Key Threatening Process Nomination Form For adding a threatening process under the Environment Protection and Biodiversity Conservation Act 1999 (epbc act)




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8.Ecosystem impacts


By altering interactions among competitive plants, compromising regeneration, affecting community structure, facilitating weed invasion, among other impacts on plants, deer can have cascade effects on biodiversity with research overseas documenting impacts on songbird abundance and species composition, nest predation rates, the abundance and density of invertebrates and the abundance and seed predation activity of small mammals (Dolman and Waber 2008). They are widely regarded as ‘ecosystem engineers’ (Cote et al. 2004). In temperate and boreal forests, large herbivores can act as ‘biological switches’ that move forest communities toward alternative successional pathways and stable states that are not reversible (ibid). The changes observed by Peel et al. (2005) in East Gippsland due to Sambar suggest the potential for this fate: Sambar are capable of ‘significant, severe and possibly lasting alteration to vegetation structure, including negative feedback loops that lead to destruction of particular vegetation types such as rainforest and wetlands’. Sambar alter and deflect rainforest successional dynamics with the plants either being killed or prevented from regenerating. Regeneration failure and gap openings expose soils and lead to disruption of internal rainforest moisture homeostasis through the loss of vine thickets and curtains, canopy tree curtains, destruction and loss of understory shrubs, increasing the risk of fire.

Although deer impacts on some preferred and declining species are reversible if deer densities are controlled, as shown by exclosure studies, others may not be: ‘the drivers of resilience in relation to deer impacts are far more complex than any simple correlation with deer density alone’ (Forsyth et al. 2003). Coomes et al. (2003) gave several examples where deer impacts may not be reversible, where:



  • control reduces the number of deer browsing on some species but the per capita intake of more preferred species increases;

  • the spread of less-browsed species prevents the re-establishment of more preferred species;

  • the course of succession has been altered;

  • there are no longer seed sources of some species;

  • deer have altered ecosystem properties – litter quality, soil microbial properties, microfauna;

  • other feral species benefit from control;

  • other factors such as weeds prevent re-establishment.



9.Threatened species and communities


Feral herbivores together constitute one of the most severe threats to Australian biodiversity. In NSW, they are known to pose a threat to >23% of threatened species and when domesticated herbivores are included, 45% (Coutts-Smith et al. 2007). Deer share many of the attributes of other threatening herbivores and are likely to substantially increase the number of threatened species as they increase and spread. Unfortunately, their range overlaps with that of numerous rare plant species with tiny distributions, and some of the coastal areas they inhabit have a high density of threatened species and are not substantially invaded by other ungulates. Deer have the potential to spread over much larger areas of Australia, increasing their potential to threaten rare plants.
Experts consulted for this nomination said they strongly suspected feral deer were a threatening process for vastly more species than identified to date. In Victoria, where there tends to be more awareness of deer impacts than elsewhere, XXXX XXXX (pers. comm.) said the species identified as threatened by Sambar to date represent the ‘tip of the iceberg’.
There is limited published information about several plant species which have been identified as being at risk from deer (eg. by inclusion in the NSW listing of feral deer as a KTP) so they are not included in the following sections. Several were found in the rumen of Rusa Deer by Moriarty (2004b) – mostly in areas with low deer density rather than high deer density. That they are palatable to deer suggests, as Moriarty says, that ‘their populations are at risk, particularly if poor climatic conditions prevail for any length of time and deer are forced to search for different foods in more marginal areas.’ Table 4 shows a list of species in this category potentially at risk as determined by the NSW Scientific Committee (2004). There are also several plants known to be regionally threatened by deer that are likely to become universally threatened if deer become more widespread. There is a large list of Victorian plant species threatened by Sambar (5 for which Sambar are the principal threat, 17 for which Sambar are a major threat and 27 for which Sambar are a secondary threat)(XXXX XXXX pers. comm.) but which are probably not nationally threatened because their range extends beyond that of Sambar into other states.
Table 4: Species identified by NSW Scientific Committee (2004) at risk from deer (in addition to species listed under Q4, Q8).

Species

EPBC status

Threat

Acacia bynoeana

Endangered

Threatened species eaten by deer

Persoonia hirsuta

Endangered

Ditto

Eucalyptus camfieldii

Vulnerable

Ditto

Leucopogon exolasius

Vulnerable

Ditto

Melaleuca deanei

Vulnerable

Ditto

Pultenaea aristata

Vulnerable

Ditto

Darwinia diminuta

Not listed

Could become threatened by grazing and environmental degradation caused by feral deer

Darwinia grandiflora

Not listed

Ditto

Epacris coriacea

Not listed

Ditto

Eucalyptus luehmanniana

Not listed

Ditto

Genoplesium baueri

Nominated CE

Ditto

Gonocarpus salsoloides

Not listed

Ditto

Grevillea longifolia

Not listed

Ditto

Lomandra fluviatilis

Not listed

Ditto

Monotoca ledifolia

Not listed

Ditto

Platysace stephensonii

Not listed

Ditto

Rulingia hermanniifolia

Not listed

Ditto

Tetratheca neglecta

Not listed

Ditto

Thysanotus virgatus

Not listed

Ditto

Isoodon obesulus

Endangered

Grazing and trampling could alter the composition and structure of their habitats

Potorous longipes

Endangered

Ditto



The case for a collective listing of deer


We propose here that all feral deer established in Australia be included in a KTP listing. The majority of adverse impacts are attributed to Sambar, the largest and most populous species, but the examples in this nomination (see Table 5) show other deer species also have adverse impacts and all have the potential to threaten species and ecological communities if they spread and increase. Most types of adverse impact – browsing/grazing and trampling on rare plants, damaging sensitive vegetation communities, causing erosion, facilitating weed invasion – are potentially caused by any deer species.
Table 5: Species/ecological communities threatened by this KTP and the deer species implicated

Species/EC

EPBC Status

Deer species & behaviours implicated

Gynatrix macrophylla

Not listed

Sambar. Browsing & antler rubbing.

Pultenaea weindorferi

Not listed

Sambar (mainly), Fallow. Browsing.

Pomaderris vacciniifolia

Not listed

Sambar (mainly), Red, Fallow. Browsing.

Tetratheca stenocarpa

Not listed

Sambar (mainly), Fallow. Browsing.

Ozothamnus rogersianus

Not listed

Sambar. Browsing & antler rubbing.

Acacia daviesii

Not listed

Sambar.

Prasophyllum canaliculatum

Not listed

Red, Fallow, Sambar. Grazing & trampling.

