, all things recommended against.
The greatest impact of the many hectares of mid-storey removal is on Red Hill’s woodland birds. Unfortunately, the prime bird habitat on Red Hill is that below the break of slope, where soils are deeper and moister, and consequently leaf, flower and insect growth is more prolific and nutritious, than that found on the hill slope proper. As is common with much of Canberra Nature Park, Red Hill is largely a hill slope environment. Typically the rich break of slope environment exists as a 50-100m strip around the base of the reserve and adjoining houses. A mid-storey structure is an important habitat requirement of many woodland birds. Thus the fuel reduction has resulted in the removal of much of the key and critical woodland bird habitat on Red Hill.
Long term woodland bird monitoring on Red Hill highlights a sorry decline in many significant species populations. Fuel reduction activities, near Kent Street, removed the last known breeding location of the threatened Diamond Firetail on Red Hill. Birds that were once observed during every Red Hill Regenerators activity, such as the Scarlet Robin and Double-barred Finch are now only rarely sighted. The recent fuel reduction activities aren’t the only factor contributing to woodland bird decline. The Red Hill regenerators acknowledge that our activities, where we have removed a 15-20% woody weed cover across the Hill, literally 100.000s of plants has been a significant factor. Our concern about the potential impact of woody weed removal led to one of our members, Darren Evans, conducting a masters thesis, through the University of Canberra, that investigated the impact of woody weed removal on Canberra’s woodland birds. Of relevance to Red Hill is that Darren found that woody weed removal resulted in a drastic decline in both bird numbers and diversity, but that after 5 years, diversity and numbers had somewhat recovered with the growth of native tree and shrub seedlings and saplings. Unfortunately it is this regrowth that has largely been removed in recent years as part of fuel reduction activities. Environment ACT has already been provided with copies of Darren’s thesis, but we are happy to make further copies available should you wish.
Given the above the Group would appreciate answers to the following questions:
What is the boundary of the fuel reduced area on Red Hill?
How was the size of this boundary determined?
Is this area larger than what would generally be required because of the fuel load of planted exotic species in neighbouring gardens?
What consideration has been given to retaining significant plant species within the asset protection zone?
Was the area of activity surveyed for significant plants and fauna habitat prior to removal activities?
What written instructions were provided to those undertaking the work?
Was consideration given to retaining elements for woodland bird breeding and use, such as clumps of shrubs?
Why have there been no attempts to mitigate the impacts of the removal of prime mid-storey habitat, by planting (or shrubbing up) activities elsewhere on the Hill?
Would support be provided for Red Hill Regenerators to undertake such planting activity in the vicinity of the cattle grazing trial area (where there is water access) or on other locations?
Slashing has resulted in a simplified understorey through loss of native species and spread of weeds. Unfortunately slashing is particularly favourable to the spread of Chilean Needlegrass and African Lovegrass, both species capable of spreading beyond areas of establishment and invading much of Red Hill. Our Group has funded the training of two people to specifically tackle these weeds (along with Blackberries and Paterson’s Curse) and they have spent hundreds of hours on their control. This activity was very successful, so that these grasses are now rare on the Hill. However Red Hill is an isolated island amidst a sea of these weeds, and the slashing activity is an open invitation to further infestations.
Originally the location of rare and threatened species were provided and marked so that slashing activity avoided their destruction. Unfortunately, Red Hill Regenerators have not been contacted for some time and each slashing event seems to protrude further into the bush. Slashing has destroyed all plants of the native Wild Mint (Mentha diemenica) known on Red Hill, and the only occurrence of a Dianella species, tentatively identified, over the phone by Geoff Carr (Dianella expert - Royal Botanic Gardens) as a woodland variety of Dianella caerulea, which he considers as a nationally threatened species and which is listed as such in Victoria. The Dianella was reported to Sarah Sharp, of Environment ACT, who may have taken a collection prior to the destruction of the plant. Wild Mint is probably now extinct on Red Hill, there is still hope that the Dianella may resprout from a cut base, but a recent search did not see any signs of a recovering plant. In addition to these two species slashing has removed a substantial proportion of the Red Hill populations of several other species, placing at risk there long-term local occurrence. These species include Blue Devil (Eryngium rostratum), Barbed Wire Grass (Cymbopogon refractus), Queensland Blue Grass (Dicanthium sericeum) and Austral Trefoil (Lotis australis).
