SUBMISSION 67 RECEIVED 01/08/2016
The Executive Officer Environment, Natural Resources and Regional Development Committee Parliament House Spring Street EAST MELBOURNE VIC 3002
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land
Dear Executive Officer,
Please find attached my submission to the Parliament of Victoria Inquiry into the control of invasive animals on Crown land.
I very much support the current regulations that permit recreational deer hunting in some of Victoria’s National Parks, and the use of volunteer hunters in well managed control programs on all crown land.
The views expressed throughout this submission are my own, and do not represent any policy or standpoint other than my own.
I am very willing to give evidence on any aspect of this submission at any public hearing conducted by the Inquiry.
Yours Sincerely
Bob Gough
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 2 “The best way to control deer is to get people to hunt more like wolves. “We should be shooting does, not bucks.” “We should have longer hunting seasons and ask hunters to shoot more than one deer.”1
Executive Summary
1. Few Australians would know that volunteer hunters from community based hunting organisations such as the ADA, SSAA and Field and Game Australia (FGA) have for many years been participating in targeted culling programs to manage overabundant and invasive native and introduced species in all Australian states except the ACT. For over 10 years across Victoria, volunteer hunters have conducted both simple and complex invasive species management on crown and private land with a range of Government and Non Government organizations and private landholders, including Parks Victoria (PV), DELWP, Trust for Nature and Landcare Victoria. Because these programs are well planned and highly organised they have an enviable safety record. The difference between these programs and common wildlife control as practiced in Australia is that they provide a sustained management effort through the long term personal investment of time and effort by volunteers. For example, organizations such as FGA have purchased conservation land in their own right at Heart Morass, and for over 40 years have built water bird nest boxes on public land, and conducted regular fox drives on Crown and private land.
2. The ADA signed a MoU with PV for deer related activities in 2004, and the SSAA signed a similar MoU for non game species in 2005. These MoU have since been modified to allow either organisation to manage any game or non game overabundant species, and it is now common for ADA and SSAA to partner on management programs for a range of species across all land tenures. The “Social License” generated by these grass roots community based programs has seen them expand in number, frequency and complexity.
3. This submission will present examples from the Author’s direct personal experience, and will suggest options for change that will allow the valuable contribution made by volunteer hunters to continue, and hopefully, to expand and improve its efficacy. For clarity, this submission is presented in three parts:
4. Part One. This section will address the Terms of Reference issued by the Parliament of Victoria, using Case Studies from the Wilson’s Promontory National Park (WPNP) Hog Deer Management Program 2015 and the Chiltern National Park Noisy Miner Management Program 2015 as well as the Author’s direct personal experience to assess the relative financial, social and environmental costs and benefits of these programs; and to highlight positive biodiversity outcomes, safety management and the benefits of spatial separation and geographically widely disbursed hunting. The Author will then use the PV – ADA – SSAA Alpine National Park (ANP) Deer Control Trial 2014 - 2020 as a case study to discuss the procedural, terrain and equipment limitations of these programs. Lastly, the effectiveness of current game Law and Regulations, and Public Safety issues of illegal shooting and associated criminal activity such as stock theft will be discussed.
1 Don Waller, Biologist, University of Wisconsin–Madison USA quoted in Levy. S, A Plague of Deer, BioScience • September 2006 / Vol. 56 No. 9 www.biosciencemag.org
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 3 5. Part Two. In order to give the Inquiry a more complete understanding of the broad involvement and sustained contribution of community based hunting organisations in invasive species management, Part Two will use case studies of current community based wildlife management programs on private land where Landcare Groups, Individual Landowners and non government conservation organisations are using volunteer hunters to achieve positive environmental, financial and social outcomes. Part two will also discuss the recent round of community based Landcare Deer Workshops conducted in Northeast Victoria, where the Author took a lead role as a subject matter expert on deer behaviour and on the lethal and non lethal management of deer. Lastly, a table outlining community based volunteer hunter programs operating in other Australian states will be presented to demonstrate the broad acceptance of volunteer hunters in wildlife management.
6. Part Three. This section will discuss factors related to the Inquiry Terms of Reference, and to the management of overabundant native and introduced species on both public and private land, including legislative matters such as wildlife carcass disposal, and will discuss why demonizing overabundant or invasive native and introduced wildlife is counterproductive to effective population management. These factors, if modified without full consideration of potential impacts and ‘downstream effects”, may have negative and unintended financial and conservation consequences on a range of public and private stakeholders and agricultural industries; and have the potential to remove current control options, such as recreational deer hunting in the Alpine National Park (that removed 30,000 deer in 2015 at no cost to the taxpayer), while affecting no actual change to current legal management methods or the development of future management options, including the use of toxicants for overabundant species such as deer.
7. Recommendations will be made throughout each section, and will be summarised in a table at the end of the document. Annexes will be used to present related information. Throughout this submission, the Author will present evidence that will prove beyond any doubt the economic, social and environmental benefits of government agencies and community based hunting organisations partnering in the management of overabundant and invasive native and introduced wildlife.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 4 Introduction
8. Australia’s Hunting History and Culture. Hunting for food, or to protect economic, environmental or social values has played a significant role in the lives of many Victorian’s since European settlement, yet Australia’s hunting culture is largely unrecognized and mostly conveniently ignored. The Australian Hunting Archive, which is funded by FGA and managed by Mr Max Downes, a wildlife biologist, and Victoria’s first government employed Game Manager, has a wealth of information recording hunting, hunting related use of land, and management of wildlife impacts.
9. The Role of Volunteer Hunters. Volunteer Hunters have a vital and expanding role to play in the management of invasive species on both public and private land. Volunteer hunters come from all walks of life, and bring with them a range of knowledge, first hand experience, specialist skills and attitudes that are readily employable in the management of a variety of overabundant or invasive species in order to derive a conservation benefit or to reduce environmental, economic and social impacts. In Victoria, hunters have monitored wildlife impacts, interpreted remote sensing camera (trail camera) data; constructed exclusion fencing to protect high value sites; trained their own members to high standards of marksmanship, navigation, field craft and in the operation of specialist equipment such as global positioning and mapping systems, drone aircraft and infra red and thermal image optical devices for use in targeting wildlife (some individuals have also privately purchased these very expensive devices for use on operations).
10. Since 2003, community based hunting organisations have regularly planned and conducted complex and sustained operations to manage populations of overabundant introduced and native species in locations as diverse as the remote Little Desert National Park, spatially restricted peri-urban sites such as Yellingbo National Park, near Melbourne; and iconic areas such as the Alpine National Park and most recently Wilson’s Promontory National Park. In the Chiltern National Park, one volunteer hunter and one DELWP Biodiversity Officer partnered to plan and conduct culling operations that removed over 300 invasive Noisy Miners (an overabundant native bird species that was impacting on an endangered native bird species) across multi-organisational boundaries with private landholders, Parks Victoria (PV), North East Water and DEPI/DELWP.
11. Volunteer hunters have also researched and written a range of policy and procedural documents to ensure safe and smooth function of operations, and have used their significant experience to pass on knowledge that improves safety and effectiveness across a range of functions. This ability to self regulate through peer pressure is a significant benefit to volunteer programs, and a key difference between paid and volunteer based management.
12. In all of these operations there have been no issues with public safety and only a few minor injuries, such as sprained ankles. The volunteers have been praised by PV for their professionalism, tenacity and dedication. Indeed, PV now refer to paid “Professional Shooters” as “Contract Shooters”, in recognition of the professionalism demonstrated by volunteer hunters (perscom Gough/PV Staff member).
