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SUBMISSION 213
RECEIVED 26/09/2016
23 September 2016
The Executive Officer,
Environment, Natural Resources and Regional Development Committee,
Parliament House,
Spring Street,
EAST MELBOURNE VIC 3002
By Email: [email protected]
Dear Sir/Madam
Animals Australia Submission to the Inquiry into the Control of Invasive Animals on Crown Land
Animals Australia is a peak animal welfare organisation that represents some 40 animal welfare
organisations and many thousands of individual supporters. On their behalf we appreciate this
opportunity to provide input to the Inquiry, and thank the Committee for the extension of time granted to
us to make our submission.
We accept that in some cases ‘invasive’ animals may pose risks to native fauna, flora and/or
ecosystems. However, these risks need to be assessed in context with other ongoing human
development risks including habitat clearing and disruption from roads, housing, mining and agriculture.
The control of invasive species must be part of an overall strategy that is humane, based on peerreviewed scientific evidence, and meets community expectations.
As such, Animals Australia strongly opposes recreational hunting on scientific, welfare and ethical
grounds. Recreational hunting poses significant unacceptable risks to target and non-target animals, as
well as to people and the environment. Importantly, there is a dearth of peer-reviewed evidence that
recreational hunting is effective in controlling invasive pest numbers or restoring native flora, fauna and
ecosystems; indeed available assessments indicate such methods are not effective. We are, therefore,
concerned by the presumptive nature of the proposal and inquiry currently before the Committee:
‘… into the benefits of Parks Victoria and other agencies such as the Game Management Authority’s
use of community hunting organisations and individuals in the control of invasive animals on Crown
land including but not limited to the following:
1 assessment of the biodiversity outcomes, community safety and limitations of the trial conducted by
Parks Victoria on control of deer populations in a national park;
2 consideration of the application of these types of programs for other invasive animal species in
partnership with Crown land managers;
3 assessment of the relative costs and benefits, financial or otherwise, of other forms of pest control in
national parks’.
Mr Kieran Crowe, Administration Officer to the Committee, clarified on 12 September 2016 that for the
purposes of this Inquiry ‘invasive animals’ were introduced species (also known as feral or exotic pest
animals), and that Crown land referred to National Parks, State Parks and State Game Reserves.
About one-third of Victoria is Crown Land (Victorian Department of Environment, Land, Water and
Planning, 2014). While this would not all be National Parks, State Parks and State Game Reserves, it
needs to be acknowledged that the proposal before the Committee has vast ramifications given the size
of the land area in question, the number of animal and plant species that would be affected by
recreational hunting, and the impacts on people who use National and State Parks for non-hunting
recreation.
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1.Assessment of the biodiversity outcomes, community safety and limitations of the trial
conducted by Parks Victoria on control of deer populations in a national park
It is difficult to comment specifically on this proposal when the results to date of the trial are
unfortunately unavailable to stakeholders. A Parks Victoria (2015) media release ‘Deer control trial for
a healthier Alpine National Park’ appears to relate to the trial referred to in the current terms of
reference. The release stated:
‘Parks Victoria, in partnership with the Sporting Shooters Association of Australia (SSAA) and the
Australian Deer Association (ADA), have begun a three year trial deer control program to limit
environmental damage deer are causing in the Alpine National Park. This trial is the first of its kind
in the park and will investigate the effectiveness of ground shooting as a method for controlling deer
to reduce their impact on the environment.
Acting Chief Executive for Parks Victoria Chris Rose said rangers have observed a marked increase
in Sambar deer activity in the park and their detrimental effects on the park’s flora and fauna are
becoming more obvious.
“In the past decade, we’ve seen evidence suggesting an expansion of deer populations within the
Alpine National Park and increasing damage to vegetation and waterways, particularly at higher
elevations. Although exact numbers are unknown, we can safely say the deer population in the park
is now in the thousands.
“Deer are degrading fragile environments, such as the alpine peatlands, through grazing, trampling
and wallowing, which is of great concern,” said Mr Rose.
Alpine peatlands are boggy wetlands which occur at the headwaters of waterways in the Alps. They
play an important role in maintaining the healthy functioning of water catchments in the Alps and
provide critical habitat for a number of important native plants and animals.
