Environment Protection and Biodiversity Conservation (Recovery Plan for the Greater Bilby Macrotis lagotis) Instrument 2023

The plan organises around a limited set of key, recurrent concepts whose definitions and operational usage shape implementation.

• Recovery plan as planning instrument and authority. The plan is expressly made under s 269A(3) EPBC Act (2.1C) and so functions as the statutory recovery plan for the species. Its stated purpose follows the EPBC recovery‑plan objective: “to halt the decline and to support the recovery of species listed as threatened so that its chances of long‑term survival in nature are maximised” (3.1). The instrument thus serves both as a statement of Commonwealth policy and as an input into conservation decision‑making by recovery partners and consent authorities (see 7).

• Objectives and performance criteria. Four objectives for 2030 (4.1) provide measurable performance criteria: population growth (performance criterion 1), maintained or increased area of occupancy / extent of occurrence (performance criteria 2a & 2b), genetic diversity maintained (3), and increased Indigenous engagement (4). The plan requires an “index of abundance” from a sample of sites to test population growth and identifies sample sites for measuring occupancy (1c-1d, 6.3.1).

• On‑ground vs supporting strategies. The plan separates direct, site‑facing biological interventions (on‑ground strategies: predator management, habitat management, metapopulation management) from supporting strategies that enable and coordinate on‑ground work (research strategy, recovery governance, monitoring & information management, Traditional Owner research & management) (6; 6.1). That structure allocates operational risk and responsibilities across actors.

• Metapopulation management. The plan treats the Greater Bilby as a single genetic management unit to be managed as a metapopulation (3.8; 6.3.6). It prescribes a three‑tier system,captive management, fenced‑wild management, and wild management,and requires a single adaptive metapopulation management plan to guide founder collection, genetic movement, supplementation, and reintroductions (3.7; 6.3.6, actions 6a-6d).

• Bilby site and habitat critical to survival. “Bilby site” is defined functionally as the geographic area within which populations may range over generations, and includes fenced wild populations and translocated populations (Box 3; 3.6). Habitat critical to survival is deliberately treated as a continuum and is provisionally defined by modelled/current distribution and any area where bilbies are found or may colonise or be reintroduced (3.10). The plan expressly notes that detailed habitat definitions at a bioregional scale were unavailable at drafting (3.10).

• Two‑way science and Indigenous engagement. The plan embeds “two‑way science” (reciprocal exchange between Indigenous and western science) as a design principle (2.2; Box 1) and places emphasis on Indigenous leadership, ranger participation and cultural knowledge transfer (numerous actions in 6.3.2). The document records that more than 70% of remnant wild bilby distribution occurs on Indigenous‑managed land and frames Indigenous engagement as central to feasibility (2.1 Summary; 3.2).

• Adaptive management & monitoring emphasis. The plan is structured as adaptive management: it calls for standardised, repeatable monitoring, sample sites for performance metrics, research linked to management, and regular review of the plan (1c-1g; 6.3.1; 6.3.7; 6.3.3 actions 3c-3d).

• Threats as interacting system. The plan repeatedly frames threats as interacting (predators, fire regimes, grazing, fragmentation, invasive plants and climate change), and emphasises that threat prevalence and intensity vary geographically. Management therefore is intended to be locally tailored and integrated (5 introduction; 5.1-5.8; 6.3.4-6.3.5).

These concepts determine how the plan allocates decision‑making, what data will be treated as authoritative, and what types of actions are prioritised. For example, the metapopulation concept directs resource allocation to captive, fenced and wild populations as complementary pieces. The “bilby site” construct enlarges the spatial scope of any assessment, and the plan’s insistence on Indigenous engagement makes local participation a practical precondition for many actions (see 6.3.2).

The plan identifies a broad, cross‑sectoral set of affected and interested parties, and describes their expected roles and potential impacts.

• Indigenous people, Traditional Owners and Indigenous ranger groups. The plan repeatedly notes that “more than 70%” of remnant wild bilby distribution occurs on Indigenous‑managed lands and stresses that Traditional Owners and rangers are central to monitoring, fire management, predator control and cultural knowledge transfer (Summary; 2.1; 3.2; 6.3.2). Table 11 lists many specific ranger groups and IPAs. Actions are tailored around building Indigenous capacity (2a-2f), facilitating Indigenous leadership in the recovery team (3a), and embedding two‑way science (Box 1).