13. Disclaimer. The views expressed throughout this submission are those of the Author, and do not represent any official policy or standpoint of any organisation.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 5 14. The Author’s Credibility and Experience. The Author is a retired Australian Army Officer, Hunter, Hunter Educator, Landcare Coordinator, Wildlife Management Consultant and practical conservationist with over 23 years experience working with Government agencies, Non Government Organisations and private landholders on a number of initiatives and programs for the control of overabundant and invasive native and introduced wildlife. These programs ranged from simple once off activities through to complex and sustained programs using lethal and non lethal methods in rural and peri urban locations across a range of land tenures. The Author worked with Parks Victoria (PV) to introduce and manage the SSAA Conservation and Pest Management (CPM) Program in Northeast Victoria from 2004 to 2007, personally training over 70 shooters for SSAA. The Author also designed and conducted the ADA Victoria Deer Management Program (DMP) Accreditation Course and trained around 80 shooters for ADA, and received a Parks Victoria Conservation Award for his efforts with CPM.
15. The Author has acted in leadership, planning, supervisory and training roles in a number of DELWP and PV native and introduced invasive wildlife control programs on Crown land; and was directly involved in the Wilson’s Promontory National Park (WPNP) Hog Deer Management Program 2015, the Chiltern National Park Noisy Miner Management Program 2015 and the PV – ADA – SSAA Alpine National Park (ANP) Deer Control Trial 2014 - 2020. The Author can provide a short biography outlining further experience and involvement if required.
Terms of Reference
16. The Terms of Reference for the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land are to “Inquire 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 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”.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 6 Submission Part One
The Benefits of Government agencies using Community Hunting Organisations and Individuals in the control of invasive animals on Crown land.
Assessment of biodiversity outcomes (and impacts).
17. Case Study: Wilson’s Promontory National Park (WPNP) Hog Deer Management Program 2015. Hog deer have been present in the WPNP for over 100 years, and populations have increased to a point where the deer are impacting on park values. The biodiversity outcome required was to reduce the population of hog deer in the Tidal River & Darby River sections of the park by shooting in order to reduce impacts. Due to the very high visitor use of WPNP the park was closed for 2 days mid week to all visitors to maximise operational focus. Due to the habituated nature of the deer, that were regularly fed by park visitors, 42 deer were culled by 15 volunteer shooters from both ADA and SSAA. Most deer were culled around Park infrastructure (buildings, roads, signs, fire hydrants etc) which significantly added to the complexity of the program. All deer were one shot kills.
18. Case Study: Chiltern National Park Noisy Miner Management Plan 2015. In partnership with the Senior Biodiversity officer at DELWP Wodonga, the Author planned and conducted ground shooting operations for the Noisy Miner (Manorina melanocephala) (an invasive and despotic native bird species that is listed as a key threatening process in several Australian states) as part of the Chiltern National Park Noisy Miner Management Plan 2015. The purpose of this cull was to reduce competition and allow the establishment of populations of a group of captive-bred nationally endangered Regent Honeyeaters (Anthochaera phrygia) into the Chiltern - Mt. Pilot National Park in autumn 2015. The aim of the activity was to remove 75% of the assessed Noisy Miner population. Due to PV staff shortages and bad weather, a total of 310 out of a possible allocation of 463 Noisy Miners were culled, which equates to 67% of the assessed population within the treatment area in the Chiltern National Park, and adjoining private land.
19. The success of the program will be measured over the following years; however immediate positive signs of reduction in competition were noted at several locations where, on a number of occasions species such as Wattle birds that are impacted by Noisy Miners were able to stand their ground in a patch of tree blossom against a single Noisy Miner, rather being bullied away by 3-8 Noisy Miners pre treatment. A full report is available if required.
20. Not just shooting. In addition to shooting, volunteer hunters have assisted with the construction of exclusion fencing to protect high value sites and regularly contribute to the assessment of biodiversity outcomes by applying their knowledge of the species and their time to monitor and interpret impacts and observations. Evidence of this contribution is in the use of Volunteer hunters by PV to conduct a five year annual deer faecal pellet counts in selected high value sites such as at Suggan Buggan in Gippsland and at Mount Buffalo and Falls Creek in Northeast Victoria.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 7 21. The PV Bogong High Plains (BHP) Trail Camera Study. The purpose of the PV BHP Trail Camera Study is to monitor deer abundance, density and habitat use. Formal analysis of all camera data is being conducted by PV using agreed monitoring protocols; and PV have sited 25 cameras in each of 2 treatment areas. Targeted deer control is being undertaken in one of the treatment areas; in the other no deer control is being undertaken. This survey is possibly the most detailed study of wild deer on public land in the Southern Hemisphere; and to give the inquiry an understanding of the project scope, the cameras are set to take three images each time they are triggered, and there are between 30,000 and 60,000 images (from 10,000 to 30,000 “triggers”) (not all of deer) in each treatment area that must be viewed and assessed.
22. As part of this camera study, the author is conducting analysis of the 25 cameras in the targeted deer control treatment area. This analysis is providing an understanding of the population demographic and herd makeup; and will allow the management program to “pattern” the deer, and to target high priority areas when populations are most vulnerable. This analysis will add to the knowledge of habitat use by sambar deer, and in time, this study will also be used to assess habitat use and movement patterns of sambar deer.
Recommendations related to biodiversity outcomes and impacts.
23. As evidenced from the examples provided above, the use of trusted hunting organisations and individuals to cull invasive animals on Crown land is delivering a range of beneficial biodiversity outcomes, both lethal and non lethal. This activity involves a range of stakeholders and grass roots contributors, and returns a significant; albeit difficult to measure, return on investment.
24. It is recommended that the use of trusted hunting organisations and individuals in the management of invasive animals on Crown land should continue and expand; and that any measurement of program success must be considered in broader terms than a cull tally or reduction in negative impacts at a specific location.
25. Specific performance measures that show trends in volunteer participation rates, and capture lessons learned that will improve program efficiency and community engagement should be developed. Intelligence information from post activity debriefs and after action reports should be captured and shared to improve knowledge of the target species. Lastly a measure that considers the effect of the program at a landscape scale, such as reducing overall populations and disrupting environmental impacts should be developed.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 8 Community Safety
26. Recreational hunting on Crown land. Hunting is a safe activity, as evidenced by the fact that recreational hunting has been permitted in Victoria’s State Forests, National Parks and other Crown Lands since European arrival and issues have been limited. In fact, hunting has an impressive safety record in Victoria when compared to other recreations. Recreational hunting on Crown land is where the majority of hunters operate, and the broad access available for recreational hunters in Victoria, often coupled with the common human interest in “what is over the next hill?” is what inspires many hunters to volunteer for wildlife management programs.
27. In winter, hunters are the major below the snowline Alpine National Park user group. The Victorian Game Management Authority (GMA) advises that in 2016 there are around 35,000 Victorian Game License holders, up from 10,000 in 2006. This represents one of the largest deer management programs in the southern hemisphere, and is conducted free of charge by volunteers. The management cost of administering firearms licensing and Game Licences is offset by the estimated $480million annual expenditure by hunters in Victoria. This makes hunting, especially for deer, one of the fastest growing recreations in Victoria, and in the cooler months, hunters are the major below the snowline Alpine National Park user groups.
28. Current Game laws and regulations are working well. In Victoria in 2015, over 30,000 Recreational hunters harvested around 60,000 deer on private and public land. The low offence rate is proof that the majority of hunters are honest and law abiding, and that current game laws and regulations are working well. In National Parks hunters are only permitted to shoot deer, and there are prescribed calibers and bullet weights to ensure humane harvest. It is an offence for recreational hunters to sight in a firearm or to shoot non game and even pest species, such as foxes and feral cats in National Parks. The GMA advises that participation in recreational deer hunting is rapidly increasing, and that in 2015, recreational hunters harvested an estimated 30,000 deer in the sections of Victoria’s National Parks where recreational hunting is permitted. One can only speculate on the number of deer that could be harvested by the increasing number of recreational hunters if all National Parks and Wilderness Areas where recreational hunting could be safely conducted were opened to recreational hunting – helping to achieve broad scale positive environmental outcomes at no cost to the taxpayer.
