Invitation to comment on EPBC Act nomination to list as a key
threatening process:
‘Biodiversity decline and habitat degradation in the arid and semi-arid Australian
rangelands due to the proliferation, placement and management of artificial watering points’
and associated threat abatement plan decision.
You are invited to provide your views about
1) whether the process: ‘Biodiversity decline and habitat degradation in the arid and semi-arid
Australian rangelands due to the proliferation, placement and management of artificial watering
points’ is eligible for inclusion in the list of key threatening processes and your reasons supporting
those views; and
2) the feasibility, effectiveness and efficiency of having and implementing a threat abatement plan
to abate the process.
The views of experts, stakeholders and the general public are welcome. Responses can be
provided by any interested person.
Anyone may nominate a native species, ecological community or threatening process for listing
under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). The
Threatened Species Scientific Committee (the Committee) undertakes assessments of key
threatening processes to determine their eligibility for inclusion in the list of key threatening
processes and provides its advice to the Australian Government Minister for the Environment.
Your comment on this threatening process will assist the Committee with its assessment of
whether the threatening process is eligible for inclusion in the EPBC Act list of key threatening
process. The Department also requests your views on the feasibility, effectiveness of efficiency of
having and implementing a threat abatement plan to abate the process. If listed, you views will
assist the Minister in deciding whether to have a threat abatement plan.
General background information about key threatening processes is at page 3 and general
background information about threat abatement plans is at page 4.
Draft information for your consideration of the eligibility of this threatening process for listing starts
at page 6 and information associated with a threat abatement plan for this process is at page 18.
To assist the Committee’s assessment, the Committee has identified a series of additional specific
questions on which it also seeks your particular guidance at page 19.
Responses to are to be provided in writing either by email to:
species.consultation@environment.gov.au
or by mail to:
The Director
Terrestrial Species Conservation Section
Wildlife, Heritage and Marine Division
Department of the Environment
PO Box 787
Canberra ACT 2601
Responses are required to be submitted by 28 February 2014.
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Contents of this information package
Information about consultation and your comments
Page
3
General background information about key threatening processes
3
General background information about threat abatement plans
4
Frequently asked questions
4
Draft information about the key threatening process: ‘Biodiversity decline and habitat
degradation in the arid and semi-arid Australian rangelands due to the proliferation,
placement and management of artificial watering points’ and its eligibility for listing
6
Draft information about an associated threat abatement plan for this process
18
Collective list of questions – your views
19
Referenced cited
20
2
Information about consultation and your comments
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 Threatened Species Scientific Committee (the Committee) to
determine if an item is eligible for listing against a set of criteria. These are set out in the guidelines
for nominating and assessing threatened species and ecological communities, and threatening
processes and are available at:
http://www.environment.gov.au/biodiversity/threatened/nominations.html.
Responses to this consultation can be provided electronically or in hard copy to the contact
addresses provided on Page 1. Responses 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 ‘personal communication’ unless you provide references or
otherwise attribute this information. The final advice by the Committee will be published on the
department’s website following the 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.
General background information about key threatening processes
A key threatening process is defined as a process that threatens or may threaten the survival,
abundance or evolutionary development of a native species or ecological community. Listing key
threatening processes under the EPBC Act provides official recognition that a process is a key
threat to biodiversity at the national level. This system of identification and recognition of key
threats raises awareness of how threats to biodiversity are operating across Australia and assists
with prioritisation of threat abatement activities.
A process may be listed as a key threatening process if it could:
 cause a native species or ecological community to become eligible for inclusion in a
threatened list (other than the conservation dependent category); or
 cause an already listed threatened species or threatened ecological community to become
more endangered; or
 adversely affect two or more listed threatened species or threatened ecological
communities.
Key threatening process and associated threat abatement plans provide an opportunity to deal with
biodiversity decline at a landscape and multi-species level.
The listing process for key threatening processes
Public nominations to list key threatening processes under the EPBC Act are received annually by
the department. Any person or organisation may nominate a threatening process for listing. The
nominations are considered by an independent scientific committee, the Threatened Species
Scientific Committee (the Committee). As part of the assessment process, the Committee consults
with the public and stakeholders to obtain information and specific details on the process, as well
as advice on what threat abatement 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
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eligibility of the key threatening process for listing and what threat abatement actions might be
appropriate. The Minister decides to add, or not to add, the threatening process to the list of key
threatening process under the EPBC Act.
More information about key threatening processes is available on the department’s website at:
http://www.environment.gov.au/biodiversity/threatened/ktp.html.
General background information about threat abatement plans
Within 90 days of listing a key threatening process, the Minister decides whether a threat
abatement plan should be made or adopted. In making this decision the Minister considers
whether implementing a threat abatement plan would be the most feasible, effective and efficient
way to abate the process. Not all key threatening processes have threat abatement plans.
Threat abatement plans establish a national framework to guide and coordinate Australia's
response to EPBC Act listed key threatening processes by identifying the research, management,
and any other actions necessary to reduce the impact of the listed key threatening process on
native species and ecological communities. Implementing the plan should assist the long term
survival in the wild of affected native species or ecological communities. Threat abatement plans
may have accompanying background documents which provide information on the biology,
distribution, impacts and current management practices relevant to the key threats.
The Minister invites comment on the proposed threat abatement plan before making or adopting a
threat abatement plan. Threat abatement plans are reviewed at least every five years.
There are currently 14 approved threat abatement plans being implemented across Australia. More
information about threat abatement plans is available on the department’s website at:
http://www.environment.gov.au/biodiversity/threatened/tap.html.
Frequently asked questions about key threatening processes and threat abatement plans:
1. Will listing a key threatening process interfere with state, regional or property management?
 Listing a key threatening process does not regulate or prevent actions undertaken by
the states, territories or individual property managers
 Key threatening processes do not trigger the EPBC Act (key threatening processes are
not matters of National Environmental Significance under the EPBC Act).
2. What are the consequences of listing a key threatening process?
 If the threatening process is listed, the Minister must ensure a threat abatement plan is
in force for the key threatening process if he thinks that a plan is a feasible, effective
and efficient way of abating the process.
3. What are the consequences of a threat abatement plan?
 Commonwealth agencies must comply with threat abatement plans and the
Commonwealth must implement them in Commonwealth areas. Threat abatement
plans are also relevant to various other matters under the EPBC Act and the Minister
cannot make decisions under the EPBC Act that are inconsistent with a threat
abatement plan.
