Comments on Representations on the
Proposed Plan of Management
for the
Australian National Botanic Gardens


In accordance with subsection 11(2A) of the National Parks and Wildlife Conservation Act 1975, notice of intention to prepare a plan of management for the Australian National Botanic Gardens (ANBG) was published on 25 January, 1992. Submissions were invited from interested parties and some 50 responses were considered in the formulation of the Plan. The Plan was published in May 1993 and interested persons were invited to comment on its provisions before 16 July 1993.

A list of the 16 organisations and individuals who made representations is given at Appendix 1. The representations covered issues that related directly to prescriptions in the Plan, plus several more general issues not relating to a specific prescription. A number of typographical and factual errors were also pointed out.

All the issues raised were formally considered by the Australian National Botanic Gardens Advisory Committee when it met on 17 September, 1993. Issues concerning the programs for the aged and people with a disability were considered at a special workshop of representatives of interested community groups held on 23 July 1993. ANBG staff and other staff in the Australian Nature Conservation Agency (ANCA) also gave extensive consideration to all representations. This report summarises the issues raised and comments on the salient points arising out of them.


The majority of representations either explicitly endorsed the Plan or were phrased in such a way as to infer general endorsement; only one expressed the view that the Plan fails to provide a comprehensive and coordinated vision for the long term development and management of the Gardens.

It needs to be emphasised that these representations cannot be used to draw any statistically based conclusions. A given issue cannot be said, for example, to have elicited more responses in favour than against because the responses in no way represent statistically usable samples. For this reason no attempt has been made to evaluate issues numerically.

The representations were extremely useful in directing attention to some of the most pressing issues confronting the ANBG. Nothing was raised that had not already been considered and a number of representations concerned relatively uncomplicated matters; others were timely reminders of real difficulties and stimulated a great deal of productive debate.

Although none of the representations convinced the ANBG and the Advisory Committee of a need to revise any of the management objectives, a number of prescriptions were redrafted to be made clearer or more specific. Changes have also been made in two sections where significant developments have occurred since the plan was released for comment. The sections on education and on community involvement have been revised to take account of the outcome of the review of the operations of the Banksia Centre and subsequent consultations with community groups on future directions in this area. The section dealing with the establishment of the Centre for Plant Biodiversity has also been revised and expanded in order to take account of the difficulties many people seemed to have in understanding the relationships between its activities and those of other sections of the Gardens.

The ANCA endorses all the management actions proposed and the prescriptions detailed in the amended Plan represent the consensus of those involved in its preparation.


8 & 14 - suggest that priority should be given to the development of the collections in Canberra, rather than to building works.


These representations raise the issue of how available resources are allocated to best further the complete spectrum of the Gardens aims. This issue has been discussed in detail and the Advisory Committee and ANCA consider that the plan represents an appropriate balance in the allocation of resources to the range of functions the Gardens has to undertake in the next 5 years.

11 - considers the Jervis Bay component of the Plan should be presented separately.

13 - considers the Jervis Bay site is inadequately covered and described in the Plan.

14 - considers it disappointing that the Jervis Bay Gardens are given a low priority in the Plan and recommends higher priority be given to increasing the level of promotion and development of visitor facilities at Jervis Bay.


Separate presentation of those components of the plan dealing with Jervis Bay is not considered appropriate as the activities there and in Canberra are closely linked and need to be seen to be integrated.

A number of changes have been made to more fully describe the site at Jervis Bay.

Development of visitor facilities and increasing promotion of the Gardens at Jervis Bay beyond that presently described in the plan is not considered desirable. The plan specifies that a detailed development planning exercise for the Jervis Bay site is to be undertaken and this will identify any requirements for additional visitor facilities.

4 - proposes the inclusion of Acton Peninsula into the ANBG.


This proposal would require changes in legislation, which cannot be addressed within the Plan of Management.

13 - points out that the Gardens are subject to the heritage provisions of the ACT Land (Planning and Environment) Act 1991 and are subject to nomination to the interim Heritage Places Register and that the Plan should define the implications of such a nomination. It considers the Plan should acknowledge the heritage value of the Gardens and clearly state management objectives and implementation strategies to conserve its heritage.


The heritage values of the Gardens and its collections are acknowledged and management is concerned to conserve these values. A number of alterations to the text have been made to address the issue of heritage conservation.