29. Spatial Separation is the key safety factor. The GMA advise that the Victorian recreational deer harvest is around 60,000 animals annually, with around 30,000 of these harvested in areas of National Park where recreational hunting is permitted. This figure does not include non licence holders, such as farmers, who shoot deer on their own land, so the actual harvest would be significantly higher. This means that at least 31,000 hunters are firing at least 60,000 rounds of ammunition in hunting situations on Crown and private land annually without incident. From the GMA figures, hunters are firing at least 30,000 rounds of ammunition annually in National Parks that are open for hunting, again largely without incident, despite the fact that Victoria’s National Parks are open all year to everyone. Spatial separation afforded by the large tracts of huntable land in Victoria is a significant safety factor, and will be discussed further as a direct factor below.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 9 30. Factors influencing the low incident rate of recreational hunting. There are a range of indirect and direct factors that influence the low incident rate for hunting.
a. Indirect factors. Include the challenging firearm licensing process, hunter education levels, cultural and ethical influences (where hunters only take what they need), and not insignificantly, the difficulty of hunting sambar deer, a species that is renowned as one of the most difficult animals in the world to hunt.
Note: Most Victorian Hunters undertake hunter education training to improve knowledge and skills. Hunting organizations use this opportunity to improve attitudes including ethics, understanding of environmental issues and consideration of other bush users. All the major hunting organisations and a number of private providers conduct hunter education, and most positions on these courses are booked out months in advance. For example, the ADA has conducted an internationally recognised two day residential hunter education course in Victoria for up to 100 students annually for over 30 years.
b. Direct factors. Include the huge area of Crown land available for hunting, that spatially separates users by season and preferred habitat; the differing terrain requirements for hunting and bushwalking; and, because the majority of non hunters use the Alpine National Park over the warmer months when the Park is closed to hunting, whereas the majority of hunters hunt in the Alpine National Park in the cooler months to preserve harvested venison (these same hunters will often use the Park over summer for non hunting activities, such as fishing and camping). Because the deer have a natural aversion to the sight, sound and smell of humans, high public use sites are generally unattractive to game species, and this factor places most hunters and other park users in different places at different times.
31. The Public Safety issues of Illegal Hunting and Criminal activity. There are always “bad apples”, and hunters are often blamed for the activities of a criminal element who disguise themselves as recreational hunters in Victoria. These are people who take advantage of the low police presence in country Victoria, and knowingly trespass, spotlight and shoot along roadsides, often to supply venison to the illegal meat trade. It is no coincidence that in areas where illegal shooting occurs the rate of stock theft is high – if a criminal has meat orders to fill, and can’t shoot enough deer, they will steal a steer instead, as they are already breaking the law.
32. Criminal misuse of firearms is a police matter, and the GMA manages hunting offences, yet criminals know that because GMA Officers are unarmed they cannot presently operate without Police support, and also know that Police protocols prevent Police from operating alone, and that Police shift arrangements mean that they usually only work “two- up” on Thursday to Sunday nights. This means that illegal shooters may operate with impunity on Monday through to Wednesday nights, and other peak periods where Police are otherwise employed, and they take full advantage of this fact.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 10 Safety management in organised volunteer wildlife management programs
33. For over 10 years, across Victoria, volunteer hunters have conducted well planned and highly organised invasive species management with a range of Government and Non Government organizations, including PV, DELWP, Trust for Nature and Landcare Victoria. During this time there have been few safety incidents. This is largely because of the application of industry based safe work practices. It is noteworthy that these activities are treated as a workplace under the Workplace Health and Safety Regulations. This means that a full physical risk assessment is conducted for each activity, and that volunteers follow all policy and procedural directives of the supporting (government or non government) agency with regard to safe work practices including fatigue management, vehicle safety and of course firearms safety. In addition, all activities are “dry” and alcohol is not consumed in the 12 hours prior to, during or immediately after any activity (such as on the trip home after an activity).
34. Additional Skills Training. Additional Skills Training for volunteer hunting programs contributes to program and community safety in shared and complex situations and environments, such as high use National Parks. ADA and SSAA volunteer hunters who participate in invasive species management programs on Crown land in Victoria undergo additional training as part of the MoU between PV, ADA and SSAA. These programs are known as the ADA Deer Management Program (DMP), and the SSAA Conservation and Pest Management (CPM) Program, and require volunteers to undertake a two day training course that requires high standards of marksmanship, navigation and field craft. This training is a prerequisite for program participation and is very challenging. Only around 33% of participants pass the course.
35. As a member of both ADA and SSAA, the author collaborated with PV and other like minded hunters to introduce CPM to North-east Victoria, targeting feral pigs at Barmah Forest and feral goats at Mt Mittamitite, near Corryong. The author then led the roll out of the ADA DMP across Victoria. This involved the design and conduct of training courses, where the author personally trained over 150 volunteers in both programs, then planned and conducted operations.
Case Study: Safety Management in the Chiltern National Park Noisy Miner Management Program 2015.
36. Background. In this program, the Park was signposted to advise the public and the volunteer shooter notified VICPOL and neighbouring landholders. Community support for the program was very high, and the social licence created by personal liaison, professionalism and community goodwill meant there were no adverse reactions to the activity.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 11 37. Skills improvement and target practice. Shooting is a perishable skill, and during the program, the shooter regularly practiced shooting, and was able to attend the Victorian Shotgun Education Program that is jointly conducted by the Victorian Game Management Authority (GMA) and hunting organisations. This one day intensive course allowed the shooter to improve skills and knowledge, through coaching, clay target shooting practice and guidance on gun fit. The shooter subsequently had a gunsmith personalise the fit of his shotgun, and with a fitted gun, and the knowledge and skill gained during the Shotgun Education Program, the shooter was able to significantly improve his on ground performance.
38. Supervision. When conducting the activity within the Chiltern National Park, Parks Victoria provided two staff per culling day. These staff closed off each end of a track while the shooter walked along the track culling birds. The shooter worked alone without direct supervision on private land and within the National Park without issue; and PV provided a trunking radio to the shooter for communications.
39. Firearm Safety. The shooter used existing protocols for humane culling, being a 12gauge shotgun using a 32gm charge of number 7.5 shot travelling at 395 metres (1300 ft) per second. Each 32gm shotgun cartridge has approximately 200 pellets with each pellet being less than 2mm in diameter. Firing a shotgun at birds in trees at steep angles is actually a very safe practice, as the pellets spread at a rate of one metre spread for every 10-15 metres of distance and rapidly shed energy, rising to a maximum height of 300 metres then falling to earth at the speed of gravity spread over a wide area.
40. Safe Target Selection Protocol. The standard procedure used was to shoot stationary birds perched in trees at distances of 10 to 30 metres. This allowed verification of the correct bird (with binoculars if necessary), and an assessment of safe angles of fire when buildings or roads were near the 300 metre safety distance required for shot size 7.5. Due to the often erratic flight pattern of the Noisy Miners, there was little opportunity for shooting birds on the wing. These factors combined to increase the complexity of the activity, and to reduce shooting opportunities, with the shooter only able to shoot around 50% of the birds seen. This is not a criticism of the procedure, but an acknowledgement of the complexity of the task. Lead shot was used in preference to steel shot because there was no risk of ingestion of lead by wading birds.