• Commonwealth, state and territory conservation agencies. These agencies are partners in governance, monitoring, research and on‑ground actions (Table 10; 6.3.3). The recovery team includes DCCEEW and state agencies (3.4), and the plan anticipates that governments will be involved in evaluating performance and in resourcing actions (4.1; 6.3.3).

• Landholders, pastoralists and other private land managers. The plan identifies pastoral leases, private lands, travelling stock routes and unallocated Crown land among tenures where habitat occurs (3.10). It sets out actions requiring engagement with pastoralists (5.2; 5.3; 5.6; 5.7), including advice to landholders on grazing and water point management (5e; 5p-5q), trials to reduce grazing intensity (5o), and a recommendation to reduce water point density to 1970s levels by 2025 where relevant (5m).

• Mining, infrastructure and development proponents. The plan notes that roads, rail, mines, pipelines and other industrial infrastructure may threaten bilbies through habitat loss, barrier effects and elevated predator densities (5.3). It expressly anticipates potential economic impacts where approvals to remove or modify habitat may be refused or conditioned by consent authorities “as a result of this plan” (section 7).

• Conservation NGOs, zoos, and private conservation organisations. The plan lists numerous conservation partners (Table 10), NGO partners (AWC, BHA, WWF, Save the Bilby Fund), and ZAA zoos engaged in captive breeding and translocations (3.7.1; 6.3.6). These partners are identified as implementers of captive breeding, fenced‑wild management and reintroductions (6.3.6).

• Researchers and universities. The plan contains a research strategy and identifies a science subcommittee, research priorities and ethical requirements for research on Indigenous lands (6.3.7; 7d; reference to AIATSIS guidelines). Universities and researchers are named as partners in research and monitoring actions (Tables 1, 4, 6, 7, 9).

• Local communities, tourism operators and wildlife interest groups. The plan recognises social benefits and roles for education and community engagement (section 7; actions 2a and 2c), and includes provisions for outreach, youth and school engagement.

Who pays and who decides. The plan repeatedly emphasises that the plan does not itself allocate funding; actions are conditional on resources and partner willingness (6.2; 6.3 notes). Decision‑making is to be exercised through the recovery team and its subcommittees, in collaboration with Indigenous subcommittee and local land managers (6.3.3). Consent authorities remain the decision‑makers for development approvals, with this plan intended to inform those assessments (7). Practically, implementation costs are expected to be borne by a mix of state/territory agencies, Indigenous ranger programmes, NGOs, zoos and, where applicable, private landholders; the plan does not fix a funding source (6.2).

Concentrated vs diffuse impacts. The plan identifies concentrated benefits and responsibilities for specific groups: Indigenous rangers and local land managers are concentrated beneficiaries/providers of on‑ground delivery (6.3.2), while the cost of changed development approvals or livestock management is likely to be concentrated at station level but diffuse at industry level (section 7). The plan therefore redistributes implementation burden towards those organisations and communities most engaged in on‑ground delivery, while leaving national prioritisation and funding allocation unresolved.

The instrument sets out expectations, roles and processes rather than civil or criminal duties attached to specific persons. The legal mechanics and practical obligations in the document are best read as obligations of process, guidance and coordination.

• Statutory provenance and plan obligations. The plan is made under s 269A(3) EPBC Act (2.1C). It therefore functions as the statutory recovery plan for the species and provides the Commonwealth’s statement of the research and management actions believed necessary to stop decline and support recovery (3.1; Summary). The plan requires the recovery team to establish governance arrangements, to provide annual reporting and to review the plan at five and ten years (6.3.3, actions 3a-3d).

• Duties of the recovery team. The recovery team is charged with coordinating the implementation of recovery actions, establishing subcommittees (Indigenous, Science, Metapopulation), developing monitoring and reporting systems, and overseeing performance measurement against the stated criteria (3.4; 6.3.1; 6.3.3). These are organisational duties; the plan provides an expectation that the recovery team will carry them out.

