Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614

email: advocacy@fog.org.au
web: www.fog.org.au

FOGís submission to the Commonwealth Department of Agriculture, Water and the Environment concerning the Proposed changes to conservation planning decisions under the EPBC Act

Submission put in via online survey form on 26 October 2021

Natural Temperate Grasslands of the South Eastern Highlands

Q2: Do you agree or disagree that the recovery of this species can be effectively guided through a conservation advice and should no longer have a recovery plan under the EPBC Act?

Disagree

Q3: Please provide your reasons for your response

This EC has been upgraded from endangered to critically endangered. Because it occurs on prime urban and agricultural land, it is continually being subject to high development pressure that can be regulated under the EPBC Act. There are also, within the ACT, significant occurrences on Commonwealth land. For these reasons we believe that a recovery plan is still needed.

Q4: Please provide any other comments or concerns in relation to the Ministerís proposed decision not to have a recovery plan for the species

Drawing on the recently developed ACT Native Grassland Conservation Strategy and Action Plans (at https://www.environment.act.gov.au/__data/assets/pdf_file/0010/1156951/Grassland-Strategy-Final-WebAccess.pdf) might be an effective way to update the recovery plan for this ecological community quickly.

Striped legless lizard (Delmar impar)

Q2: Do you agree or disagree that the recovery of this species can be effectively guided through a conservation advice and should no longer have a recovery plan under the EPBC Act?

Disagree

Q3: Please provide your reasons for your response

The Striped Legless Lizard occurs in Natural Temperate Grassland, which we also consider requires a recovery plan. Within the ACT, populations occur on Commonwealth land so a Commonwealth recovery plan seems appropriate under the principles in Ongoing modernisation of conservation planning under the EPBC Act.

Q4: Please provide any other comments or concerns in relation to the Ministerís proposed decision not to have a recovery plan for the species

Drawing on the ACTís recently developed Striped Legless Lizard Delmar impar Action Plan (at https://www.environment.act.gov.au/__data/assets/pdf_file/0019/1136062/Grassland-Strategy-Final-WebAccess-Part-B-8-Striped-Legless-Lizard.pdf) might be an effective way to update the recovery plan for this species quickly.

Golden Sun Moth (Synemon plana)

Q2: Do you agree or disagree that the recovery of this species can be effectively guided through a conservation advice and should no longer have a recovery plan under the EPBC Act?

Disagree

Q3: Please provide your reasons for your response

The Golden Sun Moth occurs in Natural Temperate Grassland, which we also consider requires a recovery plan. Within the ACT, populations occur on Commonwealth land so a Commonwealth recovery plan seems appropriate under the principles in Ongoing modernisation of conservation planning under the EPBC Act.

Q4: Please provide any other comments or concerns in relation to the Ministerís proposed decision not to have a recovery plan for the species

Drawing on the ACTís recently developed Golden Sun Moth Synemon plana Action Plan (at https://www.environment.act.gov.au/__data/assets/pdf_file/0004/1136056/Grassland-Strategy-Final-WebAccess-Part-B-5-Golden-Sun-Moth.pdf) might be an effective way to update the recovery plan for this species quickly.

Tarengo Leek Orchid (Prasophyllum petilum)

Q2: Do you agree or disagree that the recovery of this species can be effectively guided through a conservation advice and should no longer have a recovery plan under the EPBC Act?

Disagree

Q3: Please provide your reasons for your response

Our understanding is that this species is vulnerable to climate change impacts. As well, itís habitat is Yellow Box Blakelyís Red Gum Grassy Woodland and Natural Temperate Grassland (NTG) of the South Eastern Highlands, both of which are critically endangered and the latter is also on the list for this comment process.

Q4: Please provide any other comments or concerns in relation to the Ministerís proposed decision not to have a recovery plan for the species

The ACT has recently updated its action plan for this species (see ACT Native Woodland Conservation Strategy and Action Plans at https://www.environment.act.gov.au/__data/assets/pdf_file/0005/576527/Woodland-Conservation-Strategy-Tarengo-Leek-Orchid.pdf). While this plan is ACT-specific in places, we suggest that information from the ACT action plan could be used to quickly update the national recovery plan for this species without requiring large resourcing.

Kiandra Greenhood (Pterostylis oreophila)

Q2: Do you agree or disagree that the recovery of this species can be effectively guided through a conservation advice and should no longer have a recovery plan under the EPBC Act?

Disagree

Q3: Please provide your reasons for your response

A plan was originally required because of its wide distribution in fragmented subpopulations over three jurisdictions with a high number of stakeholders. The species is critically endangered and will have been impacted significantly by the 2020 bushfires within Kosciuszko National Park and possibly other areas. We understand that there is a 2010 Recovery Plan for this species, and think that this plan should be updated.

All responses

Q6: Your name:

Friends of Grasslands

Q7: Is your response confidential?

No