41. Lethality of the chosen method. The use of a 12gauge shotgun and shot size 7.5 proved very effective. Ammunition usage was approx 500 cartridges to kill 310 birds. The commonly accepted planning figure for ammunition for wildlife culling is 3 cartridges per animal, to account for misses and follow up shots, so the ammunition expended was well below the accepted figure. Wounding rates were well below the commonly accepted threshold of 5-10%. This was due to the agreed policy of only taking a low risk shot (Low risk being defined as a killing shot at the correctly identified species that would not cause a safety risk). Approximately 97% of birds were killed instantly.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 12 Recommendations regarding Community Safety
42. Community Safety in hunting programs is the top priority of both Government agencies, such as PV, and Non Government Organisations such as ADA and SSAA. Under the Victorian Worksafe Act, all stakeholders have a legal duty of care towards their staff, volunteers and the public, and are well aware that the consequences of an incident will have far reaching legal and public confidence repercussions. As discussed in the preceding paragraphs, there is ample evidence that both unsupervised recreational hunting, and the use of highly trained volunteer hunters in targeted programs to manage overabundant and invasive native and introduced species is effective and safe under extant legislation and regulations. However; there is always room for improvement, and the following recommendations are made:
a. Hunters should be represented on the committee of the Victorian National Parks Association (VNPA), so that myths and preconceptions may be reduced and hunting can be fully understood; and so that hunters can collaborate with other user groups and understand their concerns and point of view. Hunters may then contribute expertise, and be consulted as a park user and stakeholder.
b. In recognition of the ongoing contribution of the recreational deer harvest in National Parks where hunting is permitted, unsupervised recreational deer hunting on Crown and private land should continue, and opportunities to shape the recreational hunter effort should be explored.
c. In recognition of the increasing popularity and rapid growth of recreational hunting, the excellent safety record, low cost, and the demonstrated positive benefits to community engagement and to biodiversity outcomes, recreational hunting should be expanded to all areas of Crown land where it can be demonstrated as safe to do so (via the development of a practical, risk assessment process based on the method used to assess areas for suitability of use as military field firing ranges in collaboration with the Australian Defence Force, hunting organisations, VICPOL and the Crown land manager). This process should be widely promulgated to landholders and other state Government Authorities as part of knowledge sharing to benefit all communities.
d. Current Game Laws and Regulations are working well, and there is no requirement to change them. There is; however, a significant gap in enforcement that needs to be addressed.
e. Hunter Education is a significant factor in the safety of hunting, and Hunting organisations have proven they have the ability to design and conduct world class education programs. However, this costs money, and hunting organizations should be able to apply for government grants to conduct and manage hunter education, perhaps drawing on Game Licence revenue.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 13 f. In recognition of the unbroken link of hunting and the safety effect generated by spatial separation on large tracts of public land, any change to management or status of Public Land should be well considered, and include hunting organisations as a stakeholder group in all collaboration. For example, the connection of existing parks or the creation of new National Parks on Public Land where deer hunting is presently permitted should continue to permit deer hunting.
g. In recognition of the public safety issues of illegal and criminal activity involving animals, such as trespass with a firearm, spotlighting and shoot along roadsides and illegal meat trafficking, increase the number of GMA Wildlife Officers (currently around five officers to cover the entire state) and arm them with self defence tools as issued to VICPOL and Melbourne Train Guards, such as firearms, “Tasers” and pepper spray, and authorize the GMA to conduct targeted and random field operations (if Train Guards in Melbourne can be armed, why not GMA Officers?)
Limitations of the trial conducted by Parks Victoria on control of deer populations in a National Park.
43. Background and Scope of Activities 2002 - 2016. The use of organised and highly trained Volunteer Hunters in PV invasive species management programs started around 2002-3 in the Little Desert National Park, where PV and SSAA partnered to remove feral goats that were damaging the biodiversity of the Park. The Author used this program as a model for a similar program in North-East Victoria to manage feral pigs at Barmah National Park, and to manage feral goats at Mt Mittamitite State Park, near Corryong.
44. Parks Victoria deer management programs commenced around 2007 with ADA conducting deer management at Mount Worth, near Melbourne. These programs use both ADA and SSAA volunteer hunters to remove several species of deer, and are now conducted in National Park locations as diverse as Wilson’s Promontory, Yellingbo, Sherbrooke Forest and in the Alpine National Park. In recognition of the proximity to neighbouring private land, visitor use, the size of the management area and a range of local site factors, each program is managed differently and is tailored to the site. For example, Wilson’s Promontory National Park is closed to the public because operations are conducted in the main visitor camping area, whereas the Bogong High Plains Unit of the Alpine National Park is well signposted but not closed because of the geographical separation allowed by the large size of the treatment areas (approximately 4000ha each), the relatively low number of visitors, the differing terrain requirements for hunting and bushwalking and because recreational hunting and bushwalking coexist without issue in other areas in the Park. It goes without saying that volunteers operating in the Bogong High Plains program apply safe shooting practices, i.e. identify target and backdrop, know where the bullet will go, and where it will stop, and no shooting within 250m of visitor sites.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 14 Case Study: Alpine National Park (ANP) Deer Control Trial 2014 - 2020
45. The ANP Deer Control Trial is a multiple year control trial conducted at two study sites – the Bogong High Plains and the Howitt-Wellington Plains. There are 4 treatment areas at each site, 2 where targeted deer control is occurring and 2 where no deer control (other than recreational hunting where this occurs) is occurring. The trial involves pre- control monitoring, 3 years of control and post-control monitoring. It will take six years to complete the program over the two sites.
46. The Bogong High Plains program involves targeted deer control in 2 treatment areas of 4000ha each. Shooting is undertaken by volunteers from the ADA and SSAA, and by contract shooters using a range of ground shooting approaches. There are two adjacent 4000ha reference areas where no control is applied to allow comparisons.
47. The treatment areas consist of alpine peat-lands, grassy plains, open and closed heath and sub-alpine woodland with significant areas of thick re-growth scrub at lower altitudes. The areas are chosen for their high environmental value, and alpine bogs are present in all sites. The deer population are not habituated to humans, and are as difficult to hunt as any sambar (as previously noted, sambar deer are renowned as one of the most difficult animals to hunt in the world).
48. Procedures common to Contractors and Volunteers. The Park is not closed to the public, and all entry points are signposted to advise Park users of the activity. Protocols and procedures for safe shooting are in place, and bushwalkers and tour groups are formally advised of operations. Hunting methods for both Contractors and Volunteers will include daytime stalking as well as spotlighting from vehicles and on foot at night. Operations are overseen by PV staff, and shooters are issued PV trunking radios and PV GPS units in order to report regularly during operations, and to log data for Cost Per Unit effort (CPUE) information. In this way, PV staff can track the shooter’s position throughout the operation.
49. Contractor Operations. In the deer control treatment area where contract shooters have been operating the first control operation was conducted in May 2016. Contractors will use thermal and infra red devices to locate deer by day and by night, and shoot deer with Suppressed Category B (bolt action) firearms by day (because bolt action rifles are lighter to carry and targets are fewer), and use suppressed Category D (semi-automatic) firearms for night shooting. Operational planning is left to the contractor, who is given guidance and operating parameters by PV staff. Operations are overseen by PV staff, and Contractors are issued PV trunking radios and required to report regularly during operations.
50. The Author was invited to attend the initial contractor operations and visited the Contractor’s camp at Tawonga Huts over the period of 22/23 May 2016. The Author witnessed first-hand the professional conduct of the contractors, who were well organised and kitted out. The arrival of a group of around 12 Year 9 students of the Bogong Outdoor School presented a unique opportunity for the PV staff, contractors and the author to address the school group and answer questions from the students. The discussion was respectful, and the questions from the students were well considered, and showed a balanced viewpoint.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 15 51. Volunteer Operations. In the deer control treatment area where volunteers have been working, operations are currently conducted for 2-3 days each month depending on site access over the winter period in the dark phase of the moon. Hunting methods started with daytime stalking in pairs and spotlighting from vehicles at night using Category B (bolt action and single shot) firearms without suppressors fitted. As the program developed through the usual “Forming”, “Norming” and “Performing” process, experience levels improved and procedures were designed that allowed daytime stalking singly to reduce noise, the conduct of “deer drives” by small groups of beaters and hunters, and also spotlighting on foot and from static locations.
