Survey
* Your assessment is very important for improving the workof artificial intelligence, which forms the content of this project
* Your assessment is very important for improving the workof artificial intelligence, which forms the content of this project
SUBMISSION 207 RECEIVED 12/09/2016 INQUIRY INTO THE CONTROL OF INVASIVE ANIMALS ON CROWN LAND PARLIAMENTARY COMMITTEE, VICTORIA, 2016 FIELD & GAME AUSTRALIA David McNabb General Manager Field & Game Australia, Inc. PO Box 464 Seymour VIC 3661 Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 1 TERMS OF REFERENCE That, under s 33 of the Parliamentary Committees Act 2003, an inquiry be referred to the Environment, Natural Resources and Regional Development Committee for consideration and report no later than 30 March 2017 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. BACKGROUND As Field & Game Australia (FGA) is not directly involved with the trial of deer population control in National Parks, we will not discuss the outcomes of this trial. Our colleagues at the Australian Deer Association (ADA) have made a submission regarding the Parks Victoria trial of deer control. FGA has reviewed ADA’s submission, and we recognise the ADA as the subject matter experts in regards to deer hunting, and we endorse the ADA’s submission in regard to this matter. FGA’s expertise and history lies with State Game Reserves (SGRs), wetland habitat conservation, and waterfowl. The terms of reference of this inquiry are quite specific; FGA believes that a less acute approach is needed, and that all Crown and public land, including SGRs, should be assessed for recreational hunting for pest animal control where there is no good reason not to do so. FGA seeks policy formation based on facts and data, and not instinct, intuition or prejudice. FGA have a history of commitment to conservation, forming in 1958 in response to reports that the Pacific Black Duck could be extinct in as little as 10 years due to loss of habitat. The private/public partnership between conservationist hunters and the government of the time created a game licensing system, where the funds from licences purchased by hunters delivered revenue that allowed government to fund the acquisition of threatened wetlands. These wetlands provide critical breeding sanctuary for native waterbirds, offsetting habitat lost by drainage for agricultural and other purposes, and facilitate legal hunting during the prescribed season – a purpose which is often overlooked. Victoria’s SGRs encompass more than 75,000 hectares of wetlands, with further SGRs found in South Australia, for the purposes of conservation, and hunting. The most recent SGR, announced in August 2016, is the 200th in Victoria and recognises the role that habitat plays in sustainable hunting, as well as the importance of access to public land for lawful hunting activities. It is interesting to note that pest animal hunting is currently not permitted in SGRs, which is to the detriment of the native species that these reserves are intended to provide breeding sanctuary for. Presently, the method of applying control programs using volunteers is limited to those programs that operate in partnership with land managers, requiring formal programs such as the Memorandum of Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 2 Cooperation held between Parks Victoria and FGA (signed in 2010). These limitations hinder volunteer efforts to protect our native species from predation. These areas of public land are intended to be preserved as habitat for native species of both flora and fauna. It is ironic that the sanctuary status intended to protect our native species also protects the invasive species that prey on and compete with them. BIODIVERSITY OUTCOMES Conservation, restoration, and maintaining habitat remains a focus for FGA, with long-term projects such as the Heart Morass demonstrating the ability of private partnerships to deliver conservation and biodiversity outcomes. FGA formed the Wetlands Environmental Taskforce (WET) in 2002. WET is a conservation charity with the main purpose of purchasing, restoring, and conserving wetland habitats. The Heart Morass is a prime example of how volunteer invasive animal control can be effective in improving biodiversity. Two pest animal species that FGA’s volunteer members have direct experience in managing are the European fox and European rabbit. Not only do these species directly prey on or compete with native species, they can provide a vehicle for the introduction of undesirable plant species, through seed carriage in their gut or fur; and both the rabbit and fox can act as disease carriers and parasite vectors which may affect native species. FGA and WET have restored 1,349 hectares of degraded grazing land back to a thriving and diverse wetland habitat at the Heart Morass, near Sale, in Victoria’s Gippsland region. This restoration has been inclusive of active pest animal hunting of rabbits and foxes, as well as the removal of over 20 tonnes of invasive carp from the waterways. Regular monitoring and surveying of flora and fauna takes place at the Heart Morass, and has shown promising results. The Green and Golden Bell Frog Litoria aurea is listed as vulnerable with habitat loss, competition from introduced species, and predation by animals (such as foxes) contributing to the downturn of Bell Frog populations. Green and Golden Bell Frogs have recently been observed after a long absence at the Heart Morass, where pest animal hunting takes place in conjunction with habitat