Nematolepis wilsonii

Vulnerable

Sambar. Antler rubbing, thrashing, trampling.

Pseudophryne pengilleyi 

Vulnerable

Sambar. Trampling.

Littoral Rainforest and Coastal Vine Thickets of Eastern Australia

Critically Endangered

Sambar (major), Rusa (major), Hog. Browsing, antler rubbing, trampling, wallowing.

Alpine Sphagnum Bogs and Associated Fens ecological community

Endangered

Sambar (mainly), Fallow. Wallowing, trampling, browsing.

White Box – Yellow Box – Blakely’s Red Gum Grassy Woodland and Derived Native Grassland

Critically Endangered

Sambar, Fallow. Browsing, trampling.

Eucalyptus gunnii ssp. Divaricata

Endangered

Fallow. Browsing.

Syzygium paniculatum


Vulnerable

Rusa. Browsing.

Xerochrysum palustre

Vulnerable

Hog, Sambar, Red, Fallow. Grazing, trampling.

Prostanthera densa

Vulnerable

Rusa. Browsing.

Calyptorhynchus lathami halmaturinus

Endangered

Fallow. Browsing.

Leipoa ocellata

Vulnerable

Fallow (mainly), Red, Sambar, Rusa, Chital. Trampling.


A note about the evidence


Information about the environmental impacts of feral deer in Australia is inadequate. The lack of peer-reviewed research is highlighted by Forsyth (2009): Till 1960, there were two papers; and from 1960 until the 2000s there were no papers published in peer-reviewed science journals. There have been articles published in Australian Deer, the magazine of the Australian Deer Association but they are not peer-reviewed and most of the work is conducted by ADA members focused on improving the status of deer as a game animal. Some contend the lack of published information is reason to maintain the status quo for deer: of predominantly hunting-focused management (in three states) with patchy control efforts in some conservation areas and where deer threaten economic assets and safety (they cause vehicle accidents). However, the fact of deer as large exotic ungulates introduced into a country that previously had no ungulates, the weight of evidence from overseas about damaging deer impacts, and the growing accumulation of threats documented by biologists in Australia as deer populations increase lead to the conclusion that to delay more concerted action on feral deer is to guarantee biodiversity losses and environmental degradation.
It is obvious that as deer become more populous in Australia they are going to cause serious damage to the environment – as medium to large animals with hard hoofs that eat a lot of vegetation from diverse sources in diverse habitats and have destructive habits. As with other ungulates, their potential to cause damage will be related to population levels and depend on the sensitivity of the environment they inhabit. Moriarty (2009) rightly says that ‘If deer population trends in Australia continue to increase at their current rate, deer species are likely to rival both feral pigs and feral goats in distribution, abundance and impacts in the near future’. There is evidence from many places that deer populations are increasing and establishing in new areas, due to escapes and releases from farms and releases by hunters. Even a limited application of the precautionary principle warrants taking the deer problem seriously while there is still opportunity to eradicate some of these new populations, limit expansion of others and protect particular high conservation value areas from damage.
Deer are amongst the best-studied species globally and evidence from multiple countries demonstrates the damage they cause as ‘ecosystem engineers’ and ‘keystone herbivores’ (Cote et al. 2004). Evidence comes from regions where deer are indigenous but have increased in numbers (Europe and North America) and from where they have been introduced (New Zealand, in particular). Some of this evidence is applicable to Australia because it is based on deer population dynamics, behaviours and impacts that occur universally. Deer are causing problems in much of their native range because predation rates are inadequate to limit their numbers, which also applies in Australia.
Finally, there is mounting evidence of specific damage in Australian environments caused by deer, some of which is summarised here. Most of it is very recent evidence, observed by field biologists and not yet published in the peer-reviewed literature, due to the lack of research previously and because of the rapid expansion in deer populations within the past decade or two following the rise and fall of the farmed deer industry. As an example of the rapid evolution of the feral deer threat, when Shiny Nematolepis (Nematolepis wilsonii) was listed as Vulnerable under the EPBC Act in 2000 there was no deer damage observed on the one population then known. Sambar numbers then escalated in the Yarra Ranges National Park and within just a few years have rendered this species Critically Endangered (despite discovery of a second population, also affected by Sambar). Sambar were recognised as the principal threat to this species in the 2006 recovery plan (Murphy et al. 2006).




Section 2 - Impacts on Native Species and Ecological Communities

Notes:

  • General information on the mechanism of impact should not be included in this section - this is part of the description.

  • In this section only one pair of questions 4/5, 6/7 or 8/9 need to be answered. However, providing all available evidence against each question will aid in assessment on the nomination.

  • The criteria for listing a species (Part B) or ecological community (Part D) under the EPBC Act are and the Threatened Species Scientific Committee guidelines at the end of this form. It is important to refer to these criteria when answering questions in this section.

  • The EPBC Act lists of threatened species and ecological communities are available on the Department of Sustainability, Environment, Water, Population and Communities website at: www.environment.gov.au/biodiversity/threatened/index.html


Non-EPBC Act Listed Species/Ecological Communities

4. Provide a summary of those species or ecological communities, other than those that are listed under the EPBC Act, that could become eligible for listing in any category, other than conservation dependent. Please include:

  1. For each species: the scientific name, common name (if appropriate), category it could become eligible for listing in;

  2. For each ecological community: the complete title (published or otherwise generally accepted), category it could become eligible for listing in.

Species/Ecological Community


Category

Gynatrix macrophylla (Gippsland Hemp Bush)

Pultenaea weindorferi (Swamp Bush-pea)

Pomaderris vacciniifolia (Round-leaf Pomaderris) Tetratheca stenocarpa (Long Pink-bells)

Ozothamnus rogersianus (Nunniong Everlasting)

Acacia daviesii (Timbertop Wattle)

Prasophyllum canaliculatum (Summer Leek-orchid)


Endangered

Critically Endangered

Endangered

Critically Endangered

Endangered

Critically Endangered



Critically Endangered



5. Provide justification that the species or ecological communities detailed at question 3 could become eligible for listing in any category, other than conservation dependent. For each species/ecological community please include:

  1. data on the current status in relation to the criteria for listing;

  2. specific information on how the threatening process threatens this species/community;

  3. information on the extent to which the threat could change the status of the species/community in relation to the criteria for listing.



Note: The six Victorian endemic species described here have all been assessed against IUCN criteria by the Victorian Government, so further information about how they meet EPBC criteria is available. Because there is only need to meet one criterion, I have not provided information to inform a thorough assessment against all listing criteria.