The issues raised are summarised below, grouped under the headings used in the Plan.


Functions and values of the Gardens

3 - considers that the fifth of the aims should be restated to include the words `horticultural research'.


This aim has been amended to comprehend all types of research.

Purpose of the Plan

9 - states that the Plan should be clear in stating that the ANBG is declared National Land under the National Capital Plan.


The plan has been amended to clarify this matter.


Thematic structure

1 - comments that the southern precinct offers an opportunity to better integrate the Botanic Garden plantings with the greater city landscape.

Foundation plantings should be made sooner than later as they will cost little but contribute much to the landscape fabric of the area.


The potential for plantings in the undeveloped southern part of the Gardens to aid integration with the city landscape is recognised. The nature of the area is such that establishing and maintaining foundation plantings would impose a significant infrastructure development cost. This is not justifiable within the term of this Plan.

Horticultural management

3 - suggests that more attention should be paid to the development of plant breeding programs.


The plan gives a high priority to re-establishing a horticultural research program in the future and plant breeding will be considered as a component of any such program.

Remnant native vegetation

7 - states that there is no reason given for the assertion that sharp contrasts in foliage texture and height will be minimised - in some areas there will be good reason for wanting to create a sharply delineated transition.

9 - comments that weed control programs should include undeveloped areas of the ANBG as well as the public areas, especially areas adjacent to the Canberra Nature Park.


Minimising contrasts at the boundary between the Gardens and the adjacent Nature Park is important to maintaining the landscape fabric of the area.

Weed control programs will include the presently undeveloped areas of the ANBG and the text has been modified to clarify this.

Fire management

9 - states that the Reserve Manager of Canberra Nature Park should be consulted about any matters regarding fuel reduction along the boundary between the reserves and that the Gardens will have to be considered in any fire management plans developed for Canberra Nature Park.


These concerns were noted and are addressed in the plan.

Wildlife management.

9 - points out that wildlife in the Gardens is protected under the ACT Nature Conservation Act 1980 and permits for wildlife management activities should be requested from the Conservator of Wildlife. It also comments that swamp wallabies are reported to be present in the Gardens and some consideration should be given to the future management of this species, and that the Plan should address the potential to accidently import fauna from other parts of Australia with plant material collected in the field.

7 - considers the plan ought to include management objectives and implementation guidelines for the management of wildlife such as currawongs and their prey and that the management of ducks needs to be specifically planned.

16 - considers the Plan might have included a greater emphasis on birdlife in the Gardens as one of the management objectives.

16 - supports an active policy of preventing pied currawongs from nesting in the Gardens.


The Plan has been amended to reflect the fact that wildlife in the Gardens in Canberra is protected under ACT legislation as well as the Commonwealth National Parks and Wildlife Conservation Act.

The need to control the impacts of grazers is recognised in the plan and the impacts of currawongs are being studied to determine whether management action is necessary or feasible. The inclusion in the plan of specific prescriptions for the management of individual species is not appropriate.

Phytosanitary procedures currently employed help to prevent the import of fauna with plant material collected in the field and staff working in the nursery are aware of this concern. The Plan has been amended to be more explicit on this issue.

The Plan is considered to give appropriate emphasis to birdlife in its management objectives.


Thematic focus

7 - considers the Plan ought to set out a program for evaluating where the geographic and taxonomic gaps are in the collections and developing a balanced field work program to achieve a comprehensive collection.

11 - would like to see a broadening of the role of the herbarium to include exotic species cultivated in the ACT.

16 - recommends that the Gardens embark upon an enhanced program of field studies and collection.


The wording of the plan has been changed to reflect the specimen acquisition strategy and the collection and exchange programs in more detail.

The herbarium includes specimens of a wide range of exotic species, many of them from the Canberra region, and will continue to curate and identify this material. The planned amalgamation of the Gardens Herbarium with that of CSIRO will greatly increase the range of cultivated and exotic species in the collection.

Scientific specimens collection

11 - would like to see an expression if intent to seek specific legislative protection of herbarium specimens.

12 - expresses concern at the continuing absence of specific legislation covering herbarium material.


These proposals involve changes in legislation, which cannot be dealt with in the plan of management. Furthermore it is considered that sufficient protection is given to herbarium specimens through the proclamation of the Gardens as a reserve and the gazettal of the Australian National Herbarium as a Commonwealth collection.

