Consultation Document on Listing Eligibility and Conservation
Actions
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and
Verticordia plumosa var. vassensis (Vasse Featherflower)
You are invited to provide your views about:
1)
the eligibility of Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) for
exclusion from the EPBC Act threatened species list;
2)
the eligibility of Verticordia plumosa var. vassensis (Vasse Featherflower) for exclusion from
the EPBC Act threatened species list; and
3)
the eligibility of Verticordia plumosa for inclusion on the EPBC Act threatened species list.
The views of experts, stakeholders and the general public are welcome. Responses can be
provided by any interested person.
At the commencement of the Environmental Protection and Biodiversity Conservation Act 1999
(EPBC Act), the list of threatened species under its predecessor, the Endangered Species
Protection Act 1992, was transferred to the list of threatened species under the EPBC Act in
June 2000. This list includes varieties; however, varieties are not considered to be species for
the purpose of the EPBC Act and are not eligible to be listed under section 178 of the EPBC Act.
The Threatened Species Scientific Committee (the Committee) is reviewing the status of listed
varieties as they are to be removed from the list. Prior to removal, the Committee is considering
the higher taxon to determine its eligibility for listing.
Draft information for your consideration of the eligibility of Verticordia plumosa var. ananeotes
for listing starts at page 3, of the eligibility of V. p. var. vassensis for listing starts at page 5 and
of the eligibility of V. plumosa for listing starts at page 7. To assist with the Committee’s
assessment, the Committee has identified three specific questions on which it seeks your
guidance at page 11.
Responses to are to be provided in writing either by email to:
species.consultation@environment.gov.au
or by mail to:
The Director
Species Information and Policy Section
Wildlife, Heritage and Marine Division
Department of the Environment
PO Box 787
Canberra ACT 2601
Responses are required to be submitted by 30 January 2015.
Contents of this information package
General background information about listing threatened species
Information about this consultation process
Draft information about Verticordia plumosa var. ananeotes and its eligibility for listing
Draft information about Verticordia plumosa var. vassensis and its eligibility for listing
Draft information about Verticordia plumosa and its eligibility for listing
References cited
Collective list of questions – your views
Page
2
2
3
5
7
10
11
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
Page 1 of 11
General background information about listing threatened species
The Australian Government helps protect species at risk of extinction by listing them as
threatened under Part 13 of the EPBC Act. Once listed under the EPBC Act, the species
becomes a Matter of National Environmental Significance (MNES) and must be protected from
significant impacts through the assessment and approval provisions of the EPBC Act. More
information about threatened species is available on the department’s website at:
http://www.environment.gov.au/biodiversity/threatened/index.html.
The listing of species is driven by a public nomination process. Public nominations to list
threatened species under the EPBC Act are received annually by the department. In order to
determine if a species is eligible for listing as threatened under the EPBC Act, the Threatened
Species Scientific Committee (the Committee) undertakes a rigorous scientific assessment of its
status to determine if the species is eligible for listing against a set of criteria. These criteria are
available on the Department’s website at:
http://www.environment.gov.au/biodiversity/threatened/pubs/guidelines-species.pdf.
As part of the assessment process, the Committee consults with the public and stakeholders to
obtain specific details about the species, as well as advice on what conservation actions might
be appropriate. Information provided through the consultation process is considered by the
Committee in its assessment. The Committee provides its advice on the assessment (together
with comments received) to the Minister regarding the eligibility of the species for listing under a
particular category and what conservation actions might be appropriate. The Minister decides to
add, or not to add, the species to the list of threatened species under the EPBC Act. More
detailed information about the listing process is at:
http://www.environment.gov.au/biodiversity/threatened/nominations.html.
To promote the recovery of listed threatened species and ecological communities, conservation
advices and where required, recovery plans are made or adopted in accordance with Part 13 of
the EPBC Act. Conservation advices provide guidance at the time of listing on known threats
and priority recovery actions that can be undertaken at a local and regional level. Recovery
plans describe key threats and identify specific recovery actions that can be undertaken to
enable recovery activities to occur within a planned and logical national framework. Information
about recovery plans is available on the department’s website at:
http://www.environment.gov.au/biodiversity/threatened/recovery.html.