4. What will the Australian Government do to abate the threat if listing the process does not trigger
the EPBC Act and no threat abatement plan is prepared?
 The listing of a key threatening process helps inform managers of the threat that the
process can pose to biodiversity and assists with identifying additional planning,
guidance and research and helps identify priorities among these.
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
Should the threatening process be listed as a key threatening process and there is a
decision not to have a threat abatement plan, it will be because a threat abatement plan
is not considered to be the most effective and efficient way to abate the process.
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Biodiversity decline and habitat degradation in the arid and semi-arid Australian
rangelands due to the proliferation, placement and management of artificial
watering points
Artificial watering points are any watering points that are not naturally occurring and are accessible
to wildlife in the landscape. These can include but are not limited to bores, bore drains, wells, piped
reticulation systems, troughs walk-in dams and storage tanks. Artificial watering points have been
mostly provided for domestic livestock to drink, particularly cattle and sheep. Artificial supplies of
water have now been provided over vast areas of arid and semi-arid Australia through the tapping
of various forms of underground water, the pooling of surface run-off water in tanks and dams, and
reticulation of water by pumping (Landsberg et al., 1997).
Biodiversity decline and habitat degradation due to the proliferation, placement and management
of artificial watering points are unlikely to pose a direct threat to native species and ecological
communities, but can be the cause of an increase and/or focal concentration of:
 Grazers:
- domestic livestock (increasing and concentrating grazing and trampling pressure relative
to locations without artificial watering points),
- feral animal grazing (increasing and concentrating grazing and trampling pressure relative
to locations without artificial watering points)
- native grazers (increasing the impacts of grazing relative to natural incidence relative to
locations without artificial watering points).
 Predators:
- native predators (increasing the incidence of predation relative to locations without
artificial watering points),
- feral predators (increasing the incidence of predation relative to locations without artificial
watering points).
 Supporting or providing for the increased spread of invasive species and associated impacts:
- providing for the establishment of satellite populations and staging points for invasion (e.g.
cane toads) relative to locations without artificial watering points.
 Competition / replacement:
- by native or non-native species.
The area for which this process is assessed is the arid and semi-arid Australian rangelands. There
is no single definition of rangelands and the Australian rangelands have no clearly defined
boundaries. They are based around climatic conditions and the boundaries therefore change as
conditions change. They typically include the low rainfall and variable climate arid and semi-arid
areas of Australia, and some seasonally high rainfall areas north of the Tropic of Capricorn and
cover approximately 80 per cent of Australia’s land area (DEWHA, 2010). The arid and semi-arid
rangelands are defined by the presence of desert vegetation and land forms as well as by low
rainfall. They are bound by median annual rainfalls of about 250 mm in the south but up to 800 mm
in the north and about 500 mm in the east (Williams and Calaby, 1985; CSIRO, 2011).
Increasing incidence and concentration of grazing by the proliferation, placement and
management of artificial watering points
History of proliferation, placement and management of artificial watering points
Bastin (2008) provides an overview of the change in availability of water in the rangelands from the
pre-1900s to the present.
Grazing leases were established over most of eastern Australia by the mid-1800s but were
focused on permanent and semi-permanent waters of major waterways, thus most grazing
pressure was based on associated riparian habitats (Landsberg et al., 1997). High stocking rates
and drought in South Australia during 1864–1869 killed much of the saltbush in South Australia
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and led to loss of 7–15 cm of top soil, as recorded by the 1867 Commission (Landsberg et al.,
1997).
The development of machinery that enabled excavation of dams, followed by the discovery of
artesian water in the 1880s, provided for the development of artificial watering points (Landsberg et
al., 1997) and the expansion of pastoral land into more arid areas. By the 1880s, the arid and
semi-arid lands of New South Wales and Queensland were considered to be under pastoral
settlement as well as much of South Australia. This was further extended by 1900, including into
much of the Northern Territory and Western Australia (Noble, 1998).
In the 1880s, artificial watering points were widely spread, but stocking rates around these were
much greater than would currently be considered sustainable. In New South Wales, stock peaked
at 19 million in the 1890s followed by a crash to 3.5 million in the drought of 1901–02. The New
South Wales Royal Commission of 1901 (Landsberg et al., 1997) recorded land degradation as
extensive.
By the 1950s, artificial water sources in the form of troughs, dams and bores had increased in
number (Landsberg et al., 1997; James et al., 1999) following favourable environmental and
economic conditions. The severe 1959–65 drought saw drought relief bores drilled under a subsidy
scheme. From the late 1970s, the national Brucellosis and Tuberculosis Eradication Campaign led
to more fencing to form smaller, more manageable paddocks with some additional water supplies
(Bastin and ACRIS, 2008). Property sizes were reduced and smaller flocks placed less stress on
more numerous individual watering points (Landsberg et al., 1997).
A comparison of watering points between about the time of the Second World War and the 1990s
showed, that for a test area examined in the Gascoyne-Murchison of Western Australia, the area of
land within 6 km of water increased from 66 per cent to 90 per cent. A general increase in watering
point density was found for all but one land type. The increase was most pronounced on highly
productive and fragile systems (Watson et al., 2006).
Today, artificial water sources are found at high densities throughout Australia’s grazing
rangelands, with an average distance between points of less than 10 km (James et al., 1999).
Since the 1940s there has been a further increase in stocking rates (Griffin and Friedel, 1985 cited
in Southgate, 1990).
The drilling of bores following the discovery in 1878 of the Great Artesian Basin has enabled large
areas of outback Australia to be opened up for grazing, as in most of these regions this provides
the only reliable year round source of water. There are currently about 3 400 artesian bores and
over 10 000 subartesian bores, which access the aquifers of the Great Artesian Basin. Although
many of the free-flowing artesian bores have been capped and piped, a number remain, with water
flowing out under pressure into open drains, many of which are tens of kilometres long. There were
about 22 000 kilometres of open bore drains originally dug in Queensland and 9 000 kilometres in
New South Wales (Centre for International Economics, 2003).
Grazing pressure exerted by domestic livestock (sheep and cattle), kangaroos and feral herbivores
(goats, donkeys, camels, rabbits etc) is a major driver of change in the rangelands (Bastin, 2011).
