Friends of Grasslands

supporting native grassy ecosystems


PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....




Flora and Fauna Committee

PO Box 158



Attention Lee-Anne Wahren



Dear Ms Wahren


Friends of Grasslands (FoG) would like to comment on the ACT Flora and Fauna Committee's 'Proposed amendments to the guidelines and criteria for assessment of threatened species and communities in the ACT' (the Guidelines and Criteria), circulated for comment in mid-April.


FoG is a community group dedicated to the conservation of native temperate grassy ecosystems, such as grasslands and woodlands. It is based in Canberra and its members, numbering about 200, include professional scientists, landowners, land managers and interested members of the public. FOG advocates, educates and advises in matters to do with conservation of grassy ecosystems, and carries out surveys and other on-ground work.


FoG generally supports the amendments proposed.  However, FoG believes that the Guidelines and Criteria could be improved and brought up to date, given the evolving - national and international -policy, legislation and scientific context in which they exist.  Accordingly, I have attached comments provided by an expert FoG member, Benjamin Whitworth (ecologist) for your consideration.  FoG would be happy to work further with the Committee on this matter.


Thank you for the opportunity to comment, and apologies for the lateness of our reply (noting that an extension was granted to 25 May).


Yours sincerely





Kim Pullen



28 May 2007


Comments on the 'Proposed changes to nomination guidelines and criteria for recommending declaring of threatened species, communities and threatening processes'


Proposed changes to the Guidelines and Criteria look useful. There are some further changes that could be made to clarify some sections and improve their usefulness for the future.  In the comments below, underlined phrases are suggested wording changes.


Significant points


1) Genetic diversity of populations should be included



Low genetic diversity in a population may affect the species capacity to adapt to a changing environment and cause inbreeding depression leading to deformities and a reduction in fecundity. Low genetic diversity affects the ‘effective population size’ of the species.


a) The Guidelines and Criteria were first released in 1995 and there has been a revolution in genetic research, and practical implementation of this research, since then. This is likely to only increase in the field of conservation genetics over the next 10 years (assuming the Guidelines and Criteria will be reviewed again in ~10 years). Over the past 10-15 years there has been a rapid improvement in genetic research techniques such as PCR, the use of highly polymorphic microsatellites (thus being able to pick up smaller degrees of variation), sequencing of DNA, DNA fingerprinting, automated genotyping, and moving from single gene analysis to many hundreds of genes analysis. These techniques have led to dramatic improvements in the ability to detect small levels of genetic variation at a much cheaper cost in both money and time. This is likely to affect conservation genetics substantially in the near future.


b) Research on ‘threatened species’ has often identified far less genetic diversity than expected, particularly in plants (i.e. Wollemi pine, Swainsona recta, Tumut grevillea, button wrinklewort) mainly due to clones or probable inbreeding/bottlenecks. Future genetic research is likely to identify these situations with other plants and animal populations, increasing the likelihood of species being nominated as a result of genetic research.


c) The National strategy for the conservation of Australia's biodiversity was published in 1996. In this, one of the three main components of biodiversity is ‘genes’.



‘Genetics’ could be integrated relatively simply into the current Guidelines and Criteria, for example through the following changes in the 'Criteria for declaring an endangered species' at section 1.2:


1.2.1 ‘Current severe reduction in population, genetic diversity or distribution…’ and

1.2.6 ‘Extremely small population or genetic diversity of the population’.


Or alternatively


1.2.1 ‘Current severe reduction in effective population size or distribution…’ and

1.2.6 ‘Extremely small effective population size’.


(Effective population size would also need to be defined in the Glossary to include genetic diversity).


Corresponding changes should also be made in the 'Vulnerable species' section 2.2.


2) Add ‘State listing’ to criteria.