• Partner roles and voluntary commitments. The plan lists partners against each action and clarifies that inclusion indicates an intention to consider implementing the action provided adequate resources and capacity exist (6.3, note). The plan therefore creates expectations and a coordination architecture, not binding obligations on listed partners.

• Monitoring and data obligations. The plan tasks partners with developing and publishing monitoring and survey protocols, identifying sample sites for performance measurement, standardising repeatable methods across the range, collating and reporting monitoring data and investigating a national database or map (6.3.1, actions 1c-1g). Where partners accept these actions, they will take on practical data‑collection and data‑sharing obligations; action 4d explicitly mentions arrangements for data sharing and intellectual property management.

• Rights and protections for Indigenous knowledge. The plan requires research on Indigenous lands to follow AIATSIS ethical guidelines (6.3.7) and explicitly values two‑way science and Traditional Owner leadership (2.2; Box 1; 6.3.2). This creates an expectation that Indigenous interests will be respected in research, monitoring and management, and provides a normative framework for engagement.

• Interaction with approvals and consent authorities. The plan itself does not impose direct property rights changes, but it anticipates that it will be taken into account by consent authorities and may therefore influence decision‑making under other statutory regimes (section 7). Affected persons engaged in development proposals may therefore face conditions or modifications requested by consent authorities that take the plan into account.

Notably absent from the instrument are explicit enforcement powers, civil penalties or criminal sanctions arising directly from the plan text. The document therefore creates procedural and programmatic obligations for the recovery team and sets expectations for partners; actual binding regulatory constraints on third parties remain the province of approval processes and other statutory instruments rather than the recovery plan itself (see Penalties and enforcement, below).

The Recovery Plan document contains no provisions that create penalties, sanctions or criminal offences within its text. There are four points from the plan that define the enforcement landscape:

1. No internal penalty regime. The instrument and the recovery plan do not specify fines, compliance notices or enforcement mechanisms against named actors for failure to implement enumerated actions. The plan frames implementation as dependent on partners’ capacity and resources and expressly declines to assign binding obligations to listed partners (6.2; 6.3 note on partners).

2. Indirect regulatory effect through consent authorities. The plan records that economic impacts may arise where persons requiring approval to remove or modify bilby habitat are prevented or required to modify proposals “as a result of this plan” (section 7). This signals that the plan is intended to be a material consideration for decision makers (consent authorities) under environmental approvals and permitting frameworks. The enforcement consequence is therefore indirect: consent authorities exercising statutory powers under other environmental laws or planning instruments may condition or refuse approvals, which is a regulatory constraint with legally enforceable consequences in those other regimes.

3. Monitoring, reporting and review obligations. The recovery team is to provide annual reporting on progress against recovery actions and to review the plan at 5 and 10 years (6.3.3 actions 3c-3d). Failure by the recovery team to report or review would be a failure of administrative process rather than an offence; the plan does not provide for sanctions.

4. Interaction with other statutory threat‑abatement provisions. The plan refers to key threatening processes and other threat abatement advice (for example buffel grass, fire regimes) (5, references). Enforcement measures to abate specific threats are the subject of other statutory instruments and programs; the plan itself does not create separate enforcement powers.

Practical enforcement risks and uncertainties derive from this design:

• Implementation depends on voluntary cooperation and resource allocation rather than centrally imposed sanctions. That reduces the plan’s coercive bite and exposes conservation outcomes to funding and political cycles (6.2; 6.3).

• Where development approvals are influenced by the plan, enforcement of habitat protection will pivot on the consent authorities’ exercise of existing statutory powers; developers will face legally binding conditions or refusals under those instruments, not under the recovery plan itself (section 7).

• Data sharing and intellectual‑property arrangements are to be established (4d), and their enforceability will depend on bilateral or multilateral agreements, not on the recovery plan text.

In summary, the instrument sets out obligations of coordination, monitoring and planning, but attaches no standalone penalty or compliance regime; enforcement arises through other statutory approvals and through partner agreements and funding arrangements rather than through the plan instrument itself.

The recovery plan positions itself in the legal and regulatory landscape as a statutory recovery plan under the EPBC Act (2.1C), but its substantive interaction with other laws is mediated through guidance, evidence and consent processes rather than by direct prescriptive regulation.

