LC EPC Inquiry into Ecosystem Decline in Victoria Submission 605

SUBMISSION TO VICTORIAN PARLIAMENTARY INQUIRY INTO ECOSYSTEM DECLINE IN VICTORIA

29 AUGUST 2020

CONTACT: [email protected]

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Contents INTRODUCTION ...... 3 Who we are ...... 3 Our submission ...... 3 EXECUTIVE SUMMARY ...... 4 Recommendations ...... 6 BIODIVERSITY LOSS ...... 7 The drivers of biodiversity loss ...... 7 Commercial exploitation and shooting as a driver of biodiversity loss ...... 8 Biodiversity loss in Victoria ...... 8 Biodiversity Loss-Impact on Macropods ...... 8 The importance of “common species” ...... 9 LEGAL FRAMEWORK GOVERNING WILDLIFE IN VICTORIA ...... 10 Flora and Fauna Guarantee Act 1988 ...... 11 The Wildlife Act 1975 ...... 11 “Sustainable use” ...... 20 KANGAROO KILLING IN AUSTRALIA...... 12 The history of kangaroo killing in Australia ...... 12 Kangaroos as pest animals ...... 13 “Overabundance”...... 14 KANGAROO KILLING IN VICTORIA ...... 15 The ATCW permit system ...... 15 The scale of the killing ...... 15 Significant issues with the administration and operation of the ATCW permit system ...... 16 Structural failures in the design and operation of the Wildlife Act ...... 16 Failures of governance ...... 17 Failures of implementation ...... 18 The commercial kangaroo meat and skins industry ...... 18 The development of the commercial kangaroo meat and skins industry In Victoria ...... 19 The Kangaroo Pet Food Trial 2014-2019 ...... 19 Fraud and overshooting in the KPFT ...... 19 Victorian Kangaroo Harvest Management Plan ...... 20 “Sustainable use” under the Wildlife Act ...... 20 FUTURE THREATS TO KANGAROO POPULATIONS ...... 21 Kangaroos and Climate change ...... 21 CONCLUSION ...... 21

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INTRODUCTION Who we are The Australian Society for Kangaroos (“ASK”) is the leading advocate for all species of kangaroos and wallabies in Australia. ASK seeks to: • Dispel the misconceptions that have led to the ongoing mass destruction of macropod species across Australia; • Protect kangaroos and other macropods from the unrelenting slaughter that occurs across Australia; • Highlight the unnecessary suffering, killing, orphaning caused by the ongoing mass slaughter of kangaroos and other macropods. ASK contends that Australia’s brutal treatment of its kangaroos diminishes Australia as a nation and rightly calls into question Australia’s willingness and ability to meet its international and moral responsibilities to protect its unique wildlife, particularly at a time of biodiversity loss and the impacts of climate change, drought and unprecedented bushfires are having a devastating impact on Australia’s kangaroo populations. Our submission The Australian Society for Kangaroos is grateful for the opportunity to make a submission to the Victorian Legislative Council Environment and Planning Committee’s Inquiry into ecosystem decline in Victoria (“the Inquiry”). In this submission, we have directed our comments and submissions to the Inquiry’s terms of reference including: • The extent of the decline in Victoria’s biodiversity • The adequacy of the legislative framework protecting Victoria’s environment and ecosystems • The adequacy and effectiveness of government programs • Opportunities to restore the environment In this report we focus on the fragmentation of Victoria’s biodiversity laws and the inconsistencies in the current legislative framework. We explore why those laws have failed to provide effective protection for “common species” of wildlife and how that is contributing biodiversity loss in Victoria. We highlight how, at a time when Victoria is facing a looming extinction crisis, S28A of the Wildlife Act and the ATCW permit system operates to facilitate the industrial scale slaughter of hundreds of thousands of healthy wild animals and birds across Victoria every year by farmers and landholders and a permanent kangaroo meat and skins industry.

We are, of course, happy to provide further submissions and the evidence including references and research materials relied on, if required.

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EXECUTIVE SUMMARY There is overwhelming scientific evidence of significant biodiversity loss and decline across the world and that these losses are accelerating with the rapidly accumulating impacts of climate change (IPCC report 2018, WWF report 2018, IPBES report 2019, IPCC report 2019). Australia leads the world in mammal extinctions and the numbers of threatened species (Senate Inquiry into Faunal Extinction Crisis interim report 2019).

Victoria, of all the states, has long had the worst record on land clearing, ecosystem destruction and biodiversity loss (Victorian State of the Environment Report 2018).

The causes and drivers of ecological loss and decline such as habitat loss and invasive species are well known and well documented.

It is of significance, however, that while all of the UN and other international reports and research identify commercial exploitation, hunting and shooting as one of the main drivers of biodiversity loss, this issue has been completely ignored in the analysis of and reports on biodiversity loss in Australia.

This is so despite indisputable historical evidence that government sponsored eradication programs, bounties and the fur trade have had a devastating impact on Australia’s wild animals and bird populations, causing a number of species extinctions and driving many other species to the brink.

This is also so despite the fact that Australia is home to the largest slaughter of terrestrial wildlife on the planet and a major participant in the international wildlife trade through its support of the commercial kangaroo meat and skins industry and operates large scale state- based permit systems that allow landholders to kill hundreds of thousands of healthy wild animals and birds every year in the name of agricultural “damage mitigation”.

One explanation for this “blind spot” is that for over two centuries, the rural sector (with the support of Federal and state governments) has engaged in an aggressive, persistent and misinformation campaign that has convinced an ill-formed public that certain common species of wildlife (kangaroos, wombats, dingos, emus) are agricultural pests that require “management” through lethal control.

These powerful economic interests have used their considerable political influence to shape the legislation and policy governing wildlife. This influence can be seen in the weak regulatory frameworks of Australia’s biodiversity and wildlife protection laws.

At the federal level, the Environmental Protection Biodiversity Conservation Act (EPBC Act) has been an abject failure in providing adequate environmental legal protections for Australia’s faunal species and ecosystems for these reasons (Senate inquiry into the Faunal Extinction Crisis-Interim Report 2019)(Independent Review of the EPBC Act-Interim report 2020).

Similarly, Victoria’s biodiversity laws which currently consist of the Flora Guarantee Act (Vic) 1988 (“the FFG Act”) and the Wildlife Act 1975 (“The Wildlife Act”) have demonstrably failed to protect the state’s wildlife and prevent biodiversity loss over the past 4 decades with more species than ever under threat and at risk of extinction.

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The disproportionate political influence of agricultural interests also dominates the setting of government policy and decision-making in relation to wildlife management is particularly evident in the structure and operation of the Wildlife Act.

Industry capture can be seen in the way in which S28A of the Wildlife Act and the ATCW permit system operates to benefit the commercial interests of landholders over the interests of Victoria’s wild animals and birds and the long term interests of the Victorian community in protecting and conserving its wildlife and ecosystems.

In this submission, we examine the way in which S28A of the Wildlife Act facilitates the unjustified lethal control of hundreds of thousands of healthy wild animals and birds in Victoria every year under the Authority to Control Wildlife (ATCW) permit system and the commercial exploitation of Victoria’s kangaroo populations through the kangaroo meat and skins industry.

To be clear, there is no conservation benefit in either of these “wildlife management” programs. Nor is there any appreciable economic benefit to the state’s economy with kangaroo shooting only supporting 15-30 full time jobs across the state (2019 DELWP- Summary Evaluation Report-Kangaroo pet Food trial).

That the state government continues to endorse the industrial level destruction of Victoria’s wildlife at a time when biodiversity is under such severe threat is inexplicable. That this slaughter is subsidised by Victorian taxpayers is indefensible.

In this submission, we identify multiple categories of failure both in the architecture of the Wildlife Act and in operation, governance and implementation of the ATCW permit system that demonstrate the need for urgent review and reform of the Wildlife Act.

We suggest that this reform could occur in one of two ways. The first is by consolidating the FFG Act and the Wildlife Act into a single consistent legislative regime which takes an integrated ecosystem based approach to wildlife protection and management.

The second is that if the Wildlife Act is to remain a “stand alone” piece of legislation, by undertaking a complete independent public review and reform of the Act to harmonise its provisions with the FFG Act and bring it into line with best practice biodiversity protection laws.

In our view, it is critical that any reform of the Wildlife Act include:

• The end of both the ATCW permit system; • The end of the commercial kangaroo meat and skins industry in Victoria; • The establishment of a new and INDEPENDENT statutory authority to oversee governance, compliance and enforcement of both the FFG Act and the Wildlife Act.

