Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


The Director
Bushfire Affected Species Assessments Section
Protected Species and Communities Branch
Australian Government Department of Agriculture, Water and the Environment
PO Box 858
Canberra ACT 2601


Dear Sir/Madam

Leucochrysum albicans subsp. tricolor (Hoary Sunray): listing assessment

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.

In commenting on this listing, FOG notes that the proposal is to downgrade Leucochrysum albicans subsp. tricolor (Hoary Sunray) from endangered to vulnerable.

In its ongoing field trip program FOG has visited many grassland sites in the ACT, various parts of NSW and to a lesser extent Victoria. In some years we have observed good displays of the daisy along roadsides in the local area, although our impression is that these flowerings may be on the decline. At Old Cooma Common Grassland Reserve, a site where FOG has had a long-term involvement, there has been a persistent presence of a small population. Elsewhere, the presence of wild populations is not much in evidence.

We concur with comments in the paper that populations are fragmented and given that some populations are small, genetic variability may be an issue. A phenomenon that might affect the apparent distribution of the daisy in the ACT and surrounding region is its wide and successful use in seed orchards and scrape and sew applications where it readily establishes, seeds and produces off-spring. However, the genetic variability of the seed being used to establish these populations is unknown, as is the ability of these populations to withstand competition. 

While there may be an argument for downgrading the status of ACT and NSW populations, the poor status of populations elsewhere is an argument to retain the species as endangered to enhance its overall genetic variability. 

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

20 June 2021