Invitation to comment on EPBC Act nomination to list in the endangered category: Genoplesium baueri (brittle midge orchid) Anyone may nominate a native species, ecological community or threatening process for listing under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). You are invited to provide comment on the attached nomination to assist the Threatened Species Scientific Committee (the Committee) with its assessment of whether the species is eligible for inclusion in the EPBC Act list of threatened species, and, if eligible, the category in which it is eligible to be included. The Committee welcomes the views of experts, stakeholders and the general public on nominations to further inform its nomination assessment process. In order to determine if a species, ecological community or threatening process is eligible for listing under the EPBC Act, a rigorous scientific assessment of its status is undertaken. These assessments are undertaken by the Committee to determine if an item is eligible for listing against a set of criteria as set out in the guidelines for nominating and assessing threatened species and ecological communities, and threatening processes. These are available at: http://www.environment.gov.au/biodiversity/threatened/nominations.html Individual nominations may vary considerably in quality. Therefore in addition to the information presented in the nomination, the Committee also takes into account published data and considers other information received when it prepares its advice for the Minister. Responses to this consultation will be provided in full to the Minister for Sustainability, Environment, Water, Population and Communities. 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 ‘personal communication’ unless you provide references or otherwise attribute this information. The Committee’s advice may be published on the department’s website at completion of the assessment and 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. The views expressed within the attached nomination do not necessarily reflect the opinions of the Australian Government. The Australian Government and the Committee do not accept responsibility for the accuracy or completeness of the contents of the nomination. Nominated species - summary of eligibility 1. Name of species (or subspecies) Genoplesium baueri 2. Category for which the species is nominated under the EPBC Act Current listing category Proposed listing category Extinct Extinct Extinct in the wild Extinct in the wild Critically Endangered Critically Endangered Endangered Endangered Vulnerable Vulnerable Conservation dependent Conservation dependent Unlisted 3. Criteria under which the species is eligible for listing For a species nominated as critically endangered, endangered or vulnerable, identify which of the eligibility criteria it meets (one or more) from the list below. Please note that the information you provide in this nomination form should support the criteria you select. For further details on the criteria, please refer to the Threatened Species Scientific Committee guidelines attached to this form. Criterion 1 - It has undergone, is suspected to have undergone or is likely to undergo in the immediate future a very severe, severe or substantial reduction in numbers. Criterion 2 - Its geographic distribution is precarious for the survival of the species and is very restricted, restricted or limited. Criterion 3 - The estimated total number of mature individuals is limited to a particular degree and: (a) evidence suggests that the number will continue to decline at a particular rate; or (b) the number is likely to continue to decline and its geographic distribution is precarious for its survival. Criterion 4 - The estimated total number of mature individuals is extremely low, very low or low. Criterion 5 - Probability of extinction in the wild. For species nominated as conservation dependent, identify which criterion the species meets (either criterion 1 or criterion 2). Criterion 1 - The species is the focus of a specific conservation program, the cessation of which would result in the species becoming vulnerable, endangered or critically endangered; or Criterion 2: The species is a species of fish; and The species is the focus of a plan of management that provides for management actions necessary to stop the decline of, and support the recovery of, the species so that its chances of long term survival in nature are maximised; and The plan of management is in force under a law of the Commonwealth or of a State or Territory; and Cessation of the plan of management would adversely affect the conservation status of the species. Section 1 - Legal Status, Distribution, Biological, Ecological Conservation Theme 1. The conservation themes for the assessment period commencing 1 October 2010 (for which nominations close 25 March 2010) are ‘heathlands and mallee woodlands’, and ‘terrestrial, estuarine and near–shore environments of Australia’s coast’. The species nominated occurs in heathy and shrubby woodland within a maximum 22 km from the east coast (Jerrawangla NP) and the shoreline north and south of Sydney. How does this nomination relate to the conservation themes? Taxonomy 2. What are the currently accepted scientific and common name/s for the species (please include Indigenous names, where known)? Note any other scientific names that have been used recently. Note the species authority and the Order and Family to which the species belongs (Family name alone is sufficient for plants, however, both Order and Family name are required for insects). 