EEIS - Consultation on the Priority Household Target

Dr Kate Auty - Commissioner for Sustainability and the Environment - 5 May 2017


In May 2017, the office submitted a public submission to the ACT Government in response to consultation on the setting of the Priority Household Target focusing on how to

You can find the report here:

EEIS - Consultation on the Priority Household Target - pdf

EEIS - Consultation on the Priority Household Target - word

If you would like a copy of the Regulatory Impact Statement, please email or visit the Energy Efficiency Improvement Scheme website for more information.

Transforming Haig Park - from a windbreak to a 21st century park

Dr Kate Auty - Commissioner for Sustainability and the Environment - 22 March 2017

haig park

Haig Park in Turner. Photo: Kate Auty

In March 2017, the office submitted a public submission to the ACT Government on the future of Haig Park with a special emphasis on climate change adaptation.

You can find the report here:

Transforming Haig Park - pdf

Transforming Haig Park - word

Lower Cotter Catchment Draft Reserve Management Plan

Dr Kate Auty - Commissioner for Sustainability and the Environment - 14 March 2017

Cotter River

Thank you for the opportunity to comment on the Lower Cotter Catchment Draft Reserve Management Plan (RMP) 2017.

My office has been directed by Government, based on the Auditor-General’s recommendation, to evaluate the restoration of Lower Cotter Catchment (LCC) against the goals of the Strategic Management Plan[i] (2007). This will be superseded by the RMP and, with appropriate Ministerial approval, my evaluation will be against the goals within the RMP. The evaluation will commence later this year and be completed by the end of 2018.

I provide comments at this stage of consultation to support the evaluation of the RMP and improve the ability to achieve restoration of the Lower Cotter Catchment.  The comments I make have emerged directly from scoping the evaluation in recent months. The 2018 review will provide further comment and, based on available information, an evaluation of the restoration efforts.

Standards for Evaluation

There are two main standards that I will be drawing on for the evaluation. These being:

  • The National Water Quality Management Strategy[ii] (2000) (NWQMS) and its Australian and New Zealand Guidelines for Fresh and Marine Water Quality (2000). These establish processes to develop target and trigger levels that underpin management plans for catchments and other water bodies. (see Attachment 1)
  • National Standards for the Practice of Ecological Restoration in Australia[iii] (2016) issued by the Society for Ecological Restoration Australasia (See Attachment 2). These standards represent best available research and were developed by leading practitioners in the field. They provide a transparent, repeatable and thorough approach to plan, implement, monitor and evaluate ecological restoration projects. They also recognise the long-term nature of ecological restoration projects and the need to incorporate adaptive management.

The two frameworks have very similar critical elements:

  • They establish reference conditions or ecosystems to tailor goals relevant to the local environment and in consideration of current levels of degradation; and
  • They include measurable objectives that are underpinned by monitoring programs.

In fact the NWQMS might be considered a subset of the National Standards (the Standards) as they are focused purely on the aquatic environment.

Overall Comments on the RMP

I recognise the extensive work and consultation that has gone into the development of the RMP. The document is comprehensive in identifying the broad range of issues and challenges. In particular, the focus on ensuring resilience against climate change reflects the standards. The sections on Cultural Heritage and Community Engagement are also commendable.

I note that there are seven main chapters to the plan, containing 18 objectives and 66 actions. These are shown in the following diagram.

Diagram of contents of the Lower Cotter Catchment Draft Reserve Management Plan

As indicated by the diagram, the Plan’s focus is confused, subtle in its priorities, and siloed in it purpose against the 3 main management objectives on page 9.

For example on page 6, the RMP states its aim as: To actively promote regeneration of the Lower Cotter Catchment to a stable, fully functional natural ecosystem and protect it from activities that may have adverse impacts on water quality.

Yet onpage37 it states: The protection of water resources is the primary consideration for all decisions and activities occurring in the catchment.

This balance of purpose requires further clarification and rationale such as:

  • What is the baseline condition of the catchment?
  • What does a fully functional natural ecosystem look like in a catchment that is prioritised towards water supply and starting out in a state of degradation?
  • What and how will we measure progress towards it over time?

To summarise, the three main points proposed for consideration are:

  1. Applying a more comprehensive framework, as set out in the Standards, clearly identifying reference ecosystem(s) and its attributes, linking these through to the measurable and time linked objectives;
  2. Linking objectives explicitly through to the relevant operational management plans and action plans; and
  3. Strengthening the commitment and governance regarding research, monitoring and knowledge  management.

Clear Restoration Targets

It is not clear what the target outcome is in sufficient detail and appropriate priority to allow relevant indicators to be set and monitoring to be strategically employed to demonstrate management effectiveness.