Information about this consultation process
Responses to this consultation can be provided electronically or in hard copy to the contact
addresses provided on Page 1. All responses received will be provided in full to the Committee
and then to the Australian Government Minister for the Environment.
In providing comments, please provide references to published data where possible. Should the
Committee use the information you provide in formulating its advice, the information will be
attributed to you and referenced as a ‘personal communication’ unless you provide references
or otherwise attribute this information (please specify if your organisation requires that this
information is attributed to your organisation instead of yourself). The final advice by the
Committee will be published on the department’s website following the listing decision by the
Minister.
Information provided through consultation may be subject to freedom of information legislation
and court processes. It is also important to note that under the EPBC Act, the deliberations and
recommendations of the Committee are confidential until the Minister has made a final decision
on the nomination, unless otherwise determined by the Minister.
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
Page 2 of 11
Verticordia plumosa var. ananeotes
Taxonomy
Conventionally accepted as Verticordia plumosa var. ananeotes A.S.George (CHAH, 2014a).
Verticordia plumosa var. ananeotes is distinguished from other varieties of V. plumosa by the
presence of a lignotuber, longer leaves and smaller stature (George, 1991; Harris and Rye,
2013).
Reason for conservation assessment by the Threatened Species Scientific Committee
Verticordia plumosa var. ananeotes was listed as endangered under the predecessor to the
Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act), the Endangered
Species Protection Act 1992, and transferred to the EPBC Act in June 2000. It is also listed as
critically endangered under the Wildlife Conservation Act 1950 (Western Australia).
Verticordia plumosa var. ananeotes is conventionally accepted as a variety. Varieties are not
considered to be species for the purpose of the EPBC Act and are not eligible to be listed under
section 178 of the EPBC Act. The Threatened Species Scientific Committee (the Committee) is
reviewing the status of listed varieties as they are to be removed from the list. Prior to removal,
the Committee is considering the higher taxon (Verticordia plumosa) to determine its eligibility
for listing (see page 7).
This assessment is a result of advice provided for the eligibility of varieties to be listed.
Distribution
Verticordia plumosa var. ananeotes is endemic to south-west Western Australia, where it is
known from three subpopulations near Bussleton: at Ambergate Reserve, 556 plants were
known in 2002; at a road reserve near Treeton, 10 plants were recorded in 2006; and at
Edwards Road, no plants were recorded in 2002 (DEC, 2014). A fourth subpopulation of 50
plants consists of probable hybrids with V. p. var. vassensis (DEC, 2014). The variety has a
restricted extent of occurrence at 30 km2 and very restricted area of occupancy at 0.015 km2
(Taylor et al., 2005).
There are early records (1839 and 1900) from an area near Serpentine, approximately 150 km
to the north of Bussleton (Taylor et al., 2005), however, these have not been relocated.
Relevant Biology/Ecology
Verticordia plumosa var. ananeotes grows on sandy loam on seasonally inundated plains
(Western Australian Herbarium, 2014). The subpopulation in Ambergate Reserve occurs on lowlying sandy or clay soils in association with Marri (Eucalyptus calophylla), Kingia, Xanthorrhoea,
Stirlingia, Isopogon, sedges, Conostylis spp., Melaleuca spp. and Adenanthos spp. (Taylor et
al., 2005).
Verticordia plumosa var. ananeotes plants produce an abundance of flowers from November to
December. Generally, only a single seed per flower is produced, with seed set and germination
both considered to be low (approximately 5% and 26%, respectively) (Cochrane et al., 2001).
Population health and flowering vigour deteriorate without some regular burning, but too regular
fire reduces growth and condition (Williams et al., 2001). Post fire, the variety germinates from
seed and resprouts from its small lignotuber (woody stock) (Williams et al., 2001). The
Ambergate Reserve subpopulation was burnt in 2000 and was flowering again within 12 months
(WA DEC, 2007, cited in Department of the Environment, 2014).