3. Is this species conventionally accepted? If not, explain why. Is there any controversy about the taxonomy? 4. If the species is NOT conventionally accepted, please provide: The above is the extract from Australian Orchid Research Volume 1 1989 p. 81. Clements M.A. (Australian Orchid Foundation) Common name: Brittle Midge Orchid Yes (i) a taxonomic description of the species in a form suitable for publication in conventional scientific literature; OR (ii) evidence that a scientific institution has a specimen of the species and a written statement signed by a person who has relevant taxonomic expertise (has worked, or is a published author, on the class of species nominated), that the person thinks the species is a new species. 5. Is this species taxonomically distinct (Taxonomic distinctiveness – a measure of how unique a species is relative to other species)? Yes Legal Status 6. What is the species’ current conservation status under Australian and State/Territory Government legislation? 7. Does the species have specific protection (e.g. listed on an annex or appendix) under other legislation or intergovernmental arrangements, e.g. Convention on International Trade in Endangered Fauna and Flora (CITES), Convention on Migratory Species (CMS). Listed as Endangered under the NSW Threatened Species Conservation Act 1995. Not applicable Description 8. Give a brief description of the species’ appearance, including size and/or weight, and sex and age variation if appropriate; social structure and dispersion (e.g. solitary/clumped/flocks). 9. Give a brief description of the Plants growing singly or in loose groups, reddish or brownish, fleshy, brittle. Leaf 40-120 x 22.5mm; free part 10-20mm long, ending below flowers. Spike 10-50mm tall, dense, 1-9 flowered. Flowers upside-down, crowded, projecting, 8-11 x 11-13mm, brownish or reddish brown, with reddish labellum. Dorsal sepal 3-3.5-4mm; margins hairless; apex with long point. Lateral sepals widely divergent 8-10 x 1.5-2mm, erect boat-shaped. Petals about 3 x 1.5mm, margins entire; apex entire or notched. Labellum stiffly hinged to apex of column foot, oblong, tapered, 4 x 1.5mm, constricted near the middle; margins hairless. Callus fleshy, channelled, covering basal part of labellum. “Native Orchids of Australia” David L. Jones 2006. Not applicable species’ ecological role (for example, is it a ‘keystone’ or ‘foundation’ species, does it play a role in processes such as seed dispersal or pollination). Australian Distribution 10. Describe the species’ current and past distribution in Australia and, if available, attach a map. 11. What is the extent of occurrence (in km2) for the species (described in Attachment A); explain how it was calculated and datasets used. See enclosed maps (1-13) and notes for species distribution and numbers. [Maps have been removed as they contain confidential location information.] Areas of most individual populations are listed and estimated using Google Earth mapping. Other populations are those with which I have had personal experience. A list is included for each population. A total of 62 individuals or 29.6% of the total population occur in reserves. Despite this, all of those plants are under threat a. b. What is the current extent of occurrence? What data are there to indicate past declines in extent of occurrence (if available, include data that indicates the percentage decline over the past 10 years or 3 generations whichever is longer)? c. What data are there to indicate future changes in extent of occurrence (if available, include data that indicates the percentage decline over 10 years or 3 generations whichever is longer (up to a maximum of 100 years in the future) where the time period is a continuous period that may include a component of the past)? 12. What is the area of from either road work or residential development. Known to occur from Port Stephens to Ulladulla. Due to the TSC listing in 2004 this species has been the target of several searches in line with environmental assessments prior to development approval as required for residential and other forms of development. As a result more sites have been located. The total number of sites is currently 13 and the total number of recorded individuals is 209. No propagated populations occur or are likely to occur and no plants have been or are likely to be re-introduced to the wild. Other sites which are now in built-up areas were Port Jackson, Gladesville, Lane Cove River, Cowan, Asquith, Pennant Hills and Wahroonga. Two sites in the Royal National Park still exist in a near natural state. Plants on the Woronora Dam Road have not been located due to vegetation covering the site. Having regard to Sydney Catchment Authority activities, it is unlikely this small population will flower in the future. 11 sq km occupancy (in km2) for the species (described in Attachment A); explain how calculated and datasets that are used. a. b. c. What is the current area of occupancy? What data are there to indicate past declines in area of occupancy (if available, include data that indicates the percentage decline over the past 10 years or 3 generations whichever is longer)? What data are there to indicate future changes in area of occupancy (if available, include data that indicates the percentage decline over 10 years or 3 generations whichever is longer (up to a maximum of 100 years in the future) where the time period is a continuous period that may include a component of the past)? 