Centre for Plant Biodiversity Research

1 - considers the principle of developing a single national herbarium in Canberra having a functional relationship with the Botanic Gardens is very important.

5 - considers the two herbaria must be amalgamated, but expresses grave fears for the future of the ANBG, especially if any of its herbarium material is formally excised from the Gardens or moved off site.

12 - considers the proposal to operate a single national herbarium collection is welcome in principle but raises a major issue concerning the physical location and protection of the specimens.

5 & 7 - consider the relationships between the ANBG and Centre for Plant Biodiversity Research need to be explained in more detail.

7 & 11 - consider the development and operation of the Centre is so significant to the management of the Gardens that the agreement establishing the Centre should be included as an attachment to the Plan.

11 - would like to see a commitment that the integrated management of the herbarium collections will not result in the transfer of voucher specimens for living material away from the Gardens site.

12 - considers the Plan should contain a commitment that no herbarium collections will be removed from the Gardens.

15 points out that the link between the living and herbarium collections is a key aspect of the national estate value of the Gardens and that it is essential that this is maintained under the new arrangements.

5 - considers the removal of research functions away from the Gardens diminishes the status of the Gardens.


This section of the plan has been revised and expanded to in order to take account of the difficulties many people seemed to have in understanding the relationships between its activities and those of other sections of the Gardens.

The inclusion of a lengthy legal agreement in the plan is not appropriate.

The plan has been amended to note the importance of the link between the lining and herbarium collections to the national estate values of the Gardens and of maintaining and improving this link in establishing the Centre.

The Centre will operate to make the most efficient use the facilities available to it. To do so will require that some specimens, including voucher specimens, will be located at the CSIRO site.


Understanding visitors and their needs

14 - suggests that the Guides might be able to contribute to the process of gathering information on visitors.


This suggestion was noted and the utilisation of the voluntary guides will be considered in planning visitor surveys in the future.

Making the Gardens accessible

2 &14 - support the creation of an internal transport system that is consistent with the low impact/minimal intrusion policy stated in the Plan.

4 - suggests a minibus could run from the car park to the upper limit of the Gardens.

9 - suggests special consideration could be given to improving access for sight impaired visitors.

4 - would like to see greater public access to the Herbarium, with voluntary guides at the weekends.

14 - suggests a policy should be formulated on access to the Gardens for special events outside normal opening hours.


The Plan indicates that a feasibility study will be undertaken to investigate the physical and economic aspects of an internal transport system.

The ACT authorities will be consulted along with appropriate user groups in any plans to provide special facilities for sight impaired visitors.

For security and safety reasons the main Herbarium will continue to be opened to the public only on special occasions. However a Public Reference Herbarium has been established in the Information Centre to provide 7-day-a-week access for visitors, and its use will be promoted.

The Plan has been amended to clarify the use of the Gardens for special events outside normal opening hours.

Encouraging appropriate recreational activities

14 - suggests a pro-active policy of educating visitors about the appropriate use of the environment and botanic gardens in particular. It also notes that the prohibition of dogs in the Gardens is not mentioned in the Plan.


These comments have been noted and aspects of the Plan amended to include these points.

Providing facilities for visitors

2 - questions the need for a restaurant as well as a kiosk, stating that there is already an excess of restaurants in Canberra.

8 - comments that it is hard to see the priority for a new Visitor Information Centre when funds have been spent recently to refurbish the existing Centre.

14 - questions the plan to locate a picnic shelter on the Eucalypt lawn.


The need for a restaurant in the Gardens will be addressed in a feasibility study which will examine its financial viability.

The need for an Information Centre forming a `gateway' to the Gardens was identified as a high priority based on the research of the consultants preparing the Development Planning Guide. It would allow the educational message of environmental awareness and conservation to reach the majority of visitors. The recent refurbishment of the existing Centre was a temporary measure to address some immediate problems, one of which was the lack of access for some disabled people to the previous bookshop.

The need for a picnic shelter was based on public consultation, and the need for the site to be away from the congestion of the kiosk was identified.

Promoting the Gardens

4 - would like to see more promotion of the Gardens as a major tourist venue in Canberra.

