Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Director, Terrestrial Species Conservation Section
Department of the Environment
GPO Box 787 Canberra ACT 2601


Dear Sir/Madam

Leucochrysum albicans var. tricolor

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.

FOG wishes to comment on the proposed delisting of Leuchochrysum albicans var. tricolor and possible eligibility of L. albicans on the EPBC Act threatened species list. As L. albicans is a widespread species we see this question is really one of delisting L. albicans var. tricolor. The reason given for proposing to delist this plant is that it is “conventionally” accepted as a variety, not a separate species. FOG’s view is that, before the delisting occurs, genetic studies should be undertaken to find out whether, in fact, it is a separate species. As far as we understand from the Consultation package, such work has not been undertaken, and the decision to delist is based entirely on morphological features. Different varieties of L. albicans are often found in different locations and potentially have sufficiently different genetics such that L. albicans var. tricolor could be classifiable as a separate species (or subspecies).

FOG is concerned that L. albicans var. tricolor in the Central and Southern Tableland regions of New South Wales occurs mainly on sites which do not have formal conservation protection. A number are on crown land (roadside reserves, TSRs, cemeteries, council reserves, crown reserves, etc.), and on many of these L. albicans var. tricolor is vulnerable to changed management, e.g. due to increasing grazing pressure, weed invasions, higher management intensity in cemeteries, road widening or other road management activities. Many other sites are on private land, where L. albicans var. tricolor is vulnerable to changed management, such as increased grazing pressures or rural subdivision development. Page 4 of the Consultation package notes that the total population in Victoria is significantly smaller than in Tasmania or New South Wales.

In conclusion, FOG considers that L. albicans var. tricolor should retain EPBC Act listing until such time that genetic studies are undertaken to prove conclusively whether or not it is a separate taxon.

Yours sincerely


Sarah Sharp
28 January 2015