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Steve Dunn Review of the Game Council C/ Department of Primary Industries Level 6, 201 Elizabeth Street Sydney NSW 2000 [email protected]

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Steve Dunn Review of the Game Council C/ Department of Primary Industries Level 6, 201 Elizabeth Street Sydney NSW 2000 Gamecouncil.Review@Dpi.Nsw.Gov.Au Steve Dunn Review of the Game Council C/ Department of Primary Industries Level 6, 201 Elizabeth Street Sydney NSW 2000 [email protected] 22 May 2013 Dear Mr Dunn, RE: Inquiry into the NSW Game Council The Invasive Species Council is pleased to be able to offer its perspective on the NSW Game Council to inform the review requested by the Premier. The inquiry’s terms of references are at Attachment 2. This submission does not represent our full range of views on the NSW Game Council, but seeks to provide a selection of information to assist your inquiry. Ineffectiveness The Game Council has not been accurate in its claim that hunters achieve conservation outcomes and are effective in reducing numbers of feral animals. A statutory body needs to be truthful, scientific and factual in its work. The main example of the misleading work of the NSW Game Council is its claim of effectiveness. Since its establishment, the NSW Game Council has not credibly measured its conservation effectiveness. As the former CEO of the Invasive Animals CRC, Tony Peacock said: Simply quoting the number of animals killed by Game Council licensed hunters is not enough to demonstrate value. We all go on about measuring impact, not numbers, so there needs to be a demonstration of a positive impact. (see Attachment 1.) The Invasive Species Council prepared two briefings that provide detailed concerns about hunters and the NSW Game Council, one on conservation hunting in 2009 and another about recreational hunting in 2012 (both attached as Attachments 8 and Attachments 9 respectively) that demonstrate why simply counting the number of species shot by hunters is not a measure of effectiveness. The NSW Game Council often quotes the use of volunteer shooters in national parks in Victoria and South Australia to support the hunting program in NSW national parks. These states run integrated feral animal control programs, rather than the ad-hoc program run by the NSW Game Council, and should not be used to support the hunting programs of the NSW Game Council. Regarding the Victorian government’s use of hunters and shooters, the VNPA fact sheet sets out the situation well. This Fact Sheet is attached (Attachment 5) and can be found at : http://vnpa.org.au/admin/library/attachments/PDFs/Fact%20sheets/FACT%20SHEET-shootinginparks.pdf The fact sheet states: • “…recreational hunting for Sambar Deer has shown no capacity at all to reduce the numbers of this animal, even though there is now no bag limit on Sambar: • Recreational hunters are primarily motivated to ‘farm’ Sambar, making sure there remains a sustainable, or preferably increasing, population. • The frequent and random disturbance of Sambar (or other target species) results in more wary animals that are more difficult to control in the future. • Hunters tend to avoid areas where the probability of finding their target is low, thus leaving a population able to expand again.” and “In summary, pest control programs using accredited volunteer hunters in parks in Victoria: • Operate as specific strategic programs, with specific objectives aligned with the park • management plan. • Are under the control of Parks Victoria staff. • Involve considerable staff time in planning and supervision, and therefore require considerable budget allocations. • Operate with a very small number of volunteers, less than 1% of licensed game hunters in Victoria. • Have achieved varying levels of success.” Allowing the Game Council to actively promote deer hunting and to advocate within government to prevent it being declared a pest species or to use effective control measures on private land will see the range of this destructive pest species continue to expand. Lack of Hunter Competence The recent accident this year where a volunteer shooter shoot another volunteer shooter in Onkaparinga River National Park in South Australia highlights the need to ensure that all shooters have appropriate skills before allowed to participate in any volunteer shooting program. In response, the South Australian government suspended all programs involving volunteer shooters until a safety review is carried out. Last 2 week the Invasive Species Council was told by a SA Government official that this review is likely to lead to the tightening of requirements for competency testing for volunteer shooters. We attach a recent international study conducted by the Deer Commission in Scotland in 2008 comparing the competency requirement for hunters across 20 countries (see Attachment 6). This study found that all countries had a competency test and that this assisted with hunter/shooter safety and effective and humane killing of the target species. Also attached are details of hunting in Sweden and the requirement that a detailed