52. The PV Staff are very easy to work with and always keen to try new methods, and support any well considered suggestion. Several volunteers have purchased infra red and thermal image optical devices at significant personal cost (around $3500 per device) and rifle mounted spotlights (around $300 per device) to increase effectiveness, and this has seen the cull rate increase.
53. Operational planning is managed by PV staff and PV retains full oversight, with staff physically located in the hunter’s camp, and radio contact with shooters maintained via PV Trunking radio. In time, it is envisaged that PV staff will provide operational direction to the shooters, and retain oversight from their base location and that the Volunteers will manage the conduct of the operation, as occurs with contract shooters.
54. To ensure safe and smooth function of operations, volunteer hunters have researched PV policy and procedures, collaborated and written a range of “Standing Operational Procedures” (SOP) for the Program. The SOP have been widely circulated for stakeholder comment, and will be adopted across all programs. A list of SOP titles is presented in the table below, and a copy of the SOPs can be provided on request.
List of PV – ADA – SSAA SOP SOP 1 Working with Parks Victoria – a Guide for Volunteer Shooters SOP 2 The Chain of Responsibility and Duties of on Ground Staff and Volunteers SOP 3 Deconfliction of Culling activities SOP 4 Clothing and Equipment SOP 5 Spotlighting from Vehicles, on Foot and from Static Locations SOP 6 Operating Alone as part of Culling Activities SOP 7 Templates for LOCSTAT (location reporting) and MEDEVAC SOP 8 Fatigue Register SOP 9 The Planning, Conduct and Management of Shooting Drives
55. Procedural Limitations. There are few procedural limitations in the Bogong High Plains Deer Management program. This is mostly due to the flexibility of PV staff, any procedural limitations are discussed in detail, and considered using an adaptive management approach, such as rehearing and “walking through” the procedure to fully understand it, and to adjust as required to improve safety and performance.
56. Terrain Limitations. The terrain within the treatment area is limiting in many places. Tracks are minimal, and vegetation is thick, especially in regrowth areas, however methods “tailored to location” are developing with knowledge of the area; and PV staff are debriefing hunters after each activity so that collective knowledge is captured. Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 16
57. Equipment Limitations. There are some equipment limitations that, if addressed, would increase effectiveness. These are discussed in the following paragraphs:
a. Thermal imaging and Infra red sighting devices. PV has procured hand held thermal imaging devices for use in management programs. This equipment has significantly improved engagement opportunities. For example, using white light a spotlighting team saw and shot four sambar in one night, and were unable to locate two of the shot sambar, even with a scenting dog. In comparison, a spotlighting team travelling the same route in similar conditions but using a handheld thermal device and thermal rifle scope saw 17 sambar at ranges out to 600 metres and killed four (animals sighted by thermal imagery are often obscured by vegetation, preventing a safe shot. This was a significant factor in the low kill to sighting rate, and this technology is now being used in the more open areas of the treatment zone to excellent effect). Once killed, all four animals were located quickly by their heat signature using the thermal camera.
b. Suppressors. The use of suppressors is controversial in Australia, but is widespread in New Zealand, the UK and Europe, where they are used without incident. Much of the controversy involves police concerns about the potential criminal misuse of suppressed firearms that do not stand detailed scrutiny. Given that the average hunting rifle is over one (1) metre in length, and that suppressors add at least an additional 30cm to the length of the firearm they are difficult to conceal. When used with high velocity hunting ammunition, suppressors are not “silencers”; and reduce the noise of a high velocity gunshot by about 30Db, from around 140dB to around 110db (for comparison, a thunderclap is 120dB). This reduces the echoing “boom” of a muzzle blast to a loud crack, removes muzzle flash, and augments the shooter’s worn hearing protection to reduce long term hearing damage. The suppressor also reduces much of the concussive and disruptive effects of recoil allowing for more accurate shooting, and suppressors also allow firearm sights to be checked by test firing in a safe area without undue disturbance to the location immediately prior to operations (in case they were knocked in transit). These factors all translate into positive animal welfare outcomes, but not to criminal use.
c. Suppressors and Silencers are covered under Section 57 of the Firearms Act 1996 and applications are made on an individual basis. Person’s eligible to use a suppressor or silencer include (among others) an employee of a government agency such as PV or DEPI (now DELWP); a Professional Hunter or a person who works as subcontractor for a professional hunting organisation. In PV management programs, volunteer hunters are in fact acting in a similar role to PV employees and also to Professional Hunters, so the Author’s standpoint is that volunteer hunters should be permitted to use suppressors in Crown land control programs.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 17 d. In addition to the human welfare benefits, suppressors diffuse the noise of the gunshot, making it difficult for animals to locate the position of the shooter, causing the animals to pause before running away, thus presenting additional targeting opportunities. It is noteworthy that contract shooters commonly use suppressors for these reasons, and openly state that they would not operate without a suppressor fitted to their firearm (pers comm. Author/Professional Hunter, May 2016).
e. Given that volunteer hunters have been proven to be persons of good character by the police records checks in the firearm licensing process, have undertaken additional education and skills programs, and are operating in a controlled and government supervised hunting situation where government employees and contractors would be permitted to use this equipment, the Author feels that the benefit in animal welfare and efficient culling outweighs the risk of criminal misuse.
f. Suppressors and Subsonic ammunition. Those who oppose the use of suppressors by volunteer hunters will argue that the use of sub sonic ammunition with a suppressor will significantly reduce the noise of the shot; however subsonic ammunition is a poor killer on animals due to poor bullet expansion, poor trajectory and significantly reduced range. There is no place for subsonic ammunition in wildlife management, and its use is contrary to the aims and principles of the Prevention of Cruelty to Animals (POCTA) Act as well as the ADA Code of Conduct.
58. Recommendation. It is recommended that volunteer hunters who are qualified in DMP or CPM, and who can demonstrate that they regularly participate in control activities under either the DMP or CPM be approved to import, purchase and use suppressors on a nominated deer caliber firearm. This places the onus of purchase, safe storage and use onto the volunteer.
Consideration of the application of these types of programs for other invasive animal species in partnership with Crown land managers.
59. Managed volunteer shooting programs on Crown land are widely applicable for a range of invasive animal species. Volunteer hunters are currently conducting rabbit culls at Werribee Mansion and other areas of private land; and hunting organisations and individuals are working with private landholders, Conservation NGOs and Government departments across multi-organisational boundaries to manage fox, pig, goat and deer populations across Victoria. FGA are conducting fox drives on land managed by DELWP, and on adjoining private land across Victoria, SSAA are shooting goats in State Parks at Mt Mittamitite near Corryong, and the author, representing ADA, shot Noisy Miners at Chiltern; thus, in the author’s experience, the use of volunteer hunters is already occurring widely and is only limited by budget and imagination.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 18 Assessment of the relative costs and benefits, financial or otherwise, of other forms of pest control in national parks.
60. Financial Costs and benefits. Pest control, or more correctly, management of overabundant and/or invasive native and introduced species in national parks will always come at a financial cost. Prior to the volunteer hunting organisation wildlife management initiative, wildlife management in national parks was mostly conducted using Parks staff or contractors to shoot, poison, remove harbor and otherwise disrupt the population of the target species.
61. Plenty of work for contractors and volunteers. There is good use to be made of both contractors and volunteers, for example, in South Australian National Parks; volunteer shooters are used to follow up aerial shooting when aerial shooting is no longer economically viable. It should also be noted that experienced contractors are in high demand, and will naturally prefer high volume and high paying contracts, whereas volunteers are usually keen to take on most projects, so the choice between using contractors or volunteers may come down to annual project funding and volume of work. The community engagement aspect of using volunteers is also a significant consideration. Lastly, most contractors started out as recreational shooters, and volunteer management programs may well be a useful conduit for contractor recruitment.