More recently, stock density has continued to increase in many northern pastoral bioregions,
presumed to be driven by continuing strong demand, up to 2009, for live-export cattle into southeast Asia. In contrast, regional livestock densities declined between 2004 and 2008 relative to
preceding years in much of the south eastern, southern and south western rangelands (Bastin,
2011).
Grazing impact and watering points
Artificial watering points provide a focus for grazing, and the changes in vegetation in response to
these watering points is reviewed by James et al. (1999). The widespread practice in northern
Australia of spreading water points is used to help reduce grazing pressure on some country by
encouraging cattle to use all the country more evenly. In practice, the number of cattle grazed
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usually increases, resulting in greater total grazing pressure (TSSC, 2012). The widespread
occurrence of artificial watering points have provided for virtually all areas to be subject to
significant levels of grazing, resulting in declining areas of refugia for grazing-sensitive species
(Fisher et al., 2004).
As grazing pressure increases around artificial watering points, landscape function declines
considerably, with a loss in vegetation cover, an increase in erosion, and a decrease in nutrient
cycling (Howes and McAlpine, 2008). Changes to ecological variables and grazing pressures have
been directly attributed to proximity to watering points. Variables include degree of defoliation, soil
compaction, soil cover (Andrew, 1988). Landsberg et al. (1999) documented major changes in
biodiversity at different distances from artificial watering points which included between 15–38 per
cent of species decreasing in response to the presence of artificial watering points, while others
increased or did not demonstrate any response. Most of the species that decreased were native
species, such as forbs, grasses and shrubs (Landsberg et al., 1999) and ground-dwelling and
granivorous birds. Artificial watering points have been identified as the key driver of grazing
impacts on biodiversity in the rangelands (Landsberg et al., 1999).
Density of artificial watering points is considered a surrogate indicator for grazing pressure by
Fisher et al. (2007). Distance from stock water points has been shown to be a useful indicator for
pressure on biodiversity in drier rangelands. A decrease over time in the total area of water-remote
land is likely to be an indicator of negative impact on grazing-sensitive biota (Bastin and ACRIS,
2008).
In a study of artificial watering points where domestic grazing had been excluded for more than 30
years, Montague-Drake (2004) found that where artificial watering points are closely spaced and
abundant, native grazers do not display water point related grazing, implying that any impacts in
vegetation and ground-dwelling vertebrates around open artificial watering points are due to
historical sheep-grazing.
The exact nature of the relationships between distance from water, grazing pressure and impacts
on biodiversity depends on a large number of factors, including the age of water points, types of
stock, stocking history, seasonal conditions, the distributions of different soil and land types within
paddocks, and the sensitivity of different biota (Bastin and ACRIS, 2008).
Grazing - Cattle and Sheep
The area of the rangelands has had a relatively light evolutionary history of grazing by large
herbivores (Landsberg et al., 2003). The transformation of the rangelands to a higher grazing
pressure through the introduction of sheep and cattle and the artificial watering points to sustain
and increase productivity, has been underway for around 150 years (Landsberg et al., 2003). In the
late 1800s average sheep numbers in the rangelands of New South Wales were nearly twice what
they are today (Caughley, 1976 cited in OEH, 2011).
The number of artificial watering points has been increasing since European settlement and the
rate of establishment has intensified in the last few decades (James et al., 1999). ‘In the arid and
semi-arid rangelands the geographical distribution of cattle and sheep and hence the impact of
their grazing activity, is mostly determined by the placement of artificial watering points’ (James et
al., 1999).
Relationship to watering points: Watering points are a focus for cattle activity in arid environments
but habit use by cattle is also influenced by dispersion of critical forage and shade resources of
woodland (Frank et al., 2012). Areas more than 15 km from a water source are considered to be
outside the normal grazing range for cattle, and cattle will generally move within a 4-10 km radius
of a water source (Landsberg et al., 1999). The main grazing impact occurs within a 10 km radius
(Landsberg et al., 1999). Areas more than 9 km from a water source are considered to be outside
the normal grazing range for sheep. The foraging range of sheep can be as little as 3 km from
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water in hot conditions (Landsberg et al., 1999) and the main grazing impact occurs within a 5 km
radius (Landsberg et al., 1999).
Grazing - Goats
Competition and land degradation by feral goats are listed as a key threatening process under the
Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). Similarly to other
grazing animals, unmanaged goats can affect native flora and fauna by 1) grazing on native
vegetation, thereby preventing regeneration; 2) by overgrazing, which causes soil erosion; 3) by
competing for food and shelter; 4) by introducing weeds through seeds carried in their dung; and 5)
by fouling waterholes (EA, 1999).
Rangeland goats, both managed and unmanaged, are found across approximately 2 million square
kilometres of Australia; in all states, the Australian Capital Territory and some offshore islands,
including a few islands of the Northern Territory (EA, 1999). The greatest numbers of rangeland
goats are found in the arid and semi-arid pastoral regions of Queensland, New South Wales, South
Australia and Western Australia, but the greatest densities occur in areas of higher rainfall (EA,
1999). Rangeland goats are absent from the mainland of the Northern Territory, but they are found
on a few offshore islands. In the late 1980s and early 1990s, several pockets of unmanaged goats
north and northeast of Alice Springs were eradicated. No known populations currently occur in the
southern region of the territory.
The estimated feral goat population in Australia has grown from 1.4 million in 1997 to 4.1 million in
2008. In 2010, there were an estimated 3.3 million feral goats in the rangelands. An increasing
proportion of the feral goat population occurs in New South Wales, comprising 70 per cent in 2010.
In 2011, there were an estimated 2.95 million feral goats in New South Wales (Bastin, 2012).
Relationship to watering points: The distribution of unmanaged goats is limited by several factors,
including the availability of water during dry times (EA, 1999). Thus artificial watering points are
likely to provide for further extension of the range of unmanaged goats than would occur without
artificial watering points. In the rangelands of New South Wales, feral goat distribution is closely
linked to artificial watering points such as tanks and bores and surveys have indicated that goat
activity was rare more than 4 km from water (Russell et al., 2011).