competence test must be carried out before a firearm can be used (Attachment 7). Culture The current culture of the NSW Game Council is defensive, lacks scientific rigour and is hostile to those that do not agree with it. A document demonstrating the NSW Game Council’s long term views and broader political and cultural agenda is “Conservation Through Hunting: a broader environmental paradigm change in NSW” (Bauer and English 2011, Attachment 3). It reveals the broader objectives of hunters on the Game Council. It is inappropriate for the NSW Game Council to fund and promote such a plan. We had direct experience of the hostility of the Game Council to those expressing contrary view to its own when the Game Council responded to our proposal to declare deer a pest species in NSW in 2009. The Game Council issued a media release (end of May or early June 2009, since removed) titled: “Declare Invasive Species Council feral, not wild deer". In the media release the NSW Game Council accuses ISC of being an "ill- informed nuisance organisation" that is "seeking to impose extremist environmental messages onto governments" because the Invasive Species Council called on NSW to follow the lead of Queensland and South Australia (and Western Australia) by declaring deer a pest. Subsequently the Invasive Species Council replied via its own media release on 2 June 2009 (http://www.invasives.org.au/mediaReleases.php?MediaReleaseId=15&year=2009). In this media release we stated: "their [NSW Game Council’s] claim that declaration as a feral species would increase the environmental harm deer cause is difficult to understand, and the game council provides no information to substantiate this," Mr Low said. The Invasive Species Council then requested that the Game Council remove incorrect assertions about our work from its website. They refused to do so. As a result we lodged a complaint with the NSW Ombudsman. The NSW Ombudsman found against the Game Council. In the 2009-10 Annual Report, the NSW Ombudsman stated (page 91, Attachment 4) that: 3 “We found that the Game Council had published inappropriate material on their website, including a paper that misquoted and misrepresented the work of a conservation advocacy group. The NSW Ombudsman wrote to the NSW Department of Industry and Investment with concerns that: • “the Game Council h › ad not corrected the quote voluntarily when asked to do so • the content and tone of other articles on the website was inappropriate for a statutory authority • the advocacy role played by the Game Council might potentially conflict with their regulatory function of administering the licensing system for game hunters • the Game Council’s complaint-handling policy was inadequate. The CEO of the Invasive Animals CRC, Tony Peacock, wrote about this issue in his blog at the time. A copy of this is found in Attachment 1. The Game Council has not been as publicly hostile to our arguments since, yet they still continue to promote hunting as providing conservation benefits without any credible evidence (see above). Suitability of statutory arrangements While the statutory requirements governing the Game Council are outside of the scope of the current inquiry, we believe that these require a major review. This is because the government suggests that the purposes of the Game Council, and even the title of the enabling legislation – ‘Feral Animal Control’, include providing conservation benefits and undertaking effective feral animal control. The Game and Feral Animal Control Act 2002 at present does not ensure that effective feral animal control is undertaken. These matters could be included in the upcoming five-year review of the Game and Feral Animal Control Act 2002 that is meant to be underway now. The last review was conducted with limited public input and largely looked at ways of further advancing the interests of hunters rather than dealing with broader matters in the public interest such as providing effective feral animal control and protecting native species. It seems that the last five-year review was led by the NSW Game Council or interests with the then Department of Primary Industries that were in favour of expanding hunting in NSW. Some of the deficiencies where the Game and Feral Animal Control Act 2002 does not support effective feral animal control are included below: a) Objectives of the Game and Feral Animal Control Act 2002 do not include control or eradication of feral animals The current objects of the Act are: “Section 3 Objects 4 “The objects of this Act are: (a) to provide for the effective management of introduced species of game animals, and (b) to promote responsible and orderly hunting of those game animals on public and private land and of certain pest animals on public land. If the purpose of the body is to use volunteer shooters to undertake feral animal control work, the concept of a game animal should be removed from the Act and replaced with the word pest animal. The objectives should require the Game Council be tasked with a primary objective to undertake ‘effective pest control and eradication’.
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