“This trial control program is a positive step towards preserving the headwaters of many of Victoria’s
major rivers and protecting critical habitats for native species in the park, including the endangered
Alpine Water Skink,” he said.
Rhys Coote, Pest Management Coordinator from SSAA VIC said “This first operation with
volunteers from the SSAA VIC and ADA involved 12 hunters and four Parks Victoria staff. A lot of
planning was done to ensure a safe and effective hunt which resulted in four deer being shot on the
day across an approximate 400 hectare area of the park.”
ADA Deer Management Committee Chair, Steve Garlick said: “Our focus was to ensure the
operation was conducted safely, ethically and responsibly and that the planning, logistics and
communication procedures were right. Considering the conditions were less than optimal for
hunting, and the weather was extremely cold and blustery, successfully targeting four deer was a
good result. ADA is pleased with the initial results and we look forward to further collaboration with
Parks Victoria on this program.”
Key elements of the three year trial:

Control operations are proposed to occur at scheduled intervals throughout the year,
depending on weather conditions.

The trial involves a detailed scientific monitoring program to assess its effectiveness in reducing
deer numbers and impacts on areas of high environmental value, including alpine peatlands.

The current focus of the trial is on the Bogong High Plains with a plan to expand the project into
the Howitt and Wellington Plains in the southern area of the Alpine National Park in 2015/16.

Highly skilled, accredited and authorised volunteer members of the Australian Deer Association
and the Sporting Shooters Association of Australia are conducting the deer control under strict
conditions, consistent with animal welfare standards, and in the interests of public safety.
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
Deer removal operations are being conducted away from areas of high visitation and during
periods of low visitation with no park closures planned at this stage.
The trial is funded by Parks Victoria and the Australian Government’s National Landcare
Programme (via the North East, West Gippsland and East Gippsland Catchment Management
Authorities).
“I’d like to remind people that recreational deer hunting is not permitted on the Bogong High Plains
and this is a strictly controlled park management activity. We’re really pleased to be working with
the SSAA and ADA members involved in this important program,” said Mr Rose.
Parks Victoria’s partnership with the Sporting Shooters Association of Australia and the Australian
Deer Association is helping to reduce the impacts of invasive animals in a number of parks across
the state. This includes Dandenong Ranges National Park where 100 deer were culled as part of
last year’s deer control program. Subsequently, there are positive signs of environmental recovery
and revegetation in areas that have previously been damaged by deer activity’.
It is increasingly recognised that policy and legislation regarding human interactions with, or use of,
animals needs to be based on scientific evidence that is peer-reviewed and published, is humane, and
meets community expectations. We have concerns that the results to date from this publicly funded
trial do not appear to be available to stakeholders. Further, the media release makes broad statements
about deer numbers, impacts from deer on the park and its flora and fauna, and responses to shooting
so far. Such statements need to be evidence-based, rather than anecdotal. Further, our understanding
is that a scientific trial requires Animal Ethics Committee approval and be undertaken under a scientific
licence. We seek your confirmation on this point and request details of the approved AEC application
to allow us a greater appreciation of the conduct, oversight and planned assessment of this trial.
In particular, we seek further information on the assessment of the shooting skills and accreditation of
the volunteer shooters, and details of the ‘strict conditions, consistent with animal welfare standards,
and in the interests of public safety’ under which the deer control trial is being undertaken. At the very
least, this trial requires independent observers, preferably veterinarians, to accompany hunters to
assess the humaneness of kills and to ensure accurate data on injuries and deaths are collected.
Animals Australia is greatly concerned that Victoria continues to classify deer as game to be protected
as a ‘sustainable resource’. We agree with the Invasive Species Council (ISC) when it describes this
as ‘archaic and dysfunctional’ (ISC 2016). On the one hand, the Victorian Government claims deer are
a major threat to native flora, fauna and the environment and that the assistance of recreational
shooters is needed to control numbers, while on the other hand, as game, deer are effectively
conserved to provide a recreational shooting resource for hunters. Indeed, sambar deer are listed as a
‘threatening process’ under the Flora and Fauna Guarantee Act 1988 (Victorian Department of
Environment, Land, Water and Planning, 2012), while being protected under Wildlife Act 1975 as
‘game’. This creates a serious conflict of interest between the Government’s desire to earn ongoing
revenue (or political support) from the management of what is clearly an invasive species, and the
Government’s responsibility to conserve the native flora and fauna and ecosystems of Victoria.
