Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614



Ken Flower
General Manager
North West Local Land Services


Dear Mr Flower

NSW Travelling Stock Reserves – Draft State Planning Framework 2016-2019

Friends of Grasslands (FOG) is a community group committed to the conservation of natural temperate grassy ecosystems (grasslands and grassy woodlands) in south-eastern Australia, leading to its interest in the future of the Travelling Stock Reserve (TSR) network in NSW. As well as interested members of the public, FOG’s membership includes NSW primary producers, native seed collectors, NSW and ACT government employees, professional scientists such as botanists, ecologists and other biological scientists, and field naturalists who have had a long history in studying, documenting, managing, and advocating for the biodiversity conservation values of TSRs in NSW. This membership gives FOG a good understanding of TSR values and management issues. FOG advocates, educates and advises on matters to do with the conservation of grassy ecosystems, and carries out surveys and on-ground management work, and participates in advisory panels. Our members, in different roles, have undertaken field days and extensive surveys at numerous TSRs throughout NSW, provided information and management advice to TSR rangers, conducted large scale studies documenting their extent and biodiversity values, and even served as a former Rural Lands Protection Board (RLPB) director.

FOG welcomes the opportunity to review strategically the future use and management of TSRs and Travelling Stock Routes. We are pleased that this is in line with our recommendation, made in a previous submission, that stakeholders be consulted with during development of a consistent State-wide management framework. We understand that the size, distribution and condition of these TSRs vary enormously. However, as you will be aware, FOG has been concerned about the future of those TSRs with high conservation values for some time, having provided comments in January 2013 to the Crown Lands Review and in June 2014 to the Crown Lands Legislation White Paper (see Attachment C). It is disappointing to see that many of our concerns and comments are not addressed in either the NSW government’s response to the Crown Lands Legislation White Paper or in this draft framework. We are concerned that the framework does not seem to acknowledge and reference adequately the historical importance of the TSR network, nor the great amount of work, including numerous reviews, on the environmental and other values of TSRs that have occurred over the last 20 years or more. It also gives little guidance on how this work will be incorporated into future documents and management activities. FOG is concerned about the length of time the process is taking, with commensurate delays in protecting some of our most endangered native flora and fauna species and remnant native ecological communities. We have included copies of our earlier submissions (attachment C) so that these might be considered as well as the specific comments on the framework that follow.

While recognising that frameworks such as this are in general broad, FOG feels that it lacks sufficient coherence and detail in key areas that would be appropriate to include, such as timeframes and resourcing. For example, while a five year cycle is mentioned for the regional plans, when will the first regional plans be expected to be available? Who will be responsible for ensuring that the process of monitoring and reporting outlined in section 6 is well designed and actually occurs when required? What protection will be given to Travelling Stock Routes and when will that occur?

Section 1 Introduction

Section 1.3 Guiding Principles

FOG is pleased to see recognition of conservation as one of the stakeholder values in this section. However, given the threatened status of some of the endangered ecological communities (EECs) and species that occur on some TSRs, and the importance of these TSRs in mitigating against extinction of these EECs and species, we feel that preservation of these high quality conservation areas should be a separate principle – they form a lasting legacy to future generations of all Australians.

Section 1.5 The Planning Cycle

All of the important biodiversity values of the reserve network need to be carefully considered in any future management plans that are drafted, in particular the TSR regional management plans.

Section 3: Uses and values of TSRs and Crown lands

Biodiversity values

Again, FOG feels that the section 3 considerably downplays the significant biodiversity values of many TSRs and their importance in conserving our natural heritage. FOG is aware that many TSRs have outstanding biodiversity values, with excellent examples of remnant native lowland vegetation and sites with EECs. The largely agricultural areas in which they exist contain NSW’s most highly cleared (typically >70%, frequently >90%), fragmented and degraded landscapes. Many of these vegetation types are very poorly conserved in NSW’s formal reserve network because, historically, the emphasis for formal conservation of vegetation had a greater focus on large blocks of forest country and other land of low agricultural value. By definition this has excluded lowland communities such as Natural Temperate Grassland (NTG), Box-Gum Woodland (BGW), Tablelands Snow Gum Grassy Woodland and Grey Box Grassy Woodland (reference 1, attachment A). The above EECs are listed under either the Australian Government’s Environmental Protection and Biodiversity Conservation Act (1999) or the NSW Threatened Species Conservation ACT (1995), or under both Acts. These EECs have all been severely impacted upon by past agricultural and development pressures.