Identification of an appropriate indigenous reference system is a fundamental principle of ecological restoration. A reference ecosystem describes the ultimate target for a restoration project.  This involves detail of composition (species), structure (complexity and configuration) and function (processes and dynamics) and transitional pathways to indicate decline or recovery.

It is acknowledged that the LCC includes several different ecosystems including riparian forests, montane forests and open grassy woodlands.

These ecosystem attributes are described somewhat in the RMP and may be included in more detail in other documents, operational management plans or action plans.

In relation to Water Resources whereby the National Water Quality Management Strategy (NWQMS) and associated guidelines is referred to, reference indicators and trigger levels need to be developed and a clear monitoring regime implemented. It is not clear in the RMP who is responsible for developing, monitoring and reviewing the application of the NWQMS to the local environment, yet it appears to be the primary objective.

Recommendation 1

The RMP should include better spatial information representing land use and ecosystem attributes. For robustness and clarity the reference ecosystem and indicators should be clearly articulated in the RMP and consistent throughout the document. They should be spatially mapped and linked to all management actions.

Recommendation 2

The responsibility for implementing, monitoring and reporting on the NWQMS for LCC should be clearly identified and resourced.

Clear Objectives

The RMP has a variety of objectives and outcomes. These include:

  • Management objectives (page 9);
  • Key outcomes over the 10 year life of the plan (page 26);
  • Primary management objectives at the start of each system chapter; and
  • Objectives within each aspect, such as hydrology and water management (page37); native vegetation (page 54) and pests and disease (page 66).

These various ‘objectives’ are not directly linked to one another and add confusion to purpose and priority. This ultimately adds a layer of difficulty in not only implementing appropriate actions in a cohesive and efficient manner, but also in being able to evaluate outcomes and therefore management effectiveness.

Recommendation 3

Mapping out how objectives link to a reference ecosystem and applying terminology consistent with the Standards would provide a clear picture of purpose and ensure actions are linked and effective.

Robust Objectives

Objectives need to be clear about the measure, the methodology for measuring and the target over time. Measurability is critical to facilitate monitoring and reporting.

Baseline measures must be available to make the objective purposeful. It is not always clear what the relevant point in time is for the baseline measure. Time based objectives should be included and monitoring against the objective must be undertaken. Although actions have been clearly allocated to a responsible entity, the monitoring and measurement against the objective is not explicit. Tracking actions alone will not ascertain whether they are achieving the actual objective and not support an adaptive management approach.

One example is the Landscape and Habitat Connectivity where the objective is that scenic quality is maintained and recovered, and connectivity value is enhanced. The baseline for scenic quality and connectivity and how will it be monitored needs to be clearly established.

Recommendation 4

Objectives should be reviewed to ensure they are measurable, have a clear methodology, baseline measure, time based targets and a monitoring program.

Operational Management Plans

The RMP is a high level strategic document that facilitates a range of operational plans. The linkage between these and the RMP is not clear. Without a clear identification of these plans and their ‘owners’ there is a risk that some objectives will be missed or on the other hand, inefficiency of efforts through potential duplication. It also make the long list of actions unnecessarily overwhelming, I expect it will crystallise several actions into a single plan, making the document more relevant for stakeholders (ie.  Parks and Conservation Service (PCS) Road and Fire Trail Network improvement plan).

Recommendation 5

Specific operational plans relevant to the actions should be included (perhaps within Appendix 1).

Knowledge management, research and monitoring

Knowledge management and appropriate monitoring is a common challenge for a wide range of environmental management projects. It was recognised in the Lower Cotter Catchment Strategic Management Plan (2007) (page 17) whereby it states:

“Management is guided by a program of environmental monitoring and research that supports and informs management activities and long-term restoration programs”.

In a broader context, it is a clear priority of Government to be able to inform, engage and connect with the community on all matters relating to Government operations. Using information leads to better outcomes, as shown in the figure overpage sourced from the Australia State of Environment Report [iv](2016).

Research and monitoring is critical in reviewing and adapting ongoing restoration efforts.  The importance of monitoring and assessment in restoration is unquestioned[v] yet there is a globally a lack of monitoring or evaluation of performance or outcome of restoration projects[vi]. Bernhardt (2005) undertook a study looking at the common elements of successful river restoration projects in the USA. Of the 37,099 river restoration projects assessed only 10% of project records indicated that any form of assessment or monitoring occurred. The current lack of monitoring is often a result of poor planning and lack of allocated funds[vii] .

The management of the LCC is of particular community interest as it relates to a range of competing interests including recreation, natural environment, fire management and water supply. It is critical to maintain sufficient information to inform and support Government actions in the LCC and allow effective community engagement.