In order to provide background and context for our submission, we review biodiversity loss in Australia and in Victoria, the loss of macropod species, the long history and impact of eradication and fur trade in Australia, the importance of common species to the health and persistence of ecosystems, the significance of the designation of wild species as “pests’, the lack of scientific validity in the arguments justifying the need for the lethal control of

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wildlife, the significant structural and regulatory failures of the ATCW permit system and the commercial kangaroo meat and skins industry. Recommendations

The Wildlife Act has failed to provide effective protection for wildlife and to prevent biodiversity loss. It requires significant reform.

We make the following recommendations:

• That there be a comprehensive and independent public inquiry to review of Victoria’s fragmented biodiversity laws; • That any such review consider consolidating the FFG Act and the Wildlife Act into a single comprehensive and standardised legal and regulatory framework governing the protection of all wildlife in Victoria; • That if the Wildlife Act is to remain a stand-alone piece of legislation, the Wildlife Act undergo significant reform to strengthen, harmonise and standardise the protection and regulation of wildlife of all wildlife in Victoria.

We suggest that any review of the Wildlife Act will need to address the following key elements:

• The review and clarification of the purposes and objectives of the Wildlife Act; • The incorporation of a commitment to the Ecologically Sustainable Principles (ESD); • The incorporation of a commitment to landscape scale conservation and restoration; • Recognition of the ecological value of all native species; • Recognition of the potential impacts of climate change on wildlife populations and their habitats and the need for active adaptive change; • A stated commitment to rely on the best available science in decision-making; • The elimination of the inconsistencies and differing standards of regulation and protection of wildlife between the FFG Act and Wildlife Act; • The removal or restraint of the broad discretions provided to DELWP under the Act by the incorporation of a statement of guiding principles in decision-making; • The provision of 3rd party rights to low cost merit reviews of decisions at VCAT to those affected by decisions; • The establishment of a specialist wildlife crime unit to investigate and prosecute illegal killing of wildlife and other wildlife crimes; • The establishment of an independent statutory body with oversight of DELWP compliance and enforcement activities relating to wildlife.

While we note that the state government has created the Office of Conservation Regulation to provide oversight of DELWP compliance and enforcement activities, this Office still sits within DELWP and is subject to the same unmanageable conflicts of interest that undermines DELWP’s credibility as a regulator of wildlife protection laws.

Given the clear failure of DELWP and its predecessors to manage their administrative and regulatory responsibilities under the FFG Act or the Wildlife Act to protect wildlife and prevent biodiversity loss in Victoria over the last 4 decades, any oversight of Victoria’s biodiversity and wildlife protection laws must be INDEPENDENT of DELWP.

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BIODIVERSITY LOSS There is overwhelming scientific evidence that human activity, over exploitation and climate change represent an existential threat to ecosystems as well as biodiversity including terrestrial wildlife across the planet (IPCC report 2018, WWF report 2018, IPBES report 2019, IPCC report 2019).

Australia the most distinctive and unique mammal fauna in the world (Woinarski et al 2015), yet it also has one of the worst records for deforestation, extinctions and species decline. In 2019, the Organisation for Economic Co-operation and Development’s (OECD) provided a report on Australia's environmental performance. It found the overall status of Australia’s biodiversity was in a poor state and worsening, with 81 ecosystems, 511 terrestrial and aquatic animal species and 1,355 plant species listed as threatened at the national level. The OECD report indicated that the major reason for these declines was that environmental decision-making was dominated by economic interests. It indicated that Australia needed to address this issue and dramatically strengthen its climate change and biodiversity laws and policies if it wanted to improve its environmental record. In its interim report into Australia’s Faunal Extinction Crisis in 2019, the Senate confirmed the dominant role of economic interests in critical decision-making processes was a key failure of both the EPBC Act and state-based environmental laws in providing effective legal protection to threatened wildlife and their habitats. In July 2020, the Independent Review of the EPBC Act released its interim report which also confirmed weak governance and easily circumvented regulation were a key reason for the Act’s failure to prevent biodiversity loss (Independent Review EPBC Act-Interim report 7/20). There is really no question at this point that unless Australia’s biodiversity and wildlife protection laws are strengthened and properly enforced, we will not be able to address the looming extinction crisis.

The drivers of biodiversity loss The Senate Inquiry into Faunal Extinction identified a number of threatening processes that were driving biodiversity loss in Australia.

These drivers included habitat loss, degradation and fragmentation, invasive species including predators like cats and foxes, changes to fire management and disease.

The Senate’s Interim report described how these threats were being exacerbated by rapid climate change which was causing increased incidence of severe drought, increased fire intensity, more days of extreme heat and changes in foliage nutrient composition. If proof were needed, the disastrous bushfire emergency Australia experienced at the beginning of 2020 has provided graphic evidence of exactly how vulnerable Australia’s ecosystems and wildlife are to the impacts of climate change. A WWF Interim report released on 28/7/20 relying on data from University of Sydney researchers confirmed that an estimated 3 billion native animals and birds perished in the bushfires which engulfed 11.46 million hectares (WWF-Australia’s 2019-2020 Bushfires-the Wildlife Toll-Interim report)

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The level of habitat devastation caused by the 2020 bushfires, coupled with poor environmental protection laws has resulted in hundreds of mammal species being pushed to the brink of extinction. When invertebrate species were included, this estimate rose to over 700 species (Lee, 2020).

Commercial exploitation and shooting as a driver of biodiversity loss All of the UN and other global reports that deal with the issue of biodiversity loss identify the wildlife trade and the hunting, shooting and poaching of wildlife as a major driver of biodiversity loss.

This issue has not been raised let alone addressed in any of the many federal and state government inquiries and reports that have dealt with the extinction crisis, biodiversity loss and species decline in Australia.

In our view, the failure to acknowledge the role of the widespread use of lethal force in the “management” of wild species (and particularly common species) represents a significant blind spot in the current analysis of what is driving biodiversity loss in Australia.

In this submission, we examine how over two centuries of historical eradication and extermination programs, the fur trade and uncontrolled killing of wildlife has been a significant contributing factor to extinctions of and declines in many species of macropods.

We also examine how the Wildlife Act which purports to provide legal protections for wildlife in Victoria continues the large scale destruction of kangaroo species through DELWP’s administration of the non-commercial ATCW “damage mitigation” permit system and the commercial slaughter of kangaroos for meat and skins.

Biodiversity loss in Victoria The most recent State of the Environment report for Victoria (SOE) released in March 2019 documented significant declines in Victoria’s ecosystems and in both faunal and floral species native to Victoria. The SOE report also confirmed that: • More than half of the state's native vegetation had been cleared since European settlement; • Many native plant and animal species were at risk from a range of threats and pressures; and • Climate change was having an increasingly deleterious effect on Victoria’s environment-generating more extreme weather, less rainfall and snow cover, warmer sea surface temperatures, rising sea levels and the threat of greater bushfires-all of which directly and indirectly impact biodiversity. The damning findings of this report, like the damning findings in the many other reports we have cited in this submission, leaves no doubt that Victoria must take urgent action to prevent ecological and biodiversity collapses across the state.

Biodiversity Loss-Impact on Macropods According to the WWF Action Plan 2011-2021, seven species of macropod have become extinct since European settlement (Burbidge et al 2009).

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A further ten species of macropod that were once widespread are now extinct on the mainland. All other macropod species have suffered dramatic reductions in their ranges and distributions. A disproportionately high number of kangaroo (macropod) species are at risk of extinction across Australia. 76 species of macropods are listed or currently in the process of being listed on the IUCN red list. More than 50% of these are listed as threatened with extinction. In Victoria, seven of the sixteen species of macropod that existed at the time of European settlement are now extinct. Four further macropod species in Victoria are listed as endangered (Australian Wildlife Protection Council 2016). The loss, degradation and fragmentation of native habitat and the impacts of introduced predators are, without doubt, the major drivers of extinction and species decline of the smaller species of macropod. Other submissions may address these issues. In this submission we focus on the threats to the large common species of kangaroo- Victoria’s populations of Red, Western and Eastern Grey kangaroos. In particular, we question why it is that despite suffering significant reductions in numbers, range and distribution of up to 60% (when compared to historical distribution records) and at a time accelerating biodiversity loss and increasing threats, the state government maintains its support for a permit system that allows large numbers of these species to be shot and killed under ATCW permits and for profit through the Victorian commercial kangaroo meat and skins industry.