62. One off use of a single control method will always fail. The history of wildlife management in Australia is a litany of one off activities that are relied upon in isolation; indeed, recent media reports of a Queensland Council trying to remove feral goats from an island in the Great Barrier Reef are a good example of poor management outcomes using the serial application of one off use of a single pest control method. In this particular case the land manger had: “tried shooting, then tried trapping, then tried baiting and is now releasing wild dogs implanted with a time soluble lethal dose of 1080 poison to kill the goats – all workable options, but applied in a sequence of one off programs. Budget is always a limitation, however, it is often better to invest significant resources in the first instance and “use a sledgehammer to break an egg”.
63. The success of an integrated approach. A well designed management program would incorporate, shooting, baiting, trapping and wild dogs at the same time to reduce the ability for the problem species to adapt or modify its habits in response to a single management method. This “Integrated Wildlife Management approach” is widely recognised as being effective “best practice”.
64. Current Management Options. There are several current management options for overabundant and invasive wildlife control, and the key to effective and sustained management is to use all options in an integrated approach across a broad, landscape scale program. The current Governor in Council order that allows Spotlighting of deer on private land is proof that the Game status of deer in Victoria is no barrier to the species being managed as required, and that pest listing for deer is not required.
65. The management methods discussed in the following paragraphs are all effective, and all applicable, and should form an integrated “Manager’s golf bag” of solutions that are employed in an integrated wildlife management approach as appropriate.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 19 66. Ground Shooting. Ground shooting using volunteer or paid shooters can be very effective, as discussed throughout this submission.
a. Is there a price difference between Volunteers and Contractors? PV volunteer management programs use volunteers in a very similar way to contractors, and the benefit is that contractors and volunteers can be used as required, and do not represent an ongoing personnel and equipment management liability for the host agency. Contractors and volunteer programs cost money in terms of PV staff time, and in equipment and resources, and a detailed financial comparison may show that there is little difference in program costs.
b. Is there an efficiency difference between Volunteers and Contractors? A comparison of effectiveness between contractors and volunteers will always be biased towards contractors because they have access to specialist plant and equipment, and because they gain significant experience culling wildlife as a full time job. That said experienced volunteer shooters can produce similar effects if provided access to similar equipment, and given similar freedom of action to operate. The benefit of using volunteers is in the ready availability of a significant pool of volunteers, all trained to the same standard and managed by two organisations (ADA and SSAA) who partner on operations. For example, should PV require 40 shooters for a program at short notice they can organise this within a few days by dealing with two organisations. Organising 40 contract shooters would mean dealing with perhaps 25-30 separate businesses, most of whom would not have worked together previously and would not share common procedures.
67. Aerial (Helicopter) shooting. This practice is used in other states including NSW, SA, WA, QLD and the NT. It is very expensive and most effective on high population concentrations in open country, such as feral pigs, water buffalo, camels and wild horses. The NSW National Parks and Wildlife Service (NPWS) have employed aerial shooting on deer in the tall forests near Mt Kosciusko to good effect, although tree canopy is a limiting factor.
68. Electric and exclusion fencing. A number of landholders are having good results using electric fencing to exclude sambar, red and fallow deer from high value crops, and some Northeast Victorian Landholders are effectively protecting their livestock from wild dogs using electric fencing. One Mitta Valley landholder interviewed by the author erected a 5 strand electric fence 1.5m high to keep sambar deer off his commercial hazelnut orchard and had no problems with deer in that section of his property (Pers-comm Author / Mitta Valley Landholder)
69. Chemical deterrents. A number of landholders conducting revegetation work with Landcare are using chemical deterrents to good effect. Once commercially available product is “Sen-Tree”. Most of these products are a mixture of soap, egg and sand or grit sprayed on trees with a binding agent (usually watered down PVA glue). The author has used these products on revegetation projects, and they have deterred rabbits, deer, hares and wallabies from browsing the newly planted trees.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 20 70. Human Scent. For urban and peri urban issues, one of the best deterrents is human scent, and for many years urban and peri urban landholders have had good success leaving sweaty T shirts or used handkerchiefs on trees rubbed by deer. The author has found that these items usually need to be replaced every few days for best effect.
71. Future Management Options. Options such as poisoning are not currently legal for large animals such as deer. This may change in time, and any proposal for the use of poison should consider the environmental, logistic, and social cost.
The costs and benefits of the Victorian Recreational Deer Harvest
72. No assessment of the relative costs and benefits other forms of invasive and overpopulous wildlife control in National Parks would be complete without a discussion of the Victorian Recreational Deer harvest. The GMA advise that the Victorian recreational deer harvest was 60,000 animals in 2015, with 30,000 of these deer being harvested in the Alpine National Park. A study into the economic benefits of recreational hunting in Victoria found that around $480 million dollars is spent annually by hunters, with a significant percentage of this being spent in rural areas.
Part One Conclusion
73. Evidence of the financial, social and environmental benefit of using volunteer hunters to manage overabundant and invasive native and introduced wildlife on crown land is as abundant as it is quantifiable. The evidence presented in this submission proves beyond any doubt that that, given access to the same equipment, there is little difference in professionalism, effect or outcome between the use of contractors and organized and well led volunteer hunters. The main benefit of using contractors is that they have access to specialist equipment, such as thermal imaging and infra red optics and suppressed firearms. Other management options, including poison, should be used where safe and appropriate.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 21 Submission Part Two
Examples of the contribution of Hunting Organisations and individuals to Invasive species management.
The ADA’s contribution
74. ADA defines Deer Management as: “The management of wild deer impacts on public or private land by all legal means to the level required by the landowner or manager”. The objective of the ADA Deer Management Program (DMP) is to undertake an immediate and sustained landscape scale harvest effort, with a focus on female deer to reduce impacts and conflict thus achieving positive environmental, financial and social outcomes, while maintaining the status of deer as a game animal. ADA believes the overabundant native and introduced species can be managed using well coordinated volunteer hunters without significant change to existing legislation.
ADA Case Studies
75. The following brief case studies are presented to demonstrate the significant and sustained contribution of hunting organisations and individuals to invasive species management. The following examples are provided by the ADA and the author, and are indicative of a number of individuals and hunting organisations. All of these programs are conducted at no cost to the landholder, and volunteers freely give their time and expertise.
76. Economic Impact Case Study. In this program, sambar deer are impacting on a 70ha grazing and vineyard property in West Gippsland. The landholder approached ADA to reduce the impacts of deer and swamp wallabies on vineyard production. The program has been operating since August 2013, and has removed 50 deer and a number of wallaby of all age and sex classes. The Landholder estimates that his losses have reduced from $25.000 p.a. in 2012-2013 to $500 p.a. in 2013-2014, and to $200 in 2014-2015.
77. Environmental Impact Case Study. This program is conducted on several Trust for Nature (TfN) covenanted properties in East and West Gippsland (all with a crown land boundary). The average property size is less than 20ha. Landholder requirements are to reduce deer and swamp wallaby browsing on endangered native species and also on private gardens. The program has operated in East Gippsland since August 2013 and in West Gippsland since July 2015. Outcomes to date are over 100 deer and a number of wallaby taken in East Gippsland, and 30 deer and a small number of wallaby taken in West Gippsland. The Landholders are very pleased with the reduction of impacts.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 22 78. Landcare Deer Workshops. As a passionate deer hunter, conservationist and Landcarer, the author designed a presentation for Landcare groups in North – East Victoria, titled: “Living with Deer” that explained deer biology and habitat use, and outlined a number of lethal and non lethal management methods that landholders can use to manage deer. This presentation was delivered to several Landcare groups, and led to the author being requested to present “Living with Deer”, and also to brief a number of Landcare Groups on what hunting organisations could do to assist landholders at Community Deer Workshops hosted by Landcare Groups. The author also wrote a discussion paper on how different species of deer feed, and how much deer eat, in order to inform stakeholders. This paper can be provided on request.