Gynatrix macrophylla (Gippsland Hemp Bush)


A shrub from eastern Victoria (Gippsland). Described only recently (Walsh 1996). Very rare. Highly fragmented and with only localised dispersal.
Status: Not listed under any legislation. Endemic to Victoria.
Threats: Sambar are rated the ‘principal’ threat to this species (XXXX XXXX pers. comm.). Blackberry invasion is also a threat. SAC (2007) found that Sambar are or potentially are ‘a significant threat’ to the species. Their ranges substantially overlap, and observations of Sambar damage at Licola and Mitchell River locations suggest the species is likely to be in ‘deep trouble’ across its range (XXXX XXXX pers. comm.). Observations at Mitchell River NP found that saplings were browsed to death by Sambar with consequent lack of regeneration and plants were also damaged by antler rubbing (Peel et al. 2005). Observations at Licola, where Sambar are in very high numbers, showed the species as highly palatable to Sambar (preferentially browsed), as indicated by the height of the browse line observed, and it now survives mainly in places inaccessible to Sambar (XXXX XXXX pers. comm.). It is likely to be most vulnerable after fire because it recruits from seed and seedlings are likely to be targeted by deer. A recent re-survey at a site at Licola after a fire found only one plant where previously there had been a few (which is typical for this species), and deer browsing was suspected as the major contributing factor (XXXX XXXX pers. comm.). Goats are also a problem for this species in some locations but Sambar numbers are much higher and they are also much larger than goats.
EPBC Listing Criteria: Assessed as Endangered against IUCN criteria A3ce; B2ab(ii,iii,iv,v) in the DSE review of the conservation status of all Victorian plant taxa (XXXX XXXX pers. comm.). It meets criterion 2 for Endangered: severely fragmented, continuing decline, and area of occupancy <500km2.
Pultenaea weindorferi (Swamp Bush-pea)

Erect shrub 1–2 m high. Occurs in four populations in Victoria’s Dandenong Range: Mt Evelyn/Wandinn area, Wombat Ranges, Kinglake and Gembrook/Bunyip State Parks (SAC 1997), over 10-20 ha across 2700km2.


Status: Not listed under any legislation. Note that P. glabra (into which de Kok and West 2002 place P. weindorferi) is listed as vulnerable under the EPBC Act but see taxonomic note below.
Taxonomic note: There has been debate about whether the Pultenaea glabra species complex is one widespread species with geographic variants (de Kok and West 2002) or whether some variants warrant recognition as separate species. Victorian botanists dispute the revision by de Kok and West (2002), which placed P. weindorferi in P. glabra, and the Census of Victorian Plants (Walsh and Stasjic 2007) lists P. weindorferi as a species endemic to Victoria. The EPBC listing advice for P. glabra says it is located in NSW Central and Northern Tablelands and in central-eastern Queensland (but it is not listed by the Queensland Herbarium as a Queensland species). P. glabra is listed as vulnerable under the EPBC Act. If the TSSC does not recognise P. weindorferi as a separate species, it would still be part of this nomination as an existing threatened species threatened by feral deer.
Threats: Sambar are the principal threat to this species due to heavy browsing (XXXX XXXX pers. comm.). Other threats are thought to be inappropriate fire regimes and other herbivores (such as goats, which are in much lower densities). There has been a recent increase in Sambar density in 3 of the 4 locations of this species, rendering more likely the prospect of local extinction at any one of the locations (ibid.). The core population is in Kinglake NP. An environmental burn in 1990 was successful in increasing the population to about 1000 plants, which was maintained for 5-10 years (XXXX XXXX pers. comm.). However, from 2000-05 as Sambar densities greatly increased in the NP (goat populations had been controlled and remained stable), numbers declined to a ‘few dozen’ due to browsing and senescence. There was complete recruitment failure as all mature plants were being browsed and the flowers consumed, and seedlings were eaten to ground level. The browsing impacts were magnified by drought allowing deer to move further into the forest interior. Since the 2009 fires, there has been ‘reasonable’ germination in Kinglake NP (because their seeds are long-lived there were seeds in the soil from prior to deer preventing seed production), and the population currently numbers about 500 (Ibid.). Fences have been erected around the main population to protect them from deer, which have dispersed since the fire to the perimeters of the NP. Deer control is also conducted in the NP but re-invasion from surrounding areas where deer are not controlled is a major challenge. The population in Bunyip State Park is also substantially affected by deer (ibid.), which includes both Sambar and Fallow Deer.
EPBC listing criterion: Assessed as Critically Endangered against IUCN criteria B2ab(i,ii,iii,iv,v) in the DSE review of the conservation status of all Victorian plant taxa (XXXX XXXX pers. comm.). Meets criterion 2 for Critically Endangered: severely fragmented, continuing decline, and area of occupancy <10km2 (10-20 ha).
Pomaderris vacciniifolia (Round-leaf Pomaderris)

A slender shrub 1-8 m high. Found in the middle and upper catchments of the Yarra River in central Victoria. The current area of occupancy is estimated at 2-5 ha and extent 4300 km2 (Steve Meacher, Healesville Environment Watch pers. comm.). In 2006 no more than 140 mature plants could be found. Current estimates are 100-300 (prob. ~200) in 30 populations/subpopulations (XXXX XXXX pers. comm.). The February 2009 fires destroyed all known specimens at one site and most at another. It has a severely fragmented distribution, with 100 km separating populations around Melbourne with those in the La Trobe Valley and subpopulations within the core area separated by many kilometers (XXXX XXXX pers. comm.).


Status: Not listed under EPBC Act (nominated as Critically Endangered in May 2009). Listed under the FFG Act (in 2009). Endemic to Victoria.
Threats: Sambar are a ‘major’ threat to the species (XXXX XXXX pers. comm.). Major causes of mortality are thought to be browsing by herbivores (including deer, rabbits and wallabies), insect predation and senescence in the absence of fire. Browsing by deer (mostly Sambar but also Red and Fallow Deer) and rabbits are the major factors limiting survival of juvenile plants (XXXX XXXX pers. comm.). The species has poor ability to recover from browsing at all ages. Deer are a particular problem in the Kinglake area, where significant remnant populations exist, as well as in 3 other locations. Damage caused by antler rubbing was observed in one population (XXXX XXXX pers. comm.).
EPBC Listing Criteria: Assessed as Critically Endangered, against IUCN criteria B2ab(ii-v) in the DSE review of the conservation status of all Victorian plant taxa (David Cameron DSE pers. comm.). Also nominated as Critically Endangered. Meets Criterion 2: severely fragmented, with continuing declines eg. in individuals, and an area of occupancy 2-5 ha (+ extent 4300km2). (For more detail please refer to the 2009 nomination of this species.)
Tetratheca stenocarpa (Long Pink-bells)

A slender almost leafless shrub 1-1.5 m high. Grows in damp forests with tall trees and a dense and species-rich understorey of small-leafed shrubs, herbs, grasses and sedges. Severely fragmented and diffuse populations in restricted distribution, in damp forests in hilly country east of Melbourne, on French Island and in Gisborne.