Grazing - Camels
Feral camels are recognised as causing broad landscape damage including damage to vegetation
through foraging behaviour and trampling, suppression of recruitment of some plant species,
selective browsing on rare and threatened flora, damage to wetlands through fouling trampling and
sedimentation, competition with native animals for food and shelter and loss of sequestered carbon
in vegetation (NRMMC, 2010). Edwards et al. (2008) provides detail of the environmental impact of
camels, including a list of species affected. Feral camels feed on more than 80 per cent of
available plant species and have serious impacts on vegetation at densities of greater than two
animals km2 (Dörges and Heucke, 1996 cited in Pavey, 2006).
The widespread establishment of feral camel populations can be attributed to the wholesale
abandonment of domestic camels during the 1920s and 1930s (NRMMC, 2010).
Feral camels are present in up to 50 per cent of Australia’s rangelands ecosystems, which includes
most of the arid regions of Western Australia, South Australia, the Northern Territory and parts of
Queensland (NRMMC, 2010). At 2010, it was estimated that there were over 1 million feral camels
in the rangelands and that the population is doubling every 8–10 years (NRMMC, 2010). The
magnitude of the negative impacts of feral camels will undoubtedly increase if the population is
allowed to continue to increase (Edwards et al., 2010).
Relationship to watering points: Feral camels need access to sources of water, which are more
likely to be widely dispersed in arid areas. Camels are observed to drink at intervals of two to eight
days in summer if water is available, but may go up to several months without drinking in winter in
central Australia (NRMMC, 2010). Most of central Australia reported below average rainfall during
2002–2006, and at the start of 2007 conditions were very dry in most parts of the region (Edwards
et al., 2008). There are reports of influxes of as many as tens of thousands of apparently starving
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and thirsty camels into pastoral leases and settlements in the ‘western deserts’ over the summer of
2006-2007 that caused damage to infrastructure and the depletion of stock water reserves
(Edwards et al., 2008). It is likely that these artificial watering points provide refuge for camels
during long periods of drought, providing for sustained (albeit depleted) populations.
Grazing - Rabbits
Competition and land degradation by feral rabbits are listed as a key threatening process under the
EPBC Act (DEWHA, 2008b). The European rabbit (Oryctolagus cuniculus) poses a threat to a
large number of native species for example, by grazing on native vegetation and thus preventing
regeneration, and by competing with native fauna for food and shelter. They also have indirect and
secondary effects, such as supporting populations of introduced cats and foxes, denuding
vegetation and thereby exposing fauna species to increased predation, and digging and browsing
leading to a loss of vegetation cover and consequent slope instability and soil erosion (DEWHA,
2008b).
Feral species such as unmanaged goats and rabbits may not normally be considered in
determining total stocking rates on an area, but their numbers, combined with domestic livestock
numbers, may exceed safe stocking rates. The impacts of feral species will be most pronounced
during drought, when animals compete for declining food and water resources. Studies in the
Broken Hill district by Tatnell and March (1991 cited in DEWHA, 2008a) showed that rabbits were
responsible for 5–50 per cent of the total grazing pressure. Mutze (1991 cited in DEWHA, 2008a)
estimated that the grazing pressure due to rabbits was seven times the average stocking rate for
his study site in South Australia. Studies indicate that rabbits alone are capable of preventing the
regeneration of a range of native trees and shrubs (DEWHA, 2008a).
Rabbits were released on the Australian mainland in the mid to late 1800s (DEWHA, 2008b). They
were widely distributed throughout Australia by 1935 and had reached their distribution limits as
early as 1910 (Southgate, 1990). Rabbits are now widely distributed in Tasmania, many offshore
islands, and across the Australian mainland except for the most northerly regions (DEWHA,
2008b). This includes much of the rangelands. Rabbits increased to plague proportions prior to the
release of the myxoma virus in 1950 (DEWHA, 2008a).
Relationship to watering points: While rabbit populations can survive only if there is access to free
water, succulent vegetation, shaded warrens or warrens in calcareous soils (Southgate, 1990)
rabbits, however, do not exhibit water point focused impacts (James et al., 1999).
Grazing - Kangaroos
Kangaroos–predominantly four species (red Macropus rufus, eastern grey Macropus giganteus,
western grey Macropus fuliginosus, and wallaroo/euro Macropus robustus)–are grazers that
contribute to the total grazing pressure in the rangelands and therefore contribute to overgrazing.
Within sheep rangelands, the provision of permanent artificial watering points mean that kangaroos
are now more likely to be limited by food than by water and this has had a profound effect on their
distribution as well as their abundance, with increases in numbers and/or distribution from precolonial times in red, eastern grey, western grey and wallaroo (OEH, 2011).
Relationship to watering points: James et al. (1999) suggest that kangaroos will regularly travel 20
km to water. Montague-Drake (2004) found that in Sturt National Park, where pastoral grazing has
been ceased for more than 30 years, all species of kangaroo used artificial watering points to drink,
but kangaroos did not exhibit grazing patterns related to water points, demonstrating no
concentration of grazing impacts around watering points. Instead, the study revealed that the
distribution of most kangaroos was related to their preference for areas proximate to major
drainage channels, which offer green herbage and shade.
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Increasing the abundance and spread of predators by the proliferation, placement and
management of artificial watering points
Predators – general
Predators include introduced species as well as native species. These may or may not directly rely
on water but provide a focal point for prey items, thereby potentially increasing prey availability and
therefore, at least locally, increase predator numbers.
Reliable sources of water and food associated with artificial water points may increase survival
rates of predators (both native and introduced) and an increase in artificial water availability across
arid areas may also enable introduced species, including predators, to expand their range into
previously water-remote areas (James et al., 1999; Davies et al., 2010).
Predators are known to be major users of artificial water points in arid environments (Brawata and
Neeman, 2011).
Foxes
Predation by the red fox Vulpes vulpes and the feral cat Felis catus has been identified as a
primary cause of dramatic declines in native fauna in many ecosystems and are well documented
(DEWHA, 2008c). Predation by feral cats and predation by the European red fox are listed as key
threatening processes under the EPBC Act.
Foxes were introduced to the mainland by settlers during the 19th century (DEWHA, 2008d) and
now occur widely across the Australian mainland except for the far north, and more recently has
spread to Tasmania (DEWHA, 2008d). Foxes have been observed to have some extreme
dispersal distances, one recorded in a straight-line of 300 km (DEWHA, 2008d).
Relationship to watering points: Foxes, do need to drink regularly in hot weather and populations
are probably greater and more widely distributed than would be possible without artificial watering
points (James et al., 1999).