restoration and conservation. This pest animal hunting adds security to the sanctuary provided by having a thriving wetland habitat. Natural nesting and roosting locations are augmented through manmade nest boxes, roosting platforms, and relocation of stumps and logs. These also provide refuge for amphibians and fish in the wetland. Invasive plants are controlled so that native aquatic herbage can thrive. Similarly, invasive animals are controlled so that native animals can take full advantage of the habitat, protected from predation by introduced pests. This security is currently not present in SGRs or other public lands where recreational hunting of pest animals is not permitted. The success of the Heart Morass restoration shows that effective management programs can be developed and implemented, unshackled by layers of bureaucracy. Importantly, it has demonstrated that good environmental projects create great partnerships. Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 3 FGA’s conservation projects are run, staffed and implemented by an overwhelming majority of volunteer personnel. These volunteers are not motivated by wages or performance reviews, they are motivated by the value they place in the continuation of their hunting culture and traditions and/or the ability to utilise these project wetlands for research, education, or other recreation, which in turn embodies wetland habitats and waterbirds with an intrinsic value, adding to the value already held for access to these wetlands. The issue is whether the multitude of government resources applied to manage our natural environments through parks and public land (including SGRs) are delivering the optimal ecological and environmental outcomes. This can be determined by the response to the question: is this multi-layer management designed to achieve specific outcomes, or is it an outcome of a broader bureaucratic organisational design? COMMUNITY SAFETY Hunting in Victoria has an exceptional safety record. The supervised and/or volunteer hunting currently taking place in Plenty Gorge and the Alpine National Park to control foxes and deer (respectively) is representative of safe and responsible pest animal hunting. A report from the Victorian Institute of Forensic Medicine1 shows that in the period between July 1, 2000 and August 1, 2010, there were 1,473 deaths relating to recreational activities, of which 1.4% occurred while participating in hunting or shooting-related activities, and 36% of this 1.4% were from vehicle accidents. For comparison, hiking, mountaineering, and other ‘adventure’ type recreation activities – which often take place on public land such as state and national parks – made up 2.3% of fatalities in this same period. There is no evidence that supports the exclusion of hunting on public land, whether it is hunting for the table, or animal control programs, with regards to safety. Extensive safety and risk assessments have been conducted previously for deer management trials and as part of other pest animal control. The latest hog deer hunting trial, on Snake Island, follows successful models that have been in use for over 20 years. The use of signage to inform land users that hunting is taking place is a simple but effective system to educate such shared use of public land. The Tower Hill SGR near Warrnambool demonstrates another effective system of sharing public land: as an SGR, the reserve is open for hunting during the prescribed season in Victoria, however the reserve is effectively closed to hunting between the hours of 9am and 5pm. Most waterfowl hunting occurs at sunrise and sunset, so these timings are suitable for both waterfowl hunters and other daytime users of the SGR. Similar approaches may be utilised to ensure invasive animal hunting occurs during periods of least other use on public land. Similarly, the wearing of high-visibility clothing has been demonstrated to assist deer or pest animal hunters, and is now considered to be standard practice. In the event of an individual becoming lost or injured, high-visibility clothing is advantageous for locating the individual in need of assistance or rescue. 1 Australian External Cause Deaths While Engaged in Hunting Activities, NCIS Database Search, Victorian Institute of Forensic Medicine, August 2010. Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 4 It should also be considered that allowing hunting of pest animals on public land may contribute to improved community safety. There have been recent reports where wild dogs have stalked humans2 and family pets have also been attacked3 in addition to the maiming and killing of livestock and cattle on farms. These adaptable, intelligent predators could pose a threat to humans using public land. APPLYING THESE PROGRAMS FOR OTHER INVASIVE ANIMAL SPECIES Foxes, rabbits, and other pest animals pay no attention to land status. Opening up public land to recreational hunting where there is no good reason not to do so will allow a greater effort by recreational hunters. Most pest animal hunting in Victoria occurs on private property, but the fact remains that foxes and other pest animals move freely between private and public land. Public land which provides relief and shelter from hunting allows populations of invasive animals to recover, or increase further. FGA believes a review of all public land is required to help in identifying these pest animal ‘sanctuaries’. The benefits from 75,000 hectares of SGRs are not optimised if left dormant throughout the year. The reality is our landscape is