Deer are listed as pests throughout Australia, except in Victoria, Tasmania, and New South Wales.
However, their protected status in NSW is currently being reviewed given their deleterious impacts
on the environment, national parks, farms, the economy, infrastructure and human life (deer have
caused several road fatalities in NSW) (ISC, 2016).
Animals Australia is reluctant to call any animals ‘pests’ as this is unfortunately seen by some
stakeholders as justification to demonise the animals and use whatever means is cheapest in often
vain, inhumane, and ad hoc attempts to control them. What is required are humane, long term
management strategies for animals, where peer-reviewed science indicates this is required to
protect native fauna, flora, and ecosystems, or when the welfare of the invasive species is
threatened (eg by starvation).
We are yet to see peer-reviewed evidence that recreational hunting or, indeed, any form of hunting,
has achieved the desired outcome of satisfactorily controlling an invasive species, including deer. We
note the ISC stated in its submission to the Inquiry that:
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‘…recreational hunting is generally not effective in feral animal control for the following reasons:
•
Feral animals are typically highly fecund (produce many offspring) and many populations are saturated
with a large ‘doomed surplus’ (that would normally die due to lack of resources), which enables them to
quickly replace animals killed by hunters;
•
Ground shooting, even using skilled shooters, is not an effective means of primary control for most feral
animals, and according to most government standards should only be used as part of coordinated
programs, usually as a supplement to other methods;
•
Most hunting is ad hoc with no specific environmental goals, planning or monitoring, and hunting effort is
usually dispersed;
•
Hunters often prefer to kill large trophy males, which makes little contribution to control because in
polygamous species such as deer, pigs and goats the remaining males can inseminate all the females;
Hunters are often motivated to maintain feral animal populations for future hunting, leaving young and
females (indeed Victoria’s system of game management is partly aimed at sustaining feral animal
populations as a game resource for hunters);
•
•
Hunters have highly variable skill levels (few skills tests are conducted for recreational hunting licensing in
Australia). As an example, in 2010-11, each hunting day for hunters licensed by the NSW Game Council
in NSW state forests resulted on average in only 0.7 feral animals killed- a very large investment of time
for a very low kill rate, falling well short of the skill level needed for effective feral animal control’.
Even government co-ordinated programs (let alone recreational hunting) have not been found to
significantly reduce invasive animal numbers or impact. A review of existing ‘pest’ animal control
programs in Australia (Reddiex et al 2004) assessed 1306 invasive animal population control
operations (foxes, wild dogs, feral cats, feral rabbits, feral pigs, and feral goats), mostly in NSW,
Victoria and Western Australia. The analysis concluded that:
‘The belief that pest animals have caused declines in native species (and damaged production
values) is reflected in legislation and has led to many attempts to control these pests. Many
agencies and organisations including Federal, State and Local governments commit significant
resources managing these species. However, there is limited hard evidence that this
management has led to a reduction in threats and to a reversal in the decline ‘[our emphasis].
Indeed, it is also known that the complex nature of ecosystems and the interactions of the various
fauna and flora species, and habitat change (including by climate change), make the impact of any
population control measures a similarly complex task. For example, a recent University of NSW study
showed that reducing the population of one important species, in this case dingoes in NSW, can lead
to further imbalance and negative impacts from other species that take over the vacated niche:
‘In the forests of southeastern Australia, where this study was undertaken, the control of dingo
populations is associated with the reorganization of mammal assemblages whereby relatively largebodied species, such as macropods and red foxes, and arboreal mammals benefit from dingo
control while small-bodied terrestrial mammal species decline in abundance’ (Colman et al 2014).
Hunted animals often suffer stress, pain or injury before being killed. Some are left wounded and die
slowly. Young, whose mothers have been injured or killed, may starve to death, and social groups
may be destabilised by the sudden death of key individuals. Non-target animals may also be
stressed, injured or killed.
Inexperienced hunters and those who are not highly skilled are likely to injure a larger proportion of
their prey. Further, recreational hunting, especially in National and State Parks, places visitors and
hunters at risk of injury or death. While we would expect that the small trial in question is being run
professionally, we have grave doubts that if recreational hunting is permitted in National and State
Parks that it would be possible for there to be effective oversight by authorities, especially in remote
areas. Our fears are highlighted by a recent hunting trip in the Northern Territory that led to a fire
engulfing a campsite and killing at least 6 dogs and destroying a number of vehicles (NT News 2016).