The importance of “common species” By focussing almost exclusively on the conservation of rare and endangered species, current legislation and conservation efforts in Victoria have ignored the central role of “common species” to the health, well-being and persistence of many of Victoria’s ecosystems. There is a growing body of scientific research and data that indicates common and widespread species are of critical importance to the structure and effective functioning of biological communities (Gaston, Fuller 2007) (Gaston 2010)(Gaston 2016) and are of significant conservation concern because: • There is growing evidence that large numbers of presently common and widespread species are undergoing massive declines, with major ramifications for ecosystem functions and services, and potentially for many other species. • The processes that underlie these declines are intensifying in many regions of the world through deforestation and urban development and come at a time of accelerating climate change, exacerbating species declines. While there is a widespread public perception that common species are more resilient than others and are less at risk of decline and extinction, emerging scientific research says otherwise. In fact, local extinctions of common species can happen very quickly, as occurred when an entire greater glider population in South East Australia disappeared in under three years despite regular observation and monitoring by researchers (Lindenmayer 2011).

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Conservationists are increasingly concerned about this very thing-the rapid and large scale losses of common species across the planet and the implications of those losses to entire ecosystems. These concerns have been confirmed by the findings of two large studies carried out in the last 5 years that found one-third of the 27,600 land-based mammal, bird, amphibian and reptile species studied had declined significantly both in terms of their numbers and territorial range, resulting in extensive local extinctions (Ceballos et al 2016/Ceballos et al 2020) (“The Ceballos reports”). The Cebellos reports describe alarming evidence that globally, populations of species generally thought to be common, are declining at a rate and on a scale that the authors describe as “biological annihilation” based on the following findings: • As the status of a species changed from common to being on the brink of extinction, its gradual loss brought pressures to bear on other species with which it interacted; • The loss of so many populations had caused major changes in the ecosystems they had inhabited and had contributed to the extinction of other species in those ecosystems; • The losses of common species had triggered extinction cascades and the substantial alteration of ecosystems structure and function; • The wildlife trade (both legal and illegal) was decimating many endangered species and was a major cause of the population declines of common species. • The magnitude of the extinction crisis at both species and population levels highlighted the extreme urgency of taking action to save wild species from this existential threat. • There was an urgent need for a balanced consideration both of common and rare species and that conservation efforts need to be re-assessed orientated to both prevent the loss of rare species and to avoid the depletion of common species.

The Victorian government has recognised the importance of common species and the need to move towards broader scale “landscape level” threat management benefitting multiple species in its own strategic biodiversity plan “Protecting Victoria’s Environment-Biodiversity 2037” and in the amendments made to the FFG Act in 2019.

This recognition, however, has not extended to ensuring that the Wildlife Act-the legislation that governs the protection of common species-reflects these same strategic conservation goals.

LEGAL FRAMEWORK GOVERNING WILDLIFE IN VICTORIA The principal piece of legislation dealing with biodiversity conservation in Victoria is the Flora and Fauna Guarantee Act 1988.

The Wildlife Act 1975 establishes a separate legislative regime for the protection and conservation of fauna.

Both Acts are administered and managed by the Department of Environment, Land, Water and Planning (DELWP).

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Flora and Fauna Guarantee Act 1988

We do not intend to deal with the Flora and Fauna Guarantee Act (FFG Act) in any detail in this submission other than to note that: • In its first 30 years, the FFG Act failed to provide effective legal protection to rare and endangered wildlife and habitats due to failures of governance, implementation and enforcement; • While amendments made to the FFG Act in 2019 incorporated a set of guiding principles and improved assessment methods for threatened species, those amendments did not address the central reason for its failures-the broad discretions conferred on DELWP in critical decision-making processes. While still inadequate, these amendments represented at least an attempt to improve the effective operation of the FFG Act and address the need for stronger protections and preventative measures and to address the threat of climate change. No such effort has been made to review or reform the Wildlife Act to incorporate these developments and the Act remains in largely the same form as it did when first enacted 45 years ago.

The Wildlife Act 1975 The Wildlife Act has two purposes. It establishes procedures to regulate species (common species) that are not subject to the FFG Act for the purposes of:

• Promoting the ‘protection and conservation of wildlife’ including the ‘prevention of taxa of wildlife from becoming extinct’ ; but also to allow for • The ‘sustainable use of and access to wildlife’.

All wildlife is protected under the Wildlife Act with some exceptions including wildlife declared to be unprotected wildlife under the Wildlife Act itself.

The protection of wildlife and wildlife habitat under the Act are subject to a system of licenses, permits and authorisations.

Section 28A has a pivotal role within the scheme of the Wildlife Act.

Under this provision, the Secretary (of the Department-DELWP) is empowered to provide written authorisation to kill or harm otherwise protected wildlife (Authority to control wildlife permits).

In granting ATCW authorisations, DELWP must be satisfied the killing of wildlife is “necessary” for one of the seven reasons specified in S28A (1).

One of these reasons is for “damage mitigation” purposes and applies in circumstances where landholders allege wildlife is damaging farm infrastructure such as fencing or competing with stock for pasture or water.

We examine S28 A and the ATCW permit system in detail below and confirm how industry capture, weak regulation and almost non-existent oversight has resulted in the slaughter of

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hundreds of thousands of healthy kangaroos and their dependent young every year in Victoria.

We say that this permit system and destruction of wildlife it authorises is not only not a sustainable use of wildlife but is contributing to the loss of biodiversity in Victoria.

“Sustainable use” The ATCW permit system is a mechanism for farmers and landholders to remove large but unknown numbers of kangaroos and other common species from the landscape every year. As such, it does not appear to be consistent with either of the stated purposes of the Wildlife Act. It neither promotes the protection of wildlife nor does it qualify as a “sustainable use” because it has no conservation benefit. This raises significant issues about the legitimacy of its role and function within the legislative scheme of the Wildlife Act. KANGAROO KILLING IN AUSTRALIA The history of kangaroo killing in Australia In order to provide background and context for the development of the Wildlife Act and the ATCW permit system in Victoria, we review the long history of kangaroo killing in Australia. Current Commonwealth and state-based wildlife protection laws (including the Wildlife Act in Victoria) came into operation in the mid 1970’s in response to evidence presented by the CSIRO to a Senate Inquiry in 1973 that decades of uncontrolled hunting and shooting had resulted in red kangaroos being at risk of extinction (Senate report-Kangaroos 1973 and 1988). Until that time, kangaroos were the target of large scale government-funded eradication and bounty programs, fur trading and uncontrolled shooting across Australia. These extermination programs, the use of bounties and an unregulated fur trade devastated Australia’s wild animal and bird populations and contributed to a number of extinctions. The following extracts from the available historical records serve to illustrate the extent of the slaughter and the devastating impacts on many macropod species (Boom, Ben-Ami 2010): • 1788-Early settlers used kangaroos for meat initially but once livestock was established, kangaroos mainly hunted and killed for sport. • 1840s-Eastern grey Kangaroos in NSW and reduced to low numbers by large-scale killing • 1887-1907-Eight million kangaroos and wallaroos killed for bounties in Queensland. • 1880s-All states in Australia introduced legislation to eradicate all kangaroos and wallabies. • 1884- Bounties paid for 250,000 kangaroo scalps and 86,000 red-necked wallabies in NSW. • 1880s-NSW declared kangaroos and wallabies “vermin” and bounties were offered for each head. • 1883-1920-Three million bettongs and potoroos were killed for bounties-All these species were nearly wiped out. Three of these species are now extinct.

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• 1884-1914-640,000 brush-tailed rock wallabies were killed for bounties. This species is now listed as vulnerable in NSW. • 1935-1936 (1 year) 1.25 million red kangaroo skins were traded from WA into the Sydney skins market.

Kangaroos were not the only native species that were decimated by these programs and the fur trade. Wombats, dingos, wedge-tailed eagles, emus were shot and poisoned on an industrial scale. Possums too. In 1906 alone 4 million brush tail possum skins were marketed in New York.

No native animal was spared. Koalas were nearly hunted to extinction. Between 1888 and 1927, approximately 8 million were killed for the fur trade.

Nearly a century later the consequences of this slaughter can still be seen with current koala populations estimated to be 1% of their pre-settlement numbers and facing the very real threat of extinction within the next 20 years.

Kangaroos as pest animals Underlying the government-supported and financed extermination of kangaroos and other macropods across Australia was the designation of kangaroos (among other species) as agricultural “pests”.

The use of the label “pest” has been a powerful weapon in the rural sectors propaganda war against kangaroos.

Over the past two centuries, famers and landholders have consistently claimed that kangaroo numbers are “out of control” and require “management” to prevent them from competing with stock for water and pasture and damaging agricultural properties.

This aggressive and persistent misinformation campaign has been very successful in influencing governments and public opinion of the need for “management” of their numbers through lethal control.

