Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


NSW Threatened Species Scientific Committee
PO Box 1967
Hurstville NSW 2220


Dear Sir/Madam

Proposed Critically Endangered Ecological Community listing:
Monaro Tableland Cool Temperate Grassy Woodland in 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.

FOG broadly endorses the proposal to list Monaro Tableland Cool Temperate Grassy Woodland in the South Eastern Highlands Bioregion as a CRITICALLY ENDANGERED ECOLOGICAL COMMUNITY in Part 1 of Schedule 2.

FOG proposes that this community be renamed to “Southern Tableland Cool Dry Temperate Grassy Woodland” to distinguish it from the preliminary listed Werriwa Tableland Cool Temperate Grassy Woodland (which accordingly should be renamed “Southern Tableland Cool Wet Temperate Grassy Woodland”). Our reasons for doing so are:

FOG also has suggestions about addition of a number of technical details that, if adopted, will make for a stronger, more robust determination for this critically endangered community, as follows.

Spelling errors

Change these in the following sections:

Section 1.1 -  “Acaena echinate” to “Acaena echinata”, “Glycine clandestine” to “Glycine clandestina”, “Poa labillardieri” to “Poa labillardierei

Section 3.1.3 – “GRp22” to “GWp22”

Section 3.1.8 – “Lolium perrene” to “Lolium perenne

Section 4.10 – “Diuris pedunculate” to “Diuris pedunculata

Section 1.1

The species list in this section is representative of high-quality remnants, but does not necessarily reflect degraded examples where the groundlayer has been disturbed by overgrazing or other disturbances. Lower quality examples consistent with the Monaro Tableland Cool Temperate Grassy Woodland commonly have the following species, which should be reflected in the species list in section 1.1 of the preliminary determination: Bothriochloa macra, Chloris truncata, Rytidosperma auriculatum, Rytidosperma carphoides, Rytidosperma erianthum, Rytidosperma leave, Rytidosperma bipartitum, Rytidosperma longifolium, Rytidosperma pilosum, Rytidosperma racemosum, Enneapogon nigricans, Austrostipa densiflora, Rumex brownii, Convolvulus angustissimus, Cymbonotus lawsonianus and Triptilodiscus pygmaeus.

The foregoing are all listed in Costin (1954), either under the above names or under their synonyms, as being part of Costin’s Eucalyptus pauciflora-E. stellulata alliance. Section 3.1.7 lists several of these species, some under the older names as used by Costin (1954), for example Austrodanthonia spp. (now Rytidosperma spp.), Enneapogon spp., and Helipterum spp. (now Triptilodiscus pygmaeus) (Costin 1954).

Section 3.1.7 of the preliminary determination lists a number of species that should also be included in Section 1.1. These species are characteristic of disturbed areas and include Cassinia longifolia, Acacia rubida subsp. rubida, Pimelea pauciflora and Pteridium esculentum.

Additionally, the following species are commonly encountered in samples of Monaro Tableland Cool Temperate Grassy Woodland: Bursaria spinosa and Melicytus angustifolius subsp. divaricatus (syn. Melicytus dentatus (Snowfields variant)) and should be included in the species list of 1.1.

Failure to include species from lower quality examples of the community in Section 1.1 will result in a failure to protect those remnants of the community that are not in a high quality state. It needs to be noted that plot samples collected from communities for subsequent vegetation analysis are almost invariably taken from sites that are representative of a supposed characteristic state for that community and thus are rarely collected from poorer samples. Resultant vegetation classifications are therefore reflective of that bias.

A full list of species that should be added to Section 1.1 (including species from degraded remnants and shrubs species not currently on the list is as follows:

Acacia rubida subsp. rubida

Austrostipa densiflora

Bothriochloa macra

Bursaria spinosa

Cassinia longifolia

Chloris truncata

Convolvulus angustissimus

Cymbonotus lawsonianus

Enneapogon nigricans

Melicytus angustifolius subsp. divaricatus

Pimelea pauciflora

 Pteridium esculentum.

Rumex brownii

Rytidosperma auriculatum

Rytidosperma bipartitum

Rytidosperma carphoides

Rytidosperma erianthum

Rytidosperma leave

Rytidosperma longifolium

Rytidosperma pilosum

Rytidosperma racemosum

Triptilodiscus pygmaeus

Section 3.1.8

This section should include the following exotic invasive species: Phalaris aquatica, Dactylis glomerata, Festuca spp., and Hypericum perforatum as other dominant invasive species in the Monaro Tableland Cool Temperate Grassy Woodland.

Section 4.1

The sentence that begins “The ground stratum is typically dominated by Themeda triandra ...” should be reworded to read “The ground stratum of highly intact remnants is typically dominated by Themeda triandra ...”.

This sentence should then be followed by a sentence that reads “The ground stratum of poorer quality remnants may be composed of the some of the following grasses, either as monocultures or mixtures of one or more, usually several of the following grass species: Austrostipa densiflora, Bothriochloa macra, Chloris truncata, Enneapogon nigricans, Rytidosperma auriculatum, Rytidosperma bipartitum, Rytidosperma carphoides, Rytidosperma erianthum, Rytidosperma leave, Rytidosperma longifolium, Rytidosperma pilosum and Rytidosperma racemosum, with or without Themeda triandra, and with some of the more grazing-tolerant forb species listed in Section 1.1 present, along with the following: Convolvulus angustissimus, Cymbonotus lawsonianus, Rumex brownii and Triptilodiscus pygmaeus”.

Section 4.10

Include in this section the following threatened flora and fauna species:

Eucalyptus aggregate

Petroica boodang

Petroica phoenicea

Artamus cyanopterus

Yours sincerely


Geoff Robertson

17 October 2018


Costin AB (1954) ‘A study of the ecosystems of the Monaro Region of New South Wales with special reference to soil erosion.’ (A.H. Pettifer, Government Printer: Sydney)