Status: Not listed under any legislation. Endemic to Victoria.
Threats: Sambar are the principal threat to this species (XXXX XXXX pers. comm.). Populations coincide with high and increasing Sambar density. Observations of heavy browsing of this species in Bunyip State Park (XXXX XXXX pers. comm.), where the majority of site records occur and where there are 20-30 plants in each of about 6 sites, occupying ~1 ha. Deer impacts observed here likely to be general across range (XXXX XXXX pers. comm.). Also likely to be threatened by other herbivores (Fallow Deer and wallabies) and fire (XXXX XXXX pers. comm.). Because plants are scattered and uncommon it is difficult to quantify impacts. It is also impossible to fence off populations to protect them from deer.
EPBC Listing Criteria: Assessed as Critically Endangered against IUCN criteria B2ab(v) in the DSE review of the conservation status of all Victorian plant taxa (XXXX XXXX pers. comm). Meets criterion 2 for Critically Endangered: severely fragmented, continuing decline in number of individuals, and area of occupancy <10km2 (10-20 ha).
Ozothamnus rogersianus (Nunniong Everlasting)

An erect shrub to 2.5 m tall. Known from 4 disjunct populations on the Nunniong Platau, Western Otways (Great Otway NP) and Central Highlands. Very rare.


Status: Not listed under any legislation. Endemic to Victoria.
Threats: Sambar browsing and antler rubbing are the principal threat to this species (XXXX XXXX pers. comm.) Its brittle stems are easily damaged. It recruits after fire and is susceptible to loss of seedlings. There is substantial geographic overlap with Sambar and increasing Samber density in its range.
EPBC Listing Criteria: Assessed as Endangered against IUCN criteria A3ce; B2ab(v) in the DSE review of the conservation status of all Victorian plant taxa (XXXX XXXX pers. comm.). Meets Criterion 2 for Endangered: severely fragmented, continuing decline in number of mature individuals, and area of occupancy <500km2.
Acacia daviesii (Timbertop Wattle)

Discovered in 1998 near Mt Timbertop in northeast Victoria. Occupies <1.5 ha over an area <5km2 in 10 clonal populations – each population is a root-suckering clone with 9 to >1000 rametes (SAC 2004). Each population is important as there are just 9 distinct genotypes and the loss of any one could seriously deplete the gene pool (Bartolome 2002).


Status: Not listed under EPBC Act. Listed under FFG Act. Endemic to Victoria.
Threats: Recognised by SAC (2007) that Sambar are, or potentially are, ‘a significant threat’ to this species. Sambar are a secondary threat to probably fire and climate change. (XXXX XXXX pers. comm.).
EPBC Listing Criteria: Assessed as Critically Endangered against IUCN criteria 1ab(i-v)+2ab(i-v);D in the DSE review of the conservation status of all Victorian plant taxa (XXXX XXXX pers. comm). Meets Criterion 4: number of mature individuals <50 (n=10).
Prasophyllum canaliculatum (Summer Leek-orchid)

Orchid 30-50 cm high. Grows singly or in groups of 2-4 plants in dense low grass tussocks in Eucalyptus pauciflora open woodland. 2 known surviving populations: 1 in NSW and 1 in ACT. The NSW population in South East Forests NP (Nimmitabel site) was reported to number about 190 plants in January 2004 (NSW Scientific Committee 2007, citing McPherson 2004) but now numbers about 40 (XXXX XXXX pers. comm.). A previous population at Kybeyan, NSW, containing about 30 plants in 1996 (NSW Scientific Committee 2007, citing Jones 1997), no longer exists (XXXX XXXX pers. comm.). There is an ACT population in one site that recently numbered about 200 individuals (NSW Scientific Committee 2007; XXXX XXXX pers. comm.). This year, there were 20-30 flowering (Ibid.)


Status: Not listed under EPBC Act. Listed as Critically Endangered under TSC Act. Endemic to NSW (Southern Tablelands) and ACT.
Threats: Threats reported by the NSW Scientific Committee (2007) for the remaining NSW site are grazing by feral deer, rooting by feral pigs, weed invasion and illegal off-road vehicle traffic (the latter now prevented by a gate, XXXX XXXX pers. comm.). Due to small area and population size, it is also threatened by environmental and demographic stochasticity. Trampling by feral deer is an additional threat because the species occupies such a small area (<0.5 ha) frequented by deer (XXXX XXXX pers. comm.) Deer in the area include Red Deer, Fallow Deer and Sambar. The ACT population is threatened by feral pig rooting (XXXX XXXX pers. comm.).
EPBC Listing Criteria: Meets Criterion 2 for Critically Endangered: severely fragmented, continuing decline in number of mature individuals, and area of occupancy <10 km2 (a few hectares). Meets Criterion 4 for Endangered: Estimated population as low as 70 and likely no more than ~250.



EPBC Act Listed Species/Ecological Communities

6. Provide a summary of those listed threatened species or ecological communities that, due to the impacts of the threatening process, could become eligible for listing in another category representing a higher degree of endangerment. Please include:

a. For each species: the scientific name, common name (if appropriate), category it could become eligible for listing in;



  1. For each ecological community: the complete title (published or otherwise generally accepted), category it could become eligible for listing in.

Species/Ecological Community

Category

Nematolepis wilsonii (Shiny Nematolepis)

Pseudophryne pengilleyi (Northern Corroboree Frog)





Critically Endangered

Critically Endangered

7. Provide justification that the species or ecological communities detailed at question 6 could become eligible for listing in another category representing a higher degree of endangerment due to the impacts of the threatening process. Please include:

    1. data on the current status in relation to the criteria for listing (at least one criterion for the current listed category has been previously met);

    2. specific information on how the threatening process significantly threatens this species/community;

  1. information on the extent to which the threat could change the status of the species/community in relation to the criteria for listing. This does not have to be the same criterion under which the species/community was previously listed.