Given the above Red Hill Regenerators would appreciate answers to the following questions:
Does the creation of slashed zones also include a budget for ongoing weed spraying within these areas?
Are those undertaking the slashing required to clean there machinery offsite, prior to commencing work on Red Hill?
Are those undertaking the slashing required to clean machinery after they have cut areas containing seed bearing Chilean Needlegrass or African Lovegrass or are they allowed to spread these seed heads across all of the slashed areas on Red Hill?
What instruction is given to those undertaking the slashing as to the extent of their activities?
Were slashed areas surveyed for significant plant or animal species prior to the activity commencing?
What opportunity is there for any remaining occurrences of significant plants from being excluded from further slashing?
Fire Trail Activity
Recent fire trail widening and grading activities on Red Hill resulted in the loss of plants of the nationally endangered Button Wrinklewort (Rutidosis leptorhynchoides) and of the regionally rare Swanson’s Silky Pea (Swainsonea sericea), which is listed as threatened in NSW. Previously care had been taken to ensure that the area of new disturbance in trail maintenance activities did not extend beyond the existing trail surface.
Was the decision to extend the width of trail by up to several metres, subject to a survey for significant plant species, or Aboriginal heritage sites or artefacts?
Is further work planned, and if so will Red Hill Regenerators be contacted re the location of significant plants?
Red Hill Regenerators were contacted about two weeks prior to a prescribed burn occurring behind Stonehaven Crescent, in 2003. Given that 75% of the Hill was burnt in 2001, our Group was not in favour of further burning, and were pleased that the scale of the burn was reduced. Subsequent developments have borne out the caution of Red Hill Regenerators. The burn itself resulted in the loss of two hollow bearing trees, which could have perhaps been avoided if the trees had been rake-hoed around, while fuel was reduced only for at most a 6 month period. The burn activity, particularly the eastern section, resulted in prolific growth of Indian Hedge Mustard (Sisymbrium orientale), Buchan Weed (Hirschfeldia incana) and Cootamundra Wattle (Acacia baileyana), creating a higher fuel level than existed prior to the burn. This level would be much higher but for the 200+ hours that Red Hill Regenerators has put into reducing this growth. Much weed (fuel reduction) work is still required in this area.
Given the high weed load that areas close to houses had in the past, it is likely that burn activity around the base of Red Hill will result in a similar flush of weed growth and be counter- productive from a fuel reduction point of view.
In Spring of 2006, Red Hill Regenerators were contacted about a burn to be undertaken in a matter of days, adjacent to Tamar Street. Again the group was not supportive of the burn, as it is one of the few areas of high quality native understorey not recently grazed by cattle and the major location on Red Hill of several grazing sensitive plants. These include Chocolate Lily (Dichopogon fimbriatus), Rats Tail Grass (Sporobolos creber) and Wild Sorghum (Sorghum leiocladum). The concern with a spring burn is that these and other native species are in flower or early seed set. The Tamar Street area is dominated by native grass species such as Themeda, Poa and Wallaby Grass, thus there was no rapid fuel growth in early spring. The Red Hill Regenerators suggested targeted control of a few patches of the exotic Phlarus and Fescue, but a burn occurred. A one-off burn is unlikely to have a significant impact but repeated burns closer than 15 years apart is likely to result in species loss.
Given the above the Red Hill Regenerators who like to know:
What are the future plans for prescribed burns on Red Hill?
Why was there such a rush for the Tamar spring burn, when the fuel load had been fairly constant there for a number of years?
Was the presence of the threatened Perunga grasshopper (now confirmed as occurring on Red Hill) considered prior to the Tamar street burn?
What alternatives were considered to both burns?
Does the fuel reduction budget, include the cost of controlling likely prolific weed growth?
With adequate impact assessment and care in implementation, the same reduction in fuel load could have been achieved, with much less damaging results. The Red Hill Regenerators also question whether the degree of mid-storey removal was required or that prescribed burning has achieved desired results.
The Red Hill Regenerators would also appreciate copies of any impact assessment or written implementation guidelines that relate to fire management activities that occurred on Red Hill within the last three years. We hope this documentation may show our concerns about poor practice to be unfounded.
We appreciate that this letter raises questions that may take time answering and that it is a busy time of year, Nevertheless we would appreciate a reply to the questions asked by the end of February 2007, or at least an acknowledgment as to when a reply will be provided.
Red Hill Regenerators