Extensive scientific evidence published by the governments own scientists and researchers over the past 20 years confirm there is little if any scientific validity to any of these claims. For example, it is not biologically possible for kangaroo numbers to “explode”: • Kangaroo abundance is primarily regulated by natural processes-particularly the amount of rainfall in any year-which determines the availability and quality of feed and nutrition as well as other factors such disease, and predation (e.g. by dingoes and foxes) • Kangaroos are slow-growing with males taking up to 5 years to reach sexual maturity and females taking up to 3.5 years (Dawson 1995) • Kangaroos have relatively low reproduction rates (about the same as koalas at one per year) and high juvenile mortality rates (70% in the first year under normal conditions (Arnold 1991) and up to 100% under drought conditions) (Shepherd 1987). There is also no scientific basis for the claim that kangaroos eat and destroy crops. Research has instead confirmed that wheat crop damage was overstated and that in any case,

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kangaroo killing largely takes place in regions which do not produce crops (Arnold CSIRO: 1980). Again, there is no substance to the claim that kangaroos compete with stock for water or pasture and/or damage grazing lands. Research by the governments own scientists has confirmed: • That kangaroos do not compete with sheep for pasture or have a significant impact on wool production (Olsen and Braysher 2000) and • That there is no correlation between kangaroo control and damage mitigation on pastoral properties or the landscape generally (Olsen and Low 2006; Olsen and Braysher 2000; Herbert and Elzer 2011; S Mcleod: Edwards, Croft and Dawson). As far as the claim that kangaroos damage fencing and other agricultural assets is concerned, in its 1988 report the Senate Select Committee into Animal Welfare noted graziers nearly always mistakenly attributed damage done to pasture and fencing by other animals, by insects and by weather events to kangaroos. The first attempt to properly investigate and properly assess these claims did not occur until 2004. That analysis found that claims by the pastoral industry of the costs of damage caused by kangaroos were significantly overstated and that kangaroos in fact had a very low monetary impact on the agricultural sector (R. McLeod 2004). The overstatement of kangaroo impacts by farmers and landholders was again confirmed in a 2011 report commissioned by the National Farmers Federation which forced it to revise its own estimate of the economic impact of kangaroos on the rural sector across Australia down from $200 million pa to $44 million pa (Sloane Cook and King Pty Ltd 2011). Despite being discredited, DELWP still relies heavily on these unsupported arguments to justify its kangaroo management programs including both the ATCW permit system and the commercial slaughter of kangaroos.

“Overabundance” As scientific evidence has emerged over the past 20 years that has undermined traditional arguments for controlling kangaroo numbers, the farming lobby, state government wildlife agencies and the wildlife management “industry” have instead turned to the concept of “overabundance” to justify the need for the lethal control in kangaroo “management”.

The problem is that the concept of overabundance has no scientific validity as described by Dr David Lavigne, Science Advisor to IFAW:

“In my humble (scientific) opinion, the term “hyper-abundant” has absolutely no scientific validity…it is a propaganda word, promoted by individuals masquerading as scientists…and passed on to bureaucrats, managers and politicians…none of whom seem to know that the term has absolutely no basis in science. Regardless, the term has been used so often that it has become part of the mythology and is used almost universally to justify the culling of animals” (McKay 2017). In our submission, the use of the concept of overabundance to justify lethal control of wildlife requires urgent review given the emerging science on the importance of common species and the need to move to landscape level conservation.

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KANGAROO KILLING IN VICTORIA The ATCW permit system S28A of the Wildlife Act allows landholders to apply for permits to kill wild animals and birds which they claim are causing damage to their property or are having a financial impact on their business.

The scale of the killing According to data published by DELWP on its website, a large and increasing number of wild animals and birds are killed in Victoria under ATCW permits every year.

That data shows that in the 10 years between 2009 and 2019 (last reported figures), the total number of animals and birds (including all species) killed under ATCW permits in Victoria was a staggering 1,702,372.

The vast majority of animals killed under these permits are kangaroos. DELWP’s published data shows that since 2009 a total of 1,143,399 kangaroos have been killed under ATCW permits.

The species subject of lethal control under these authorisations are many and varied. For example, in 2019, a total of 188,759 wild animals and birds consisting of the following species were authorised by DELWP for control:

Fur Seal (45) Australian Magpie (260) Australian Magpie Lark (41) Australian Pelican (10) Australian Raven (3152) Australian Shelduck (348) Australian White Ibis (495) Bell Miner (50) Black Kite (20) Black Swan (500) Black Wallaby (1028) Black-faced Cuckoo-shrike (90) Cape Barren Goose (265) Chestnut Teal (330) Brushtail Possum (32) Long-necked Tortoise (100) Wombat (3655) Crimson Rosella (460) Eastern Grey Kangaroo (112477) Eastern Rosella (272) Emu (966) Eurasian Coot (500) Fairy Martin (14) Fallow Deer (1700) Galah (2681) Great Cormorant (140) Grey Butcherbird (1) Grey Teal (160) Grey-headed Flying-fox (6604) Hog Deer (39) Koala (100) Little Black Cormorant (30) Little Corella (6919) Little Pied Cormorant (140) Little Raven (678) Long-billed Corella (3790) Lowland Copperhead (100) Maned Duck (3492) Masked Lapwing (191) Musk Lorikeet (1365) Noisy Friarbird (170) Noisy Miner (242) Pacific Black Duck (510) Pied Currawong (445) Rainbow Lorikeet (620) Red Deer (1260) Red Kangaroo (10073) Red Wattlebird (460) Red-necked Wallaby (113) Sambar (2274) Satin Bowerbird (60) Silver Gull (440) Silvereye (226) Straw-necked Ibis (50) Sulphur- crested Cockatoo (4570) Tiger Snake (101) Welcome Swallow (15) Western Grey Kangaroo (13952) White-faced Heron (10) White-winged Chough (8) Yellow-tailed Black Cockatoo (1).

We have highlighted the macropod species authorised for lethal control. At a total of 137,643 animals, macropod species represented 72% of all native animals killed under permits in 2019.

These figure DO NOT include the 60,000 kangaroos allocated for commercial slaughter under quotas set by DELWP in the Victorian Kangaroo Harvest Management Plan for 2019- 2020.

We have attached a copy of the available data showing the numbers and species subject of lethal control In Victoria between 2009 and 2019 as art of this submission.

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It is important to note that because there is no oversight of shooters activities (including at the point of kill) and there is no requirement for shooters to provide “returns” documenting and verifying the numbers of animals killed, it impossible for DELWP to ensure that landholders do not overshoot or kill more animals than nominated in their ATCW permits

The ATCW data and figures provided by DELWP are not therefore an accurate assessment of the numbers of animals and birds killed under ATCWs.

DELWP acknowledges as much in its own commercial kangaroo harvest report for 1/10/19- 30/12/20 (online):

“It is important to note that the ATCW figures reported…are numbers of kangaroos approved for control during this period – not kangaroos actually controlled. There is no reporting of kangaroos controlled under ATCWs issued for private land, unlike for the Kangaroo Harvesting Program, so actual figures controlled are generally unknown.”

The lack of oversight of shooters activities through inspections and the requirement for returns is a central failing of the ATCW permit system.

This raises a critical question-if DELWP do not know how many animals are actually being killed under these permits, how can it be confident that these activities are “sustainable” and do not pose a threat to local kangaroo populations?

The answer is, it cannot be.

Significant issues with the administration and operation of the ATCW permit system ASK has identified multiple factors that contribute to DELWP’s poor management and administration of the ATCW permit system. These factors include:

• Weak institutional capacity; • High levels of industry or regulatory capture by farmers and land holders; • Poor co-ordination across DELWP regions • Low levels of compliance activity • Almost non-existent enforcement activity • Lack of accountability and lack of transparency.

Specifically, we identified the following broad categories of failures in the Wildlife Act and in DELWP’s management of the ATCW system:

Structural failures in the design and operation of the Wildlife Act The Wildlife Act has been in operation for 45 years. It has never undergone any significant review or amendment despite the dramatic increases in the threats to biodiversity that have developed in the intervening decades.

Unlike the FFG Act, there has been no attempt to amend the Wildlife Act to bring it into line with best practice global conservation and wildlife protection goals such as the principles of ecologically sustainable development (ESD), including:

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• The principle of sustainable use; • The principle of integration; • The precautionary principle; • The principle of inter-generational and intra-generational equity; • The conservation of biological diversity and ecological integrity.

The Wildlife Act institutionalises the fundamental (and unmanageable) conflict of interest between DELWP’s role as the agency responsible for the protection of the state’s wildlife and its role as the regulator of the lethal control of wildlife.

The Wildlife Act also confers an unfettered discretion on DELWP in relation to all critical decision-making under the Act, including in the administration of the ATCW permit system.

That discretion is exclusively exercised in favour of the interests of farmers and landholders over the interests of either the animals themselves or the interests of the broader community in protecting and conserving local wildlife populations.