This is by no means an isolated event.
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An ABC Four Corners program in 2013, ‘The Hunting Party’, looked at recreational hunting in Victoria
and NSW (ABC Four Corners 2013). While it showcased ‘responsible’ hunters, some of these
expressed grave concerns about the experience, competence, and integrity of hunters and the
dangers they posed. Comments included: ‘Some people just fire at anything’; ‘They just do anything
to get a kill’, and ‘More hunters-more risk’. Farmers and other residents living on the edges of
National and State Parks reported near misses from high calibre fire arms, some with ranges of 5km;
and illegal hunting on their properties and in ‘no hunting’ areas.
Disturbingly, in 2014 the Head of the (then) NSW Game Council, Greg McFarland, and a veteran
Game Council volunteer, Edward Hoogenboom, were convicted of firearm and hunting offences (The
Sydney Morning Herald 2014a) after entering private land to hunt an animal without the consent of
the owner, and carrying firearms onto enclosed land. This begs the question that if the leaders of this
‘sport’ break the law, what do rank and file hunting enthusiasts do?
These convictions led to the 2014 Dunn inquiry by the NSW government into governance at the
Game Council, which saw its dissolution. Amongst other damning findings, the ‘independent review
found the council lacked any governance framework and did not possess the ''skills, tools and
resources to ensure effective compliance'' with its regulatory responsibility to ensure safe, ethical
hunting’ (The Sydney Morning Herald 2014a).
In rejecting a recent proposal for a 2-year trial of recreational hunting in Western Australian National
parks and other conservation reserves, the Environment Minister Albert Jacob said:
‘…the trial would not be conducted because the Government's number one priority was community
safety.
Much of the state's south-west is heavily visited and used by tourists and local residents, and their
safety in accessing these areas is paramount ...
Other reasons for this decision include effectiveness of pest animal control, animal welfare issues
and the significant resources required to establish and administer trials such as the one
recommended by the committee’ (ABC News, 2015).
A study commissioned by the then Game Council NSW using the National Coroners Information
System (NCIS) found that in Australia between 2000 and 2010:
‘Of … 1473 fatalities, 22 involved a Target Sport, with 13 of these deaths relating to an unintentional
shooting incident. An additional 12 fatalities involving an unintentional shooting event during a
leisure/hunting activity were identified where the activity had not been coded as occurring during a
‘Sport’’(Victorian Institute of Forensic Medicine 2010).
Appendix 1 of the report details ‘Shooting / Hunting Deaths’. The following is one typical example:
‘Case 5: VIC
The deceased was accidentally shot by a companion with a .22 caliber Winchester Magnum
Rimfire, lever action rifle. The deceased and three companions were spotlight shooting kangaroos.
Shortly after alighting from their vehicle and using the bonnet as a rest, one animal was wounded.
The deceased and the companion walked beside the
animal while trying to re-load. The companion was then asked to open a gate and while undertaking
this task, their firearm discharged, striking the deceased. Neither the deceased or the companion
were licensed’.
During the same 10-year period, the report showed 864 persons were killed in individual water based
sports. What the report didn’t provide were the numbers of people participating in shooting versus
water-based sports to put these results into context. Anecdotally, we believe many more Australians
are involved in water-based activities than hunting, and this is reflected in the NCIS data. Further,
these data do not provide the number of non fatal injuries from hunting /shooting accidents, the
number of near misses, the fear experienced by people whose lives are impacted by hunting (as
highlighted in the Four Corners program discussed above), or the dangers posed by having more
guns for non-essential purposes in the community (especially high powered ones).
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Critically, from Animals Australia’s perspective, there is no documentation available of the number of
target and non-target animals that have suffered pain, injury, or distress from shooting/hunting
activities. Whilst the difficulty in quantifying this is recognised, estimates should be possible and are
needed to allow proper consideration of recreational hunting, including by the community.