Nematolepis wilsonii (Shiny Nematolepis)


A shrub or small tree to 10 m high growing in the understorey of Cool Temperate Mixed Forest between old-growth wet forest, dominated by Mountain Ash, and Cool Temperate Rainforest dominated by Myrtle Beech (Murphy et al. 2006). Known from two populations in the Yarra Ranges National Park, with only 12 mature individuals remaining. >400 mature trees were destroyed in the February 2009 fires in one site and an unknown number in the other site (only discovered in 2010). Seedlings have emerged since the fires (Bennett and Coulson 2011) numbering in the tens of thousands.
Status: Vulnerable under EPBC Act (based on a 2000 assessment). Listed under the FFG Act. Endemic to Victoria.
Threats: Damage caused by Sambar is identified in the recovery plan as the greatest threat (Murphy et al. 2006) and this remains the case. Other lesser threats are weed invasion and road maintenance. Deer rub their antlers on this species to remove velvet, thrash saplings as part of rutting and trample seedlings. Antler rubbing can result in ringbarking and death. Otherwise, stem wounding creates access for wood boring insects or fungal infections (Bennett and Coulson 2011). Antler rubbing damage was recorded on 27% of individuals in May 2005, with the population then consisting of an estimated 400 mature trees and 1000 saplings (Bennett and Coulson 2011, citing Lorimer and Lorimer 2005). Rubbed trees that don’t die from ringbarking have significantly poorer health and less foliage (on average 19% less) than non-rubbed trees (Bennett & Coulson 2011). Deer are known to favour particular species for antler rubbing. The threat has emerged only in the past few years as Sambar numbers have increased in the Central Highlands. There was no evidence of damage to the one known stand in 1995 (XXXX XXXX pers. comm.) and deer damage was first identified as a threat in 2003 (after it was listed as Vulnerable under the EPBC Act).
EPBC Listing Criteria: DSE’s review of the conservation status of Victorian plants has assessed it as Critically Endangered against IUCN criteria A3ce; B1ab(i,ii,iii,iv,v)+2ab(i,ii,iii,iv,v) (XXXX XXXX pers. comm.). Consisting only of 2 populations in a limited location, with recent severe reduction in number of mature individuals (from >400 to 12), and occurrence and occupancy (just over 5 ha) both very restricted, it meets criterion 2 for Critically Endangered. With only 12 mature individuals known to exist in the wild it meets criterion 4 for Critically Endangered.

Pseudophryne pengilleyi (Northern Corroboree Frog)


A small, colourful frog growing to 2.5–3 cm. Restricted to montane and sub-alpine woodlands, heathland and grassland above ~1000 m. Known from 3 disjunct regions: the Fiery Ranges, the Northern Brindabella Ranges and the Southern Brindabella Ranges. Each region contains a genetically distinct subpopulation (Morgan et al. 2008). During the summer breeding season the frog inhabits sphagnum bogs, wet tussock grasslands, and wet heath. In other seasons it inhabits the litter, logs and dense ground cover in the understorey of snow gum woodland and heath forest usually about 10-30 m away from the breeding area (NSW Scientific Committee 2010). Surveys of calling males and egg counts suggested a 2008 population of 2000-3000 (Ibid.). Since 1988 (about 3 generations) there has been an estimated >95% decline in the population occupying the Bridabella Ranges (2 subpopulations) and an estimated 86% decline in the Fiery Ranges population (Ibid.).
Status: Vulnerable under EPBC Act. Critically Endangered under TSC Act. Endangered under the ACT Nature Conservation Act 1980. Endemic to NSW and ACT.
Threats: Population decline has been rapid and precipitous since the early 1990s due primarily to disease caused by Amphibian Chytrid Fungus (Batrachochytrium dendrobatidis). Climate change is considered a serious threat (NSW Scientific Committee 2010). Fire – by causing direct mortality and altering habitat - and weed invasion of breeding sites are also threats (Ibid). A further threat is damage by pigs and horses to breeding and overwintering habitats. Horse trampling has caused considerable disturbance to breeding sites in the Fiery Range (Ibid.)
Sambar have recently increased in distribution and abundance in southern NSW particularly since the 2002-03 fires, are now ‘omnipresent’ throughout the species’ range, and are most prolific in the last known stronghold of the frog in the Fiery Ranges (XXXX XXXX pers. comm.). Sambar presence has recently been documented in the frog’s breeding habitat, in 17 of 23 breeding sites in the north of Kosciuszko NP (Ibid.) Sambar damage observed includes trampling of vegetation at the bogs and in the habitat linking bogs and the formation of trails. They have the potential to cause serious damage to breeding sites, and are cause for ‘great concern’ (ibid.)
EPBC Listing Criteria: In 2010 the NSW Scientific Committee reassessed the species’ status as Critically Endangered (see http://environmentaltrust.nsw.gov.au/determinations/northerncorroboreefrogPD.htm and also NSW Scientific Committee 2010). The species meets Criterion 1 (A1) and (A2) for Critically Endangered: a reduction of >90% in population size over 3 generations (A1) as well as a reduction of >80% in population size with the causes of decline ongoing (A2), as assessed by the NSW Scientific Committee:
‘Populations of the Northern Corroboree Frog in NSW have experienced significant decline in recent years. For example, in 1988 the number of adult males in the Brindabella Ranges (northern and southern subpopulations combined) was estimated to be 2 000-3 000 (Osborne 1988), yet in 2009 just 25-75 adult males were thought to be present (XXXX XXXX pers. comm. 2009). This represents a decline of between 96 and 99% over 21 years (or three generations). Similarly, tens of thousands of adult males were believed to be in the Fiery Range subpopulation in 1988 (Osborne 1988), and although this estimate is very broad, assuming a minimum historic population of 10 000 males and based on the 2009 estimate of between 1 000 – 1 400 males (XXXX XXXX pers. comm. 2009), this subpopulation has experienced a decline of between 86 and 90%. In addition, many of the previously known breeding sites in the Brindabella Ranges no longer contain the species, or contain extremely low numbers of individuals (Hunter et al. 2006).’
The species meets Criterion 2 for Endangered: there is severe population fragmentation; ongoing decline in populations; and the area of occupancy is <500 km2 (estimated to be no more than 340 km2) and extent of occurrence is <5000 km2 (estimated to be <2000 km2).