The reason many TSRs contain excellent examples of these EECs is in part due to the past management of travelling stock – grasslands and grassy woodlands have benefited from the occasional grazing that managers of travelling stock have applied to the sites. Lowland grassy ecosystems benefit from occasional biomass removal including that which is applied by occasional grazing associated with travelling stock. This former grazing style has also not been deleterious to many of the grazing-sensitive flora species that are still found in numerous TSRs and indeed, as identified above, may have resulted in the retention of some species that are no longer found in sites subject to other forms of management.

The EECs on TSRs have a high irreplaceability value. Should these values be damaged or destroyed by inappropriate future management, it would be very difficult and costly, if not impossible, to restore those values. However, there is no mention at all of EECs in this section.

Many TSRs also contain populations of threatened flora and fauna species. The flora species are often specialised grassy ecosystem species. For example, of the five populations of the endangered Tarengo Leek Orchid (Prasophyllum petilum), two occur on TSRs, with the other three on country cemeteries (Attachment A, reference 2). Again, there is no recognition in section 3 of the rarity of some species found on TSRs or the major role TSRs play in conserving these species into the future. Conservation of endangered species or EECs is even more incompatible with activities like mountain bike riding than is bird watching, but is not mentioned in this context in section 3.2.

With regard to the categories in Table A, it is not immediately obvious what the distinction between categories D and E are, since both are titled “Recreation/conservation”. The active uses listed seem to imply that category E might be of higher conservation value since most active uses are excluded, although starting the title with “Recreation” implies that this is the more important use. In fact there should be a category titled “Conservation” where the only active use is “passive recreation” and possibly “strategic grazing to preserve conservation values” – this would take account of those TSRs of high conservation values, e.g. those containing listed species or EECs.

Connectivity values

As FOG has pointed out in its earlier submissions, Travelling Stock Routes have very important connectivity values. This is particularly the case in the west of the State, where the routes in the cropping zone of the western slopes and plains are often the only intact lowland native vegetation in those regions, i.e., the only vegetation where the native tree cover and ground layer is more-or-less intact. Linked as they are by the TSRs, they together form a network both within NSW and connecting to stock routes and corridors in other States. These interstate connections are important for biodiversity and ecological health overall. The way in which the TSR network is managed will have effects well beyond NSW borders.

However, connectivity is only mentioned briefly in the framework (under “Biodiversity review” on page 4), and the proposed structure is likely to emphasize local or at best regional considerations rather than overall connectivity. We repeat our earlier recommendation to the Crown Lands Review:

“Conservation and management of TSRs needs to be broadened to protect and promote connectivity values and to include Travelling Stock Routes as well as the Reserves. As well, to maintain connectivity, safeguards need to be in place to ensure that the network is not fragmented between land management agencies, nor parts sold off. TSR managers should also work with managers of other non-TSR vegetation to ensure landscape connectivity is maintained and improved, for example, in relation to Council roadside reserves. Therefore local partnerships should be promoted, for example with the Office of Environment and Heritage, local Councils, Great Eastern Ranges, Slopes to Summit, and Kosciuszko to Coast.”

At the very least the framework should include some mention of connectivity values in section 3 and possibly also section 4.