Our view is that the use of firearms, especially high-powered ones, in remote, vast and uncontrolled
regions, increases risks to animals and humans alike. Some National and State Parks abut farms
and homes, as highlighted in the Four Corners program discussed above, and in this situation,
hunting poses serious risks to community members. When these risks are measured against the
harm to target animals and the recognised ineffectiveness of any ‘pest’ reduction by recreational
hunting, the risk to human safety cannot be justified.
A person with a gun may also become frustrated if the ‘pest’ or ‘game’ species is not readily available
and may be tempted to shoot other native or protected animals. ‘Buck fever’, as it has been called, is
particularly concerning and has in the past led to documented human deaths and to the shooting of
protected species. The evidence can often also be seen on road signage or other public property
that have been shot at by hunters.
In Victoria, licensed recreational duck shooters in a pre-planned gathering on a remote property at
the opening weekend of the 2013 duck shooting season, shot in excess of 1,000 waterbirds including
rare protected species and left most of them in situ (The Age 2014). A ‘cone of silence’ by hunters
frustrated Police and Government investigators such that no charges were laid despite the frenzied
and illegal killings that occurred. There is little doubt that non-target animals are sometimes shot to
satisfy the needs of ‘recreational hunters’ when legal targets are either not available or in low
numbers.
Further, recreational hunters may often have motivations contrary to the goals of invasive animal
population control, and in fact have an incentive to maintain populations to ensure they have ongoing
hunting opportunities (for example, by moving on from a heavily hunted region, or leaving the young
or breeding females). It is also well documented that rogue hunters deposit the young or breeding
animals caught in one area into other habitats (Moriarty 2004; Spencer and Hampton 2005). This
‘seeding’ is designed to ensure future hunting opportunities in favoured locations, and is known to
occur with deer and pigs particularly. While it is illegal to translocate ‘pest’ species, this practice
occurs in remote areas with poor or no monitoring and is likely to continue unchecked if recreational
hunters are given legal access to such areas.
Contrary to claims by the hunting lobby, there is no peer-reviewed evidence to suggest that the ad
hoc hunting of invasive species by recreational shooters in any way effectively controls their numbers
or reduces impact. Many of the targeted animals have high fecundity and are usually able to quickly
fill any resource niche if others are removed. Wherever individuals are killed, and (given even local
eradication is rarely attempted and virtually never achieved), the remaining niches of those killed
animals are taken over by other individuals of the same species that would otherwise not have
survived because there were no niches available for them. It has been estimated that some 87% of
rabbits, 65% of foxes (Hone 1999) and over 40% of deer (Hone et al 2010) need to be killed each
year to achieve population reduction. Ground shooting of these species and others (including pigs
and goats) are not considered effective techniques to reduce populations (Australian Department of
the Environment and Water Resources 2007; Sharp 2013).
Additionally, because current practices generally involve lethal control, they select forever
increasingly control-resistant strains or wary, educated and adapted individuals of invasive animals.
Fox control bounties in Victoria in 2002/2003, for example, were ineffective in reducing populations
substantially, with less than a 4% reduction in numbers recorded (Fairbridge and Marks, 2005). One
hypothesis is that the naïve young foxes are killed, leaving the more cautious established breeding
pairs to survive and reproduce (Sharp 2013).
Other problems associated with recreational hunting/shooting, as seen in the Four Corners program
we referred to earlier, include the attraction of scavengers, such as wild dogs, cats, and foxes, to
carcases and body parts left behind my some hunters (eg as occurs with large animals in particularly
remote areas or where the animals are unlikely to be prized as trophies or meat, such as foxes).
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Also, the new paths and trails that may be formed through Crown land as hunting access is
increased, may push invasive animals into novel areas. Such movement by hunters and increased
corridors for animals may also facilitate the ingress of invasive weeds and pathogens, such as
‘dieback’ or ‘cinnamon fungus’ (Phytophthora cinnamomi) (Parks Victoria 2016).
Moreover, hunting for recreation, and the establishment of recreational hunting for commercial benefit
(including as a cost cutting strategy for Government), promotes the out-dated perception that
pursuing and killing animals for pleasure is an ethically acceptable past time. Increasingly, the
Australian community is concerned with the welfare of animals, including that of invasive and game
species. This is perhaps most recently demonstrated by the tourist backlash in response to the culling
of a thousand animals, including wallabies, possums and birds, on Hamilton Island in Queensland
(Seven News 2016). This was undertaken by authorities and included monitoring by a consultant
wildlife veterinarian. Imagine the disgust if recreational shooters had been permitted to undertake the
cull?