highly modified, and wetlands are in short supply with an estimated 85% of wetlands drained since European settlement. It’s incumbent on land managers, with support from interested stakeholders and volunteers, to actively manage our wetlands for the future. FGA’s experience in conserving wetland habitats and improving breeding opportunities within SGRs has lead us to consult with Associate Professor Graham Hall from the University of New England, to develop a list of key regions and key wetlands to survey in order to focus management efforts and resources to enhance waterfowl populations and develop an adaptive resource management approach. FGA would anticipate that a similar management–research–monitoring cycle would be present when utilising recreational hunters for the management of invasive species. This research can be overlaid with watering plans to identify high potential wetlands for focus of effort and resources. The theory to be applied and monitored is for a program of proactive management to reduce pest animals, improved breeding habitat and biodiversity. In turn, this framework contributes to improved breeding events for all waterbirds Further access to public land for pest animal removal would not only assist in reducing mortality rates of native animals by removing predators, but would also assist primary producers in areas neighbouring public land. This issue was raised in a Weekly Times story last year, with Gippsland farmers identifying the ‘sanctuary’ provided by state and national parks, stating that “Part of the problem is that you can’t go out to the breeding ground to get them,” referring to national parks4. Another said “We need to get out into all the national parks. As community people, we’re not allowed in there with a gun, we can’t trap in the national park. So it’s like the Government is breeding them [wild dogs]”. 2 ‘Dog victim: “I was screaming – I thought I was going to die”’, Alina Rylko, Tweed Daily News, March 23, 2015 <http://www.tweeddailynews.com.au/news/wild-dog-pack-hunted-down-grandmother/2580986/>. 3 ‘Wild dogs attack. Resident warns a child could be next’, Jarrard Potter, The Daily Examiner, March 14, 2016 <http://www.dailyexaminer.com.au/news/in-the-space-of-half-an-hour-norman-gray8217s-kids/2963370/>. 4 ‘Wild dog attacks: Farmers desperate for more dog trappers’, Kath Sullivan, The Weekly Times, April 29, 2015, <http://www.weeklytimesnow.com.au/news/national/wild-dog-attacks-farmers-desperate-for-more-dog-trappers/newsstory/ab9c6149d791b504ad90d961fba3c0e7>. Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 5 Parks Victoria states that its vision is ‘to be a world-class park service ensuring healthy parks for healthy people’. The 2013 Parks Victoria strategy document Shaping Our Future discusses several values and opportunities, many of which relate to hunting. Parks Victoria has a history of working with recreational hunters and volunteers to deliver outcomes. In 2010, FGA signed a Memorandum of Cooperation with Parks Victoria with the aim of conducting pest animal control within SGR boundaries, as well as other cooperative projects and ventures such as habitat enhancement, revegetation, monitoring, and hunter and community information, interpretation and education programs. In a less official capacity, FGA members and branches also work with local councils, landowners, and primary producers to deliver conservation outcomes via reduction of pest animals and protecting livestock and native wildlife from predation. In conjunction with volunteer hunters, Parks Victoria has been able to remove 250 foxes from the Plenty Gorge suburban park5. Hunting at this park is highly controlled due to the proximity of the park to suburban housing developments. When considered alongside the deer population control trials conducted in Victoria, the precedent of government agencies cooperating and coordinating with recreational hunters in order to deliver positive outcomes for our environment has been set. ASSESSMENT OF RELATIVE COSTS AND BENEFIT S A University of Queensland study in 2014 concluded that almost all of Australia’s 300 000 recreational hunters would be willing to participate in pest control activities, if they had the opportunity6. DEPI’s economic impact study found that Victoria’s hunters spent $144 million to hunt pest animals7 and that over 40% of Victoria’s hunters hunt to reduce pest species populations. Hunting contributed $439 million to Victoria’s economy in 2013. This indicates a vast pool of volunteer resources available and willing to participate, all that is needed is the framework to provide access for further legal, regulated hunting activity in Victoria. The accepted alternatives to recreational harvest worldwide are predators, professional culling, and commercial harvesting. PREDATORS Since the expansion of human populations, particularly following the industrial revolution, large predators have not fared well in most habitats. Australia’s largest predator, the dingo, has been known to eat foxes, and areas where dingo populations are high have low fox populations8. However, interbreeding with stray and feral domestic dogs has resulted in invasive animal management issues for these hybrid predators. 5 ‘Fox whistler Abe Andrews is more cunning than a fox’, Chris McLennan, The Weekly Times, May 4, 2015, <http://www.weeklytimesnow.com.au/news/national/fox-whistler-abe-andrews-is-more-cunning-than-a-fox/newsstory/5b8b98c29f37925ec6bfb8e548d119c5>. 