Thank you for your letter of 15 October, address to me as Chair of the Western Australian Threatened Species Scientific Committee at the Department of Biodiversity, Conservation and Attractions. The Department forwarded your letter to me.
I did read the paper by Richard McLellan et al. when it was published. I can understand your concern.
The Western Australian TSSC reviews nominations that have been submitted to them for the listing of flora as threatened flora under the WA Biodiversity Conservation Act 2016, in accordance with the provisions of the Act and Ministerial Guidelines. Members of the community may submit nominations at any time, following the Ministerial Guidelines, and using the nomination form available on the Department of Biodiversity, Conservations and Attractions (DBCA) web page, dpaw.wa.gov.au/plants-and-animals/threatened-species-and-communities/118-nominations.
As well as the list of threatened species, the WA priority flora list is a non-statutory list maintained by DBCA. Recommendations for addition to the priority flora list may be submitted to DBCA at any time, to [email protected]. Additions to the priority flora list do not require a nomination form. Priority list recommendations are not required to be submitted to or to be reviewed by the TSSC, although TSSC may make recommendations to DBCA on priority listings and DBCA may request TSSC advice on priority listings. Having a plant on the priority flora list does ensure that it is considered when environmental impact and other decisions are made, although that level of protection is not as high as threatened listing.
I am advised that a nomination for the listing of Australian Sandalwood (Santalum spicatum) as a threatened flora species has not been received, nor has a recommendation been received for addition to the priority flora list.
As the species occurs in WA and South Australia, the assessment of a nomination must also follow the requirements for cross-jurisdictional assessments under the Intergovernmental memorandum of understanding - Agreement on a common assessment method for listing of threatened species and threatened ecological communities, awe.gov.au/environment/biodiversity/threatened/cam. While WA TSSC may review a nomination for a species that occurs both in WA and in anther jurisdiction, and can recommend listing to the state Minister, it is sometimes simpler to nominate such a species to the Commonwealth TSSC; however, you should note that they have priorities set by their Minister, and a nomination may not be considered for some time if it does not fit the current priorities.
If a nomination of species that occurs both in WA and outside WA is received by DBCA, it will be considered by the WA TSSC and after the state Minister makes a decision whether or not to list, it is then referred to the Commonwealth. Except for emergency nominations, WATSSC typically meets once a year and its recommendations go to the state Minister within a reasonably short time.
I suggest that your best course of action would be to, in the immediate future, recommend sandalwood to the WA Flora Priority List and then fill in a threatened species nomination form so that the TSSC may consider recommending listing.
Dr Andrew A Burbidge AO
Chair WA TSSC
9 November 2021