• Foundation in the EPBC Act. The instrument is adopted under subsection 269A(3) EPBC Act (2.1C). That statutory provenance gives the plan a formal status within Commonwealth endangered species governance. The plan’s stated purpose mirrors the EPBC Act recovery plan purpose (3.1).

• Influence on approvals and consent decisions. Section 7 explicitly recognises that consent authorities may prevent or require modifications to proposals to remove or modify bilby habitat “as a result of this plan.” That indicates the plan is intended to be a material document in environmental assessments or approvals under other laws (for example environmental protection, planning and development approval regimes), though the plan itself does not create the approval powers. The legal effect therefore is indirect: the plan supplies evidence and management guidance that other regulatory decision‑makers can and are likely to rely on when determining whether proposed developments would compromise bilby habitat or recovery objectives.

• Overlap with state/territory conservation statuses and instruments. The plan summarises the species’ conservation listing in Commonwealth and state laws (3.3 table): bilby is listed as vulnerable under the EPBC Act, but status varies across state statutes (for example extinct in NSW, endangered in Qld). The plan will therefore interface with state and territory statutory frameworks for biodiversity, land use and tenure, and with agencies listed as partners (3.3; Table 10). Actions taken pursuant to the plan on state land or under state regulatory regimes will need to comply with the applicable state legislation.

• Tenure and land management laws. The plan repeatedly notes that bilby habitat occurs across many tenures , Indigenous lands, private land, pastoral leasehold, national parks, travelling stock routes (3.10) , so interactions with land‑tenure, native title, pastoral lease regulation and IPA/Indigenous land management schemes are expected. The plan does not change tenure rights but anticipates negotiation and stewardship activities where habitat occurs on private or leased lands (5.3; 5k-5p).

• Research and Indigenous rights. Research on Indigenous‑managed land is to be consistent with AIATSIS ethical guidelines and two‑way science (6.3.7; Box 1). This creates an expectation that research projects will meet recognised ethical standards and Indigenous consultation frameworks; such standards often align with state and Commonwealth requirements for research with Indigenous peoples.

• Threat abatement and other Commonwealth instruments. The plan references existing threat abatement advice (e.g. for buffel grass, fire regimes) and situates its actions in relation to those processes (5.5; references). Implementation of measures to abate these threats may involve coordination with other Commonwealth programs and state threat‑abatement measures where statutory powers and funding streams exist.

• Data, intellectual property and privacy arrangements. The plan proposes data sharing, the potential development of a national database/map, and arrangements for intellectual property management (4d; 6.3.1). Any data sharing would need to comply with applicable IP, privacy and Indigenous knowledge protocols and with agreements negotiated between partners.

Mechanically, then, the plan functions as a Commonwealth planning instrument that will be used as authoritative guidance by decision‑makers under other statutory regimes. It does not amend, override or create rights under other statutes, but it creates a structured body of evidence, protocols and performance metrics that other laws and consent processes will consider. Practical interaction thus depends on the extent to which consent authorities, state agencies, landholders and developers incorporate the plan into approvals, land management plans and contractual arrangements.

The instrument itself includes limited explicit amendment history in the text provided:

• Adoption and replacement. The instrument notes that it replaces the recovery plan titled “National Recovery Plan for the Greater Bilby Macrotis lagotis” adopted under the EPBC Act - section 269A - Instrument Adopting Recovery Plans (dated 09/05/2007) (note to 2.1B). The 2023 instrument thereby supersedes the prior 2007 recovery plan.

• Date and signatories. The instrument is dated 5 April 2023 for the Commonwealth Minister (Tanya Plibersek) and contains dates and signatures (or dates) for relevant state and territory ministers and representatives: Western Australia (Reece Whitby, dated 23 March 2023), Queensland (Meaghan Scanlon, dated 13 March 2023), Northern Territory (Lauren Moss, dated 16 March 2023), New South Wales (Penelope Sharpe, dated 4 April 2023), and South Australia (Susan Close, dated 16 March 2023). Those dates evidence multi‑jurisdictional support and the collaborative nature of the instrument.

• Commencement. The instrument commences the day after registration (2.1B), which is the standard commencement mechanic for such instruments. No subsequent amendments or revisions are recorded within the text provided.