13. How many natural locations do you consider the species occurs in and why? Where are these located? The term 'location' defines a geographically or ecologically distinct area. 110.05 hectares Other sites which are now in built-up areas were Port Jackson, Gladesville, Lane Cove River, Cowan, Asquith, Pennant Hills and Wahroonga. Two sites in the Royal National Park still exist in a near natural state. Sixty two individuals or 29.6% of the total population exist in reserves; however all of these plants are under threat from either road works or residential development. There are 13 sites where G. baueri has been located in the past 10 years from Port Stephens (Tomaree Peninsula) to Ulladulla, a distance of 420 km by road. These populations contain a total of 209 plants. See enclosed maps. [Maps have been removed as they contain 14. Give locations of other populations: captive/propagated populations; populations recently re-introduced to the wild; and sites for proposed population reintroductions. Note if these sites have been identified in recovery plans. 15. Is the species’ distribution severely fragmented? What is the cause of this fragmentation? Describe any biological, geographic, human-induced or other barriers causing this species’ populations to be fragmented. Severely fragmented refers to the situation in which increased extinction risk to the taxon results from most individuals being found in small and relatively isolated subpopulations (in certain circumstances this may be inferred from habitat information). These small subpopulations may go extinct, with a reduced probability of recolonisation. confidential location information.] No propagated populations occur or are likely to occur and no plants have been or are likely to be re-introduced to the wild. Other sites which are now in built-up areas were Port Jackson, Gladesville, Lane Cove River, Cowan, Asquith, Pennant Hills and Wahroonga. Two sites in the Royal National Park still exist in a near natural state. Populations are severely fragmented with low numbers the norm. The self pollinating mechanism, saprophytic nature wind based seed dispersal and non-annual tuber production, are all factors mitigating against the build-up and natural maintenance of large populations. The average height of plants (80 mm) and average flower count (3-5) per plant is also an indicator to a precariously situated population. G. baueri is limited to these sites due to a finely defined habitat preference type. a16. Departmental Use Only: Global Distribution 17. Describe the species’ global distribution. 18. Give an overview of the global population’s size, trends, threats and security of the species outside Australia. 19. Explain the relationship between the Australian population and the global population, including: a. b. c. What percentage of the global population occurs in Australia; Is the Australian population distinct, geographically separate or does part or all of the population move in/out of Australia’s jurisdiction (give an overview; details in Movements section); Do global threats affect the Australian population? This species is endemic to NSW. Surveys and Monitoring 20. Has the species been reasonably well surveyed? Provide an overview of surveys to date and the likelihood of its current known distribution and/or population size being its actual distribution and/or population size. Most populations were discovered accidentally during the course of surveys for other species or by observant naturalists with extensive experience with native orchids. The Callala Beach population was recorded by XXXX XXXX. The Port Stephens population was surveyed by XXXX XXXX, although no date (year) is available. Extensive surveys by XXXX XXXX were undertaken for the Vincentia population and extensive surveys of the Jerrawangla NP and Bomaderry Creek populations by XXXX XXXX from 2002 to 2010. The Ulladulla population was only confirmed in 2010. The Ku-ring-gai Wildflower gardens population was discovered in 2009 and surveyed then and in 2010 by XXXX XXXX. The Ulladulla population was also discovered in 2009 and surveyed in 2010 by XXXX XXXX. 21. For species nominated as extinct or extinct in the wild, please provide details of the most recent known collection, or authenticated sighting of the species and whether additional populations are likely to exist. 22. Is there an ongoing monitoring programme? If so, please describe the extent and length of the programme. No Life Cycle and Population 23. What is the species’ total population size in terms of number of mature individuals? How were population estimates derived and are they reliable? Are there other useful measures of population size and what are they? In the absence of figures, terms such as common, abundant, scarce can be of value. 24. Does the species occur in a Estimated total population based on personal communication with XXXX, XXXX, XXXX, XXXX, XXXX, XXXX and extensive personal experience, is 209 individuals. Recorded numbers arose from intensive ground inspections at each potential area of suitable habitat. None other than those already mentioned. number of smaller populations? How many? For each population give the locality, numbers and trends in numbers and tenure of land (include extinct populations). Can these be considered to be subpopulations and why? Subpopulations are defined as geographically or otherwise distinct groups in the population between which there is little demographic or genetic exchange. 25. Provide details on ages of the following: Not applicable a. sexual maturity; b. life expectancy; c. natural mortality. 