Animals Australia believes it would be an unwise and retrograde step for Victoria to allow recreational
hunting of deer (or any other species) in National and State Parks. We are totally opposed to the
extension of this trial.
Consideration of the application of these types of programs for other invasive animal species
in partnership with Crown land managers
The wording of this term of reference also requires clarification. By ‘these types of programs’ we
assume what is meant is recreational hunting using firearms in National and State Parks that would
target animals including feral pigs, wild dogs, cats, and foxes. However, we note with concern that the
2005 Code of Practice for the Welfare of Animals in Hunting (revision no. 1)[Hunting Code](Victorian
Department of Economic Development, Jobs, Transport and Resources 2016a), which is adopted
under the Prevention of Cruelty to Animals Act 1986 (POCTA), permits bow as well as firearm
hunting. This is despite peer-reviewed evidence that bow hunting is far less humane and effective
than an accurate gunshot (Gregory, 2005).
Under no circumstances does Animals Australia see any role for bow hunting, including of invasive
animals. The POCTA and Hunting Code urgently require amending to ban this cruel activity.
In duck, fox, pig, and deer hunting, dogs may be used to track, and/or retrieve the prey. While the
Hunting Code does not permit dogs to attack animals being hunted, there is strong anecdotal
evidence that this regularly occurs in pig hunting and that pig dogs often suffer extensive injuries as
well as the pigs. It also happens in the hunting of other species, as a recent cruelty prosecution
demonstrates (The Weekly Times 2016). Again, we strongly oppose the use of dogs in recreational
hunting.
As the greyhound racing ban in NSW (announced by Premier Baird in July 2016) has demonstrated,
activities that abuse animals, which may have been acceptable to the community in previous eras ,
eventually lose their ‘social licence’. Even in states that have not decided to ban greyhound racing,
there have been regulatory overhauls to ensure far greater oversight. In particular, the exposure of
live baiting was met with revulsion by the Australian community. At some point, the community will
ask if this is so different to recreational hunting, especially when dogs are used to attack and distress
quarry.
Again, it is difficult to comment specifically on this term of reference in the absence of further details
and a peer-reviewed evidence-base to assess the proposal. However, as provided in response to the
first term of reference above, we oppose recreational hunting as a means of controlling invasive
animals on animal welfare, human safety, environmental, and ethical grounds.
Assessment of the relative costs and benefits, financial or otherwise, of other forms of pest
control in national parks
Again, we seek clarification of what is meant by ‘other forms of pest control’ and, as with the two
previous terms of reference, we seek the evidence-base required for an informed consideration of
this proposal. For the purposes of this submission, we will assume that poisoning and trapping,
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which are generally not recognized as ‘hunting’ and do not appear in the Hunting Code, are also to be
considered, as well as hunting techniques allowed under the Hunting Code, such as dog-assisted
hunting, and hunting with horses and hounds.
Animals Australia vehemently opposes the use of inhumane poisons such as 1080 and strychnine. If
poisons must be used, they must be as humane as possible, such as PAPP (Pestsmart 2016), or the
animal rendered unconscious before the effects of the poison are felt. Despite the fact PAPP is now
available in Victoria for dog and fox control, there is no plan to phase out 1080, despite the relative
advantages of PAPP including: its relative humaneness (over 1080); that dogs, foxes, and cats are
the most susceptible animals; there is an antidote in cases of accidental poisoning; there is a low risk
of secondary toxicity, and there is high environmental safety. While ‘PAPP does present additional
risk to some native animals that are not affected by 1080… these risks can be managed’ (Pestsmart
2016).
While the POCTA prohibits the intentional poisoning of animals, there are exceptions made to permit
poisoning of invasive animals, including by 1080, under the Catchment and Land Protection Act
1994, the Wildlife Act 1975 and the Drugs, Poisons and Controlled Substances Act 1981. It is our
strong view that (as a minimum), the POCTA and related legislation must be amended to ensure that
only the most humane and effective poisons are used as part of strategic and integrated control
methods that are evidence-based. As such, we oppose the further use of 1080 in National or State
Parks.
Animals Australia is also highly opposed to trapping methods that cause animals pain and/or distress.
