Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


The Director
Species Listing, Information and Policy Section
Biodiversity Conservation Division
Department of Climate Change, Energy, the Environment and Water
John Gorton Building - King Edward Terrace
GPO Box 3090


EPBC listing of four species of Grassland Earless Dragon

Reference: proposed listing of Tympanocryptis pinguicolla (Victorian Grassland Earless Dragon (VGED), T. mccartneyi (BGED), T. lineata (CGED) and T. osbornei (MGED) as critically endangered   

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 native 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 has for many years actively supported the conservation of the Grassland Earless Dragon, through advocacy, active participation in the former GED recovery team, public education and communication, on-ground work, and financial support. The GED Recovery Team was closed down when it proffered an opinion on the northern road at the Canberra Airport. This was an unfounded decision and when the non-government members of the team made their comments known to the department, they received no response.


FOG agrees that the GED should be split into four species and each species be listed as critically endangered, based on the scientific research published by Melville et al. in 2019, which taxonomically distinguished four separate species of Grassland Earless Dragon lizards.

Further to this, we urge the Commonwealth government to re-establish the recovery team for GED, either collectively for all four species, or separate sub-teams for one or more species.  

Specific comments in relation of each of the new species:

Canberra GED

We welcome the inclusion of Table 1, p7 on the number of CGEDs at the nine sites known to have T. lineata. We also welcome the statement on Captive Breeding and Reintroductions.

Herbage mass varies considerably in GED habitat, so that vegetation may be either too tall and dense, or too low and sparse after drought for the preferences of GEDs. The section on threat abatement should in our view suggest some more intensive micromanagement approaches which might be trialled, such as creating a number of smaller patches suitable for dragons, prepared by ecological burning, slashing with removal of slash, removal of unsuitable plants, watering in dry times, and so on. Small predator-proof enclosures (possibly roofed by open wire - this would need some thought) where dragons could move in and out of the enclosure could also be considered.

Data on monitoring such as Table 1 should be published at regular intervals so that the public is kept informed of monitoring outcomes. This should be a commitment. Consideration could also be given to training volunteers to take part in monitoring as a citizen science program.

Consideration should be given to ensuring how the two genetic forms of the CGED (north and south Canberra populations) are managed genetically.

Monaro GED

Over the years, FOG has visited a number of sites at which MGED has been sighted. In one visit in about 2000,  a new population was discovered. On an early occasion, many FOG members participated in a successful survey for MGED and striped legless lizard on the Cooma tip area adjacent to Kuma Nature Reserve. It currently has taken out a lease to manage Top Hut TSR, where MGED are present, and holds regular work parties there. Recently, in consultation with the NSW Department of Environment and NSW Local Land Services it agreed to an ecological burn being conducted.

The paper Consultation on Species Listing Eligibility and Conservation Actions circulated with the listing, fails to mention several matters of note. Some years ago, a captive breeding program was conducted by the Canberra University using animals from the cleared wind farm at Nimmitabel. The outcome of the breeding program should be included in the paper.

The “Distribution” section of the paper mentions various surveys of MGED conducted on the Monaro. This should be converted into tabular form similar to that in Table 1, p7 of the CGED report. This would provide a clearer assessment of what is happening. Through FOG, the ACT Herpetological Association and other groups, it should be possibly to train volunteers to undertake surveys of MGED. Such surveys might cover some actual and likely sites on an irregular basis, but such surveys would be highly useful. Some surveys across Canberra sites currently involve volunteers.

Victorian GED and Bathurst GED

FOG has no direct experience with these species. However, from its experience elsewhere, it agrees with the Consultation on Species Listing Eligibility and Conservation Actions statement released and concurs with the Conservation and management priorities in that statement.


Yours sincerely


Professor Jamie Pittock

14 October 2022