• Planned review cycle. The plan itself mandates internal reviews at five and ten years after making (6.3.3, action 3d). Those procedural reviews create a formal timetable for future amendments or replacement: the recovery team and relevant government agencies are to participate in those reviews.

• Dynamic updates to implementation maps and partner lists. The plan anticipates that site maps and partner lists will be revised during the life of the plan to reflect new information (6.3). These are programme‑level updates rather than instrument amendments; the text explicitly treats the lists and maps as living elements that the recovery team may revise.

There is no record in the instrument text of interim amendments between adoption and the present, nor are there transitional provisions describing how existing arrangements under the 2007 plan would be managed. The 2023 plan therefore appears to be a full replacement, with its own internal governance processes intended to generate future amendments and operational updates through review and recovery‑team processes.

The recovery plan document itself contains no reference to litigation, legal challenges or case law concerning the instrument, its content or its implementation. The text does not name any judicial decisions, and no litigation history is provided in the instrument.

Accordingly, within the source material supplied:

• There are no named judicial proceedings or administrative appeals arising from adoption of the plan referenced in the document.
• The plan does not cite cases or legal interpretations of s 269A or related provisions of the EPBC Act.
• There is no record of challenges to the earlier 2007 plan contained in this instrument.

Because the instrument is an administrative policy instrument adopted under the EPBC Act, any litigation relating to its application (for example, by developers, landholders, or conservation groups challenging approvals influenced by the plan) would be pursued under the laws and judicial processes separate from the recovery plan itself. The document does not provide information on such matters; practitioners seeking litigation precedent should base analysis on EPBC Act case law and administrative decisions external to this plan.

This section flags specific operational, legal and strategic pitfalls that the plan itself discloses or makes likely. Each point is grounded in the plan text.

1. No prioritisation, no costing. The plan deliberately does not prioritise actions and does not provide costs (6.2). That leaves implementation dependent on external funding decisions and partner discretion. Practically, projects may be commissioned without a national prioritisation framework, causing potential inefficiencies or duplicated effort. The plan’s insistence on local adaptation (6.2) increases flexibility but also raises coordination and allocation risks.

2. Reliance on voluntary partners and resourcing. The plan lists partners against actions but clarifies that listing indicates interest conditional on resources and capacity (6.3 note). The legal effect is therefore non‑binding: listed partners are not compelled by the plan to act. Conservation outcomes are therefore reliant on voluntary cooperation and funding streams, which introduces execution risk.

3. Data gaps and standardisation challenges. The plan requires standardised monitoring and the publication of monitoring protocols (1e-1f), and explores a national database (1g). But it acknowledges site‑by‑site variability in methods and the difficulty of producing comparable data (6.3.1). In practice, data heterogeneity, intellectual‑property or Indigenous knowledge protections, and uneven monitoring capacity will complicate national aggregation and performance evaluation.

4. Intellectual‑property and data sharing friction. Action 4d requires arrangements for data sharing and intellectual property management. The plan does not prescribe the legal or contractual form of such arrangements, leaving open issues of ownership, access rights and Indigenous data sovereignty. If not handled carefully, disputes over data rights could delay research and monitoring.

5. Indigenous engagement is essential but not guaranteed. The plan elevates two‑way science and Indigenous leadership (Box 1; 6.3.2). However, it also acknowledges that many Indigenous groups were not involved in plan drafting and that partner lists are incomplete (2.2; 6.3). Meaningful engagement requires resourcing, trust‑building and governance arrangements,processes that are time‑consuming and that carry reputational and legal risk if mishandled.

6. Uncertain effect on approvals and property rights. The plan signals that consent authorities may act “as a result of this plan” (section 7). For developers and land users this creates regulatory uncertainty: the plan is not prescriptive about thresholds or precise habitat delineations (3.10 emphasises interim and modelled habitat descriptions). Developers may face ad hoc or case‑by‑case conditions, increasing transaction costs and project uncertainty.