Strategies that restrict the access of predators to water may reduce their abundance, distribution
and impact on native prey species, both in the long-term and by decreasing predation around
artificial water (Brawata and Neeman, 2011).
Feral cats
Feral cats may occupy a home range of 10 square kilometres, or larger if food is scarce (DEWHA,
2008c). While cats are known to have been brought into Australia by settlers in the 18th century,
and deliberately released during the 19th century to control rabbits and mice, cats may have
arrived with much earlier visitors to the continent (DEWHA, 2008c). The widespread distribution of
feral cats through the rangelands is thought to have preceded foxes and rabbits, and had occurred
prior to the 1900s (Southgate, 1990). Cats derive most of their water needs from live prey (James
et al., 1999) and the distribution of feral cats does not appear to be limited by artificial watering
points. However, cats do occur at higher concentrations around watering points and therefore
watering points increase the threat posed by cats. Feral cats were more likely to be found closer to
water where 1080 baiting was conducted and dingoes (and non-target foxes) were controlled
(Brawata and Neeman, 2011).
Dingos
Dingoes were found by Brawata and Neeman (2011) more likely to be near water than further
away and may therefore be advantaged by the increase in number and distribution of artificial
watering points.
Relationship to watering points: Dingos need to drink regularly in hot weather and populations are
probably greater and more widely distributed than would be possible without artificial watering
points (James et al., 1999). Predation on macropods by dingoes is often focussed around water
resources (Shepherd, 1981 cited in Brawata and Neeman, 2011). Carcasses of cattle and sheep
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around watering points during drought help maintain populations of dingos and foxes (James et al.,
1999).
Toads
Cane toads (Bufo marinus) provide numerous threats to native species as outlined in DSEWPaC
(2011). These include the direct threat from toads as carnivores of native species (e.g., groundnesting species such as rainbow bee-eaters Merops ornatus), but pose the additional threat of
poisoning native predators due to toxicity of cane toads (e.g., northern quolls Dasyurus hallucatus)
(DSEWPaC, 2011). Shine (2010) provides an overview, and the variability, of these impacts
among native fauna.
Cane toads were introduced to Australia in 1935 and have spread rapidly throughout Australia ever
since, including into areas that were thought to be marginal cane toad habitat (DSEWPaC, 2011)
including arid landscapes.
Relationship to watering points: The availability of water is a critical factor in the distribution of cane
toads, as desiccation is a factor for their survival and dispersal in arid environments (Tingley et al.,
2013). This potential constraint in the rangelands has been removed in many places by artificial
watering points (Tingley et al., 2013). These watering points are serving as important breeding
sites and dry-season refuges for toads and may allow for toads to establish satellite populations
that subsequently coalesce during the wet season (Tingley et al., 2013).
Tingley et al. (2013) demonstrate that artificial watering points will facilitate the spread of cane
toads through the Kimberley-Pilbara corridor and in the absence of these, toads will be unable to
colonise the Pilbara. Tingley et al. (2013) also show that a high density of artificial watering points
can allow a population of toads to spread through a landscape that would otherwise be unsuitable.
A biodiversity assessment of species in a pilot region in the rangelands (Gascoyne–Murchison of
WA) found that feral animals and grazing pressure are largely responsible for declines in
vertebrate species in the region, while for flora, grazing pressure, feral animals as well as exotic
weeds and changes in fire regimes are driving these trends (Watson et al., 2006; Legge et al.,
2011).
Examples of competition / replacement
The provision of additional available water by artificial watering points has made conditions more
suitable and provided for expansion in range and increase in numbers of species that would not
otherwise occur in these areas or in these numbers. These species may out-compete more arid
species for breeding habitat (e.g., princess parrots) and food resources. More water dependent
species may also partially or completely replace more arid zone species, for example, hybridisation
and genetic introgression of the black-eared minor (Manorina melanotis) by the yellow-throated
minor (Manorina flavigula).
In northern Australia, competition between cane toads with native species for food and shelter sites
is also likely and expected to be highest near permanent water bodies during the dry season
(DSEWPaC, 2011).
Biodiversity decline and habitat degradation in the arid and semi-arid Australian rangelands due to
the proliferation, placement and management of artificial watering points is not currently listed as a
threatening process by any state or territory government.
12
Consideration of eligibility for listing as a key threatening process
Section 188(4) of the EPBC Act states:
A threatening process is eligible to be treated as a key threatening process if:
a) it could cause a native species or an ecological community to become eligible for listing
in any category, other than conservation dependent; or
b) it could cause a listed threatened species or a listed threatened ecological community
to become eligible to be listed in another category representing a higher degree of
endangerment; or
c) it adversely affects 2 or more listed threatened species (other than conservation
dependent species) or 2 or more listed threatened ecological communities.
a)
Cause listing of a species or ecological community
Could the threatening process cause a native species or an ecological community to become
eligible for listing in any category, other than conservation dependent?
Evidence:
The impacts of invasive cane toad invasions on some species, at least initially after invasion, has
been well documented (Shine, 2010). Cane toads could cause native species to become eligible
for listing as threatened soon after invasion, particularly in areas where species are endemic, or in
areas where the species retains high population numbers relative to the rest of their range.
Species that are endemic to, or have the last strongholds of populations in the Pilbara region of
Western Australia, where cane toads have not yet, but are predicted to invade, are likely
candidates in meeting this criterion.
Varanus bushi (Bush’s varanid)
Tingley et al. (2013) demonstrate that artificial watering points will facilitate the spread of cane
toads through the Kimberley-Pilbara corridor and enable the colonisation of the Pilbara.
Varanids are particularly susceptible to lethal toxin ingestion by cane toads. While no native
species is known to have become extinct as a result of cane toads, populations of varanids show
dramatic declines after cane toad invasions, at least initially. Examples include V. mertensi at
Manton Dam south of Darwin with dramatic change in site occupancy including local site
extinctions; 77–92 per cent decline for V. panoptes in the Adelaide River floodplain in the Northern
Territory (Griffiths and MacKay, 2007; Ujvari and Madsen, 2009; Shine, 2010). Varanus panoptes
and V. mertensi are listed as vulnerable in the Northern Territory primarily as a result of population
declines (estimated at >30 per cent) attributed to cane toad invasion.
