Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


Department of Agriculture, Water and the Environment
GPO Box 858
Canberra ACT 2601


Dear Sir/Madam

Threatened Species Action Plan 2021 – 2026: consultation paper

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.

We have answered questions in the consultation paper from the perspective of conservation of our grassy ecosystems and the species that rely on these ecosystems.

Action Area 1 - Mitigating new and established threats

We strongly agree with the proposed actions under 1.1 – Invasive predator management – Feral cats and foxes, 1.2 – Myrtle Rust and 1.3 – Invasive grasses.

With regard to 1.1., expenditure on safe havens is minuscule. Greater attention should be paid to protecting natural grasslands fauna species, such as the Grassland Earless Dragon in the ACT-Queanbeyan area which is perilously close to extinction but unlikely to be considered a “priority species”. This may require predator fencing of some grassland reserves.

Another activity we suggest under 1.1 is mandatory cat containment in urban areas near reserves and other high quality areas of native habitat, as is being adopted within the ACT.

Action Area 2 - Conserving, restoring and improving habitat

We strongly agree with the proposed actions under 2.1 – Building habitat connectivity, 2.2 – Protect and improve habitat for priority species and places, and 2.3 – Two-way fire management. However, we consider what is proposed falls far short of a strategy required to achieve the objectives, and stronger strategies need to be put in place. Some suggestions applicable to grassy ecosystems follow, but these principles would apply to other types of threatened species habitat.

First, natural temperate grasslands and grassy woodlands (critically endangered ecological communities) often exist in isolated remnants. There are situations where poorer quality native vegetation (such as native pastures or depauperate woodlands) that still qualifies as part of a threatened ecological community might provide useful connectivity between high quality grassland/grassy woodland areas and thus should be protected.

Second, under Commonwealth Government practice, areas of very high quality natural temperate grasslands are continuing to be “developed” for commercial or urban development. The recent development of Yorke Park (Barton), and the proposed DHA housing estate at Lawson north are examples in the ACT. Until this ceases, we will continue to lose rather than conserve threatened species habitat.

Third, there should be investment in the Paul Gibson-Roy method of restoration of grasslands and use of seed orchards.

Fourth, we are very impressed by what may be accomplished by using traditional first nation land management practices, including the use of fire to both prevent extreme fires and to bring about recovery of biodiversity and ecological function. This needs a large investment to make this a widespread phenomenon - including training of first nation people by knowledge holders and in public awareness programs.

Action Area 3 - Emergency preparedness and response

We support the actions listed under 3. However, this is far too little too late. There has been little funding of insurance populations. More bold thinking is required to build in resilience. For example, if research was done into reptiles, it would most likely be found that just about every species has suffered a serious decline. We should be encouraging the return of native flora and fauna to open areas and home gardens as well as to conservation areas, since this might enhance protection against long-term species loss.

Action Area 4 - Climate change adaptation and resilience

We wonder whether the right questions are being articulated here? In our view all species and ecosystems are being impacted by climate change! Obviously, research into how climate change impacts is very important, e.g. temperature sex-determination in reptiles is offering some important insights into their conservation. While the EPBC Act tends to focus on threatened species and communities, there needs to be more work done on general decline in species and ecological communities and restoring biodiversity resilience. If not, many of the species and ecological communities not considered to be at threat now will become so in the future.

Action Area 5 - Effective planning for conservation

We strongly agree with the proposed actions under 5.1 Conservation planning for priority species and place, and 5.2 Pilot new conservation planning tools. However, these principles have been announced many times before and have failed to be carried through, possibly due to the Department being provided insufficient resources to implement them.

We are concerned that many grassland species and ecological communities will not make it onto the priority species or place lists, since they are generally not as well regarded by the general population as more obvious species, forested ecological communities and so on. By taking a regional and whole of ecosystem approach, it would be possible to cover a number of listed threatened species and ecological communities with the one group of actions. We suggest that the second dot point under section 5.2 be amended along the lines of:

“Support the development of multi-species/ecological community plans for coordinated protection and recovery action for species that share habitats and/or threats and for the endangered ecological communities they occur in.”

We also think that effective conservation planning needs to be done at a landscape level and ignore jurisdictional boundaries, as should targets that measure the effectiveness of action plan implementation.

Action Area 6 – Knowledge and tools

We strongly agree with the proposed actions under 6.1 Monitoring standards, 6.2 Baseline data for priority species and places, 6.3 Mechanisms for improved data sharing, 6.4 Tackling knowledge gaps, and 6.5 Developing and deploying new tools and technology. However, these strategies are broadly stated and it is not clear how they might be implemented. We are also curious about what progress has been made about creating an independent agency to undertake these tasks, as has already been suggested.

With regard to collection of baseline data, as well as new data collections that meet the standards, it would be useful to consider how to include historical data (even if imperfect) into the new data collections, so that true declines in species can be determined.

Action Area 7 - Forging stronger partnerships

We strongly agree with 7.1 Strengthen partnerships with Aboriginal and Torres Strait Islander peoples, although we wonder how the Department plans to achieve this.

In relation to 7.2 Promote, facilitate and support the use of innovative financing and co-funding (market-based solutions), it could be argued that current offset arrangements under the EPBC Act fit this category. In FOG’s view offsets (or purchase of biodiversity credits) are sometimes seen by developers as a way to buy off their obligations – and the long term net effect is a net loss in the relevant endangered species or ecological community. While innovative funding mechanisms need to be considered, it is essential that they do not become a way to continue to impact on our biodiversity by a simple payment. We also remain somewhat skeptical of market-based instruments, not because we oppose them as such, but because they are shrouded by “commercial-in-confidence” and there is no evidence that they provide the measurable outcomes they are meant to.

Action Area 8 - Community leadership and engagement

We strongly agree with the proposed actions under 8.1 Outreach - communications and engagement, and 8.2 Community leadership. This section should also make reference to raising the profile of less eye-catching species and ecological communities, of which grassy ecosystems and species that occur within them are one example.

Questions on selecting priority places

FOG’s view is that a landscape approach to the conservation of grassy ecosystems is essential, so it considers that priority places should be larger scale. However, each of these levels has a place. Biodiversity is a complex network, all of which need attention but some components more so or more urgently that others.

All of the six prioritisation principles are important, but FOG would consider both Risk of extinction (important habitat under imminent threat) and Multiple benefits (important habitat for many threatened species) to be the most significant from a grassland conservation perspective. We are very concerned that a whole ecological community such as Natural Temperate Grasslands could lose functionality and become extinct. As this particular community (and grassy ecosystems more broadly) is important habitat for many species, we are concerned that we will lose a number of species that live in the community – in fact the Grassland Earless Dragon is already on the brink of extinction.

Each of the six priorities should have a place in our consideration. Recovery of many grassy ecosystems is feasible with current investment in terms of resources (government, private, research and volunteer), or with a relatively small increase in investment. These ecosystems are widely valued within our region and by our first Australian communities. They are unique to Australia, and represent a range of places from different environments, tenures and part of Australia. 

Yours sincerely


Naarilla Hirsch
Advocacy coordinator

26 July 2021