While the sale and use of all traps in Victoria is regulated under the POCTA and the Prevention of
Cruelty to Animals Regulations 2008 (Victorian Department of Economic Development, Jobs,
Transport and Resources 2016b), as is unfortunately the case with poisons, legislation that is
designed to protect animals from cruelty actually permits it when those animals are deemed to be
‘pests’. The Regulations allow traps including leg hold, confinement, net, non-kill snare, and kill traps
to be used.
Our abhorrence of the use of inhumane traps is supported by a report ‘Welfare Outcomes Of LegHold Trap Use In Victoria’ (Nocturnal Wildlife Research Pty Ltd 2008) that stated:
‘Potentially there may be a wide range of stressors associated with trapping, many of which are not
directly related to the trap mechanism. Startle, primary acute trauma and pain, restraint, handling,
noise, light, loss of cover, social and spatial dislocation, food, odour, water and thermal stressors
may act in various combinations to influence the degree to which animals resist traps and the
overall stress and welfare outcomes of trapping…
Secondary physical trauma (eg. ischemia, predation, insect attack etc), chronic pain, anxiety and
fear, self-mutilation, capture myopathy, exhaustion, impacts on young (loss of dependent young,
ejection of pouch young and abortion etc), starvation, dehydration, hypothermia, hyperthermia and
death are pathological endpoints of stress and the consequence of exposure to intense stressors or
a combination of stressors. Good welfare outcomes of trapping should seek to prevent or mitigate
such consequences…
The assessment of injuries using trauma scales to determine welfare is limited in its ability to
estimate the impact of many stressors and pathological outcomes of trapping. A key deficiency
associated with the use of trauma scoring in trap studies is that the amount of time that an animal
spends in captivity is rarely known with any accuracy’.
The Four Corner footage referred to earlier shows foxes and dingoes being caught using leg hold
traps as part of a professional ‘pest’ eradication service. While these traps are rubber-lined, it is
abundantly clear that the animals are highly distressed by the trapping process. More humane
methods are urgently needed.
As such, Animals Australia does not support any proposal that seeks to control invasive animals
using inhumane trapping methods in National or State Parks. There also appears to be little
evidence that trapping is an effective control tool for invasive species.
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Not surprisingly, Animals Australia strongly opposes the payment of bounties for the killing of
invasive species, primarily because these practices encourage the participation of inexperienced
and incompetent persons in the hunting/trapping of animals; provide a financial incentive that
encourages attempts to kill the animal when the chances of a ‘clean’ kill may be low, and may
inadvertently cause the ‘pest’ animal to be seen as a money-making resource that needs to be
‘conserved’, in much the same way that game animals are currently viewed.
Finally, there appears to be no evidence-base to support the idea that bounties are a successful
tool in the management of invasive species. The ISC in its submission to the Inquiry (ISC 2016)
was scathing in its assessment of bounties: ‘…the fox bounty in Victoria did not effectively reduce
the impacts of foxes as a pest species- rendering the public funds applied to the bounty scheme a
dead loss to the public purse’.
The Victorian bounty on foxes that was introduced in October 2011 offered a $10 per scalp payment
to recreational shooters and landowners. At the beginning of the scheme, the (then) Department of
Primary Industry estimated there were over 1 million foxes in Victoria (The Age 2011). By early 2014,
the then Agriculture Minister announced some 250,253 foxes scalps had been collected and said
‘The only good fox is a dead fox, and I am pleased the … successful initiative is helping farmers deal
with these vicious pests’ (The Weekly Times, 2014).
We know from scientific estimates that the annual rate of population renewal (potential growth) for
foxes is approximately 105%, and that at least 65% of foxes need to be removed annually to
effectively reduce the population (Hone 1999). The fact that this Victorian bounty scheme removed
only 10% of the fox population per year indicates that there will have been no significant impact on
fox numbers.
Given the Victorian bounty scheme cost $2.5M in bounties over this period, plus administration costs,
it was a futile and expensive exercise at best. It is a great shame that these public funds were not
used instead to research humane and effective invasive animal management and control.