Varanus bushi (Bush’s varanid) is restricted to the Pilbara region in Western Australia where it is
associated with mulga woodland and is at least partially arboreal (Aplin et al., 2006). There is no
information available on the estimated population size of this species. Like other varanids, it is
highly susceptible to population declines as a result of ingestion of cane toads. Having a more
limited distribution than either V. mertensi and V. panoptes, the relative impact to V. bushi of
invasion of cane toads following invasion into the Pilbara is likely to be more significant than to a
more widely distributed species. Varanus bushi is highly likely to suffer population declines as a
result of future invasion of the cane toad into this area which is predicted to be facilitated by the
proliferation, placement and management of artificial watering points, and could cause this species
to become eligible for listing as vulnerable.
13
Acanthophis wellsi (Pilbara death adder)
Like varanids, snakes are very susceptible to lethal toxin ingestion by cane toads and snake
populations have shown dramatic declines after cane toad invasions, at least initially. . Snakes
capable of ingesting toads are more susceptible (Phillips et al., 2003; Phillips and Shine, 2004;
Phillips and Shine, 2005; Phillips and Shine, 2006a, b). Individuals of the Acanthophis hawkei
(plains death adder) have been known to die in large numbers when cane toads arrive in an area
(Hagman et al., 2008, 2009; Phillips et al., 2010). Like other death adders, Acanthophis wellsi
(Pilbara death adder), is susceptible to cane toads. Like Bush’s varanid, the Pilbara death adder is
restricted to the Pilbara region with populations in widely scattered localities throughout the Pilbara
(Aplin and Donnellin, 1999). Significant decline in numbers of individuals of the Pilbara death adder
are likely should colonisation of the Pilbara by cane toads occur, facilitated by artificial watering
points. Given the species’ limited range to the Pilbara, the relative impact of invasion by cane toads
to this region could cause this species to become eligible for listing as vulnerable.
Demansia rufescens (rufous whipsnake)
The diet of eastern Australian whipsnakes is lizards, especially skinks and the genus Demansia,
like other Australian elapids, feed mainly or exclusively on vertebrate prey (Shine, 1980).
Morphological, behavioural and ecological similarities among whipsnakes are interpreted to be
adaptations to chase and capture fast moving diurnal prey items, especially lizards (Shine, 1980).
Demansia rufescens (rufous whipsnake), like the Pilbara death adder and Bush’s varanid, is limited
to the Pilbara region of Western Australia (Atlas of Living Australia, 2013). This species, if it is able
to consume cane toads, may be similarly susceptible to cane toad invasion into the Pilbara and
could cause this species to become eligible for listing as vulnerable.
Amytornis modestus subspecies (thick billed grasswrens)
Amytornis modestus (thick-billed grasswren) is currently listed as vulnerable under the EPBC Act.
Amytornis modestus has six subspecies: Amytornis modestus modestus, A. m. inexpectatus, A. m.
raglessi, A. m. curnamona, A. m. indulkanna, A. m. obscurior. Of these, thick billed grasswrens
inhabit chenopod shrublands, particularly those dominated by saltbush Atriplex spp. and bluebush
Maireana spp. and forage on the ground for berries, seeds and insects (Garnett, 2011).
Amytornis m. inexpectatus and A. m. obscurior occurred as endemic subspecies in New South
Wales. Both A. m. inexpectatus and A. m. obscurior have suffered significant declines that have
been attributed to heavy grazing of their shrubland habitat by domestic stock in the 1880s
(corresponding with extreme stock numbers relative to numbers of dams), and subsequent
droughts in the 1890s (McAllen, 1987 cited in Garnett et al., 2011). Neither subspecies is listed
separately from A. modestus under the EPBC Act, but Garnett (2011) provide information
indicating that A. m. inexpectatus could be listed under the EPBC Act as extinct and A. m.
obscuriour could be listed as critically endangered
Amytornis m. inexpectatus (thick-billed grasswren, central New South Wales) could be listed under
the EPBC Act as extinct and was last recorded in 1886. Its habitat was scrubs and clumps of a
shrub-like tree resembling the Barilla Atriplex cinerea (McAllan 1987 cited in Garnett et al., 2011).
The extinction has been attributed to destruction of habitat by livestock (Garnett et al., 2011).
Amytornis m. obscuriour (thick-billed grasswren, north-west New South Wales) could be listed as
critically endangered based on Criterion 4: the estimated total number of mature individuals of less
than 50; a population of up to 10 birds were seen in 2008–2010 (Black, 2011 cited in Garnett,
2011). The identified threats are overgrazing by sheep, cattle, feral goats, and rabbit in
combination with drought, and infrequent recruitment of food plants.
Amytornis m. modestus (thick-billed grasswren, MacDonnell Ranges) was last recorded in the
Northern Territory in 1936 and could be listed under the EPBC Act as extinct (Garnett et al., 2011)
with the most likely reason identified as overgrazing by cattle and rabbits in combination with
drought, having once been abundant on near watercourses or on alluvial planes – areas most
heavily grazed pre 1936 (Garnett et al., 2011).
14
Amytornis m. raglessi (thick-billed grasswren, Flinders Ranges) could be listed under the EPBC
Act as vulnerable under Criterion 2, with an extent of occurrence less than 20 000 km 2 and area of
extent less than 2 000 km2, less than 10 locations with plausible future threat, suspected
continuing decline in distribution, habitat quality, and number of locations. The identified threats are
overgrazing by sheep, cattle, feral goats, and rabbit in combination with drought, and infrequent
recruitment of food plants.
b)
Cause the uplisting of a species or ecological community
Could the threatening process cause a listed threatened species or a listed threatened ecological
community to become eligible to be listed in another category representing a higher degree of
endangerment?
Evidence:
Liasis olivaceus barroni (Pilbara olive python)
Liasis olivaceus barroni (Pilbara olive python) is currently listed under the EPBC Act as vulnerable.
The species is restricted to the Pilbara region in Western Australia.
Snakes are very susceptible to lethal toxin ingestion by cane toads. While no native species is
known to have become extinct as a result of cane toads, populations of snakes show dramatic
declines after cane toad invasions, at least initially. Snakes with larger heads (such as the Pilbara
olive python), and capable of ingesting toads are more susceptible (Phillips et al., 2003; Phillips
and Shine, 2004; Phillips and Shine, 2005; Phillips and Shine, 2006a,b).