The broad discretions under the Act makes legal challenge (through judicial review) almost impossible. Other challenges relate to the prohibitive legal costs involved and the issue of standing and adverse costs order(Australian Society for Kangaroos v Secretary DELWP and anor (No 2) [2018] VSC 407)

There is also no provision either internal/informal review or for third party rights of appeal under the Act including access to low costs merits review at VCAT for those affected by decisions made under S28 A (other than some very limited categories of rights of appeal set out in S86 C).

Failures of governance

DELWP relies on a fragmented, decentralised model of governance which generates inconsistencies in the levels of regulation and standards applied from region to region.

Decentralisation also contributes to already significant issues relating to DELWPs lack of accountability and its lack of transparency in the provision of information under FOI laws or otherwise.

As indicated earlier DELWP claims to be committed to “evidence-based” decision-making and yet continues to rely on discredited, unsupported or incorrect assertions and out of date research to justify its policy positions, management practices and decision-making in relation to lethal wildlife control and kangaroo management.

There is no system of audits, evaluation or reporting in place to determine if the use of lethal control under ATCW permits is actually achieving the stated objective of mitigating damage to agribusiness.

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Lack of transparency and accountability is also a significant issue with DELWP publishing very little information in relation to any aspect of the ATCW permit system apart from general data relating to how many permits are issued. In our experience, DELWP make obtaining access to any more detailed information under FOI very difficult despite a 2012 investigation and review of its processes by the Victorian Auditor General’s Office.

Failures of implementation

The ATCW permit system relies entirely on self-assessment and self-regulation by landholders and shooters.

Other than applications that DELWP deem to be “high risk” DELWP do not carry out inspections of applicant’s properties to verify assertions made in ATCW permit applications.

Self-assessment, without any requirement to provide corroborating evidence, is accepted in relation to the following matters:

• The extent of the damage applicants allege wildlife are doing to their properties; • That it is in fact wild animals or birds that are causing the damage (as opposed to non-native animals); • The number of animals for lethal control, using “best estimates”; • That non-lethal methods of control have failed to address the “problem”.

The lack of rigour in the application process extends to DELWP’s monitoring and compliance activities.

The ATCW permit system does not include a robust system of independent inspection, monitoring and reporting nor any oversight at the point of kill.

Proper oversight is critical for DELWP to be satisfied that the conditions under which the ATCW permit are being complied with and that breaches including cruelty offences, overshooting and other practices which threaten kangaroo populations are detected;

There is almost no enforcement of the conditions of permits. On the rare occasions when offences are detected, enforcement measures are inadequate and prosecutions rare. In any case, the penalties available under the Wildlife Act are minimal and not effective in deterring wrongdoers.

The weaknesses we have identified in the ATCW permit system are even more evident in DELWP’s oversight of for profit exploitation in Victoria’s recently created permanent commercial kangaroo industry.

The commercial kangaroo meat and skins industry

The commercial kangaroo meat and skins industry represents the largest slaughter of land- based wildlife in the world.

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Based on figures provided by the Commonwealth government since 2000, an average of over two million kangaroos per year have been shot by commercial shooters (Croft, Ramp, Townend, Boronyak 2019).

These figures do not include an estimated 500,000 dependent joeys that are shot, have their necks broken, are bashed to death or decapitated and discarded as “by catch” of the kangaroo industry every year (Ben-Ami, Boom, Boronyak 2014). There are significant issues raised by the commercial slaughter of millions of kangaroos across Australia every year. These include not only the very significant concerns relating to cruel practices involved especially in the destruction of dependent young but also the potential threat this industry poses to the viability of kangaroo populations during times of drought and population declines.

We do not deal with those issues in detail in this submission but we are happy to provide further evidence regarding these matters, if requested.

The development of the commercial kangaroo industry In Victoria Victoria previously attempted to establish a commercial kangaroo meat and skins industry in the early 1980s.

The Commonwealth Agriculture Department’s website contains archived records that indicate quotas were set at 30,000 in 1981 and 31,500 in 1982.

The industry was both disastrous and short-lived due to over-exploitation and a lack of regulatory oversight.

The then state government abandoned the industry after a ground survey conducted by CSIRO researchers in 1982 revealed that in just 2 years, shooters had reduced kangaroo populations to “quasi-extinct levels” of below 1 per square kilometre across 85% of Victoria (Short, Grigg 1982).

The Kangaroo Pet Food Trial 2014-2019 After years of political pressure from the Victorian Farmers Federation (VFF) the then Victorian government introduced a quasi-commercial kangaroo industry through the Kangaroo Pet Food Trial (KPFT) in 2014. This “trial” ran between 2014 and 2019.

Fraud and overshooting in the KPFT Despite DELWP’s claims that it was closely monitoring the KPFT, an evaluation of the trial in 2018 found evidence of widespread fraud, corruption and over-shooting (DELWP-Kangaroo Pet Food Trial Evaluation-Summary Report 2019).

The findings of the evaluation report included:

• A 250 % increase in the number of kangaroos killed under ATCW permits in Victoria; • Evidence of shooters encouraging landholders to apply for authorisations by actively filling in application forms; • Evidence of kangaroo shooters exaggerating the scale of the kangaroo problem or suggesting landholders apply for larger numbers than necessary;

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• Evidence of kangaroo shooters providing financial incentives to landholders to over- estimate kangaroo numbers; • Evidence of shooters leaving “unsuitable” carcasses including small females or incorrectly shot carcasses (which processors would refuse to take) and instead, shooting other kangaroos, leading to overshooting.

These findings demonstrated not only how opaque and unethical the kangaroo industry is but that DELWP was incapable of the level of oversight required to ensure this “industry” constituted a sustainable use of wildlife under the Act and not a threat to the future viability of kangaroo populations.

Despite this clear evidence of fraud, corruption and overshooting and the potential risks these activities posed to kangaroo populations, DELWP proceeded with its plans to establish a fully operational commercial kangaroo industry in Victoria in 2019 without any public consultation.

Victorian Kangaroo Harvest Management Plan The Victorian Kangaroo Harvest Management Plan (VKHMP) was established on 1/10/19 as a “recognised wildlife management plan” under S28 A (1) (h) of the Wildlife Act.

Under the VKHMP, DELWP retains control over setting of quotas, but has delegated responsibility for its implementation and governance across 4 other state government departments and agencies. Responsibility for compliance and enforcement was delegated to the Game Management Authority (GMA).

The GMA was the subject of a damning Pegasus Economics report in 2017 which found that the GMA was neither a credible nor an independent regulator of hunting in Victoria following its failure to enforce its own regulations during the 2016 duck hunting season, failures which led to a large number of endangered waterbirds being illegally shot and killed.

The delegation of its oversight role in the commercial kangaroo industry to a discredited and incompetent regulator raises serious questions about DELWP’s ability to properly monitor and protect Victoria’s kangaroo populations from overexploitation and long term harm.

More generally, the broad decentralisation of governance for this industry also raises the same issues about accountability and transparency we highlighted in our assessment of the ATCW system.

“Sustainable use” The concept of “sustainable use” was developed as a strategy to protect wildlife by giving it a commercial value. It is a strategy that has been a failure globally (Hoyt 1996). Instead of providing a profit incentive to conserve and protect wildlife, it has increased pressure on wildlife populations and done nothing for the conservation of species (Jones MLC, 1997) (WWF report 2019). There are many examples where profit incentives have not protected wildlife but have instead led to over-exploitation that has resulted in the decimation of the species involved.

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“Sustainable use” under the Wildlife Act DELWP maintains that its kangaroo management policies and programs including the Kangaroo Pet Food Trial and the permanent commercial kangaroo meat and skins industry represent a sustainable use of wildlife, despite the fact these programs have no conservation benefit and there are significant gaps in knowledge in relation to the potential impacts. We dispute this assertion, relying on scientific research and reports from well-respected non-government ecologists that have suggested that large-scale removal of kangaroos from the landscape presents a serious risk to kangaroo populations (Boom, Ben-Ami 2012). We also contend that the removal of such large numbers of a critical common species has potential landscape level biodiversity impacts on the other species they interact with and on the functioning of entire ecosystems.

FUTURE THREATS TO KANGAROO POPULATIONS Kangaroos and Climate change There is no question that kangaroo populations will, like all other native species in Australia, be significantly affected by climate change. Increased and more extreme temperatures constitute a real risk to the welfare and persistence of kangaroo populations. Scientific research which directly addressed the issue of the potential impact of climate change on kangaroo populations has warned of the potentially dire consequences of increased global temperatures on kangaroo species (Ritchie, Bolitho 2008). One specific threat to kangaroo populations is the impact of droughts and increased temperatures on the survival of dependent young and juveniles, which can suffer 100% mortality in dry and extreme conditions. There is no recognition in the Wildlife Act nor in any of aspect of DELWP’s governance or administration of the ATCW permit system or commercial kangaroo meat and skins industry of the significant threat climate change poses to the long term viability and persistence of Victoria’s kangaroo populations or commitment to adaptive change to address these issues. Any review and reform of the Wildlife Act needs to incorporate mechanisms to address the increasing threats of climate change to the long term persistence of kangaroo populations across Victoria.