7. Complexity of predator management and counterintuitive ecological interactions. The plan recognises complex predator interactions (dingoes, feral cats, foxes), the potential for positive effects of dingoes, and the context‑dependent nature of predator control (3.5.1; 5.1-5.2; 6.3.4 actions 4m). Predator control that fails to account for these interactions can produce perverse outcomes. The plan instructs adaptive monitoring but leaves much experimental design and threshold setting to recovery partners (4h).

8. Reintroduction risks and evolutionary naivety. The plan documents limited understanding of long‑term effects of restricting bilbies’ dispersal and the risks that fenced or captive populations may lose antipredator behaviours (3.7; 3.7.1; 5.1). Reintroductions from predator‑free enclosures have previously failed without sustained predator control (3.7). Implementers must therefore manage genetic and behavioural adaptation risks.

9. Broad spatial scope, unclear habitat thresholds. The plan’s habitat critical to survival definition is intentionally broad and provisional (3.10). That produces ambiguity about which precise areas will be treated as “critical” for approvals, land use and management. Practitioners must therefore combine plan guidance with local survey data to reduce uncertainty (Table 1 actions).

10. Governance fragmentation risk. The plan proposes multiple subcommittees and a recovery coordinator (3a-3b). Without committed funding and clear accountability lines, there is a risk of governance fragmentation and duplication across Commonwealth, state, NGO and Indigenous partners.

11. Dependence on long‑term monitoring funding. Performance metrics and adaptive management require sustained monitoring. The plan sets reporting and review expectations but does not identify sustained funding mechanisms. Funding uncertainty poses a risk to achieving the 2030 objectives and to the integrity of metapopulation management (6.3.1; 6.3.6).

12. Climate change and emergent threats. The plan acknowledges climate change uncertainties (3.11) but does not translate specific climate‑adaptation funding or regulatory responses into the recovery actions. Climate‑driven range shifts or altered fire regimes could render some site‑level investments less effective.

These “gotchas” are not speculative,they are consequences of choices explicitly made in the plan (flexibility, local adaptation, non‑binding partner lists, no costing) together with the ecological uncertainties the plan documents (predator dynamics, genetic risks, climate change). Practitioners should therefore anticipate the need for negotiation, contractual clarity, secure funding and staged, monitored trials when implementing the plan’s actions.

Compliance with the plan means different things for different actors because the instrument creates expectations, governance requirements and recommended actions rather than prescriptive legal duties. Below are concrete steps, tied to the plan text, tailored to typical stakeholders: recovery teams and government agencies; Indigenous ranger groups and Traditional Owners; land managers, pastoralists and developers; zoos, conservation NGOs and researchers.

For the recovery team and government conservation agencies (Commonwealth, state, territory)

• Establish governance and accountability arrangements called for in the plan. Implement action 3a: create the Indigenous subcommittee, science subcommittee and metapopulation subcommittee and appoint a recovery coordinator (6.3.3, actions 3a-3b). Ensure terms of reference clarify decision‑making, funding responsibilities and reporting lines.

• Produce the annual reporting and review deliverables. Commit to action 3c (annual reporting on progress against recovery actions) and to the 5‑ and 10‑year plan reviews (3d). Use these reviews to amend priorities, resolve funding gaps and update maps and partner lists (6.3.3; 6.2).

• Deliver standardised monitoring protocols and identify sample sites. Implement actions 1c-1g (6.3.1): define sample sites for performance measurement within 12 months, publish monitoring protocols, and begin collation of data. Ensure protocols state measurable metrics for Performance Criteria 1-3 at section 4.1.

• Secure funding and define responsibilities. Because costs are not specified (6.2), the recovery team should prepare a prioritised implementation budget, allocate responsibilities among partners, and pursue Commonwealth, state and philanthropic funding to avoid the plan remaining aspirational.

• Create data‑sharing and IP frameworks. Implement action 4d: establish legal agreements covering data sharing, intellectual property and Indigenous data sovereignty. Ensure arrangements comply with AIATSIS guidance for Indigenous research (6.3.7) and with privacy/IP law.

For Indigenous ranger groups and Traditional Owners

• Engage with the recovery team and seek representation. Use the Indigenous subcommittee process (3a; 6.3.2) to secure leadership roles and influence metapopulation decisions. Seek capacity funding tied to agreed actions (2a-2f).

