Friends of Grasslands

supporting native grassy ecosystems

PO Box 987

Civic Square ACT 2608

Phone: 02 62.. ....



Native Vegetation Regulation Review
Conservation Policy and Strategy Section
Office of Environment and Heritage
Level 12, PO Box A290
Sydney South NSW 1232

Dear Sir/Madam

Native Vegetation Regulation Review

FOG is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of grassy ecosystems, and carries out surveys and other on-ground work. FOGís members include professional scientists, landowners, land managers and interested members of the public. While FOG is based in Canberra, it has a number of members from New South Wales, including the south coast and the Southern Tablelands as well as areas immediately surrounding the ACT.

FOGís comments on two of the papers included in the review of the Native Vegetation Review follow.

Review of the Native Vegetation Regulation: Managing Native Grasslands Discussion paper

All areas containing the defined natural temperate grassland (NTG) ecological community should be subject to similar assessment and consideration of offsets using the same criteria, as required. Assessment should include surveys for threatened species, which may inhabit native grassland in poorer condition.

In addition, areas of poorer condition may improve with application of alternative management. Dominance of particular grass species at a point in time may not accurately reflect the quality of a grassland; after short duration intense grazing, some grasslands recover once stock is removed or grazing is reduced.

Methods for assessment of sites should be based on existing methods, including Biometrics and, for more detailed assessment of grasslands, Rehwinkel 2007.  Grassland sites need to be assessed in spring or early summer to ensure the data are collected at the best time of the year to accurately determine the sitesí biodiversity.

Removing the need to consider offsets when clearing native grasslands is opposed to the Native Vegetation Actís principal of improving or maintaining environmental outcomes.  Consideration of offsets should be consistent across all native grasslands.

Native Vegetation Regulation 2012 Environmental Outcomes Assessment Methodology

Pasture cropping is likely to reduce the ecological values of native grassland, through disturbance to the soil, to changes to processes (including increase in available nitrogen), and modification of habitat for a range of native species. It is well documented that application of fertilisers severely reduces the abundance of many native herbaceous species. Applying the precautionary principle, no pasture cropping should be allowed in those areas that have been identified as containing the endangered NTG ecosystem and/or habitat for threatened species. Trials to determine effects of pasture cropping need to be undertaken.

FOG has not been able to apply the assessment methodology to grasslands it is familiar with, to ascertain the appropriateness of both methodology and the benchmarks used. However, it is concerned that benchmarks may be set too low, resulting in clearing of NTG of reasonable or good quality. Reasons include the fact that, in some native grasslands, dominance of certain species is regarded as being indicator of high site quality, regardless of other species present. At times, high cover of dominants may mask the presence of other species, or they may simply not be present. As mentioned above, methods of assessment of grassland sites should include assessment processes developed specifically for these unique ecosystems (e.g. Rehwinkel 2007).

Sincerely yours



John Fitz Gerald


14 August 2012



Rehwinkel, R (2007) A method to assess grassy ecosystem sites: using floristic information to assess a site's quality. NSW Department of Environment and Climate Change, Report to the Natural Temperate Grassland National Recovery Team (see