Threats
Threats to Verticordia plumosa var. ananeotes include weed invasion, inappropriate fire
regimes, grazing and trampling by livestock, Road/track maintenance and dieback caused by
the plant pathogen Phytophthora cinnamomi (Taylor et al., 2005).
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
Page 3 of 11
Assessment of available information in relation to the EPBC Act Criteria and Regulations
and Consideration for delisting
As identified in the “Reason for conservation assessment” discussion provided above,
Verticordia plumosa var. ananeotes is not considered a species for the purpose of the EPBC Act
and is not eligible for listing in any category. Delisting is not expected to have any negative
impacts as the species, Verticordia plumosa, is abundant and widely distributed.
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
Page 4 of 11
Verticordia plumosa var. vassensis
Taxonomy
Conventionally accepted Verticordia plumosa var. vassensis A.S.George (CHAH, 2014a).
Verticordia plumosa var. vassensis is distinguished from other varieties of V. plumosa by the
smallness of its flower (George, 1991). A recent treatment suggested that flower size was
similar to the revised V. p. var. brachyphylla, but that the position of flowers was significantly
different to keep the varieties separate, but further review is required (Harris and Rye 2013).
Reason for conservation assessment by the Threatened Species Scientific Committee
Verticordia plumosa var. vassensis was listed as endangered under the predecessor to the
Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act), the Endangered
Species Protection Act 1992, and transferred to the EPBC Act in June 2000. It is also listed as
endangered under the Wildlife Conservation Act 1950 (Western Australia).
Verticordia plumosa var. vassensis is conventionally accepted as a variety. Varieties are not
considered to be species for the purpose of the EPBC Act and are not eligible to be listed under
section 178 of the EPBC Act. The Threatened Species Scientific Committee (the Committee) is
reviewing the status of listed varieties as they are to be removed from the list. Prior to removal,
the Committee is considering the higher taxon (Verticordia plumosa) to determine its eligibility
for listing (see page 7).
This assessment is a result of advice provided for the eligibility of varieties to be listed.
Distribution
Verticordia plumosa var. vassensis is endemic to south-west Western Australia, where it is
known from 10 extant subpopulations and three extinct subpopulations near Bussleton. The
distribution of the variety is highly fragmented existing in isolated pockets of remnant vegetation.
The majority of the known subpopulations occur in road and rail reserves or private land, with
one third of the total known plants occurring in Ruabon Townsite Nature Reserve. The variety’s
total number of mature individuals is estimated to be approximately 3200 mature plants. A
subpopulation of 50 plants consists of probable hybrids with V. p. var. ananeotes (DEC, 2014).
The variety has an extent of occurrence of 772 km2 and an area of occupancy of 0.045 km2.
Relevant Biology/Ecology
Verticordia plumosa var. vassensis grows on a variety of sands and swampy clay soils in mostly
winter-wet flats and depressions (Western Australian Herbarium, 2014). It often grows with
Golden Spray (Viminaria juncea), sedge and rushes, or in low heath containing Hypocalymma
sp., Grass Tree (Kingia australis), Pericalymma ellipticum and Rose Coneflower (Isopogon
formosus) (Brown et al., 1998; Williams et al., 2001).
Verticordia plumosa var. vassensis flowers from October to February, occasionally continuing
until April. It regenerates from seed following fire and soil disturbance (Brown et al., 1998).
Threats
The main identified threats to Verticordia plumosa var. vassensis are habitat degradation due to
horse riding (such as trampling) and infrastructure maintenance (such as road, firebreak
maintenance); invasive weeds; inappropriate fire regimes; and dieback caused by Phytophthora
cinnamomi (Williams et al., 2001). The variety is also at risk of plant damage or mortality caused
by myrtle rust (Puccinia psidii) (Kriticos et al., 2013), if the pathogen was to become established
in Western Australia.
