Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


NSW Threatened Species Scientific Committee
PO Box 1967
Hurstville BC NSW 1481

Dear Sir/Madam

White Box – Yellow Box – Blakely's Red Gum Grassy Woodland and Derived Native Grassland in the NSW North Coast, New England Tableland, Nandewar, Brigalow Belt South, Sydney Basin, South Eastern Highlands and NSW South Western Slopes Bioregions (Preliminary determination)

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 with many members in surrounding NSW. Its members include professional scientists, landowners, land managers and interested members of the public. This submission was compiled by Friends of Grasslands member, Rainer Rehwinkel, a retired ecologist whose former career with the NSW Office of Environment and Heritage focussed on the survey, conservation and ecology of grassy ecosystems of south-eastern NSW. Rainer is a recognised expert in the ecology of White Box Yellow Box Blakely's Red Gum Woodland and Natural Temperate Grassland.

FOG is concerned that the determination still requires a lot of work, especially in the following areas:

  1. The determination requires a slight broadening of its range to reflect occurrences in areas not covered, and subsequently, a slight change in its name would be required.
  2. There are significant taxonomic issues, with many species' names requiring a taxonomic update.
  3. The determination has significant distributional issues, with a strong bias away from the occurrence of the community in south-eastern NSW. This is reflected in the poor representation of the species that characterise the community in the south-east of its range in Section 1.1 of the determination.
  4. The determination includes elements and vegetation types characterised by those occurring in the less fertile, and thus the less threatened parts of the community's environmental envelope, as defined by the determination. Should this determination be accepted, then it would mean that the higher value, more threatened parts of the community that occur on the lower, more fertile parts of the community's distribution will continue to be depleted in favour of the less fertile parts. A direct result of this will be greater attention on the less fertile parts due to offsetting the loss of the more threatened parts. FOG strongly believes that the addition of species and communities occurring in lower fertility gradients as in the current preliminary determination warrants further justification. While the determination notes the importance of the typical, more traditionally accepted box and gum eucalypts (as in the current listing), the ambiguity in the language throughout the determination could be used to support a range of interpretations. This is of concern to conservationists, ecologists and compliance officers and would be a perverse outcome, should the determination not be significantly amended.

Details of FOG’s comments, including notes outlining a solution to this last issue, can be found in the attachment.

Yours sincerely

Geoff Robertson

30 January 2020