26. Reproduction For plants: When does the species flower and set fruit? What conditions are needed for this? What is the pollinating mechanism? If the species is capable of vegetative reproduction, a description of how this occurs, the conditions needed and when. Does the species require a disturbance regime (e.g. fire, cleared ground) in order to reproduce? For animals: provide overview of breeding system and of breeding success, including: when does it breed; what conditions are needed for breeding; are there any breeding behaviours that may make it vulnerable to a threatening process? 27. What is the population trend for the entire species? a. What data are there to indicate past decline in size (if available, include data on rate of decline over past 10 years or 3 generations whichever is longer)? b. What data are there to indicate future changes in size (if available, include data which will indicate the percentage of decline over 10 years or 3 generations whichever in longer (up to a maximum of 100 years in the future) where the time period is a continuous period that may include a component of the past)? 28. Does the species undergo extreme natural fluctuations in population numbers, extent of occurrence or area of occupancy? To what extent and why? Extreme fluctuations can be said to occur in a number of taxa when population size or G. baueri normally flowers approximately six weeks after a significant rainfall event (20 mm25 mm) in a 24 hour period during February and March. Flowers last from two–three weeks; self pollinate during March and disperse seed, usually within 21-28 days. Plants have a single perennial tuber-like root, which is not replaced annually as in a similar Genus, Corunastylis. Plants are not necessarily enhanced by fire but occasional vegetation thinning via this mechanism provides less competition from other vegetation and permits plants to grow, whereas they are repressed by continually dense ground cover. Population numbers vary according to the seasonal factors of rainfall, fire and vegetation growth. During periods of drought from 2002–2010 few plants could be found at a range of sites and the timing of rain at a period of approximately six weeks prior to flowering in February or March is essential for the survival of this species. A single event rainfall of 20 mm–25 mm in a 24 hour period is necessary for the annual flowering event, although good summer and autumn rain to follow this single event is also required. The season of 2010 is the first average season for seven years but this will be negated if the following season fails to produce a similar pattern. Some populations merely limit themselves to minimal numbers but others fail to produce any plants unless consecutive seasons record appropriate rainfall at the required time. Of the previously recorded two populations (2+7) at Bomaderry Creek Regional Park where G. baueri was known to occur, only one site produced a single plant in 2010. All other sites recorded in 2010 eventuated from more extensive surveys and good seasonal conditions. distribution area varies widely, rapidly and frequently, typically with a variation greater than one order of magnitude (i.e. a tenfold increase or decrease). 29. What is the generation length and how it is calculated? Generation length is the average age of parents of the current cohort (i.e. newborn individuals in the population). Generation length therefore reflects the turnover rate of breeding individuals in a population. Generation length is greater than the age at first breeding and less than the age of the oldest breeding individual, except in taxa that breed only once. Where generation length varies under threat, the more natural, i.e. pre-disturbance, generation length should be used. 30. Identify important populations necessary for the species’ long-term survival and recovery? This may include: key Contrary to these numbers was the recording of three individuals only, in the Jerrawangla NP as previous surveys from 2002-2009 had resulted in locating no less than 10 individuals over five kilometres of Yarran Road, which is the main trail through this section of park. Insufficient knowledge is available regarding the propagation rates of G. baueri; however as the plant does not (in the true sense) produce an annual tuber but a tuber like root, consistent good seasonal conditions must be considered essential for the long-term survival of this species. Tubers can remain viable for a season or two during drought but lose their viability (shrink) in extended drought periods but little is known about the type of root system of G. baueri and its ability to resist extended dry periods. The fact many plants are not located during drought conditions would give some credence to this observation. With the low overall total population numbers, no site can, or should be afforded more importance than any other. breeding populations, those near the edge of the species’ range or those needed to maintain genetic diversity. 31. Describe any cross-breeding with other species in the wild, indicating how frequently and where this occurs. 32. Departmental Use only: G. baueri is not known to cross-breed with any other species. Populations In Reserve 33. Which populations are in reserve systems? Which of these are actively managed for this species? Give details. Four populations, Royal National Park, Jerrawangla NP Bomaderry Creek Regional Park, Ku-ring-gai Chase NP, are in reserves, although none are actively managed for this species. Only the Royal National park population is free from the risk of trail maintenance works, housing and road building proposals. Habitat 34. Describe the species’ habitat (e.g. aspect, topography, substrate, climate, forest type, associated species, sympatric species). If the species uses different habitats for different activities (e.g. breeding, feeding, roosting, dispersing, basking), then describe each habitat. G. baueri is a highly localised species occurring in small areas of open forest, shrubby forest and heathy forest in well-drained sandy or gravelly soil at altitudes from 0-250m. The sites in Bomaderry Creek Regional Park are located in shrubby &/or heathy woodland. Some small groups of one or two plants occur in small naturally cleared areas of habitat. Such areas 35. Does the species use refuge habitat, e.g. in times of fire, drought or flood? Describe this habitat. 