6 ‘Expenditure and motivation of Australian recreational hunters’, Neal Finch, Peter Murray, Julia Hoy and Greg Baxter, Wildlife Research 41(1) pp. 76-83, 2014. 7 Estimating the economic impact of hunting in Victoria in 2013, Department of Environment and Primary Industries, 2014. 8 Australia's Mammal Extinctions: A 50 000 year history, Chris Johnson, 2006, Cambridge University Press, Melbourne. Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 6 Whilst the encouragement of large predators in areas where humans live is controversial, there is no question they can have a significant effect on populations of other animals. PROFESSIONAL CULLING Culling is the removal or slaughter of animals where the principal objective is the reduction in overall numbers or certain individuals. Whilst the culled animals might be utilised, this is a by-product of the actual cull. When the purpose of taking an animal is its use then the act is a harvest as opposed to a cull. Situations where professionals are employed can include forestry plantations, water reserves, military bases or other fenced areas that create high concentrations of wildlife populations. These control activities occur regularly in Australia for kangaroo populations and have also targeted deer in recent years (Sambar deer in Victorian water reserves, hog deer in a highly sensitive recreation zone). Government culling programs often involve professionals shooting from a helicopter. This method has a long history in Australia for controlling pigs, horses, donkeys, camels, buffalo and wild cattle. In recent years, wild deer have been culled in Queensland and South Australia using helicopters. Helicopter culling is expensive but effective at reducing high densities in a short period of time over a small area. The practice of aerial culling can be very controversial, depending on the target species, as we have seen with the recent uproar over plans to cull wild brumbies from the Kosciusko National Park9. COMMERCIAL HARVESTING Commercial harvesting is the taking of animals with the intention being to sell the animal (or part of the animal) for profit. Wild deer have been harvested commercially for their meat for centuries. Supply of venison to feed a growing population in North American effectively exterminated many herds of wild deer in the late 1800s. The individuals involved in the harvest hunted on foot with rifles considered primitive by today’s standards. Despite difficult terrain and rudimentary equipment, the incentive to make money reduced or exterminated deer from all habitats close to human settlement. This overharvesting of wildlife is credited as the impetus for the current wildlife management paradigm in North America. Harvesting for commercial gain has been illegal for over a century on this continent. Wild deer are currently harvested commercially in Queensland. This is a small industry, driven by a limited demand. Deer are harvested by licensed game harvesters usually in the pursuit of macropods. Due to Australian regulations for safe food production, animals can only be harvested where vehicle access is relatively easy. This limits the potential for commercial harvesting to areas of open forest with good vehicle access, a description which does not match many areas of public land in Victoria. COSTS The joint SSAA NSW/NRC program is over 600 times more expensive than the demonstrated best practice for the use of recreational hunters for wildlife control on NSW public land. The interim report into the SSAA NSW/NRC joint supplementary pest control trial (February 2016) reports that the program has removed 9 ‘NSW Government to cull 90pc of brumbies in Kosciusko National Park over next 20 years’, ABC News, May 1, 2016 <http://www.abc.net.au/news/2016-05-01/plans-to-drastically-reduce-snowy-mountains-brumby-population/7373634>. Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 7 2,846 animals at a cost of $3.6 million, or $1,264.93 per animal10. By contrast, the last Public Benefit Assessment tabled for the Game Council NSW (June 2013) reported a removal of 1,230,090 animals at a cost of $2.5 million, equating to just $2.08 per animal11. FGA members regularly report their pest and vermin hunting activities. Since 2007, FGA members have removed over 30,000 feral and pest animals, including 10,990 foxes. This is primarily on private land and is performed at no cost to the taxpayer, or indeed the landowner. Appropriate accreditation of hunters, combined with public awareness campaigns through signage and education, and other control measures such as timing hunting access to coincide with periods where other use of public land is reduced, would remove the need for paid supervisory staff during hunting on public land. BENEFITS The economic benefits from hunting are documented, with Victoria receiving $439 million in 201312. The return from pest animal hunting is significant ($144 million) and demonstrates the contribution recreational hunters provide in social, environmental and clear economic benefits. It should be noted, however, that the 2013 DEPI study surveyed game licence holders, as access to the firearms licensing database was not possible. As game licences are not required for pest animal control, it is likely that the $144 million economic impact from recreational hunters is in fact a conservative estimate. A study into the economic impact of hunting for the whole of Australia is yet to be performed, however the Invasive Animals Cooperative Research Centre’s report estimated that invertebrate pests (introduced and invasive birds, rabbits, wild dogs, mice, foxes, and feral pigs) are