• Develop site‑level action plans. For each actively managed site, prepare a spatially explicit, plain‑language annual or multi‑year action plan as per action 2d (6.3.2). Link those plans to monitoring protocols (1e-1f) and to Traditional Owner knowledge and two‑way science (Box 1).

• Participate in monitoring and capacity building. Use the Bilby Blitz and other programmes (1b, 2f) to access training, standardised methods and data‑management support.

For pastoralists, private land managers and developers

• Treat the plan as an authoritative source in project planning and environmental assessments. Because the plan is expected to be considered by consent authorities (section 7), incorporate the plan’s habitat mapping (3.10; Figure 2), monitoring protocols and mitigation guidance (5g) into project impact assessments early.

• Commission surveys aligned with plan protocols. Where works may affect bilby habitat, support or commission surveys using the published monitoring/survey protocols (1e-1f) and submit survey data to the recovery team or national map/database when arrangements permit (1g; 4d).

• Engage in best practice mitigation and stewardship. Consider voluntary stewardship payments or water‑point reductions where these are viable options, as the plan suggests investigating stewardship payments to reduce water points (5m). Liaise with recovery team and state conservation agencies before modifying grazing or water infrastructure (5k-5q).

For zoos, captive‑breeding programs and conservation NGOs

• Coordinate genetic and translocation activities around the metapopulation plan. Implement actions 6a-6d: participate in a single adaptive metapopulation management plan and develop captive‑management plans in line with the metapopulation objectives (6.3.6).

• Maintain documentation and share genetic/resource movement records. Ensure movement of genetic resources, founder collection and release records are tracked and shared under agreed IP/data arrangements (4d; 6.3.6).

For researchers and universities

• Follow the AIATSIS Guidelines and promote two‑way science. Research on Indigenous land must follow ethical research principles and reciprocity (6.3.7). Design projects to support recovery priorities identified in the plan (7d) and coordinate with the recovery team’s science subcommittee.

• Orient studies to management needs. The plan emphasises applied questions (predator thresholds, fire regime effects, habitat connectivity). Prioritise research that feeds directly into adaptive management (Tables 4-9) and commit to sharing data under agreed terms.

For consent authorities and planners

• Use the plan as an evidentiary input. When assessing proposals affecting bilby habitat, consider the plan’s habitat critical to survival (3.10), sample sites, monitoring protocols and recommended mitigation measures (5g; 5i) and require remedial/mitigation actions consistent with the plan where appropriate.

• Condition approvals to require monitoring and adaptive management. Where development is permitted, condition consents to require monitoring using plan protocols, reporting to the recovery team, and adaptive mitigation if population or occupancy metrics decline.

Operational and contractual steps

• Negotiate Memoranda of Understanding (MoUs) and funding agreements that reflect the plan’s non‑binding partner list but create enforceable commitments for specific actions, monitoring, and data sharing.

• Specify thresholds and triggers in contracts. Where predator control or reintroductions are to be funded, specify the tolerable predator occupancy thresholds, monitoring frequency, and trigger points for management action (action 4h).

• Build in governance review clauses. Given the plan’s five‑ and ten‑year review cycle (3d), include clause mechanisms that allow programme partners to adapt funding allocations and modify operational designs in response to the recovery team’s reviews.

Practical compliance checklist (short)

• Recovery team: establish subcommittees, appoint coordinator, publish monitoring protocols, identify sample sites, set data‑sharing arrangements, and develop metapopulation and captive management plans (6.3.1; 6.3.3; 6.3.6).
• Indigenous groups: develop site action plans, participate in subcommittees, and secure training and resourcing for monitoring and on‑ground actions (2d; 2f).
• Developers/pastoralists: commission plan‑aligned surveys, engage early with consent authorities, and negotiate mitigation or stewardship actions if habitat is present (3.10; 5g; 5m).
• Researchers: adhere to AIATSIS and two‑way science, coordinate with science subcommittee, and prioritise management‑relevant studies (6.3.7).

All of the above steps rest on the plan’s premise that implementation is an iterative, partnership‑driven process and that formal legal compulsion is the domain of other instruments. Consequently, compliance in practice will be operationalised through agreements, funding instruments, planning approvals and robust governance rather than through penalties embedded in the recovery plan itself.