NSW National Parks and Wildlife Service
nationalparksestablishmentplan@environment.nsw.gov.au

 

Dear National Parks and Wildlife Service (NPWS),

Re. Submission on the draft National Parks Establishment Plan 2026

Friends of Grasslands (FOG) is a community group dedicated to the conservation of grassy ecosystems in south-eastern Australia — natural temperate grasslands and grassy woodlands. FOG advocates, educates and advises on matters relating to the conservation of these ecosystems, and carries out surveys and on‑ground work. FOG members include professional scientists, landholders, land managers and interested members of the public.

We welcome the opportunity to comment on the draft National Parks Establishment Plan 2026 (the Plan). We raise what we consider a significant gap in the protection of natural temperate grassland and grassy woodland ecosystems in the NSW portion of the South Eastern Highlands (SEH) bioregion, within the Tablelands and Western Slopes planning region. As set out below, we submit that grassy ecosystem protection in the SEH bioregion is not representative, comprehensive or adequate.

The gap, and its source

The Plan's bioregion-level statistics (Table 10) show the SEH bioregion as 10–15 per cent protected. At this level, the Plan does not identify this bioregion as a ‘critical gap’, nor even a ‘high priority’, for further reservation. While given the protection levels across the state this is understandable, with local knowledge we submit this aggregate figure conceals a serious problem at the subregion scale, where the SEH bioregion's grassy, largely treeless country is concentrated. The protection of multiple SEH subregions in NSW is well below what is considered representative^[1], e.g., Murrumbateman 1.76 per cent, Orange 2.52 per cent, Bathurst 3.06 per cent, Hill End 5.14 per cent, Crookwell 7.22 per cent, and Monaro 8.01 per cent.

We submit the protection within these subregions is not comprehensive nor, in consequence, adequate. We suspect the treeless and sparsely treed regional ecosystems are grossly under-represented across the NSW protected area system.

Why the gap is invisible to the Plan

Natural Temperate Grassland of the South Eastern Highlands (NTG SEH) is listed as a critically endangered ecological community (CEEC) under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). However, there is no equivalent listing for natural temperate grassland of the NSW South Eastern Highlands under the NSW Biodiversity Conservation Act 2016 (BC Act). FOG nominated the community for listing on 24 July 2024; to date, we have received no response. Natural temperate grassland in the SEH bioregion therefore remains unprotected under NSW law, notwithstanding its Commonwealth listing.

One consequence of this gap is that patches of natural temperate grassland may be assessed as low conservation value under NSW criteria alone, triggering no more than a notification to Local Land Services of intentions to clear or spray patches of grassland, rather than any requirement for approval. This is occurring despite the higher protection threshold afforded to these patches under the EPBC Act.

Being unprotected under the BC Act, natural temperate grassland does not appear in the Plan's inventory of threatened ecological communities for the Tablelands and Western Slopes planning region (Appendix 2); this inventory is compiled from NSW statutory listings. The region's focus criteria for acquisition (Table 2) correspondingly prioritise threatened entities and forested areas. There is no recognition of the lack of comprehensiveness in what is protected.

We doubt the Plan's statewide conservation opportunity model (Figure 8) adequately captures this gap either. Figure 8 is built from spatial layers for environmental value, ecological connectivity and under-representation; however, each of these is more readily detected in forested, structurally complex vegetation than in the treeless or sparsely treed grassland that has characterised parts of the SEH bioregion for millennia.

The Plan itself acknowledges that its bioregion and subregion statistics "do not reflect the availability of suitable remnant native vegetation for conservation across the planning regions." We ask that the final Plan address this gap. We urge you to report reservation statistics for grassy ecosystems specifically in the Plan. This way, the under-representation of grassy regional ecosystems in the SEH bioregion will no longer masked by the better-protection of forested and alpine subregions.

Summary of requests

• Support and if possible expedite a determination on FOG's 24 July 2024 nomination to list Natural Temperate Grassland of the NSW South Eastern Highlands under the BC Act.
• Recognise EPBC-listed ecological communities known to occur in NSW, including NTG SEH, in the Plan's threatened entity inventory (Appendix 2), regardless of NSW statutory listing status.
• Amend the Tablelands and Western Slopes regional focus criteria (Table 2) to name natural temperate grassland and grassy woodland remnants as an explicit acquisition priority, alongside forested habitat.
• Report reservation statistics for grassy ecosystems specifically, in addition to bioregion/subregion aggregates.
• Prioritise acquisition of grassland remnants for new and additional protected areas in the Murrumbateman, Orange, Bathurst, Hill End, Crookwell and Monaro subregions, which together record the SEH bioregion's lowest rates of reservation.

FOG would welcome the opportunity to discuss this submission further and to assist with survey data, mapping or other information relevant to grassy ecosystem protection in the Tablelands and Western Slopes planning region.

Yours sincerely,

SIGNED

Professor Jamie Pittock

President, Friends of Grasslands

6 October 2026

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Reference

[1] Department of Climate Change, Energy, the Environment and Water (Cwlth) (statistics as at 30 June 2024) Collaborative Australian Protected Areas Database 2024, Terrestrial CAPAD 2024 NSW summary, www.dcceew.gov.au/sites/default/files/documents/capad-2024-terrestrial-nsw.xlsx, IBRA Subregions tab.