Ross was found guilty of murdering his girlfriend's daughter, Tanilla Warrick-Deaves, after weeks of abuse and was sentenced to a maximum jail term of 40 years with a non-parole period of 30 years in May 2014.

But defence barrister Chris Bruce, SC, told the NSW Court of Criminal Appeal on Tuesday that his client should have received a discount in his sentence due to the "ongoing fear of violence and intimidation" he would experience in prison as a result of his status as a child killer.

The court heard that Ross had been assaulted in prison, was constantly afraid, and claimed that "someone had a price on his head".

"It's highly unlikely he will get parole. That means there will be 40 years of this ongoing intimidation and violence, this continual hyper vigilance as I put it," Mr Bruce said.

"The reality is this will be ongoing, this won't cease ... in fact, if he does stay in jail, he will be 68 when this might cease."

Ross, who did not appear during the hearing, abused the child for weeks before her death in her Watanobbi home on the NSW Central Coast in August 2011, forcing her to run laps, whipping her with various implements and beating her.

The abuse culminated in Ross striking the child repeatedly, banging her head on a glass shower screen, holding her over the toilet and causing her to bash her head on a cupboard door.

She lay unconscious in a pram for two days until she stopped breathing.

Justice Clifton Hoeben told the appeal court that Ross' taunting of Tanilla with a belt to "show he could make her scream without even touching her" was one of the "most horrible" incidents he had read during his career.

Sally Dowling SC, for the Crown said the sentence length was a "reflection of the extreme objective seriousness" of the offence, which had fallen just short of warranting a life sentence.

Ms Dowling said Tanilla was tortured, and urged the three appeal judges to look at the autopsy photographs of her body.

"After inflicting those blows that ultimately caused her death, he left her sitting in the pram to die. At some point in time, he could have saved her and he didn't," she said.

Ms Dowling told the court that Ross, who has a job in prison, had regular contact with other people and access to education programs.

The judges have reserved their decision.

The former partner of Tanilla's father, Brooke Bowen, who was stepmother to the child, described Ross' appeal as "unbelievable" and said he should have been sentenced to life in prison.

"What about Tanilla? She was fearing for her life for weeks and he was bashing her. What help did she get?" Ms Bowen said over the phone after the appeal hearing.

"She couldn't even live to see three and he expects people to be lenient [to] him. No, there should be the death penalty in Australia for people like him."

Tanilla's mother Donna Deaves, who gave evidence against Ross during his trial, has been jailed for at least nine years for manslaughter.