10 - considers the links between the Gardens and the National Museum of Australia should be mentioned and consideration given to the development of the whole tourist area. Plans could be developed for thematic plantings of the 2.6 km strip between the Gardens and the Museum, along Lady Denham Drive.


The need for more promotion was noted and is addressed in the plan.

Administration of the land along Lady Denham Drive is not the responsibility of ANCA and it would not be appropriate to deal with this issue in the plan.

Information and interpretation

9 - suggests there are opportunities for the ANBG and Canberra Nature Park to develop linked facilities for visitors.

10 - considers the Plan could reflect the Gardens commitment to ongoing cooperation with the National Museum of Australia in areas of mutual interest.


These suggestions have been noted and the Plan has been amended to include them.


3 - considers that programmes teaching primary school children to grow plants should be reintroduced.


This comment has been noted and taken into account in the revision of this section of the plan.

Community involvement

14 - raises the question of whether all volunteers at the Gardens should be members of the Friends.

5 - states that whilst recognising the excellent work that volunteers perform, the ongoing functions of the ANBG should not be replaced solely with volunteers


These comments have been noted but it was not considered necessary to amend the Plan.

It would be inappropriate to require all volunteers to become members of the Friends; volunteers are nevertheless encouraged to join the Friends.

The plan clearly states that the use of volunteers will be to the extent consistent with safety, efficiency and harmonious industrial relations. There is no suggestion or intention that they should or could replace staff required for ongoing functions.


1 - points out that the institution will only continue to be a national programme focus for botanic gardens and herbaria if sufficient resources are forthcoming to permit national coordination of activity and national projects.


This concern was noted.


4 - states that there should be no general entry fee but that a small charge should be made for wedding parties, for the conduct of tourist parties through the gardens by qualified guides and for any transport service provided within the Gardens.

3 - considers there is a need for the Gardens to employ horticultural apprentices.

7 - states that this section does not provide an organisation chart for the upper levels of the Gardens and thus fails to indicate that the Gardens no longer has a full time Director.


The Plan states that consideration will be given to introducing charges for the range of activities suggested.

The concerns regarding the employment of horticultural apprentices were noted but no need was seen to change the management prescriptions relating to staffing.

The plan makes clear the present management structure and the responsibilities of the senior staff of the Gardens: the inclusion of an organisation chart in the Plan of Management is not considered necessary. A description of the other program responsibilities of the Executive Director would be out of place in a plan of management for the Gardens.


12 - considers high priority should be given to the preparation of a landscape master plan for both the Gardens in Canberra and the Jervis Bay Annex. 14 - requests that provision for a Friends Lounge and Office be made in the building rationalisation program and that the Plan reflect the arrangements made for the Friends to develop and use propagating facilities at the northern end of the Gardens. 14 - supports recycling measures and initiatives taken to save water and electricity, and proposes additional measures which might be introduced in these areas.

15 - points out that the proposed new buildings and infrastructure do have potential for significant impacts on the national estate values of the Gardens in Canberra and that discussion with the Australian Heritage Commission staff early in the planning of these activities would facilitate clarification of heritage conservation requirements.

15 - supports the development of a style manual, regarding this as a key document in maintaining some national estate values.

16 - suggests a policy of strict control and isolation of food and food waste from the kiosk and proposed restaurant.


Landscape master planning for the Gardens in Canberra and at Jervis Bay is accorded a high priority in the Plan.

The comments on potential impacts of developments on national estate values and on the development of a style manual are noted and the Australian Heritage Commission will be consulted at an early stage in the planning of developments.

The requirements of the Friends will be considered when reallocating space made available through building developments.

The additional recycling and resources conservation measures suggested have been noted and will be investigated.

Control of food and food waste from the kiosk are not seen to be a significant problem at present but this situation will be kept under review.


1 - states that the priorities for implementation seem appropriate for an institution having national responsibilities and custodianship of the unique Australian flora.

3 - considers the prioritisation of matters needs to be re-assessed if the Gardens is serious about horticultural research.

7 - considers the Plan does not give any indication of how competition for scarce resources between sectional activities will be reconciled.


Priorities have been re-assessed in light of the representations received but no substantial changes were considered necessary.

The establishment of the Centre for Plant Biodiversity Research will provide enhanced facilities and increased opportunities for horticultural research by the Gardens staff.


Index of representations received on the
proposed Plan of Management
for the Australian National Botanic Gardens