responsible for an overall loss of $620.8 million for our primary producers13. FGA considers that the conservation and biodiversity outcomes delivered by the removal of invasive and pest animals is of immense value, and hunting as a recreational activity delivers more intangible benefits for the individual. The dual purpose of SGRs in Victoria endows them with a value for hunters, especially the value placed on the ability to access these wetlands in order to harvest wild game for the table during the legislated hunting season. That value is in part what motivates conservationist-hunters and FGA members and volunteers to act as caretakers and conservationists to ensure that their recreation and their culture will continue in the future. Management that includes hunting of pest animal species will create further motivation for recreational hunters, by adding the valued access and ability to perform conservation hunting. Recreational hunters have contributed enormously to a reduction in pests, for example in Victoria since 2011, hunters have taken over 410,000 fox scalps for the fox bounty. It’s reported that each fox eats on 10 Supplementary pest control trial: Interim Evaluation, NSW Natural Resources Commission, February 2016, <http://www.nrc.nsw.gov.au/_literature_212103/Interim evaluation>. 11 2012-13 Public Benefit Assessment: Final Report, NSW Game Council, June 2013, <http://pandora.nla.gov.au/pan/141622/20130712-1233/2013.pdf>. 12 Estimating the economic impact of hunting in Victoria in 2013, Department of Environment and Primary Industries, 2014. 13 The economic impacts of vertebrate pests in Australia, Invasive Animals Cooperative Research Centre, 2009. Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 8 average 27 birds each year14 – presumably native. Therefore, it can be assumed the fox scalps taken by recreational hunters have reduced the mortality rate by almost 11 million birds. Taking into account that the 410,000 foxes represents a portion of the pest animal control performed by recreational hunters (not all fox hunters will claim the bounty), the reduced mortality rate may be a severe underestimate of the true benefit of recreational hunters. The wild dog bounty, which ceased in June 2015, resulted in 2,129 wild dogs removed by recreational hunters. After the cessation of this bounty program, the Victorian state government has extended other wild dog management programs, with funding for additional baiting announced in the 2016/17 Victorian State Budget. There are calls to reintroduce the wild dog bounty in Victoria, currently managed with poisoning and other measures. In 2013–14, 587 wild dog bounties were claimed by volunteer, recreational hunters, in addition to the 480 destroyed by paid state government trappers15. It should be noted that noise suppressors (also known as “sound moderators”) may assist in effective hunting of invasive animals which move in packs, such as wild dogs or pigs, as the sound from shooting is reduced (but not eliminated) and becomes less likely to alarm the remaining animals after the first shot. This gives hunters time and opportunity to take the animals unaware, increasing the number taken at a given time. These devices are commonly used in the UK when performing pest animal control close to the residential/rural interface, and New Zealand has no restrictions on the manufacture, sale, possession, or use of suppressors. In the UK the use of these tools are widely endorsed and have become standard practice. UK police forces usually approve applications for a suppressor for hunting and target shooters, as the risks of litigation for personal injury, especially high-tone deafness resulting from shooting-induced hearing loss, are significant; and noise pollution in general is a problem for shooting sports. The widespread acceptance of use is demonstrated with reviews of rifles in the shooting and hunting industry media routinely making reference to the specific sound moderator used for the test. Rifles are delivered from the manufacturing factory with the barrel pre-tapped with a thread to allow easy application of the moderator. Some limited samples of rifles are delivered in Australia with this thread applied, with a simple collar supplied to screw onto the thread. The challenges of managing wild dogs in NSW has been recently highlighted16 where the exclusion provided for wild dogs in ‘Schedule Two’ lands prevents effective control. Properties adjoining these conservation sites are reported to bear the brunt of wild dogs moving between farmland and the conservation zones where they are afforded practical protection along with the dingoes that Schedule Two land is designed for. Similar issues in Victoria have been discussed previously, and will occur wherever private property is adjacent to Crown land. Optimal ecological and environmental outcomes cannot be restricted to isolated areas. Our landscape, though highly modified, is continuous, and management should reflect that quality. Habitat restoration and conservation is only part of the bigger picture to ensure that our native species are able to thrive. There is 14 ibid. ‘Fox bounty extension a win for farmers’, The Stawell Times, April 20, 2016 <http://www.stawelltimes.com.au/story/3860082/bounty-on-foxes-is-being-funded/>. 16 ‘Vicious wild dogs protected’, Jessie Davies, The Land, May 20, 2016 <http://www.theland.com.au/story/3906784/deadly-wilddogs-resting-easy/>. 