Knowledge management for the LCC is a critical issue for all stakeholders and requires immediate focus. There has been significant research undertaken in the LCC over the years, particularly since the 2003 bushfire but it is fragmented and difficult to source. It is noted that PCS had been identified as custodian of all research projects (page 118) in the draft RMP.

Diagram showing how using information leads to better outcomes

Source: Australia State of Environment Report 2016

Previous Commissioner’s Reports

The 2015 ACT State of Environment Report[viii], produced by my office, identified this issue in relation to land, water and biodiversity.  Specifically:

  • Recommendation 5 – Land – That the ACT Government provides resources to fully implement priority action in the ACT Nature Conservation Strategy....(such as) Conservation Effectiveness Monitoring program
  • Recommendation 7 – Water -  That the ACT Government .... assess the need for collecting more information for indicators
  • Recommendation 8 – Biodiversity – That the ACT Government provides the necessary resources to complete the next phases of the Conservation Effectiveness Monitoring Program (CEMP)
  • Recommendation 9 – Biodiversity – That the ACT Government formalise biodiversity conservation data collection and storage... to integrate reports commissioned by different agencies....

The ACT Government responded to these recommendations as “Supported”.

This issue was also identified in previous reports by this office, namely the Report on Canberra Nature Park Reserves[ix] (2011), Recommendation 3 – Better direct and inform the management of nature reserves by:

  • Preparing a Nature Reserve Operational Plan, and
  • Developing and implementing a nature reserve monitoring strategy.

The ACT Government responded to these recommendations with Agreed in Principle and in Part, noting a need to prioritise and rationalise approaches.

Recommendation 6

The role of PCS should be expanded to include all monitoring, reporting and reviews for completeness. Given the current state of knowledge management, a committed resource needs to be allocated to this task to ‘catch up’ and develop processes and systems to facilitate efficient knowledge management into the future. This role should also provide guidance on monitoring gaps and have some delegation to endorse monitoring programs within various operational plans.

Recommendation 7

A budget must be allocated to ongoing research and monitoring, and include sufficient resources to implement the CEMP into the Lower Cotter catchment as a matter of priority.

Recommendation 8

All objectives and/or operational plans must include a requirement for monitoring and reporting. These should be linked to the CEMP.

I commend the work of Government in reaching this point and trust that you will consider the value in the recommendations I have put forward to assist in informing the ongoing efforts of the restoration of the Lower Cotter Catchment.

Thank you once again for the opportunity to comment on the Lower Cotter Catchment Draft Reserve Management Plan.

Attachment 1 – Australian and New Zealand Guidelines for Fresh and Marine Water Quality (2000) Framework

Diagram of Guidelines for Fresh and Marine Water Quality

Attachment 2 – National standards for the practice of ecological restoration in Australia


[i] ACT Government (2007): Lower Cotter Catchment Strategic Management Plan.

[ii] ANZECC and ARMCANZ (2000): National Water Quality Management Strategy and Australian Guidelines for Fresh and Marine Water Quality.

[iii] SERA (2016): National standards for the practice of ecological restoration in Australia.

[iv] Australian Government, Department of Environment and Energy, 2016: Australia State of Environment Report.

[v] Aguiar F.C., Fernandes M.R. & Ferreira M.T. (2011): Riparian vegetation metrics as tools for guiding ecological restoration in riverscapes. Knowledge and Management of Aquatic Ecosystems, 402, 21-33.

[vi] Wohl E., Angermeier P.L., Bledsoe B., Kondolf G.M., MacDonnell L., Merritt D.M., Palmer M.A., Poff N.L. & Tarboton D. (2005): River restoration. Water Resources Research, 41, 176-188; and

Bernhardt E.S., Palmer M., Allan J., Alexander G., Barnas K., Brooks S., Carr J., Clayton S., Dahm C. & Follstad-Shah J. (2005) Synthesizing U. S. river restoration efforts. Science, 308, 636-637; and

Kondolf G.M. & Micheli E.R. (1995) Evaluating stream restoration projects. Environmental Management, 19, 1-15; and

Erskine W.D. (2001) Geomorphic evaluation of past river rehabilitation works on the Williams River, New South Wales. Ecological Management and Restoration, 2, 116-128.

[vii] Purcell A.H., Friedrich C. & Resh V.H. (2002) An assessment of a small urban stream restoration project in northern California. Restoration Ecology, 10, 685-694.

[viii] Office of the Commissioner for Sustainability and the Environment (OCSE) (2016): ACT State of Environment Report.

[ix] OCSE (2011): Report on Canberra Nature Park (nature reserves); Molonglo River Corridor (nature reserves) and Googong Foreshores Investigation.

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