8. Provide a summary of those species or ecological communities, listed as threatened under the EPBC Act, that are considered to be adversely affected by the threatening process. Please include:

  1. For species: the scientific name, common name (if appropriate) and category of listing under the EPBC Act;

  2. For ecological communities: the complete title (exactly as listed) and category of listing under the EPBC Act.

Littoral Rainforest and Coastal Vine Thickets of Eastern Australia. Critically Endangered.

Alpine Sphagnum Bogs and Associated Fens ecological community. Endangered.

White Box – Yellow Box – Blakely’s Red Gum Grassy Woodland and Derived Native Grassland. Critically Endangered.



Eucalyptus gunnii ssp. divaricata (Miena Cider Gum). Endangered.

Syzygium paniculatum (Magenta lilly pilly). Vulnerable.

Xerochrysum palustre (Swamp Everlasting). Vulnerable.

Prostanthera densa (Villous Mintbush). Vulnerable.

Calyptorhynchus lathami halmaturinus (Glossy Black-Cockatoo). Endangered.

Leipoa ocellata (Malleefowl). Vulnerable.


9. Provide justification that the species or ecological communities detailed at question 8 are affected adversely by the threatening process.



Littoral Rainforest and Coastal Vine Thickets of Eastern Australia


Represents a complex of rainforest and coastal vine thickets on the east coast of Australia, typically within 2 km of the coast or adjacent to a large salt water body, such as an estuary.
Status: Critically endangered under EPBC Act. Includes ‘Littoral Rainforest in NSW North Coast, Sydney Basin and South East Corner Bioregions’ which is endangered under the NSW TSC Act. Many of the Regional Ecosystems included within the EC in Queensland are ‘of concern’.
Threats: Deer species damaging this ecological community include Sambar, Rusa and Hog Deer.

The Threatened Species Scientific Committee has already recognised feral deer as a significant threat to this EC, with the 2008 EPBC listing advice stating:


‘Grazing and browsing by feral deer {Sambar deer (Cervus unicolor) and Hog deer (C. porcinus)} has been shown to detrimentally impact the ecological community on both a local and landscape level. Browsing prevents regeneration of littoral rainforest canopy and understorey species and creates gaps in the vegetation which allows colonisation by weeds. This has occurred in the area near Genoa River, in Victoria, where the vegetation gaps have been colonised by Cape Ivy (Delairea odorata) and dense thickets of Madeira Winter-cherry (Solanum pseudocapsicum). These weeds are seriously contributing to the collapse of the existing littoral rainforest patches through the smothering of shrubs and young trees. Severe damage to littoral rainforest has also been observed from Twofold Bay in NSW to the Gippsland Lakes in Victoria. Persistent infestations are documented as causing the local loss of rainforest species and whole sections of mature rainforest in Victoria (Peel et al. 2005). The coastal expansion of feral deer has reached at least as far north as Bermagui (XXXX XXXX in prep.). Where the ranges of the two deer overlap, patches of littoral rainforest (e.g. Marl Island) have been destroyed (XXXX XXXX in prep.).’
The NSW Scientific Committee (2004) found that grazing and trampling by feral deer could alter the composition and structure of this ecological community. Moriarty (2004b) found that where Rusa Deer exist in high densities they substantially reduced diversity in littoral rainforest in Royal NP (see section 5 under Q3). In plots subject to high deer density the mean number of plant species was 17 compared to 37 in plots subject to low deer density. Sapling diversity was reduced by 58% understorey species diversity by 28%, groundcover diversity by 65%, and the total plant diversity by 54%.
Peel et al. (2005) documented severe damage to littoral rainforest communities in East Gippsland. Sambar damage was observed in 74 sites surveyed during 2002-2005. Several species were suffering high rates of morality from Sambar browsing. Those species subject to heavy browsing during drought have reduced capacity to recover. Destruction of regeneration refuges is of particular concern (see section 5 under Q3) as it exposes palatable seedlings to browsing by native and exotic herbivores and undermines species’ capacity for regeneration. Peel et al. (2005) rated this impact of browsing as perhaps causing the most severe damage. Wallowing, antler rubbing and rutting behaviours also cause considerable damage. Damage to rainforest can facilitate weed invasion and increase the risk of fire. Sambar trails into thick forest provides pathways for exotic predators and carcasses left by deer hunters provide feral dogs with a reliable food source during breeding.

Alpine Sphagnum Bogs and Associated Fens ecological community


Alpine vegetation community occurring in fragmented remnants in Tasmania, Victoria, NSW, ACT.
Status: Alpine Sphagnum Bogs and Associated Fens ecological community listed as endangered under the EPBC Act. Alpine Bog and Fen (Bog Pool) communities listed under the FFG Act. Montane Peatlands and Swamps of the New England Tableland, NSW North Coast, Sydney Basin, South East Corner, South Eastern Highlands and Australian Alps bioregions listed as endangered under the TSC Act.
Threats: Grazing and trampling by exotic ungulates is well recognised as a threat, particularly by cattle and horses, and also by deer, goats and pigs (EPBC Listing Advice 2008):
‘Even though alpine cattle grazing has ceased in the national parks, its impact remains, and is now perpetuated by the habits of other (largely feral) non-native animals, primarily horses, deer, goats and pigs. These animals also trample delicate vegetation and wallow in pools and waterways, making them an ongoing threat to the structural integrity of the Alpine Sphagnum Bogs and Associated Fens ecological community. The threat of damage is substantially increased following a fire, due to improved access into bogs for animals, and the presence of burnt, highly-erodible peat.’
In Victoria, both Fallow Deer and Sambar inhabit alpine country. Sambar are of greatest concern (Tolsma 2009). They create tracks from the treeline into mossbeds and scrape out wallows. Tolsma (2009) assessed the condition of 424 individual mossbeds (or sub-sections of larger mossbed systems) across alpine Victoria between 2004 and 2009. Signs of deer activity (scats, tracks or prints) were found at 17% (n=72) and wallows were found at 7% (n=28) of the mossbeds assessed. Lake Mountain and the Wonnangatta-Moroka Unit of the Alpine National Park were assessed to have the highest rates of deer activity overall (58% and 47% respectively of mossbeds assessed), and the latter contained most of the wallows observed (n=20). Deer damage tends to be localised (in contrast to extensive pugging by horses and cattle). Deer activity is likely to increase as the vegetation recovers from fires, as Sambar are drawn to regenerating areas, and the extent of damage will depend on deer numbers.
In NSW, deer have increased in distribution and abundance in southern NSW since the 2002-03 fires, and Sambar are now ‘omnipresent’ (XXXX XXXX pers. comm.). Some damage has been observed, including at one bog site ‘severely trampled and wallowed’ along the Burrungubugee River in Kosciuszko NP (XXXX XXXX pers. comm.) Of ~33 sites examined recently (for feral horse damage), there was deer sign at 3, with impacts including grazing and trampling (XXXX XXXX pers. comm.). Sambar presence recently documented in the breeding habitat of the critically endangered Northern Corroboree Frog (Pseudophryne pengilleyi) is of great concern; they have been recorded in 17 of 23 breeding sites in the north of Kosciuszko NP (XXXX XXXX pers. comm.) (see under Q5, Q6). Feral deer have been noted as a likely threat also to alpine wetland habitats of the Alpine Tree Frog (Litoria verreauxii alpina) (vulnerable under the EPBC Act) (Clemann and Gillespie 2010).