CONCLUSION Nature is declining at an unprecedented rate in Victoria putting entire ecosystems and wild species, including kangaroo populations, at risk of extinction within the next few decades. These trends can be halted but only if we, as a society, are prepared to make transformative changes to the way in which we value and interact with nature. That transformative change includes prioritising the health of ecosystems and wildlife populations over short term political expediency and commercial interests. That transformative change must also include an urgent overhaul of Victoria’s biodiversity laws including the Wildlife Act and putting an end to the mass killing of wildlife under the ATCW permit system and the commercial kangaroo meat and skins industry in Victoria.

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Thank you for consideration of this submission.

Tina Lawrence

Nikki Sutterby

Fiona Corke Australian Society for Kangaroos

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References relied on in this submission

Australian Conservation Foundation CF Create laws to end extinction-Fast racking extinction- Australia’s national environmental law (2018)

Australian Panel of Experts on Environmental Law, Blueprint for the Next Generation of Australian Environmental Law (2017)

Boom, K. and Ben-Ami, D. (2011) 'Shooting our wildlife: An Analysis of the law and its animal welfare outcomes for kangaroos & wallabies' 5 Australian Animal Protection Law Journal 44.

Ceballos, Paul R. Ehrlich, and Rodolfo Dirzo (2016) Biological annihilation via the ongoing sixth mass extinction signalled by vertebrate population losses and declines PNAS July 25, 2017 114 (30) E6089-E6096; first published July 10, 2017

Ceballos, Paul R. Ehrlich, Peter H. Raven (2020) Vertebrates on the brink as indicators of biological annihilation and the sixth mass extinction Proceedings of the National Academy of Sciences Jun 2020, 117 (24) 13596-13602; DOI:10.1073/pnas.1922686117

DELWP-ATCW published data-2009-2019. Available on DELWP website

DELWP-ATCW permit system review-Consultation Paper 2018

DELWP-Protecting Victoria’s Biodiversity 2037 (2017)

DELWP–Living with Wildlife Action plan (2018)

DELWP-Victorian Kangaroo Pet Food Trial (2014)

DELWP-Victorian Kangaroo Harvest Management Plan (2019)

DELWP-Kangaroo Harvest report (2020)

Department of the Environment and Energy, Australia State of the Environment 2016, Overview, p. 27, https://soe.environment.gov.au/theme/overview (accessed 28 February 2019).

Environmental Rule of Law Report UN 24/1/19

Independent review of the EPBC Act-Interim report July 2020

Lee, M 2020 Australia’s bushfires could drive more than 700 animal species to extinction [Accessed 20 February 2020].

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LindenmayerJ.T. WoodL. McBurneyC. MacGregorK. YoungentobS.C. Banks (2011) How to make a common species rare: A case against conservation complacency https://doi.org/10.1016/j.biocon.2011.02.022

McKay 2017-The myth of Hyperabundance (Animal Alliance Canada)

P Olsen and M Braysher, 'Situation analysis report: Current state of scientific knowledge on kangaroos

in the environment, including ecological and economic impact and effect of culling

'http://www.environment.nsw.gov.au/resources/nature/SituationAnalysisFinal.pdf>4August 2010.

Pickrell, J., 2020. Australian fires have imperilled up to 100 species. Available at: https://www.sciencenewsforstudents.org/article/australian-fires-have- imperiled-up-to-100-species[Accessed 10 February 2020].

Organisation for Economic Co-operation and Development, OECD Environmental Performance Reviews: Australia 2019

Rubbo, L. & Wellauer, K., 2020. Koala losses from recent NSW bushfires ‘One of the most significant biodiversity impacts in our history’. [Online] Available at: https://www.abc.net.au/news/2020-03-07/koalas-losses-post-bushfires-bigger- than-modelled/12033834[Accessed 19 March 2020].

State of the Environment Advisory Council, State of the Environment Report Victoria (2018)

Senate Select Committee on Animal Welfare, Parliament of the Commonwealth of Australia, Kangaroos (1988)

Senate Interim report Australia’s faunal extinction crisis 3 April 2019

WWF Living Planet Report - 2018: Aiming Higher. Grooten, M. and Almond, R.E.A.(Eds). WWF, Gland, Switzerland

WWF-Australia’s 2019-2020 Bushfires-Interim Report

Woinarski, J. C. Z., Burbidge, A. A. and Harrison, P. L. (2015) ‘Ongoing unraveling of a continental fauna: decline and extinction of Australian mammals since European settlement’ PNAS Vol 112. No.15 4531-4540

24 of 35 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 605 Authorities to Control Wildlife

Authority to Control Wildlife (ATCW) Data

Under the Wildlife Act 1975, it is Important information about this data illegal to disturb or destroy Number of animals protected wildlife in Victoria The data represents the maximum number of animals without an ATCW. authorised for control. The actual number of animals that were controlled under each ATCW may be lower. The ATCW system Lethal and non-lethal methods In some areas, human activity and wildlife conflict. It is important that the needs of people and the protection of The number of ATCWs represents the total number of wildlife is balanced. In many cases this means people authorisations issued for both lethal and non-lethal must adapt their practices to live with wildlife. The methods (for example, trap and release or trap). ATCW system provides authorisation to humanely Lethal control of wildlife is only issued as a last resort control wildlife that are harmful to people’s livelihoods, and when non-lethal methods have been unsuccessful safety or the environment. at resolving the program or are impractical to An ATCW is required to scare, trap, move or destroy implement. wildlife. An applicant must demonstrate that the wildlife in question is damaging property, farmland or habitat, or Threatened species posing a risk to the safety of people. ATCWs are sometimes issues for the non-lethal control An ATCW for lethal control is only issued as a last of threatened species (for example Grey-headed Flying- resort and when non-lethal methods have been foxes causing damage to property). unsuccessful in resolving the problem or are impractical to implement. ATCW applications are assessed by Table 1. ATCW data for 2019 Conservation Regualtor authorised officers. No. No. Species Further information about the ATCW application ATCWs animals process can be found at here. Australian Fur Seal 6 45 All ATCWs include strict conditions to ensure that wildlife is controlled humanely. An ATCW stipulates the Australian Magpie 27 260 type of method that must be used to control the wildlife Australian Magpie Lark 6 41 and any other restrictions that apply. Australian Pelican 1 10 Anyone acting under an ATCW is required by law to comply with the conditions. Non-compliance is an Australian Raven 102 3152 offence under the Wildlife Act 1975. Australian Shelduck 11 348 Transparent approach to ATCWs Australian White Ibis 7 495 Information about the number of ATCWs issued can be Bell Miner 1 50 accessed by the public. Black Kite 1 20 The species, number of ATCWs and the number of animals authorised for control is outlined below. Black Swan 1 500 The following table presents annual ATCW data for Black Wallaby 123 1028 2019. Black-faced Cuckoo-shrike 5 90 Cape Barren Goose 11 265

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No. No. No. No. Species Species ATCWs animals ATCWs animals Chestnut Teal 3 330 Sambar 16 2274 Common Brushtail Possum 5 32 Satin Bowerbird 4 60 Common Long-necked 1 100 Silver Gull 8 440 Tortoise Silvereye 12 226 Common Wombat 273 3655 Straw-necked Ibis 3 50 Crimson Rosella 18 460 Sulphur-crested Cockatoo 61 4570 Eastern Grey Kangaroo 2122 112477 Tiger Snake 2 101 Eastern Rosella 11 272 Welcome Swallow 2 15 Emu 60 966 Western Grey Kangaroo 69 13952 Eurasian Coot 1 500 White-faced Heron 2 10 Fairy Martin 1 14 White-winged Chough 1 8 Fallow Deer 12 1700 Yellow-tailed Black- 1 20 Galah 51 2681 Cockatoo Great Cormorant 6 140 Table 2. ATCW data for 2018 Grey Butcherbird 1 1 Grey Teal 4 160 Species No. ATCWs No. animals Australian King-parrot 2 10 Grey-headed Flying-fox 5 6604 Australian Magpie 21 603 Hog Deer 7 39 Australian Magpie Lark 7 77 Koala 1 100 Australian Raven 95 3625 Little Black Cormorant 2 30 Australian Shelduck 15 1185 Little Corella 52 6919 Australian White Ibis 8 320 Little Pied Cormorant 6 140 Black Kite 1 20