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
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Assessment of available information in relation to the EPBC Act Criteria and Regulations
and Consideration for delisting
As identified in the “Reason for conservation assessment” discussion provided above,
Verticordia plumosa var. vassensis is not considered a species for the purpose of the EPBC Act
and is not eligible for listing in any category. Delisting is not expected to have any negative
impacts as the species, Verticordia plumosa, is abundant and widely distributed.
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
Page 6 of 11
Verticordia plumosa
Taxonomy
Conventionally accepted as Verticordia plumosa (Desf.) Druce (CHAH, 2014a).
Verticordia plumosa had six accepted varieties, of which V. p. var. ananeotes and V. p. var.
vassensis have restricted distributions.
Reason for conservation assessment by the Threatened Species Scientific Committee
This assessment is the result of Verticordia plumosa being the closest higher order taxon
eligible for assessment that is related to V. p. var. ananeotes and V. p. var. vassensis. These
varieties are listed under the Environmental Protection and Biodiversity Conservation Act 1999,
however, varieties are not considered to be species for the purpose of the EPBC Act and are not
eligible to be included on the list of threatened species. The Threatened Species Scientific
Committee (the Committee) is reviewing the status of listed varieties as they are to be removed
from the list. Prior to removal, the Committee is considering the higher taxon
(Verticordia plumosa) to determine its eligibility for listing.
Distribution
The species Verticordia plumosa is endemic to south-west Western Australia were it is common
and widely distributed. The species occurs from Arrowsmith River south to Scott River and east
to Point Malcolm (200 kilometres east of Geraldton) and occurs on a mixture of public and
private land, but also in many conservation reserves such as Boonanarring Nature Reserve,
Stirling Ranges National Park, Fitzgerald River National Park and Cape Arid National Park
(CHAH, 2014b).
Relevant Biology/Ecology
Verticordia plumosa occurs on sand, clay, and gravelly soils on rock outcrops undulating plains
in winter-wet areas (Western Australian Herbarium, 2014). The total population is unknown and
threats undocumented, but at the species level there is no evidence of a substantial decline in
this common species (Harris and Rye, 2013).
Threats
The threats the species Verticordia plumosa are undocumented however there is no evidence of
a substantial decline in this common species. The species is at risk of plant damage or mortality
caused by Phytophthora cinnamomi (Podger, 1972, Shearer et al., 2013) and myrtle rust
(Puccinia psidii) (Kriticos et al., 2013), the latter of which is yet to be recorded in Western
Australia. Verticordia plumosa in cultivation in eastern Australia is known to be susceptible to
myrtle rust (Morin et al., 2011).
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
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Assessment of available information in relation to the EPBC Act Criteria and Regulations
Criterion 1. Population size reduction (reduction in total numbers)
Population reduction (measured over the longer of 10 years or 3 generations) based on any of A1 to
A4
Critically Endangered
Very severe reduction
Endangered
Severe reduction
Vulnerable
Substantial reduction
A1
≥ 90%
≥ 70%
≥ 50%
A2, A3, A4
≥ 80%
≥ 50%
≥ 30%
A1
A2
Population reduction observed, estimated, inferred or
suspected in the past and the causes of the reduction
are clearly reversible AND understood AND ceased.
Population reduction observed, estimated, inferred
or suspected in the past where the causes of the
reduction may not have ceased OR may not be
understood OR may not be reversible.
A3
Population reduction, projected or suspected to be
met in the future (up to a maximum of 100 years) [(a)
cannot be used for A3]
A4
An observed, estimated, inferred, projected or
suspected population reduction where the time period
must include both the past and the future (up to a
max. of 100 years in future), and where the causes of
reduction may not have ceased OR may not be
understood OR may not be reversible.
(a)
direct observation [except A3]
(b)
an index of abundance appropriate to
the taxon
based
(c)
on any
of the
following
:
(d)
a decline in area of occupancy,
extent of occurrence and/or quality of
habitat
(e)
actual or potential levels of
exploitation
the effects of introduced taxa,
hybridization, pathogens, pollutants,
competitors or parasites
Evidence:
Verticordia plumosa is widespread and not considered threatened and there is no evidence of
decline.
