Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614



Ecological Communities Section
Department of the Environment
GPO Box 787
Canberra ACT 2601


Dear Sir/Madam

Natural Temperate Grasslands of the South Eastern Highlands Bioregion

Friends of Grasslands (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. FOG is based in Canberra and its members include professional scientists, landowners, land managers and interested members of the public.

Support of listing

FOG supports the listing of Natural Temperate Grassland (NTG) of the South Eastern Highlands bioregion as threatened. We are aware that the previous listing of Natural Temperate Grassland of the Southern Tablelands of NSW and the Australian Capital Territory excludes some grassland sites that meet the same criteria but fall outside the geo-political boundary on which the first listing was based. Examples are Logans Travelling Stock Reserve (TSR no. 34) at Tumbarumba, Shadforth Reserve in the Orange area and Wrights TSR (no. 67) in the Bathurst area.

FOG also supports the inclusion of two more grassland types, no 4 – Lacustrine Grass – Forbland of the South Eastern Highlands Bioregion and no 8 – Kangaroo Grass – Purple Wire-grass – Wattle Mat-rush dry tussock grassland in the Southern Tablelands region of the South Eastern Highlands Bioregion, in the definition of Natural Temperate Grassland. Again, we are aware of examples of both types of grassland within the bioregion that were not covered by the original listing, such as in Yass Gorge, Gundary TSR and the Aprasia habitat along the Molonglo and Murrumbidgee Rivers.

Listing category

FOG believes that this ecological community should be listed as critically endangered rather than endangered. While we have not been able to apply the criteria to determine this rigorously, our observations within the ACT have led us to this view. Within the ACT many NTG sites have degraded due to the recent drought, weed invasion, and insufficient management (due mainly to lack of resources). In her 2009 Report on ACT Lowland Native Grassland Investigation the ACT Commissioner for Sustainability and the Environment (CSE) concluded that, of the ACT’s 49 lowland native grassland sites, only 40% were in good condition, with 20% being in critical condition and the remainder approaching a critical threshold. While this was in part due to the drought, such conditions will be more common in the future due to climate change and will continue to threaten our NTG areas. Since the CSE’s report, the quality of one of the sites that was approaching a critical threshold (Constitution Avenue, Reid (CC02), EPBC referral 2012/6292) has deteriorated and the site has been subsequently removed for development, albeit with offset conditions. Other sites continue to be threatened, in particular by weeds and over-grazing but also in some cases by development pressures.

FOG considers that further investigations by relevant authorities should be undertaken as a matter of priority in order to determine the appropriate threat classification for the proposed grassland community.

Condition thresholds

In the Moderate condition threshold category in section 1.5.2 step2, FOG has the following comments:

In the High condition threshold category in section 1.5.2 step2, FOG has the following comments:

Additional considerations

In reading section 1.5.3 Additional considerations, FOG felt that some of the points here, while very important, were not actually considerations in assessing the condition of NTG areas, e.g. the first paragraph on land use and the third paragraph on buffer zones. Perhaps these points could be moved into a separate section, to improve the clarity of the Key diagnostic characteristics and condition thresholds section in terms of its application on the ground.

With reference to the definition of a patch, FOG supports the statements regarding the dynamic nature of patch boundaries.  For example, in Appendix B Detailed description of biology and ecological processes, there is reference to the dynamic nature of NTG with variations in weather conditions.  The patch size of an area of NTG during a drought might be much smaller than same patch size as assessed during a good year. In determining patch sizes the precautionary principle needs to be applied, i.e. boundaries of patches need to be based on the maximum possible extent of the area of native vegetation, rather than the minimum, particularly if the assessment is being undertaken in a poor season.

In the section on Buffer zones, FOG’s view is that any action that has a significant impact on buffers must be referred for assessment, and that there should be no adverse impacts in buffers as well as in the conservation area itself. Buffer zones not only provide protection for the ecological community, but also provide an area for the endangered community to spread in a good season, thus increasing the size of the NTG area. This is particularly important for NTG communities since many of the areas left are quite small and so more vulnerable to disturbance. If adverse impacts from, say, urban development, occur in the buffer, this in effect reduces the size of the buffer and increases the vulnerability of the high quality area being conserved.

FOG recommends that the section on Sampling protocols be revised to improve clarity and provide specific guidance for sampling requirements. Guidelines should be established to ensure survey data is comparative across all survey sites. For example, it isn’t clear what is meant by “thoroughly” or “representative” in the text “… site should then be thoroughly sampled on a representative basis for vegetation cover…”. Survey requirements including the minimum number of sampling points per ha to determine vegetation cover (i.e. whether or not the percentage cover of native vascular plants in the patch is greater than the percentage cover of perennial exotic species) as well as guidance to determine the number of 0.04 ha sampling sites per hectare (to determine level of diversity and therefore condition class) should be specified to ensure adequate and comparative data is collected. Further analysis should be conducted to determine the appropriate level of survey effort required. FOG supports the recommendation that sampling should be based on 0.04 ha and that one hour per 0.04 ha be required to adequately detect species.

FOG also recommends that assessments be targeted at determining maximum diversity rather than be undertaken on a random basis. Accordingly, assessments should be undertaken within the most diverse parts of the site. Given the poor condition, patchy nature and small size of many remnant native grassland sites, it is highly possible that random surveys may fail to detect areas of high diversity. The determination of White Box – Yellow Box – Blakey’s Red Gum grassy woodlands and derived native grasslands, which shares similar groundcover characteristics with native grasslands, requires surveys within the parts of the patch that contain the most native species in the ground layer.

In the section on Timing of surveys, FOG supports the statement “ that the High and Excellent condition categories can only be identified if surveyed in spring or other time when plant species are most evident”. We further recommend that, for adequate assessment of a site’s condition, all grassland surveys must be done at the most appropriate time, i.e. the time of maximum flowering or diversity. This may vary from year to year as conditions vary.

Another factor that FOG believes needs to be taken into account when conducting assessments is the potential impact of the application of simple weed control measures. There are NTG areas that have been invaded somewhat by weeds such as African Love grass, Chillean Needle grass or St Johns wort. At times these areas still contain significant biodiversity – if the weeds were sprayed over a couple of years, the area has potential to revert to a moderate or high quality native grassland, i.e. the NTG is recoverable. However, a significant disadvantage of the assessment methods currently used is that the presence of such weeds means that the area may not meet the initial criteria of being predominately native and is excluded at that point from further assessment. In view of the parlous state of NTG, consideration needs to be given to assessing the possibility of returning such areas to good quality NTG following some simple management actions.

Surrounding environment and national context

In the second paragraph in section 1.6, the word “indicators” in line 6 should be replaced by “factors”, since these are all factors that the Minister may need to consider in making decisions about these matters. In particular, these factors can be used to determine the relative importance of a remnant grassland patch and therefore assist in the development of referral conditions should these be required.

Areas critical to the survival of the ecological community

FOG supports the statement that all patches that meet thresholds to be listed as the community should be considered as critical to the survival of the community. The term “plus buffer zones” needs further clarification. This would assist FOG and other groups/ individuals when providing comments on referral documents where there may be potential impacts on NTG or buffer zones.

Yours sincerely



Naarilla Hirsch
Advocacy coordinator

4 May 2014