White Box – Yellow Box – Blakely’s Red Gum Grassy Woodland and Derived Native Grassland


Characterised by ‘a species-rich understorey of native tussock grasses, herbs and scattered shrubs, and the dominance, or prior dominance, of White Box, Yellow Box or Blakely’s Red Gum trees’ (EPBC Listing Advice 2006). Occurs along the western slopes and tablelands of the Great Dividing Range in highly fragmented patches, with >95% having been cleared or degraded (ibid.).
Status: Critically endangered under EPBC Act. White Box Yellow Box Blakely’s Red Gum Woodland endangered under TSC Act. Yellow Box – Red Gum Grassy Woodland endangered under ACT NC Act. Some component regional ecosystems are of concern or endangered in Queensland. Some component Ecological Vegetation Classes are threatened in Victoria. Only portions of the state-listed areas with a predominantly native understorey are part of the EPBC listing.
Threats: Much of this ecological community has been cleared for agriculture (EPBC Listing Advice). In uncleared areas, most of the characteristic understorey has been removed due to grazing and pasture improvement, and grazing also prevents the regeneration of overstorey species (ibid.). Weed invasion and inappropriate fire regimes are also major threats.
Increasing deer populations are an additional threat to this EC. For example, observations in the Byadbo Wilderness component of this EC are that Sambar and Fallow Deer are ‘causing severe disruption to the understorey shrub layer, browsing and trampling and causing soil erosion’ (XXXX XXXX pers. comm.) In addition, deer inhabit creeklines once dominated by evidence of nationally threatened species such as the Spotted-tailed Quoll (Dasyurus maculatus), where they are likely to be damaging latrine sites vital for quoll breeding and communication (ibid.).

Eucalyptus gunnii ssp. divaricata (Miena Cider Gum)


Small-medium woodland tree to 12-15 high. Part of a continuum between Eucalyptus gunnii and Eucalyptus archeri. Restricted to frost hollows in open woodland around the Great Lake region on Tasmania’s Central Plateau in an area 40 x 40 km.
Status: Endangered under the EPBC Act. Endangered under the Tasmanian Threatened Species Protection Act 1995. Endemic to the Tasmanian Central Plateau.
Threats: Threats identified in the EPBC listing advice (2003) are ‘frequent burning; grazing sheep, rabbits and native marsupials (e.g. brushtail possums); clearing for roadwork; flooding; seed collection; and drought’. Brushtail Possums, which have increased in the area, intensively browse new growth and may hasten the death of mature trees and prevent establishment (Potts et al. 2001). They are regarded as a major threat. Browsing of saplings by Fallow Deer is a more recently recognised threat (Tasmanian Threatened Species Listing Statement), which may be just as severe as that due to possum browsing (XXXX XXXX pers. comm.). E. gunni ssp. divaricata is probably the most palatable eucalypt in Tasmania, and landholders with it on their land have observed that deer are browsing the plant and having a major impact. This is consistent with recent observations of damage to E. gunni ssp. divaricata saplings within an exclosure that excludes herbivores other than deer (XXXX XXXX pers. comm.).

Syzygium paniculatum (Magenta Lilly Pilly)


A rainforest tree 3-8m high. Grows in subtropical and littoral rainforest on sandy soils or stabilized dunes near the sea; widely separated localities between Bulahdelah and Jervis Bay.
Status: Vulnerable under EPBC Act. Vulnerable under TSC Act. Endemic to NSW: South Coast, Central Coast & North Coast.
Threats: Highly palatable to Rusa Deer (Keith & Pellow 2005). The NSW Scientific Committee (2004) identified it as a threatened species known to be eaten by deer. Keith and Pellow (2005) assessed the impacts of Rusa Deer on this species in Royal NP. They planted 93 individual S. paniculatum and protected them behind fencing until they were 1-1.4 m tall. Rusa were given access to the plants for 3 months then excluded. 5 plants in an adjacent fenced area were used as a qualitative control with deer excluded. The only other herbivore, brush-tailed possums, had access to both areas. All 93 plants exposed to deer suffered loss of foliage and 84% had <25% of foliage remaining. About 15% had their bark stripped or their main stem broken near the ground. About 90% started to recover when deer were again excluded. None of the 5 control plants suffered damage. The experiment showed that deer ‘may have very substantial impacts on at least some plant species over a relatively short time frame’.

Xerochrysum palustre (Swamp everlasting)


Perennial erect herb to 30–100 cm high. Distributed from central eastern New South Wales through Victoria to north-eastern Tasmania. ~ 35 populations known, with total abundance estimated at >10,000 plants (rhizomatous habit and dense clumps with large numbers of stems within clumps makes counting difficult) (Carter and Walsh 2010). Grows in wetlands including sedge-swamps and shallow freshwater marshes, often on heavy black clay soils. In Victoria estimated 5,000–10,000 plants; incomplete information from NSW; distribution & abundance in Tasmania poorly known.
Status: Vulnerable under EPBC Act. Listed under FFG Act. Not listed in NSW (rare in scattered locations in Central & Southern Tablelands). Not listed in Tasmania. Endemic to south-eastern Australia.
Threats: Recognised threats in the draft recovery plan (Carter & Walsh 2010) include grazing and damage by deer particularly in dry seasons. Trampling by deer is of concern, for example in South East Forests NP where it is in a small area (<0.5 ha) potentially frequented by Sambar, Red Deer and Fallow Deer (XXXX XXXX pers. comm.). Other threats identified in the recovery plan are wetland drainage/modification (major threat), weed invasion, maintenance, ploughing, mining, climate change and grazing by kangaroos, rabbits, cattle, feral horses, pigs.
Deer are recorded as a threat to the species in the following locations (Carter & Walsh 2010):

  • NSW South East Forests National Park: Packers Swamp, Nunnock Swamp, NSW: Damage by deer (Sambar, Red Deer & Fallow Deer); deer (& pig) presence attracts shooters, who drive their vehicles across the drier parts of the swamps [this is now prevented by a gate].