The information considered appear to demonstrate that the species Verticordia plumosa is not
eligible for listing in any category under this criterion. However, the purpose of this consultation
document is to elicit additional information to better understand the species status. This
conclusion should therefore be considered to be tentative at this stage, as it may be changed as
a result of responses to this consultation process.
Criterion 2. Geographic distribution is precarious for either extent of occurrence
AND/OR area of occupancy
Critically Endangered
Very restricted
Endangered
Restricted
Vulnerable
Limited
B1. Extent of occurrence (EOO)
< 100 km2
< 5,000 km2
< 20,000 km2
B2. Area of occupancy (AOO)
< 10 km2
< 500 km2
< 2,000 km2
=1
≤5
≤ 10
AND at least 2 of the following 3 conditions:
(a)
Severely fragmented OR Number of
locations
(b)
Continuing decline observed, estimated, inferred or projected in any of: (i) extent of occurrence; (ii) area of
occupancy; (iii) area, extent and/or quality of habitat; (iv) number of locations or subpopulations; (v) number of
mature individuals
(c)
Extreme fluctuations in any of: (i) extent of occurrence; (ii) area of occupancy; (iii) number of locations or
subpopulations; (number of mature individuals
Evidence:
The geographic distribution of Verticordia plumosa is not considered to be very restricted,
restricted or limited (extent of occurrence 300,000 km2 and area of occupancy 50,000 km2
(CHAH, 2014b) and no specific threats have been identified that are operating that would make
the species’ geographic distribution precarious for its survival.
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
Page 8 of 11
The data presented above appear to demonstrate that the species Verticordia plumosa is not
eligible for listing in any category under this criterion. However, the purpose of this consultation
document is to elicit additional information to better understand the species status. This
conclusion should therefore be considered to be tentative at this stage, as it may be changed as
a result of responses to this consultation process.
Criterion 3.
Small population size and decline
Critically
Endangered
Very low
Endangered
Low
Vulnerable
Limited
< 250
< 2,500
< 10,000
Very high rate
25% in 3 years or 1
generation
(whichever is longer)
High rate
20% in 3 years or 1
generation
(whichever is
longer)
Substantial rate
10% in 10 years or 3
generations
(whichever is longer)
≤ 50
≤ 250
≤ 1,000
90 – 100%
95 – 100%
100%
Estimated number of mature individuals
AND either (C1) or (C2) is true
C1
An observed, estimated or projected
continuing decline of at least (up to a
max. of 100 years in future
C2
An observed, estimated, projected or
inferred continuing decline AND its
geographic distribution is precarious
for its survival based on at least 1 of
the following 3 conditions:
(a)
(b)
(i) Number of mature individuals in
each subpopulation
(ii) % of mature individuals in one
subpopulation =
Extreme fluctuations in the number of
mature individuals
Evidence:
The estimated total numbers of mature individuals of Verticordia plumosa is considered to be
greater than 10 000.
The data presented above appear to demonstrate that the species Verticordia plumosa is not
eligible for listing in any category under this criterion. However, the purpose of this consultation
document is to elicit additional information to better understand the species status. This
conclusion should therefore be considered to be tentative at this stage, as it may be changed as
a result of responses to this consultation process.
Criterion 4.
Very small population
Number of mature individuals
Critically Endangered
Extremely low
Endangered
Very Low
Vulnerable
Low
< 50
< 250
< 1,000
Evidence:
The estimated total numbers of mature individuals of Verticordia plumosa is considered to be
greater than 1000.
The data presented above appear to demonstrate that the species Verticordia plumosa is not
eligible for listing in any category under this criterion. However, the purpose of this consultation
document is to elicit additional information to better understand the species status. This
conclusion should therefore be considered to be tentative at this stage, as it may be changed as
a result of responses to this consultation process.
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
Page 9 of 11
Criterion 5.
