Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Professor Michelle Leishman
NSW Scientific Committee
PO Box 1967
Hurstville NSW 1481


Dear Professor Leishman

Listing of Tablelands Snow Gum, Candlebark and Kangaroo Grass Grassy Woodland in the NSW South Western Slopes, South East Corner, South Eastern Highlands and Sydney Basin Bioregions

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 has a number of members from New South Wales. Its members include professional scientists, landowners, land managers and interested members of the public.

While FOG supports changing the determination of Snow Gum, Candlebark Grassy Woodland to critically endangered, given the parlous state of this plant community, it has some concerns about details of the listing as presented for comment.

FOG is surprised that the report by R.C. Armstrong, K.D. Turner, K.L. McDougall, R. Rehwinkel and J.I. Crooks (2013) – Plant communities of the upper Murrumbidgee catchment in New South Wales and the Australian Capital Territory (Cunninghamia 13(1): 125-265) – is not included in the references for this listing. This is a definitive work that has identified all vegetation communities that occur within the bioregion in question. In forming its views on this listing, FOG has drawn upon this report and asks that the Scientific Committee incorporates information from this report when finalising this listing.

Armstrong et al. (2013) identifies a number of Snow Gum and Candlebark Grassy Woodland communities that should be covered by the proposed new listing – see the attachment. Some of these communities appear to have been excluded by the proposed listing. It isn’t clear why this is the case, nor what will be the ongoing status of these communities. As the new listing is more restricted than the existing listing, what will be the status of Grassy Woodland communities in the current listing but excluded from the proposed Critically Endangered listing – will there be another determination to cover them? If so, shouldn’t such a determination be put forward at the same time? If not, what is the basis for excluding communities that include endangered grassy woodland.

FOG has some concerns about the emphasis on Kangaroo Grass in the listing name. Many sites of the current EEC are of considerable value but have not retained a significant level of Kangaroo Grass cover. The inclusion of Kangaroo Grass in the name implies that this species must be present, even though

As well, grazing or other disturbance may have reduced the Kangaroo Grass cover at a particular site but other elements of the community may still be present, so that the site is still of considerable conservation value.

As indicated in Armstrong et al (2013) Natural Temperate Grassland (NTG) is distinct from any Snow Gum Candlebark Grassy Woodland communities. Even in the absence of trees (whether naturally or by clearing), there are differences in understory species and position in landscape between the two communities, even if they do bear a number of similarities. At times, NTG may occur in the same general site as Grassy Woodland, but one is not a variant of the other. The current EPBC listing of NTG EEC is quite different from the current Tablelands Snow Gum Grassy Woodland listing. As well, the proposed new EPBC listing specifically states that “…NTG–SEH may also resemble the derived grassland state of two other listed ecological communities: the NSW-listed Tablelands Snow Gum, Black Sallee, Candlebark and Ribbon Gum Grassy Woodland in the South Eastern Highlands, Sydney Basin, South East Corner and NSW South Western Slopes Bioregions…”, a clear recognition of two distinct communities. Reference to grassy variants of Snow Gum Candlebark Grassy Woodland as being part of the EPBC listing of NTG should be removed from section 4.8, and mention of it intergrading with NTG made in section 4.7.

FOG also has some concerns about the species list defining the listing. Species such as Eucalyptus amplifolia, Eucalyptus cinerea, Eucalyptus melliodora, Eucalyptus mannifera and Eucalyptus tereticornis are not generally part of Snow Gum Grassy Woodland (see Armstrong et al., 2013), and it isn’t clear why they are on the species list. Another concern is that many of the species included are sensitive to grazing, fertiliser addition and other disturbances. While these species need to be on the list, in its current form the list will bias site assessment against sites with a history of disturbance. The danger in this is that floristically less diverse sites having other vales such as site size, fauna habitat, old growth trees or connectivity values will be excluded.

In this regard, the 38% criterion (of the vascular plant species present being on the species listed in the determination) proposed is significant. It is not clear what the basis for this figure is. It also appears to contradict the stated intent of the Scientific Committee, that “…all occurrences of the ecological community …independent of their condition … be covered by this Determination”. A more usual criterion is that the understorey be predominately native, with or without a component of characteristic species, and it isn’t clear to FOG why such a criterion has not been used here. Another of FOG’s concerns is that there are likely to be floristically rich sites of the current EEC that won't reach a value of 38% of species that are on the new species list.

The document refers to additional information that has become available, but some of the recent publications in this area (e.g. from Cunninghamia) are not in the reference list. It isn’t clear to FOG what the additional information is or how it could be accessed, and thus if there is other evidence concerning some of the points FOG has raised that we have not been able to take into consideration.

The intention is to list this community as critically endangered, a proposal that FOG supports. However, given the critical nature of the ongoing existence of this community, FOG’s view is that the listing needs to err on the liberal side rather than be so restrictive that only the very highest quality sites are covered. Medium quality sites have potential in terms of being rehabilitated and their quality improved, in providing important habitat for the fauna species that use this community, and in providing important corridors for migratory birds and other species linking conservation islands across the landscape.

Yours sincerely

Sarah Sharp

23 July 2014


Attachment: Snow Gum Candlebark communities in Armstrong et al. relevant to the listing

e24         Mountain Gum – Snow Gum very tall dry shrubby open forest primarily in the Kybeyan – Gourock subregion of the South EasternHighlands bioregion

m31       Ribbon Gum – Snow Gum – Cassinia longifolia tall shrub-grass open forest of gullies in quartz-rich ranges in the Monaro and Kybeyan-Gourock subregions of the South Eastern Highlands bioregion

p220      Ribbon Gum – Snow Gum tableland flats tall grassy woodland primarily on granitoids in the Kybean – Gourock and Monaro subregions of the South Eastern Highlands bioregion

p520      Ribbon Gum very tall woodland on alluvial soils along drainage lines of the eastern South Eastern Highlands bioregion

u22         Mountain Gum – Snow Gum ± Robertson’s Peppermint grass-forb very tall woodland to open forest of the Australian Alps and South Eastern Highlands bioregions

u23         Snow Gum – Drumstick Heath – Leptospermum myrtifolium tall woodland to open forest of drainage depressions primarily of the South Eastern Highlands bioregion

u27         Snow Gum – Candlebark tall grassy woodland in frost hollows and gullies of the South Eastern Highlands bioregion

u28         Snow Gum – Mountain Gum – Daviesia mimosoides tall dry grass-shrub subalpine open forest of the Australian Alps and South Eastern Highlands bioregions

u78         Snow Gum grassy mid-high woodland of the South Eastern Highlands bioregion

u118:     Black Sallee grass-herb woodland in drainage depressions and moist valley flats in the South Eastern Highlands and Australian Alps bioregions


Source: R.C. Armstrong, K.D. Turner, K.L. McDougall, R. Rehwinkel and J.I. Crooks (2013) – Plant communities of the upper Murrumbidgee catchment in New South Wales and the Australian Capital Territory, Cunninghamia 13(1): 125-265