79. The purpose of the Community Deer Workshops was to allow the community to discuss the economic, social and environmental issues surrounding deer, and to inform the community of the laws, regulations and management opportunities for deer. A typical Deer Workshop will involve landholders and community stakeholders, local Police, Catchment Management Authority, PV, DELWP and GMA Compliance and the ADA and SSAA. At each Deer Workshop, the three high priority issues that were identified are: (1) Environmental and Financial impacts, (2) Carcass disposal and (3) Illegal shooting.
80. Managing the issues raised in the Deer Workshops. The preceding paragraphs demonstrate the reduction in financial loss and environmental impacts that is possible when using recreational hunting, and / or volunteer shooters in coordinated management programs as part of an integrated wildlife management approach. Illegal shooting was discussed in the section on Community Safety. Carcass disposal will be discussed in Part Three of this submission.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 23 The use of community based volunteer hunter programs in other Australian States.
81. Across Australia, Landholders and Government and private Landmanagers are increasingly embracing the use of organised hunters in community driven wildlife management programs. A table outlining community based volunteer hunter program operating in other Australian states is presented below.
Description of Community Based Hunting Organisation Programs State Approved activities WA Recreational hunting is permitted on private land. Recently approved invasive species management programs on Crown Land. SA Recreational hunting is permitted on private land. SSAA Flinders Ranges Goat and control program operating for over 30 years. Recent use of Volunteers to manage invasive species in some National Parks. NT Recreational hunting is permitted on private land. Recently approved invasive species management programs on Crown Land QLD Recreational hunting is permitted on private land. Recently approved invasive species management programs through SSAA and ADA on Crown Land. NSW Recreational hunting is permitted on private land. Recently approved invasive species management programs on state forests, managed by NSW DPI, and in national Parks under the Supplementary Pest Control Program partnership between NSW NPWS and SSAA NSW. VIC Recreational hunting is permitted on private land. A long history of recreational hunting for native and introduced game species on Crown land. Commenced CPM Program with SSAA and the DMP with ADA around 2003/4. ACT Recreational hunting is permitted on private land; however there is no recreational hunting on crown land. Overabundant native and introduced species management is conducted by contractors or government staff. TAS A long history of recreational hunting and control programs for native and introduced wildlife, such as duck, wallaby and deer on private and Crown land. Commenced (private) Property Based Deer Management Programs more than 20 years ago, which improved landholder relations and reduced illegal hunting. Also conduct Rabbit Control on offshore Islands such as Macquarie Island using volunteer shooters.
Part Two Conclusion
82. The contribution of Hunting Organisations and individuals to invasive species management is significant, sustained and increasing in scope and complexity. The aim of targeted wildlife management programs must always be to undertake an immediate and sustained landscape scale cull in order to achieve positive environmental, financial and social outcomes. This can be achieved without significant change to existing legislation by using well coordinated volunteer hunters to “Hunt like wolves” and target the breeding population of females of the overabundant species to maximise the cull effect and reduce impacts and land use conflict.
Recommendation
83. The Victorian Government should formally recognise the contribution of biodiversity provided by the engagement of managed, community driven wildlife management programs, and should remove any administrative or bureaucratic impediments to program success.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 24 Submission Part Three
Contributing factors, and legislative matters that, if modified without full consideration, may have negative and unintended financial and conservation consequences on a range of public and private stakeholders and agricultural industries.
Carcass disposal
84. Disposal methods. Under current law, deer carcasses may not be sold or traded. There is concern among landholders that any control operations they conduct will produce significant numbers of deer carcasses that may attract wild dogs if left to decompose in the field. The Meat Industry Act Section 35 allows for a Governor in Council order to permit deer carcasses to be disposed of to “knackeries”, and this option appears to be the simplest solution. Other options include gifting carcasses to dog shelters or Hunt Clubs, both of which feed a significant number of dogs each day. Other carcass disposal options include covering carcasses with lime, burning or burying.
85. Commercial harvest. There appears to be little interest in commercial harvest for human consumption or pet food, however these options should be considered, as they have the potential to offset costs for landholders through royalties. However; any venison “market” created should be managed by Prime-Safe to ensure the product is safe to eat, and the shooter is trained and accredited. A “backyard” venison market, where any shooter can sell venison could in fact increase the illegal shooting activity and thus the public safety risk, as occurs presently with the illegal venison market.
Pest Status - Why demonizing overabundant or invasive native and introduced wildlife is counteractive to effective population management
86. Terminology. A number of stakeholders apply the emotive term “Pest” to introduced, overabundant or invasive species when those species cause negative social, environmental or economic impacts. This practice of “demonising” a species to create the social licence that will secure research funds, or allow the species to be culled, or commercially utilised either for pet food or human consumption is common in Australian and New Zealand wildlife management practice but not often encountered in Africa, Europe, the UK and the US due to most species such as deer, being native to these countries.
87. The Author believes that overabundant and invasive native and introduced species respond to management rather than name calling. Indeed, if Australians subscribe to the simplistic view that only introduced species are pests that need to be managed; the land manager’s job becomes difficult when faced with managing invasive native species, such as the Noisy Miner (which has been declared a Key Threatening Process in some states) or overabundant native species, such as the Eastern Grey Kangaroo.
88. Unintended Negative Consequences. Deer in Australia are often called a pest, and few would argue that they are invasive, and in some areas causing negative financial and environmental impacts, however; with recreational deer hunting in Victoria generating $480million in expenditure, hunting related tourism is also a valuable recreational resource. The bottom line is that all wildlife requires sustained management. Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 25 89. A detailed examination of the situation, including the various legislation, regulation and law reveals that removing Game Status for deer in Victoria will give no additional management benefit to land managers, and could have the unintended consequence of making individual landholders financially responsible for the removal of deer from their properties, as presently occurs with other pest species such as rabbits. Indeed, in Queensland, where deer are declared a pest, landholders are now required to have a management plan for deer on their properties. This is sound practice, but the requirement adds another layer of administration and scrutiny to landholders, and would be legally enforceable should the government of the day decide to take action. Other consequences of pest listing are outlined below:
90. No change to current legal management methods. Declaring deer a pest will not change current legal management methods for land managers – the only legal method of lethal control is by shooting, and there are regulations regarding minimum calibers and bullet weights to support humane control. There is no current legal poison or specialised poison delivery mechanism for deer; and “Game status” does not prevent the development or application of a suitable toxicant or specialized delivery method for deer as part of a management plan.
91. No restrictions on private land. Apart from the closed season on sambar deer in the Alpine National Park over the high visitor use period of summer, and the closed season on hog deer (which are mostly in very low numbers) there is no closed season or bag limit on any of the deer species found in Victoria; and Landholders can engage contract shooters or volunteer shooters to control deer. Additionally, the current Governor in Council (GiC) Order allows for spotlighting, night vision and thermal imaging to be used by landholders who are impacted by deer, and these methods are proving very effective if applied in a well considered and sustained manner.
92. Alpine National Park closed to recreational hunting. In Victoria today, there is effectively a 9 month hunting season in National Parks that involves up to 31,000 licensed hunters conducting disbursed hunting activities across all Parks where hunting is permitted. Parks Victoria has openly stated that they will not allow recreational hunting of pest animals in National Parks, therefore if deer are declared pests; at least 30,000 deer will not be harvested annually from the Alpine National Park, which will compound the overabundance and environmental issues within the National Park, and the adjoining private land.