For far too long the costs and benefits that are assessed as part of pest control strategies fail to
recognise the welfare imposts, including cruelty, to target animals. Given the huge role of humans in
the destruction of the environment by way of land clearing for roads, housing, mining and agriculture,
and by climate change, we find it extraordinary that pest animals are persecuted to a degree that is
yet to be demonstrated to be commensurate with their impacts or with any real outcomes on their
numbers or effects on native fauna, flora and ecosystems. A more humane, integrated and scientific
approach is urgently required. This will require humane research and legislative amendment to
ensure all animals are protected from cruelty.
Finally, Animals Australia is concerned with possible integrity issues associated with the recent
sacking of the chief executive officer of Parks Victoria, Bradley Fauteux, over allegations of
inappropriate conduct, which are now being investigated by the Independent Broad-based AntiCorruption Commission (IBAC). It was reported that ‘Chair of the Parks Victoria board Andrew Fairley
said the chief executive was sacked "as a result of unacceptable conduct in relation to integrity" which
breached its ethics policy and public sector code of conduct’ (ABC News 2016).
Until the nature of the integrity issues are known and the matter is determined by the IBAC, our view
is that Parks Victoria must not enter into any agreements with community hunting organisations and
individuals to facilitate the attempted control of invasive animals on Crown land.
Likewise, we share the concerns of the ISC (ISC 2016) that the Victorian Game Management
Authority has unmanageable conflicts of interests between its role to work ‘with the community as an
effective, independent regulator…’ and simultaneously as an ‘influential authority for game
management and quality hunting options in Victoria’ (Game Management Authority 2016). The ISC
stated in its Submission to this Inquiry that:
‘Indeed the GMA Act provides that Authority Members may actually have pecuniary interests in
game hunting or game management (so long as those interests are no greater than the interests of
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Seven News 2016. https://au.news.yahoo.com/a/32568986/youre-a-disgrace-hamilton-islandslammed-after-killing-1000-animals/#page1
Sharp T 2013. Model code of practice for the humane control of foxes. NSW Department of Primary
Industries http://www.pestsmart.org.au/wp-content/uploads/2013/01/FOX003 groundshooting web.pdf
Spencer PBS, Hampton JO. 2005. Illegal translocation and genetic structure of feral pigs in Western
Australia. Journal of Wildlife Management 69: 377-384.
The Age 2011 http://www.theage.com.au/victoria/sly-new-twist-on-the-fox-problem-201112211p5oh.html
The Age 2014 http://www.theage.com.au/victoria/duck-shoving-claimed-in-box-flat-bird-massacre20140315-34u1k.html
The Sydney Morning Herald 2014a http://www.smh.com.au/nsw/game-council-boss-convicted-onhunting-gun-charges-20140213-32nd9.html
The Sydney Morning Herald 2014b http://www.smh.com.au/nsw/game-council-to-be-abolished20130704-2pdte.html
The Weekly Times 2014 http://www.weeklytimesnow.com.au/news/national/victorian-governmentsfox-bounty-passes-250000-mark/story-fnkfnspy-1226858562874
The Weekly Times 2016
http://www.weeklytimesnow.com.au/news/national/numurkah-man-punished-for-using-dogs-to-takedown-deer/news-story/2a2b69a06a1b445fc9b849eae915e1b6
Victorian Department of Economic Development, Jobs, Transport and Resources 2016a
http://agriculture.vic.gov.au/agriculture/animal-health-and-welfare/animal-welfare/animal-welfarelegislation/victorian-codes-of-practice-for-animal-welfare/code-of-practice-for-the-welfare-of-animalsin-hunting-revision-no.-1
Victorian Department of Economic Development, Jobs, Transport and Resources 2016b
http://agriculture.vic.gov.au/agriculture/animal-health-and-welfare/animal-welfare/humane-vertebratepest-control
Victorian Department of Environment, Land, Water and Planning 2012
http://delwp.vic.gov.au/ data/assets/pdf file/0019/251515/201207-FFG-processes-list.pdf
Victorian Department of Environment, Land, Water and Planning, 2014.
http://www.dtpli.vic.gov.au/property-and-land-titles/land-titles/about-land-titles/crown-land
Victorian Institute of Forensic Medicine 2010. Australian External Cause Deaths
While Engaged In Hunting Activities
http://ssaa.org.au/assets/news-resources/hunting/australian-external-cause-deaths-engaged-huntingactivities.pdf
Voiceless 2016 https://www.voiceless.org.au/content/federal-election-2016-independent-office
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