15 Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 9 little point in maintaining an isolated pristine habitat if introduced animal species are allowed to move freely in and out of that habitat and are protected while within the boundaries. HARVEST VS CONTROL The DEPI economic impact study from 201417 showed that the main motivator for hunting was the harvesting of food. Until relatively recently, hunting was the main vehicle for delivering meat to Melbourne’s population. While some pest animals are unpalatable, many species defined as pests offer rich sources of protein which should be utilised. With increasing pressure on food supply from a growing population, it does not make sense to discard the meat provided by pest animals; if it is palatable, safe for human consumption, and nutritious, it should be used. Hunting for the table can encompass pest species; the alternative is to simply ‘shoot to waste’ – the antithesis of ethical hunting. It should be noted that some native animals can present as pests when their populations are not managed, and the terms of reference do not acknowledge this. Kangaroo culls take place around the country and can currently be processed for pet food in certain areas of Victoria, however, under current Authority to Control Wildlife permits, only 80 kg of meat and bone can be taken by the individual conducting the cull. With adult males weighing on average between 50 and 66 kg, it’s expected that culls of more than three or four animals at one time will result in wastage (i.e. disposal) of the remains. All kangaroo meat sold commercially in Victoria for human consumption is sourced interstate. It is not unusual for permits to be issued for the culling of tens, or hundreds, of kangaroos, and if these culls take place in areas outside of the pet food trial areas, it creates problems. The overarching problem is the waste of a natural resource. The second problem is disposal. If the kangaroos cannot be utilised, they must then be disposed of. Disposal has its own logistics, creates an additional burden for those undertaking the cull, and can vary from burial, burning or simply abandoning the carcasses. Abandoned or improperly disposed-of carcasses can in turn attract opportunistic scavengers, such as the European fox and wild dogs, which creates even further issues for existing pest animal management. Changing the status of some introduced species (i.e. deer) to pest is not supported by FGA, as this puts the onus to control these animals back onto landowners with little or no support from government, and does not consider the refuge created by prohibiting hunting on Crown land. The FGA/ADA joint submission18 to the NSW NRC Pest Animal Review goes into more detail on this. SUMMARY The terms of reference of this inquiry are specific to National Parks, and deer as a specific species, however FGA believes that all Crown land, including SGRs, should be assessed for recreational hunting of all pest animals. Pest animal hunting will add further security to the sanctuary provided by our thriving natural habitats within the boundaries of public land. 17 Estimating the economic impact of hunting in Victoria in 2013, Department of Environment and Primary Industries, 2014. ‘Shared Problem, Shared Solutions – Pest Animal Management Review’, Australian Deer Association and Field & Game Australia submission to NSW Natural Resources Commission, May 2016. 18 Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 10 Current limitations and bureaucratic layers hinder volunteer efforts to protect our native species from competition and predation by introduced species. As our landscape is continuous, pest animal management should reflect this quality and should not be restricted to isolated areas. FGA recognises the role that recreational hunting can play as part of wider pest and invasive animal control programs. It is an effective tool which is safe, targeted, and humane, and Australia has a vast pool of volunteer resources available and willing to participate. All that is needed is the framework to provide access for further legal, regulated hunting activity in Victoria. Our recommendation to this inquiry are as follows: 1. A state-wide strategy should be developed, adopted and properly resourced to sustainably manage wild deer populations in Victoria. The advice from our ADA colleagues is supported, in that actions should focus on preventing the establishment of new populations of deer and on protecting high value environmental assets. 2. Existing and future deer (and other wildlife) management programs involving public land managers and recreational hunters should be assessed against a series of objective criteria and resourced appropriately. FGA recommends the extension of this proposed management program specifically, but not limited to, SGRs. 3. An approved management program must be based on data and evidence that supports the programs to enhance the biodiversity outcomes of these important wildlife sanctuaries. This should include factbased management, research and monitoring. 4. The Game Management Authority employs specialist Game Managers and has a breadth of experience in game and hunting policy. It should be tasked and resourced as the lead agency for the planning and oversight of deer (and other wildlife) programs. 5. The use of sound moderators should be made legal for recreational rifle shooters in Victoria. 6. Necessary changes to regulation should be made to allow the processing of wild shot food for human and pet consumption on commercial premises. Inquiry into the Control of Invasive Animals on Crown Land – September 2016 – Field & Game Australia Page | 11