  • NSW Wadbilliga National Park: Damage and grazing by feral animals including deer

  • NSW Tantawangalo State Forest: Deer grazing.

  • Victoria Blond Bay Wildlife Reserve: Grazing by Hog Deer. This population has been ‘severely damaged’ by Hog Deer (XXXX XXXX pers. comm.).

The NSW Scientific Committee (2004) identified it as an unlisted species (for NSW) that could become threatened due to deer.



Prostanthera densa (Villous Mintbush)


Erect shrub to 2 m high. Grows in sclerophyll forest and shrubland, on coastal headlands and near-coastal ranges, on sandstone; from Nelson Bay to Beecroft Peninsula.
Status: Listed as vulnerable under EPBC Act. Listed as vulnerable under TSC Act. Endemic to NSW.
Threats: Fairley (2004) lists development, fire and deer grazing as the main threats. The EPBC Act Conservation Advice (2008) identifies clearing as the main threat. Deer grazing, inappropriate fire and phytophthora dieback are identified as potential threats. The NSW Scientific Committee (2004) listed in the feral deer KTP advice as a threatened species known to be eaten by deer. The population at Royal NP had been thought for many years to be extinct due to deer, as the species was reportedly ‘quite common’ on Marley Beach prior to deer (XXXX XXXX pers. comm.). A remnant of this population was recently discovered in scree on a cliff face inaccessible to deer (ibid.).

Calyptorhynchus lathami halmaturinus (Glossy Black-Cockatoo)


A South Australian subspecies that has disappeared from the SA mainland and is currently restricted to Kangaroo Island.
Status: Endangered under EPBC Act. Endangered under SA National Parks and Wildlife Act. Endemic to South Australia.
Threats: The cockatoo feeds almost exclusively on the seeds of Drooping Sheoak (Allocasuarina verticillata) (Garnett and Crowley 2000) and requires highly quality sheoak woodland for foraging. The recovery plan (Mooney & Pedler 2005) identifies habitat destruction as the primary cause of decline and grazing – including by deer – as a threat to regenerating habitat on Kangaroo Island. Fallow Deer are also present on the Fleurieu Peninsula, where it is proposed to protect and expand suitable habitat to re-introduce the cockatoo in future. Other threats include nest predation by Brushtail Possums and grazing by domestic stock, native wildlife and feral goats.
Fallow Deer have been causing substantial damage in Coorong National Park (XXXX XXXX pers comm.), which they invaded from a neighbouring pastoral property after feral goats had been eradicated from the NP. At the time researchers were conducting a rabbit exclusion experiment using tree guards to protect regenerating clusters of Allocasuarina verticillata. Surviving seedlings at ~ 2 m high and ~ 3 years of age and well above rabbit browse height were destroyed by Fallow Deer, implicated by the height of the browse line. There remain 3-4 exclusion plots where there is continuous and healthy recruitment of A. verticillata but in non-protected areas it is generally unable to escape browse height and recruitment is very poor (XXXX XXXX pers. comm.). This shows that Fallow Deer are a major threat to regenerating habitat for the Glossy Black-Cockatoo. Drooping Sheoak woodland is an endangered vegetation association in southeast South Australia.

Leipoa ocellata (Malleefowl)


A large ground-dwelling bird inhabiting semi-arid regions of southern Australia. Found in semi-arid to arid shrublands and low woodlands, especially those dominated by mallee and/or acacias. Populations severely fragmented (Benshemesh 2007).

 

Status: Vulnerable under the EPBC Act. Vulnerable under the SA National Parks and Wildlife Act 1972. Endangered under the NSW TSC Act. Critically Endangered under the Territory Parks and Wildlife Conservation Act 2000. Listed under the FFG Act. Classified as 'rare' or 'likely to become extinct' under the WA Wildlife Conservation Act 1950.

 

Threats: Major identified threats in the recovery plan are clearing, habitat fragmentation, grazing (sheep grazing can reduce breeding densities by 90% and deer are noted as a potential problem in this respect), predation (particularly by foxes) and fire (Benshemesh 2007). Deer trampling of malleefowl mounds is an additional recently observed problem (escalating over the past decade) in the South East region of South Australia. It has been observed in all 5 grids being monitored in the South East, especially from 2006-2008 (XXXX XXXX pers. comm.). It was most evident in the 2 monitoring grids in Gum Lagoon Conservation Park (25 mounds affected in 2007 and 17 in 2008), where the ‘surrounding bush was also trampled, bashed and criss-crossed with well used pads’ (ibid). Gum Lagoon Conservation Park and Duck Island (which are jointly managed by the SA Government and landowner James Darling, who is also a member of the South East Deer Advisory Committee) is a stronghold for Malleefowl, one of the most densely populated areas in their range (XXXX XXXX pers. comm.) Feral deer – mainly Red Deer and Fallow Deer, sometimes Rusa, occasional Sambar and Chital – have been a major problem in the area for the past decade. Most have escaped from a nearby, poorly fenced deer farm. Aerial shooting in the upper South East region on conservation reserves and some private properties has been conducted for the past 3 years and has been successful in ‘containing’ deer numbers, but farm escapes continue to replenish numbers (ibid.). Deer are attracted to Malleefowl mounds (as they are to sandy banks) seemingly for play ‘like children in a sandpit’ (ibid.). Their trampling damages the mound, sometimes collapsing the egg chamber. Although malleefowl are tenacious about maintaining mounds (some mounds are >100 years old) deer damage can result in abandonment, and otherwise requires extra maintenance efforts. James Darling and other landholders have fenced some mounds to protect them (while deer occasionally breach the fences, it prevents groups gathering on the mound). He considers that the entire malleefowl population in the South East would be threatened by mound trampling if deer were not controlled (>800 were killed last year by helicopter shooting and >800 by ground shooting).

 

Other feral deer threats probably include grazing/browsing impacts that deny food to Malleefowl and change the structure and floristic diversity of habitats; Malleefowl are highly sensitive to grazing (Benshemesh 2007). Deer browsing can be particularly damaging for regeneration after fire. In the Gum Lagoon and Duck Island area, 70% of which was burnt in 2006, seedling consumption by feral deer has been extensive, including in revegetation projects (XXXX XXXX pers. comm.). There has also been damage to saplings and trees caused by antler rubbing (ibid.).






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