Little Raven 23 678 Black Swan 1 20

Long-billed Corella 39 3790 Black Wallaby 134 1260 Lowland Copperhead 1 100 Black-faced Cuckoo- 2 30 shrike Maned Duck 106 3492 Cape Barren Goose 8 296 Masked Lapwing 38 191 Chestnut Teal 1 40 Musk Lorikeet 22 1365 Common Brushtail 3 135 Possum Noisy Friarbird 8 170 Common Long-necked 1 100 Noisy Miner 11 242 Tortoise Common Wombat 268 3830 Pacific Black Duck 11 510 Crimson Rosella 22 537 Pied Currawong 21 445 Eastern Brown Snake 3 100 Rainbow Lorikeet 15 620 Eastern Grey Kangaroo 2849 150607 Red Deer 8 1260 Eastern Rosella 8 170 Red Kangaroo 22 10073 Emu 75 1221 Red Wattlebird 12 460 Eurasian Coot 1 20 Red-necked Wallaby 10 113

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Fairy Martin 1 20 Table 3. ATCW data for 2017

Fallow Deer 14 1235 Species No. ATCWs No. animals Galah 46 4370

Great Cormorant 5 95 Australian Fur Seal 2 2 Australian Magpie Grey Teal 3 120 23 556 Australian Magpie Lark Grey-headed Flying-fox 8 11700 13 106 Australian Raven 84 2196 Hog Deer 7 38 Australian Shelduck 14 880 Laughing Kookaburra 1 1 Australian White Ibis 11 506 Little Black Cormorant 4 70 Bell Miner 3 150 Little Corella 33 3010 Black Kite 1 20 Little Pied Cormorant 4 55 Black Swan 2 70 Little Raven 16 345 Black Wallaby 108 994 Black-faced Cuckoo-shrike Long-billed Corella 53 8585 3 40 Cape Barren Goose Lowland Copperhead 3 160 6 100 Common Brushtail Possum 1 100 Maned Duck 106 3327 Common Ringtail Possum 3 18 Masked Lapwing 19 144 Common Wombat 252 3374 Musk Lorikeet 34 3125 Crimson Rosella 16 425 Noisy Friarbird 10 230 Dingo 1 4 Noisy Miner 16 598 Eastern Brown Snake 1 10 Pacific Black Duck 14 440 Eastern Grey Kangaroo 2732 161331 Eastern Rosella Pied Currawong 22 545 10 225 Emu Rainbow Lorikeet 17 1760 53 786 Eurasian Coot 5 66 Red Deer 8 925 Fairy Martin 2 300 Red Kangaroo 16 7133 Fallow Deer 14 586 Red Wattlebird 13 445 Galah 45 3605 Red-bellied Black Snake 2 60 Gang-gang Cockatoo 1 30 Red-necked Wallaby 25 257 Great Cormorant 6 150 Sambar 20 1823 Grey Butcherbird 4 8 Grey Teal Satin Bowerbird 2 40 4 150 Grey-headed Flying-fox Silver Gull 8 355 5 10300 Hog Deer 3 15 Silvereye 14 305 Laughing Kookaburra 1 1 Straw-necked Ibis 3 105 Little Black Cormorant 5 105 Sulphur-crested 62 3670 Cockatoo Little Corella 44 3746 Tammar Wallaby 3 30 Little Pied Cormorant 5 70 Tiger Snake 4 161 Little Raven 21 479 Long-billed Corella Welcome Swallow 9 94 50 5854 Lowland Copperhead Western Grey Kangaroo 103 11252 1 10 Maned Duck 109 3375 White-faced Heron 1 10 Masked Lapwing 18 108 TOTAL 4254 230844 Musk Lorikeet 19 705

Noisy Friarbird 6 125 Noisy Miner 11 172 27 of 35 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 605

Pacific Black Duck 12 265 Crimson Rosella 12 335 Pied Currawong 24 500 Eastern Banjo Frog 1 10 Rainbow Lorikeet 19 675 Eastern Brown Snake 2 20 Red Deer 6 209 Eastern Grey Kangaroo 2690 144774 Red Kangaroo 10 15187 Red Wattlebird 15 515 Eastern Rosella 6 138 Red-bellied Black Snake 1 10 Emu 81 1119 Red-necked Wallaby 17 160 Eurasian Coot 2 55 Rufous Night Heron 1 12 Fallow Deer 14 430 Sambar 17 919 Galah 48 3216 Satin Bowerbird 4 75 Silver Gull 17 6013 Great Cormorant 4 130

Silvereye 10 130 Grey Butcherbird 2 5 Straw-necked Ibis 4 130 Grey Teal 2 80 Sulphur-crested Cockatoo 64 4505 Grey-headed Flying-fox 4 3400 Tiger Snake 1 10 Hog Deer 2 10 Welcome Swallow 8 507 Western Grey Kangaroo 99 12568 Little Black Cormorant 3 34 White-faced Heron 1 10 Little Corella 34 4835 Yellow-tailed Black-Cockatoo 1 50 Little Pied Cormorant 4 44 Species 4049 244303 Little Raven 10 271

Long-billed Corella 42 3830 Table 4: ATCW data for 2016 Lowland Copperhead 2 20 Species No. ATCWs No. animals Magpie Goose 1 1500 Australian Fur Seal 1 40 Maned Duck 94 3080 Australian Magpie 30 403 Masked Lapwing 16 128 Australian Magpie Lark 4 22 Musk Lorikeet 24 1255 Australian Raven 84 2437 Noisy Friarbird 9 235 Australian Shelduck 8 145 Noisy Miner 6 180 Australian White Ibis 8 370 Pacific Black Duck 5 255 Bell Miner 3 170 Pied Currawong 16 400 Black Kite 1 20 Purple Swamphen 5 95 Black Swan 2 90 Rainbow Lorikeet 19 925 Black Wallaby 233 2214 Red Deer 3 60 Black-tailed Native-hen 1 20 Red Kangaroo 8 10798 Brolga 1 1 Red Wattlebird 16 565 Cape Barren Goose 6 320 Red-necked Wallaby 12 162 Common Brushtail Possum 2 60 Rufous Night Heron 2 13 * Common Long-necked 1 9999 Tortoise Sambar 17 1665

Common Ringtail Possum 2 12 Satin Bowerbird 3 60

Common Wombat 270 3975 Silver Gull 23 3990

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Silvereye 19 600 Grey Butcherbird 2 10

Straw-necked Ibis 2 95 Grey Teal 4 3070

Sulphur-crested Cockatoo 65 4366 Grey-headed Flying-fox 2 1800

Tiger Snake 3 30 Hog Deer 2 105

Welcome Swallow 5 248 Laughing Kookaburra 2 6

Western Grey Kangaroo 105 13972 Little Black Cormorant 4 100

White-faced Heron 2 20 Little Corella 41 2945

TOTAL 3699 187536 Little Pied Cormorant 4 70

*Please note: ATCW issued to trap and hold Common Long- Little Raven 8 245 necked Tortoise that may have been encountered during contructions works undertaken to an artificial water body. No Long-billed Corella 49 4540 tortoises were encountered and therefore no tortoises were Lowland Copperhead 1 10 controlled under this authorisation. Maned Duck 119 3729 Table 5: ATCW data for 2015 Masked Lapwing 17 133

Species No. ATCWs No. animals Musk Lorikeet 19 970

Australian Magpie 22 347 Noisy Friarbird 7 165

Australian Magpie Lark 5 40 Noisy Miner 6 313

Australian Raven 82 2372 Pacific Black Duck 7 160

Australian Shelduck 11 888 Pied Currawong 22 565

Australian White Ibis 3 95 Purple Swamphen 3 65

Bell Miner 1 250 Rainbow Lorikeet 17 810

Black Kite 1 20 Red Deer 3 25

Black Swan 4 60 Red Kangaroo 8 1150

Black Wallaby 193 2809 Red Wattlebird 15 586

Black-faced Cuckoo-shrike 2 15 Red-necked Wallaby 11 190

Cape Barren Goose 1 200 Rufous Night Heron 3 32

Common Brushtail Possum 4 190 Sambar 20 1262

Common Ringtail Possum 1 10 Satin Bowerbird 5 100

Common Wombat 285 3666 Silver Gull 10 2970

Crimson Rosella 18 555 Silvereye 19 570

Dusky Moorhen 2 250 Straw-necked Ibis 2 95

Eastern Brown Snake 1 10 Sulphur-crested Cockatoo 73 3990

Eastern Grey Kangaroo 2597 130963 Tiger Snake 1 20

Eastern Rosella 8 220 Wedge-tailed Eagle 1 2

Emu 105 1261 Welcome Swallow 5 185

Eurasian Coot 4 150 Western Grey Kangaroo 94 3774

Fallow Deer 9 215 White-faced Heron 1 10

Galah 39 2575 Yellow-tailed Black-Cockatoo 2 19

Great Cormorant 5 130 TOTAL 4008 181942

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Table 6: ATCW data for 2014 Little Pied Cormorant 8 87