93. Some organisations, like the VNPA recommend replacing current recreational hunting access with a 2 month hunting season involving ADA and SSAA trained volunteers, under direct supervision of Parks Victoria Staff in targeted programs. This option ignores the broad scale and cost free population reduction provided by the recreational harvest, that, while difficult to measure is certainly having an impact.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 26 94. The VNPA proposal does not stand detailed scrutiny. Using 2015 figures, the VNPA proposal seeks to use less than 1% of licensed hunters (around 310 hunters actively involved in programs in 2015) to have to harvest 100 deer each over a 2 month period to equal the 2015 recreational harvest. Additional factors that would limit success are the allocation of Park Victoria staff and physical resources; the shooters balancing volunteer activities with a full time job; rest periods as part of fatigue management for spotlighting shifts and bad weather. This could reduce the shooters time on the ground to around 16 days. So, in effect, the VNPA expects 310 volunteer hunters to harvest around 7 deer each 24 hour period, just to equal the 2015 Recreational harvest, which the VNPA itself regards as insufficient.
95. In addition, 31,000 licensed deer hunters, most of whom now hunt in the Alpine National Park will seek private land hunting access, reducing the spatial separation that contributes to the safety of hunting, and distracting farmers from their core business. This is a very good reason why hunters need a voice in the VNPA.
96. Loss of recreational hunting revenue. Recreational hunting will be reduced to pest control, and some hunters will find another recreation. This could lead to reduced expenditure by hunters in regional areas.
97. Loss of Scent trailing Hounds. Those who hunt with hounds declare that the use of scent trailing hounds is a very effective control method for sambar deer. If deer lose game status, scent trailing hounds will be banned as the POCTA Act does not permit the use of hounds to hunt pest species.
Part Three Conclusion
98. A detailed recognition of the complex elements of amending legislation is required to foresee and prevent negative and unintended financial and conservation consequences for a range of public and private stakeholders and agricultural industries. An exemption to the Meat Industry Act Section 35 is the simplest solution for carcass disposal.
99. Overabundant and invasive native and introduced species respond to management, and are a significant financial resource. Legislators must consider the potential loss of recreational deer hunting revenue, the transfer of management responsibility to individual landholders, with no change to available management methods; the loss of recreational hunting of deer in the Alpine National Park, and the loss of spatial separation that contributes to the safety of hunting. In short, listing deer as pests will compound overabundance issues within National Parks, will disincentivise hunters, and will create conditions where land managers and the public will blame the government for not managing deer.
Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 27 Recommendations
100. Carcass disposal. An exemption to Section 35 of the Meat Industry Act by a Governor in Council order to allow deer carcasses to be disposed of to “knackeries” is recommended as the most simple carcass disposal solution.
101. Retention of Game status for deer. Because Pest status will give no additional management benefit to land managers and may have undesirable environmental, financial and social consequences, it is recommended that deer retain their status as Game.
102. If deer were to be listed as a pest species, it is recommended that:
a. Individual landholders are not made financially responsible for the removal of deer from their properties unless they originally owned the deer.
b. Crown land areas with a history of recreational hunting such as the Alpine National Park, where deer hunting is presently permitted, should allow the continuation of deer hunting regardless of the animal’s status as either game or Pest.
c. The POCTA Act should be reviewed and revised to allow the continuation of the use of scent trailing hounds as a method to control sambar deer on land where the practice has been traditionally carried out.
Submission Conclusion
103. The requirement for sustained management of invasive and overabundant wildlife is a constant and enduring challenge. Recreational hunting, and the use of community based hunting organisations and volunteer hunters to manage invasive and overabundant native and introduced wildlife as part of an integrated management approach is, by any measure an outstanding success in Victoria, and is increasingly used across Australia because, with leadership and sound management, it delivers the triple bottom line of positive environmental, social and financial outcomes. Hunting is recognised worldwide as an effective wildlife management tool, and in Australia, hunting has a long but understated history of sustained operations, and an enviable safety record. There is significant scope for the expansion of volunteer wildlife management programs across most land tenures; and it is up to hunting organisations and those charged with management of Crown land to provide suitable leadership, sound policy and practice and opportunity. It is also up to the volunteers to improve their knowledge, skills and attitudes to become better hunters, and to lift their commitment and participation rate in these valuable programs. The government’s role in this is to reduce or remove any impediment to success, and to fully consider the ramifications of policy and legislative change. Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 28 List of Submission Recommendations Part One - The Benefits of Government agencies using Community Hunting Organisations and Individuals in the control of invasive animals on Crown land.
Recommendations related to biodiversity outcomes and impacts:
The use of Hunting Organisations and Individuals in the control of invasive animals on Crown land is safe and broadly applicable to most wildlife management programs as part of an integrated management approach, so should continue and expand.
Any measurement of program success must be considered in broader terms than a cull tally or reduction in negative impacts at a specific location, and should include volunteer participation rates, lessons learned that will improve community engagement, improved knowledge of the target species, and the landscape scale impact on the target species, such as reducing overall populations and disrupting environmental impacts.
Recommendations regarding Community Safety
Hunters should be represented in the Victorian National Parks Association (VNPA), so that they can collaborate with other user groups, contribute expertise, and be consulted as a stakeholder.
Unsupervised recreational deer hunting on Crown and private land should continue, and opportunities to shape the recreational hunter effort should be explored.
In recognition of the increasing popularity and rapid growth of recreational hunting, the excellent safety record, low cost, and the demonstrated positive benefits to community engagement and to biodiversity outcomes, recreational hunting should be expanded to all areas of Crown land where it can be demonstrated as safe to do so (via the development of a practical, risk assessment process based on the method used to assess areas for suitability of use as military field firing ranges in collaboration with the Australian Defence Force, hunting organisations, VICPOL and the Crown land manager). This process should be widely promulgated to landholders and other state Government Authorities as part of knowledge sharing to benefit all communities.
Current Game Laws and Regulations are working well, and there is no requirement to change them. There is; however, a significant gap in enforcement that needs to be addressed.
Hunting organisations should be able to apply for government grants to conduct and manage hunter education, perhaps drawing on Game Licence revenue.
Any change to management or status of Public Land should be well considered, and should include hunting organisations as a stakeholder group in all collaboration. For example, the connection of existing parks or the creation of new National Parks on Public Land where deer hunting is presently permitted should continue to permit deer hunting.
Increase the number of GMA Wildlife Officers and arm them with self defence tools as issued to VICPOL and Melbourne Train Guards, such as pistols, “Tasers” and Pepper spray, and authorize the GMA to conduct targeted and random field operations. Submission by Robert (Bob) Gough to the Parliament of Victoria Inquiry into the control of invasive animals on Crown Land 29 Part Two - Examples of the contribution of Hunting Organisations and individuals to Invasive species management
Recommendation. The Victorian Government should formally recognise the contribution of biodiversity provided by the application of well organised and managed community driven wildlife control programs, and should remove any administrative or bureaucratic impediments to program success.
Part Three - Contributing factors, and legislative matters that, if modified without full consideration, may have negative and unintended financial and conservation consequences on a range of public and private stakeholders and agricultural industries.
Carcass disposal. An exemption to Section 35 of the Meat Industry Act by a Governor in Council order to permit deer carcasses to be disposed of to “knackeries” is recommended as the most simple carcass disposal solution.
Retention of Game status for deer. Because Pest status will give no additional management benefit to land managers and may have undesirable environmental, financial and social consequences, it is recommended that deer retain their status as Game.
Were deer to be listed as a pest species, it is recommended that:
- Individual landholders are not made financially responsible for the removal of deer from their properties unless they originally owned the deer.
- Crown land areas with a history of recreational hunting such as the Alpine National Park, where deer hunting is presently permitted, should allow the continuation of deer hunting regardless of the animal’s status as either game or Pest.
- The POCTA Act should be reviewed and revised to allow the continuation of the use of scent trailing hounds as a method to control sambar deer on land where the practice has been traditionally conducted.