The Guidelines and Criteria include a criterion for species to be nominated because they are ‘recognised as threatened in an authoritative international or national listing’. It would be useful to include a reference to state listing, particularly in NSW.


a) As the ACT is entirely within NSW it makes practical sense to have an option to nominate based upon a species/community being already listed as threatened in NSW.


b)  The current Criteria for Declaration do make numerous mentions about working closely with state agencies. However, in practice there seems to be a mismatch between lists of declared threatened species in NSW and the ACT.


For example, in the ACT Lowland Woodland Conservation Strategy (Action Plan No. 27) Table 4.1 shows that there are five extra animal species listed as threatened in NSW that also occur in the ACT but are not declared threatened in the ACT. In the ACT Lowland Native Grassland Conservation Strategy (Action Plan No. 28) Table 2.2 there are four plant species listed in NSW that are not declared in the ACT. This difference may be due to differences in the ACT and NSW populations, or more likely due to the amount of time and effort it takes to assess threatened species nominations.



To help streamline the nomination and declaration process, it would be useful to include the option for nominating species in the ACT that are currently listed in NSW. This already occurs for internationally and nationally listed species in the Guidelines and Criteria. The suggested change would be:


‘1.1 Species is known or suspected to occur in the ACT region* and is already recognised as endangered or presumed extinct* in an authoritative international, national, or state (particularly NSW) listing’


And make corresponding changes to sections 2.1 and 3.2 for vulnerable species and endangered communities, respectively.


Other areas for clarification


3) More explicit mention of other taxa (i.e. sub species/var) would be useful within the Guidelines and Criteria.



Species should be declared endangered/vulnerable at the taxon of most relevance. The Guidelines state that subspecies can be nominated (pg 8: para 1). On the current ACT list of endangered and vulnerable species there are no subspecies listed. In contrast, the national EPBC Act’s list of threatened species has many subspecies listed. For example, in endangered birds 23 of the 40 listed birds are subspecies. It is possible that the discussion about listing species at the species level, not subspecies level, in the bottom paragraph of page 8 may be confusing nominators. In the ACT, listing species at the subspecies/var level may be the most appropriate taxon in some cases, particularly since it is a small region. Examples of some subspecies/varieties in the region that would have usefully been listed below the species level include the white hoary sunray (Leucochrysum albicans var tricolor), the weeping snowgum (Eucalyptus lacrimans) and reptile complexes. With improved genetic techniques this is likely to become more of an issue in the future.



Clarify comments on page 8 (bottom paragraph) relating to listing subspecies, perhaps concluding with ‘Populations should be nominated at the ‘taxon’ of most relevance’.


Include reference to ‘other taxa’, such as ‘subspecies’ in the Description section (pg11).


Criterion 1. and 2. ‘Criteria for declaring an endangered species (or subspecies).’


4) More explicit mention of fragmentation and connectivity



Fragmentation and metapopulation science has improved over the past 10 years.


a)      Fragmentation is not a problem per se, the problem is reducing connectivity between populations. For example, even a low degree of fragmentation could have devastating impacts on grassland species, such as flightless moths and grasshoppers, and many reptiles, whereas birds may be less affected. Encouragingly, theory has shown that even a low level of gene transfer can maintain genetic diversity (i.e. 1% transfer per generation). Similarly, low numbers of individuals moving between sites can maintain a regional population through recolonisation. Even so, it is likely that the current landscape has divided populations to such an extent that they should be assessed, and managed, as isolated populations.


b)      Fragmentation is currently included in the Criteria for endangered and vulnerable species, but not explicitly within the endangered ecological community Criteria. It might be a part of 3.3.5 and 3.3.6, but this seems unlikely from the descriptions. For ecological communities, fragmentation and connectivity is an important criterion.


c)      For ecological communities, fragmentation also affects patch condition: the size of the patch affects the core and buffer areas.



In the Guidelines ‘Distribution’ section (pg 12) mention up-front ‘range, area of occupancy, fragmentation and connectivity.’


In the ‘seriously/severely fragmented’ glossary descriptions, explain how ‘ecological processes’ are likely to be disrupted in more detail.