36. Is the extent or quality of the species’ habitat in decline? If the species uses different habitats, specify which of these are in decline. 37. Is the species part of, or does it rely on, a listed threatened ecological community? Is it associated with any other listed threatened species? can be less than one square metre. The Ku-ringgai NP population occurs in heath and shrubby woodland. Habitat photos (1-13) are included for several sites [These have been removed as they may contain confidential location information.] G. baueri relies on the overall habitat and does not use or require a specifically associated (sympatric) species. Not applicable A number of sites have been destroyed by urban development in the past. The following sites of Wahroonga, Cowan, Asquith, Gladesville, Pennant Hills, Lane Cove River and Pittwater are all urban areas with a very low possibility of orchid occurrence. The majority of existing sites are threatened by road or residential development. Not associated with any listed threatened ecological community. Not associated with any other listed threatened species at most sites; however the Port Stephens population is also home to Diuris praecox and Diuris arenaria. D. praecox is listed as a Vulnerable Species under the NSW Threatened Species Conservation Act 1995 (TSC Act) and D. arenaria is listed as an Endangered Species under the same legislation. In the Jerrawangla NP Cryptostylis hunteriana is within metres of G. baueri and it is listed as a Vulnerable Species under the Commonwealth Environment Protection Biodiversity Conservation Act 1999 and as a Vulnerable Species under the NSW TSC Act. Feeding 38. Summarize the species’ food items or sources and timing/seasonality. 39. Briefly describe the species’ feeding behaviours, including those that may make the species vulnerable to a threatening process. Movement Patterns (fauna species only) 40. Describe any relevant daily and seasonal pattern of movement for the species, or other irregular patterns of movement, including relevant arrival/departure dates if migratory. 41. Give details of the species’ home ranges/territories. Survey Guidelines 42. Give details of the distinctiveness and detectability of the species. 43. Describe methods for detecting species including when to conduct surveys (e.g. season, time of day, weather conditions); length, intensity and pattern of search effort; and limitations and expert acceptance; recommended methods; survey-effort guide. G. baueri is unmistakable in bud or flower, albeit usually to experienced persons. Its stem is the same reddish colour from the base to the apex of the raceme. The flowers are larger and wider spreading than others in the similar Genus Corunastylis. G. baueri is a deciduous terrestrial species with the leaf enclosing the flower stem and ending just below the flowers. Plants are not visible until the stem and leaf are developed. Identification prior to flowering by careful scrutiny of the habitat is possible due to the stem and leaf colour and usually by experienced observers only. This occurs from early to mid-February and time of day and weather conditions is irrelevant. The key factor is a significant rainfall event (20 mm-25 mm) in a 24 hour period approximately six weeks prior to this period. Plants are unmistakable when in flower. Section 2 - Threats and Threat Abatement Threats 44. Identify past, current and future threats, to the species indicating whether they are actual or potential. For each threat, describe: a. how and where it impacts on this species; The Port Stephens population is being encroached upon by residential development and already suffers from chemical spraying for Lantana & Bitou Bush, Trail Bike Riders, and easy access to the population area via a power line easement. Normal road maintenance in the Jerrawangla NP has impacted adversely on plant numbers in that instance. This occurred prior to the TSC listing. The population at Bomaderry Creek is mainly on Vacant Crown Land (VCL) with a small area within the Bomaderry Creek Regional Park. The current zoning is urban for both the VCL and the Regional Park. A draft LEP due for public exhibition in 2010 proposes a national park/nature reserve zoning (E1) for the regional park and urban zoning (R1) for the VCL. The VCL is also subject to an Aboriginal land claim under NSW legislation. If this land is developed 91% of the population will be b. c. d. what its effect has been so far (indicate whether it is known or suspected; present supporting information/research; does it only affect certain populations); what is its expected effect in the future (is there supporting research/information; is the threat only suspected; does it only affect certain populations); what is the relative importance or magnitude of the threat to the species. destroyed, either by actual housing construction or associated infrastructure for essential services. An adjacent road is proposed which will bisect the Regional Park. The Shoalhaven City Council has been active for many years in their efforts to construct this road and it is now listed under the NSW Environmental Planning