Quantitative Analysis
Indicating the probability of extinction in
the wild to be:
Critically Endangered
Immediate future
Endangered
Near future
Vulnerable
Medium-term future
≥ 50% in 10 years or 3
generations,
whichever is longer
(100 years max.)
≥ 20% in 20 years or
5 generations,
whichever is longer
(100 years max.)
≥ 10% in 100 years
Evidence:
There is no quantitative data available to assess against this criterion.
References cited in the advice
Brown A, Thomson-Dans C and Marchant N (Eds) (1998). Western Australia’s Threatened
Flora. Department of Conservation and Land Management, Como, Western Australia.
Cochrane A, Brown K, Cunneen S and Kelly A (2001). Variation in seed production and
germination in 22 rare and threatened Western Australian Verticordia (Myrtaceae).
Journal of the Royal Society of Western Australia 84:103–110.
Council of Heads of Australasian Herbaria (CHAH) (2014a). Australian Plant Name Index.
Integrated Biodiversity Information System, Australian National Botanic Gardens,
Australian National Herbarium
Viewed: 15 October 2014
Available on the Internet:
http://www.cpbr.gov.au/cpbr/databases/apni-search-full.html
Council of Heads of Australasian Herbaria (CHAH) (2014b). Australia’s Virtual Herbarium.
Viewed: 15 October 2014
Available on the Internet:
http://avh.chah.org.au/index.php/about/
Department of Environment and Conservation (DEC) (2014). Extract from the Threatened and
Priority Flora Database, 6 May 2014.
Department of the Environment (2014). Verticordia plumosa var. ananeotes. In: Species Profile
and Threats Database, Department of the Environment, Canberra.
Viewed: 15 October 2014
Available on the Internet:
http://www.environment.gov.au/sprat
George AS (1991). New taxa, combinations and typifications in Verticordia (Myrtaceae:
Chamelaucieae). Nuytsia 7(3):231–394.
Harris AM and Rye BL (2013). A re-assessment of the varieties recognised in Verticordia
plumosa (Myrtaceae: Chamelaucieae). Nuytsia 23:163–170.
Morin L, Aveyard R and Lidbetter J (2011). Myrtle rust: host testing under controlled conditions.
Report number: C2010/9785. CSIRO and NSW Department of Primary Industries.
Kriticos DJ, Morin L, Leriche A, Anderson RC and Caley P (2013). Combining a Climatic Niche
Model of an Invasive Fungus with Its Host Species Distributions to Identify Risks to
Natural Assets: Puccinia psidii Sensu Lato in Australia. PLoS ONE 8(5): e64479.
Podger F (1972). Phytophthora cinnamomi, a cause of lethal disease in indigenous plant
communities in Western Australia. Phytopathology 62: 972–981.
Shearer BL, Crane CE, Cochrane JA and Dunne CP (2013). Variation in susceptibility of
threatened flora to Phytophthora cinnamomi. Australasian Plant Pathology 42(4): 491–
502.
Taylor H, English V and Webb A (2005). Tufted Plumed Featherflower (Verticordia plumosa var.
ananeotes) Interim Recovery Plan 2005-2010. Department of Conservation and Land
Management, Wanneroo, Western Australia.
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
Page 10 of 11
Williams K, Brown A, Wood S and Webb A (2001). Declared Rare and Poorly Known Flora in
the Central Forest Region. Department of Conservation and Land Management, Perth,
Western Australia.
Western Australian Herbarium (2014). Descriptions by the Western Australian Herbarium,
Department of Parks and Wildlife.
Viewed: 8 May 2014
Available on the Internet:
http://florabase.dpaw.wa.gov.au/
Collective list of questions – your views
1. Can you provide evidence that would change the outcome of the assessment of
Verticordia plumosa?
2. Can you provide evidence that V. p. var. ananeotes is considered a species or a
subspecies?
3. Can you provide evidence that V. p. var. vassensis is considered a species or a
subspecies?
Verticordia plumosa var. ananeotes (Tufted Plumed Featherflower) and Verticordia plumosa var. vassensis (Vasse
Featherflower) consultation
Page 11 of 11