Tingley et al. (2013) demonstrate that artificial watering points will facilitate the spread of cane
toads through the Kimberley-Pilbara corridor and enable the colonisation of the Pilbara.
There is no information available on the estimated population size of the Pilbara olive python. Like
many other pythons, it is highly susceptible to population declines as a result of ingestion of cane
toads. The relative impact to the Pilbara olive python of invasion of cane toads following invasion
into the Pilbara is likely to be more significant, having a distribution limited to this region, than to a
more widely distributed species. The Pilbara olive python is highly likely to suffer population
declines as a result of future invasion of the cane toad into this area which is predicted to be
facilitated by the proliferation, placement and management of artificial watering points, and could
cause this species to become eligible for uplisting from vulnerable to endangered.
Amytornis barbatus barbatus (grey grasswren)
Amytornis barbatus barbatus (grey grasswren) is currently listed as vulnerable under the EPBC
Act. Grey grasswren feed on seeds and insects in Atriplex nummularia (old man saltbush) and
Halosarcia spp (samphire) and nest in lignum and swamp canegrass.
When listed as vulnerable in 2005, the species was listed based on Criterion 2; with a restricted
and precarious (extreme fluctuations and highly fragmented) geographic distribution. The process
is likely to cause this species to become eligible for listing in the endangered category, which
represents a high degree of endangerment.
Garnett et al. (2011) identify the grey grasswren as having:
 extent of occurrence less than 5 000 km2
 area of occupancy less than 500 km2
 fewer than five locations
 plausible future threat
 inferred continuing decline in extent, habitat quality and number of individuals
These make the species eligible for listing as endangered based on Criterion 2.
The current threat to the grey grasswren (Bulloo) is loss and degradation of habitat through grazing
and trampling by livestock (cattle) and feral animals, such as rabbits, pigs, goats and horses
15
(TSSC, 2008). This threat is identified (Garnett et al., 2011) as being to nesting habitat (e.g.,
lignum and swamp canegrass) which is expected to be around natural watering points, but is also
likely to include feeding habitat areas of saltbush and samphire. While natural watering for cattle is
provided by the Bulloo River and associated wetlands, the river is frequently dry, but the area is
provided with artificial watering from the Great Artesian Basin, with bore drilling having begun in
the region in the 1890s (e.g., Thargomindah) (Heritage Australia, 2013).
Additional threats linked to the proliferation, placement and management of artificial watering
points of predation by feral carnivores and water extraction from the Bulloo River are also noted to
be significant potential threats.
c)
Adverse affect on listed threatened species or ecological communities
Does the threatening process adversely affect 2 or more listed threatened species (other than
conservation dependent species) or 2 or more listed threatened ecological communities?
Evidence:
Acanthophis hawkei (plains death adder)
Acanthophis hawkei (plains death adder) is currently listed as vulnerable under the EPBC Act. The
proliferation, placement and management of artificial watering points adversely affects the plains
death adder by providing for the survival and spread of cane toads.
The introduced cane toad presents the greatest threat to the plains death adder. The plains death
adder is an ambush forager and has a specialised foraging tactic of luring prey by waving the tip of
its tail. Native frogs make up a large proportion of the species’ diet (Webb et al., 2005). The cane
toad responds more strongly to this lure than native prey species and cane toads are more likely to
elicit luring from plains death adders than native prey (Hagman et al., 2008). The species does not
appear to have the ability to discriminate between cane toads and native frogs (Hagman et al.,
2008; 2009). The toxins in cane toads’ skin typically cause death in the plains death adder.
Individuals have been known to die in large numbers when cane toads arrive in an area (Hagman
et al., 2008, 2009; Phillips et al., 2010).
Cane toads are spreading across northern Australia at a rate of approximately 40–100 km per year
(Phillips et al., 2007, Urban et al., 2008), and it is predicted that by 2030 cane toads will have
encompassed almost all of the plains death adder’s range (Phillips et al., 2003). The Committee
considers that the plains death adder is likely to undergo a substantial reduction in numbers as a
result of the cane toad’s range expansion (TSSC, 2012).
The proliferation, placement and management of artificial watering points is further identified as
potentially adversely affecting the plains death adder (TSSC, 2012) due to the increase in total
grazing pressure, which reduces groundcover and areas that could act as refugia for this species.
Dasyurus hallucatus (northern quoll)
Dasyurus hallucatus (northern quoll) is currently listed as endangered under the EPBC Act. While
not the only threat to the northern quoll, death by ingestion of cane toad toxin is considered the
most immediate threat to northern quolls in the Northern Territory and Western Australia (Hill and
Ward, 2010). The threat of cane toads is predicted to be supported, particularly into the Kimberley
and Pilbara, by artificial watering points (Tingley et al., 2013).
In Queensland, some populations of northern quolls have persisted following colonisation by cane
toads, individuals appear to either avoid eating can toads or have adapted mechanisms to cope
with the toxin. Northern quolls occur across the Top End of the Northern Territory including
offshore islands, but populations are currently declining as cane toads spread. In Western Australia
the northern quoll has been recorded from many areas in the Kimberley and several areas in the
Pilbara and offshore islands (Hill and Ward, 2010).
16
Other threats to the northern quoll are thought to include inappropriate grazing regimes and fox
predation, which may be assisted by the proliferation and placement of artificial watering points.
Macrotis lagotis (greater bilby)
Macrotis lagotis (greater bilby) is currently listed as vulnerable under the EPBC Act.
Predation by the introduced European red fox, feral cat and dingo/wild dog is considered to be a
major threat to the greater bilby (Pavey, 2006). The national recovery plan for the greater bilby
(Pavey, 2006) notes that the impacts of predation may be increased by pastoral activity, mining
and other development though provision of access to water, as well as increasing the opportunity
for movement and scavenging by predators.
The proliferation, placement and management of artificial watering points adversely affect the
greater bilby by increasing total grazing pressure. Pavey (2006) notes the degradation of this
species’ habitat by introduced herbivores that have been exacerbated by the provision of waterpoints that increase the grazing range of livestock. Pavey (2006) notes that in the Northern
Territory, the camel population is doubling in size approximately every eight years (Edwards et al.