and Assessment Act as a Part 3a development. The development is now considered (January 2010) to be a Controlled Action by the Federal Environment Minister under the EPBC Act. This proposed road would cause the destruction of the remaining 9% of the existing population. The Callala Beach (largest) population is currently zoned rural and was surveyed for residential development in 2006. It has a proposed zoning of RU2 (Rural Landscape) in the current Draft Shoalhaven City Council Local Environment Plan. This zoning allows a range of activities that could lead to the destruction of this population. The Ulladulla population area is listed as Environmental Conservation (E2) which allows certain destructive developments (see general notes on Council’s web page for permitted developments). The Ku-ring-gai population is currently under threat from proposed road widening. The St. Ives population is under threat by plans to develop the area around the St. Ives Showground containing the Ku-ring-gai Wildflower Gardens. This will include increased water run-off from widening of the existing bitumen road, chemical contamination from same, added vehicle parking, which will reduce orchid habitat, planned use for cycle racing (contrary to the land use charter) See enclosed poster. Within the Jerrawangla NP some plants were known to be lost to normal road maintenance prior to the 2004 TSC listing. The DECCW is now aware (2010) of all populations within their areas of immediate control, but over time with changing personnel and memory lapses this is no guarantee that further loss will be avoided. At sites not under secure reservation, the future for this species is even more uncertain. The threat level is high regarding several populations and those remaining without immediate threat, comprise the smaller populations only. 45. If not included above, identify catastrophic threats, i.e. threats with a low predictability that are likely to severely affect the species. Identify the threat, explain its likely impact and indicate the likelihood of it occurring (e.g. a drought/cyclone in the area every 100 years). 46. Identify and explain any additional biological characteristics particular to the species that are threatening to its survival (e.g. low genetic diversity)? Drought must be considered to be a serious threat to G. baueri. Extended dry periods will eventually reduce the viability of the tuber-like root system of the plant to a state where it lacks sufficient strength to produce plants. No studies regarding this possibility have been undertaken or are planned. Another most serious and constant threat is via the human impact of planned development and incidental roadwork. Genetic diversity is not considered a problem but given the fragmented populations, low numbers, fragile nature of the species reproduction and development pressures upon several populations, the prospects for survival of this species must be considered marginal in most of the small populations. 47. Identify and explain any quantitative measures or models that address the probability of the species’ extinction in the wild over a particular timeframe. 48. Is there other information that relates to the survival of this species that you would like to address? A real threat to the long-term survival of some populations is the lack of specialist orchid knowledge by some who undertake environmental assessments for government bodies, and private developers (personal comments to the EPBC Review Committee 2009). To some extent this can be applied to some DECCW and NPWS personnel via a lack of training in orchid identification generally and EPBC and TSC listed orchid species in particular. The same applies to private persons who undertake environmental assessments on behalf of developers. Threat Abatement and Recovery 49. Give an overview of how broad-scale threats are being abated/could be abated and other recovery actions underway/ proposed. Identify who is undertaking these activities and how successful the activities have been to date. 50. For species nominated as extinct in the wild, provide details of the locations in which the species occurs in captivity and Maintenance of habitat in as natural a state as possible is the only mechanism which will assure the long-term survival of this species. As this species exists in well drained habitat types, no adjacent development must in any way, be allowed to alter the hydrology of any orchid site. There are no recovery actions underway or proposed. The self-pollinating saprophytic nature of this species which lacks the formal tuber structure of most terrestrial orchids would prove an overwhelming obstacle if a recovery operation was considered. the level of human intervention required to sustain the species. Mitigation Approach 51. Describe any mitigation measures or approaches that have been developed specifically for the species at identified locations. Identify who is undertaking these activities and how successful the activities have been to date. To date, mitigation measures have been confined to orchid specialists advising DECCW and NPWS staff of population sites including GPS points for as many populations as possible. 52. Departmental use only: Major Studies 53. Identify major studies on the species that might relate to its taxonomy or management. Currently no scientific studies are active or planned in regard to this species. Management Documentation 54. Identify key management documentation available for the species, e.g. recovery plans, conservation plans, threat abatement plans. 55. Departmental use only: No recovery plans are currently in place or are being planned.