Ecological communities, under the ‘Criteria for declaring’ add ‘Fragmented or poorly connected’ as this seems particularly important for this category, but is not mentioned; i.e. ‘Severely fragmented and disconnected* distribution for an ecological community currently occurring over a small range or having a small area of occupancy within its range.’


And make corresponding changes using 1.2.5 for ecological communities, suggest a minimum patch size.


5) Thresholds are too low



It is always hard to state thresholds because as soon as a number is given people will argue over the number when it is only supposed to be a guide. Nevertheless, the threshold guidelines currently given are too low and may discourage people from nominating species.


a)      Thresholds for ‘area of occupancy’, ‘number of mature individuals when other factors are also affecting the species’ (i.e. 1.2.4, 1.2.5) and ‘medium term’ are all lower than in the EPBC Act Guidelines (based on IUCN), and


b)      For species, thresholds for minimum population size have been based on empirical research on randomly breeding individuals in ideal and stable environmental conditions (i.e. not fluctuating) using genera such as Drosophila. This is clearly not the case for most rare species, i.e.: most rare species do not mate randomly; fragmentation of the populations means they cannot mate with the whole population; a fluctuating population may go extinct more easily; there is disproportionate representation of genes within each population; and genetic diversity can be quite low. As far back as 1990 Thomas suggests that thresholds be at least 1000 mature individuals (equating to an effective population of a few hundred) as the minimum and at least 5000 for long-term survival to ensure fluctuations in population do not send a population extinct. For insects, which tend to have more variable fluctuations in population, he recommends multiplying by 10. These results are for a contiguous population, not a fragmented population. A quick review of more recent literature suggests higher thresholds. It would make sense to set thresholds at these levels for ‘each population’ or alternatively change all references to ‘population’ to ‘effective population size’.


c)      Some fairly standard thresholds for ecological communities now exist in the ecological and other literature. For example, in the EPBC Guidelines and Criteria they have 30% of original extent for vulnerable, and 10% for endangered, 5% critically endangered. Rates of decline are mentioned in the EPBC Guidelines and Criteria. Having a minimum patch size would also be useful in the ACT Guidelines and Criteria.



A quick review of the literature (e.g. Conservation Biology) and EPBC Act Guidelines would be useful to update the thresholds. This is likely to come up with the following suggestions:


Threshold for area of occupancy and length of ‘medium term’ should be at least doubled.


For species, either

For ecological communities, set endangered at 10% of original extent and vulnerable at 30% of original extent.


Other minor recommendations


Small effective population size.  Change 'small population' to 'small effective population' size. A species may have a reasonable population size, but if there are mostly males, or it has a breeding strategy which favours certain individuals (e.g. polygamy), or has low genetic diversity (i.e. being inbred) or has a population of clones (e.g. plants), the number of actual breeding individuals contributing to the population may be significantly lower.


Add ‘Vulnerable ecological communities’ to Criteria.


'Special conservation need' is mentioned on page 9, but not described in the Glossary.


International.  Under 'World-wide protection of wildlife’ (pg3) it would be useful to mention ‘International or national listing informs the ACT process' explicitly.


Serious reduction- rate of reproduction (pg 26).  Perhaps this should be a ‘decrease’ in reproduction/recruitment, rather than an ‘increase’?


Categories of threatened.  It would be useful to be consistent with the EPBC Act/IUCN categories, changing ‘endangered, vulnerable’ to national categories:

This could be achieved simply by separating out the Criteria for ‘species’, until the legislation changes.  For ecological communities this may be more difficult.



Benj Whitworth





Thomas, C.D. (1990) What do real population dynamics tell us about minimum viable population size. Conservation Biology vol 4, no 3.


TSSC. Guidelines for assessing the conservation status of native species according to the Environment Protection and Biodiversity Conservation Act 1999 (the EPBC Act) and EPBC Regulations 2000, Dept of Environment and Water. Canberra.


TSSC. Guidelines for ecological community nominations for listing, changing the status or delisting under the EPBC Act, Dept of Environment and Water. Canberra.