2004; cited in Pavey, 2006). The environmental impacts of camels in arid Australia are not well
understood, but their large size (up to 1 000 kg), consumption of a range of plant species, and
preference for dune systems, indicates that the species may impact significantly on bilby habitat
(Pavey, 2006). Feral camels feed on more than 80 per cent of available plant species and they
have serious impacts on vegetation at densities of greater than two animals per km2 (Dörges and
Heucke, 1996; cited in Pavey, 2006). Populations already occur at this density and above over
much of the species’ range in the Northern Territory (Pavey, 2006).
Manorina melanotis (black-eared minor)
The provision of additional available water by artificial watering points has made conditions more
suitable and provided an expanded range for the native Manorina flavigula (yellow-throated minor).
This expansion is impacting on the EPBC Act endangered Manorina melanotis (black-eared
minor), which is suffering hybridisation and genetic introgression by the yellow-throated minor as
well as loss of preferred habitat as a result of increased grazing pressures (NSW Scientific
Committee, 2008, Garnett et al., 2011).
Polytelis alexandrae (princess parrot)
Records in some regions of Polytelis alexandrae (princess parrot) have become less frequent
since the 1950s. The princess parrot is currently listed as vulnerable under the EPBC Act. Its
numbers may be as low as 1 000 mature individuals in poor years (Garnett et al., 2012). Garnett et
al. (2012) note that increased availability of water in areas grazed by domestic stock may have
allowed other, more water-dependent parrots to expand into the arid zone and compete with
princess parrots.
Notomys fuscus (dusky hopping mouse)
Notomys fuscus (dusky hopping mouse) listed as vulnerable under the EPBC Act. It is an arid zone
native mouse that eats seed, green plants and some insects and small lizards. The species does
not need to drink water (Dickman, 1993). The habitat of the dusky hopping mouse shows evidence
of historical overgrazing, including sheet erosion, scalding and the presence of vegetation known
to flourish in overgrazed areas (Moseby et al., 1999). Predation by the feral cat and the fox may
also pose a significant threat (NSW Scientific Committee, 2003).
Pseudomys australis (plains rat)
Pseudomys australis (plains rat) is an arid zone species listed as vulnerable under the EPBC Act.
Historically, this species occupied a wider variety of habitats including sand ridges and dense
grasslands (Brandle et al., 1999).The plains rat has had a significant reduction in total distribution
since European colonisation and this species has not been recorded east of Lake Eyre since 1975
(Brandle et al., 1999). It is likely to be susceptible to habitat degradation (Pavey and Cole, 2012)
and trampling and over grazing by rabbits and cattle is of particular concern. Foxes and feral cats
may also threaten populations by increasing the speed of declines during the bust phase of
population cycles (Pavey and Cole, 2012) and may have contributed to its contraction in range.
17
Brandle et al, (1999) note that most core habitat occurs in areas well away from areas of stock
concentration such as watering points and floodplains, however, the current pastoral practice of
piping water across previously unwatered country may alter this balance.
Considerations for a Threat Abatement Plan
A number of the threats identified as being amplified by the proliferation and placement of artificial
watering points are already identified as key threatening processes:
http://www.environment.gov.au/cgi-bin/sprat/public/publicgetkeythreats.pl
These are:
 Competition and land degradation by rabbits
 Competition and land degradation by unmanaged goats
 Novel biota and their impact on biodiversity (this key threatening process includes all potential
invasive species
 Predation by European red fox
 Predation by feral cats
 The biological effects, including lethal toxic ingestion, caused by cane toads (Bufo marinus).
Some of these threats have threat abatement plans to guide and coordinate Australia's response
to the impacts, or national action plans that focus on addressing the negative impacts. These are
available at http://www.environment.gov.au/biodiversity/threatened/tap-approved.html
and are:






Threat Abatement Plan for Competition and Land Degradation by Rabbits
Threat Abatement Plan for Competition and Degradation by Unmanaged Goats
Threat Abatement Plan for Predation by European Red Fox
Threat Abatement Plan for Predation by Feral Cats
Threat Abatement Plan for the Biological Effects, Including Lethal Toxic Ingestion, Caused by
Cane Toads (Bufo marinus).
National Action Plan for Feral Camels
Efforts to cap artesian bores are being undertaken across the rangelands, providing more control
over the placement and management of artificial watering points (e.g., Watson et al., 2006). For
example, the Great Artesian Basin Sustainability Initiative (GABSI) (1999-2014) has accelerated
work on the repair of uncontrolled artesian bores and the replacement of open earthen bore drains
with piped reticulation systems through the Great Artesian Basin. Up to 30 June 2012 work funded
under the GABSI had achieved the capping of 600 bores and removal of over 18,000 km of open
bore drains. Whilst GABSI has the primary aim of restoring water pressure within the Basin, further
environmental benefits of replacing open bore drains with pipes have been to reduce the potential
for the spread of woody weeds and the removal of easily accessible open water sources which
previously benefited feral animal populations.
Actions for a threat abatement plan could include:
- identify further research into how artificial watering points can be closed or fenced so that
the water is not freely available e.g., Russell et al. (2011).
- further research into total grazing pressure.
- further research into grazing pressures on palatable/non-palatable species and whether
distance to water is impacting.
- how to humanely close a water point for both native and invasive species that might be
reliant on that source.
18
Collective list of questions – your views
1. What are your views on whether the threatening process is eligible for inclusion in the list of
key threatening processes, and what are the reasons supporting those views?
2. Is the information used to identify this process as a key threatening process accurate?
3. Can you provide any additional data or information relevant to the claim that this process is
having an adverse effect on species/ecological communities?
4. Can you suggest any other EPBC listed species or ecological communities that may be
adversely affected by this process? And can you provide the relevant data to support this
suggestion?
5. Can you suggest any other species or ecological communities that may become eligible for
listing under the EPBC Act as a result of this process? And can you provide the relevant data
to support this suggestion?
6. Can you suggest any other EPBC listed species or ecological communities that may become
eligible for listing at a higher level of endangerment as a result of this process? And can you
provide the relevant data to support this suggestion?
7. Can you provide additional data or information relevant to this assessment?
8. Have you been involved in developing this nomination?
9. Please provide advice on the feasibility, effectiveness or efficiency of having and implementing
a threat abatement plan to abate the process.
10. Please provide any advice on actions that could be included in a Threat Abatement Plan that
might reduce the impact of artificial watering points on biodiversity decline and grazing
pressure.
19
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