Values for the wider community

Another important passive use of TSRs is their value to the wider community for educational and research purposes. The reserves provide great opportunities for school and university students and those in interest groups such as FOG to access lands that contain remnants with these EECs and threatened species and undertake important research related to recovery of these ecosystems. One good example is the Dunedoo Woodland Learning Centre (near Dubbo), a collective effort by a range of government, council and community organisations as well as individuals. A track and excellent signage have been added to the Grassy Box Woodland in what was formerly the Dunedoo TSR to create something for (in their words) “People and Nature – educating, conserving and balancing”.

Weed invasion

Table B in section 3 mentions weed and pest control as one of the management principles. In this regard we would like to draw to your attention a potential conflict between this management principle and possible uses of TSRs.

We understand that in the last few years, some reserves have been grazed under different regimes through a grazing permit system applied by previous or current managers of these reserves (i.e. the RLPBs, LHPAs and now LLSs). This has resulted in increased weed invasion in some sites, as well as declines in the ground-layer flora, as both observed by members of FOG, and by reference to data collected by members of FOG (reference 3). An example of this effect is at Gundary TSR, near Goulburn. When this site was first surveyed in the late 1990s, it was unfenced and therefore not suitable for holding stock for any length of time. The TSR was fenced in the early 2000s. Grazing by cattle was then introduced. In the early surveys, small populations of African Lovegrass were recorded there. In recent surveys, greater densities of African Lovegrass were recorded, with this species now occurring over significant areas of the reserve. This is directly attributed to the introduction of more frequent cattle grazing. Such trends may be expected to increase with greater pressure associated with the introduction of long-term grazing on the reserves.

Section 5: Funding

FOG understands that funding for maintenance of the TSR network has long been a problem. We are concerned that the framework suggests that a minimum effort is required to look after those TSRs with high conservation values (section 5.1, page 13). In fact, this is not necessarily the case. FOG is also concerned about the implied devolvement to the regional level of acquisition of national or state based funding, since this is likely to lead to quite different levels of care being applied to similar value areas. Some suggestions for additional funding sources are:

In any event, FOG sees it essential that the NSW Government ensure that sufficient funding is available to manage TSRs with high conservation values, so that these reserves retain their values for future generations.

Section 6: Monitoring and reporting

This section lacks sufficient detail. We reiterate and paraphrase most of our response to the question requesting suggestions to improve governance standards for Crown reserves in our Crown Lands Legislation White Paper submission and recognise this also links to Section 2 Management Context and Section 4 Consultation and Liaison. We also provide guidance on understanding TSR biodiversity values for use in developing this section of the framework.

To meet Government priorities for improved transparency, accountability, and consistency of management we suggest:

Understanding biodiversity values

The NSW Government should use the available data as a basis for further assessment work, to gain a full understanding of the biodiversity values of the TSR network. There already exists a wealth of material about the biodiversity of TSRs. One such resource is a dataset of the values of TSRs for the Identification of priority conservation Travelling Stock Reserves in NSW project, work which was undertaken in 2008-2009 by the NSW Office of Environment and Heritage (OEH) with Australian Government funding. This work built on another NSW OEH and Australian Government project undertaken from 2004 to 2007 surveying biodiversity values of remnant Box Gum Woodland EEC and other native vegetation on private and public land throughout the NSW sheep-wheat belt. The TSR project dataset is available at and was last updated in 2010. Note that, while it contains information for just over 50% of TSRs in the NSW Central Division that had been surveyed between 1996 and 2009, there were large data gaps at that time. Also some EECs had not been recognised at that date and those EECs are known to occur on some TSRs (Attachment A, reference 4). This dataset should be updated and completed for use in benchmarking management of the TSRs.

The methods and key findings of this project are summarised in Attachment B below. Several are of particular importance in relation to the draft framework. The first is that some TSRs were not identified as RLPB land by the TSR rangers and therefore not being actively managed by them. Next, of the surveyed TSRs, about 65% were likely to support at least one nationally and State listed EEC. Finally, the existing available survey data also indicated that at least 20% were rated as of stand out (high) biodiversity conservation value and at least 75% were rated as of important (medium to high) conservation value


FOG urges the NSW Government to consider carefully the future of the TSR network and especially those sites that contain outstanding examples of EECs, threatened flora and fauna and other vegetation and wildlife values. The NSW Government has a responsibility to abide by the NSW Threatened Species Conservation ACT (1995) that it administers. Conservation of biodiversity values of TSRs will go a long way to conserving the under-represented EECs and their associated threatened species.

In particular,

FOG is grateful for the opportunity to make comment on the future of the TSRs. We would welcome the opportunity to provide further input in regards to this matter, or to provide comment on those TSRs on which we have particular knowledge.

Yours sincerely



Sarah Sharp

3 December 2015


Attachment A: References


Note that web references marked with * contain data from surveys of grassy ecosystems from throughout NSW, in surveys with the following relevant “survey names”: GEDBFFP, GEDBRAHP, GEDBRAP, and GEDBSWBP. At the time of writing this submission, these surveys were in the process of being uploaded into the NSW VIS Module.

Attachment B: Summary of findings of Identification of priority conservation Travelling Stock Reserves in NSW project

The 2008-2009 TSR project study area comprised 30 of the former 47 RLPB district areas in The Long Paddock Travelling Stock Reserve and Route Directory and contained approximately 4,000 (80%) of the nearly 5,000 listed TSRs including Stock Watering Points (SWPs). The existing TSR biodiversity assessment datasets covered 21 of the 30 former RLPB districts in the project study area although not every TSR was assessed in each RLPB district. At the time this left nine RLPB districts in the project study area without any existing comprehensive standardised expert survey assessments of their TSR biodiversity conservation values.

To supplement the existing survey data, face to face interviews were conducted with TSR rangers to draw on their extensive on-ground knowledge and were either completed or commenced for 28 of the 30 RLPB districts. Although the intention was to obtain data on all TSRs in each RLPB district, priority was given to conducting interviews in RLPB districts for which there was little or no known existing TSR survey data and in those districts most likely to support Box-Gum Woodland EEC. Through a standardised set of expert designed questions, it was possible to gain an indication of TSR biodiversity conservation value (CV) rankings without requiring TSR rangers to have expert ecological knowledge.

The TSR ranger interviews also yielded existing survey data, information about other TSR conservation and use values (e.g. cultural heritage), current management status and issues, and updated TSR identification and mapping details (e.g. Long Paddock name & ID number, component land parcels). There is still work required in compiling, updating, and analysing all of this data as well as filling data gaps for omitted TSRs. It was found the project study area had in the order of 1000 more TSRs than listed in the Long Paddock Directory i.e. 5,000 rather than 4,000. This was assuming another estimated 100-200 TSRs for the two RLPB districts that did not have TSR ranger interviews. The total area of TSRs estimated to occur within the project study area was around 490,000ha with just under 8,000ha of that not identified as RLPB land by the TSR rangers and therefore not being actively managed by them. Individual TSRs ranged in size from 0.5ha to 3,681ha.

Analysis of available existing expert survey data sets obtained for approximately 2,700 of 5,000 TSRs spread throughout the project study area indicated that about 65% were likely to support at least one nationally and State listed EEC. Of the TSRs likely to support an EEC, ~45% were likely to support Box-Gum Woodland, ~35% Inland Grey Box Woodland, and ~10% Myall Woodland. The existing available survey data also indicated that at least 20% were rated as of stand out (high) biodiversity conservation value and at least 75% were rated as of important (medium to high) conservation value. By coincidence the TSR ranger interview data sets gave the same overall biodiversity conservation value rankings, however, this included many of the 9 RLPB districts without existing expert survey data. The TSR ranger interview data also indicated that at least 40% of TSRs contain or adjoin a permanent natural water source such as a creek, river, spring, lagoon, billabong, swamp, wetland, water hole, or lake.

Attachment C: FOG’s previous submissions

Crown Lands Legislation White Paper 18 June 2014

Travelling Stock Reserves and the Crown Lands Review 22 January 2013