Species No. ATCWs No. animals Little Raven 8 260

Australian Magpie 20 507 Long-billed Corella 64 6744

Australian Magpie Lark 4 30 Maned Duck 114 4275

Australian Raven 94 2522 Masked Lapwing 18 176

Australian Shelduck 10 665 Musk Lorikeet 36 1940

Australian White Ibis 7 970 Noisy Friarbird 6 130

Black Kite 1 20 Noisy Miner 23 438

Black Swan 1 20 Pacific Black Duck 15 370

Black Wallaby 111 1899 Pied Currawong 23 445

Black-faced Cuckoo-shrike 1 15 Purple Swamphen 8 100

Black-tailed Native-hen 1 20 Rainbow Lorikeet 19 1020

Cape Barren Goose 4 354 Red Deer 7 70

Chestnut Teal 5 50 Red Kangaroo 11 9657

Chital 1 25 Red Wattlebird 15 386

Common Brushtail Possum 11 299 Red-bellied Black Snake 5 50 Common Ringtail Possum 6 149 Red-necked Wallaby 23 782 Common Wombat 204 2829 Rufous Night Heron 2 13

Crimson Rosella 22 513 Sambar 18 352

Dingo 5 50 Satin Bowerbird 5 110

Dusky Moorhen 1 20 Silver Gull 16 7650

Eastern Brown Snake 6 60 Silvereye 16 465

Eastern Grey Kangaroo 1549 62570 Sulphur-crested Cockatoo 78 4335

Eastern Rosella 15 328 Tiger Snake 5 50

Emu 72 1002 Welcome Swallow 8 170

Eurasian Coot 2 70 Western Grey Kangaroo 75 11873

Fallow Deer 16 365 White-winged Chough 5 50

Galah 50 3126 Yellow-tailed Black-Cockatoo 2 330

Great Cormorant 4 135 Yellow-throated Miner 1 30

Grey Butcherbird 2 10 TOTAL 2951 141699

Grey Teal 9 235

Grey-headed Flying-fox 7 8560 Table 7: ATCW data for 2013

Hardhead 1 100 Species No. ATCWs No. animals

Highland Copperhead 5 50 Australian Fur Seal 1 5

Hog Deer 2 14 Australian Magpie 21 327

Laughing Kookaburra 7 56 Australian Magpie Lark 5 34

Little Black Cormorant 9 122 Australian Raven 112 2866

Little Corella 55 2212 Australian Shelduck 14 262

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LC EPC Inquiry into Ecosystem Decline in Victoria Submission 605

Australian White Ibis 1 30 Noisy Miner 13 260

Black Kite 1 20 Pacific Black Duck 21 540

Black Swan 2 26 Pied Currawong 20 465

Black Wallaby 118 1919 Purple Swamphen 3 45

Brolga 1 50 Rainbow Lorikeet 23 960

Cape Barren Goose 2 60 Red Deer 65 901

Chestnut Teal 1 10 Red Kangaroo 2 3061

Common Brushtail Possum 11 117 Red Wattlebird 10 275

Common Ringtail Possum 1 5 Red-bellied Black Snake 8 75

Common Wombat 189 2181 Red-necked Wallaby 15 160

Crimson Rosella 15 378 Sambar 126 2677

Dingo 6 60 Satin Bowerbird 4 75

Dusky Moorhen 1 20 Silver Gull 13 10351

Eastern Brown Snake 8 75 Silvereye 16 440

Eastern Grey Kangaroo 1680 65579 Straw-necked Ibis 1 10

Eastern Rosella 9 138 Sulphur-crested Cockatoo 75 3357

Emu 83 1162 Tiger Snake 8 75

Eurasian Coot 12 750 Welcome Swallow 3 1056

Fallow Deer 84 1345 Western Grey Kangaroo 81 6499

Galah 61 3283 TOTAL 3297 139759

Great Cormorant 2 40

Grey Butcherbird 2 30 Table 8: ATCW data for 2012

Grey Teal 9 160 Species No. ATCWs No. animals

Grey-headed Flying-fox 3 5200 Australian Fur Seal 1 1

Highland Copperhead 1 5 Australian Magpie 19 419

Hog Deer 2 15 Australian Magpie Lark 5 61

Laughing Kookaburra 3 22 Australian Raven 70 1940

Little Black Cormorant 7 75 Australian Shelduck 13 298

Little Corella 46 5065 Black Wallaby 104 1525

Little Pied Cormorant 6 60 Black-faced Cuckoo-shrike 1 10

Little Raven 5 42 Black-tailed Native-hen 1 20

Long-billed Corella 59 10445 Cape Barren Goose 2 258

Lowland Copperhead 2 15 Common Brushtail Possum 8 557

Magpie Goose 1 10 Common Ringtail Possum 2 10

Maned Duck 145 4459 Common Wombat 163 1780

Masked Lapwing 15 237 Crimson Rosella 11 323

Musk Lorikeet 35 1700 Eastern Brown Snake 2 25

Noisy Friarbird 8 195 Eastern Grey Kangaroo 1250 44469

31 of 35 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 605

Eastern Rosella 4 88 Sulphur-crested Cockatoo 54 2173

Emu 82 1016 Tiger Snake 3 26

Eurasian Coot 1 30 Western Brown Snake 1 1

Fallow Deer 117 2142 Western Grey Kangaroo 58 1213

Galah 43 2936 Yellow-throated Miner 1 40

Great Cormorant 2 28 TOTAL 2658 99767

Grey Butcherbird 3 60

Grey Teal 3 110 Table 9: ATCW data for 2011

Grey-headed Flying-fox 1 1000 Species No. ATCWs No. animals

Hardhead 1 15 Australian Fur Seal 2 110

Highland Copperhead 1 5 Australian Magpie 18 380

Hog Deer 3 9 Australian Magpie Lark 3 22

Laughing Kookaburra 2 20 Australian Raven 78 2391

Little Black Cormorant 1 20 Australian Shelduck 13 223

Little Corella 30 1965 Australian White Ibis 1 50

Little Pied Cormorant 1 20 Black Kite 2 40 Little Raven 4 150 Black Swan 1 10 Long-billed Corella 28 1660 Black Wallaby 128 2239

Lowland Copperhead 3 26 Black-faced Cuckoo-shrike 3 25

Mallee Ringneck 4 20 Black-tailed Native-hen 6 170

Maned Duck 101 3198 Cape Barren Goose 2 302

Masked Lapwing 7 155 Common Brushtail Possum 7 211

Musk Lorikeet 25 1220 Common Ringtail Possum 1 5

Noisy Friarbird 11 225 Common Wombat 134 1612

Noisy Miner 3 65 Crimson Rosella 19 525

Pacific Black Duck 13 477 Dingo 1 10

Pied Currawong 20 500 Eastern Brown Snake 3 42

Purple Swamphen 1 20 Eastern Grey Kangaroo 866 33539

Rainbow Lorikeet 19 1045 Eastern Rosella 5 90

Red Deer 82 1140 Emu 53 708

Red Kangaroo 4 35 Fallow Deer 111 2070

Red Wattlebird 7 190 Galah 35 2335

Red-bellied Black Snake 3 26 Great Cormorant 2 22

Red-necked Wallaby 18 227 Grey Butcherbird 2 30

Sambar 208 4013 Grey Teal 3 140

Satin Bowerbird 5 90 Grey-headed Flying-fox 1 1000

Silver Gull 19 20432 Hog Deer 5 134

Silvereye 9 240 Laughing Kookaburra 3 30

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LC EPC Inquiry into Ecosystem Decline in Victoria Submission 605

Little Black Cormorant 2 22 Black Wallaby 79 1200

Little Corella 35 2377 Black-faced Cuckoo-shrike 1 5

Little Pied Cormorant 2 22 Common Brushtail Possum 9 199

Little Raven 8 215 Common Ringtail Possum 2 10

Long-billed Corella 21 1750 Common Wombat 123 1285

Mallee Ringneck 3 15 Crimson Rosella 20 478

Maned Duck 96 3433 Dingo 1 10

Masked Lapwing 7 185 Eastern Brown Snake 1 5

Musk Lorikeet 39 2430 Eastern Grey Kangaroo 1090 37716

Noisy Friarbird 12 265 Eastern Rosella 9 138

Pacific Black Duck 8 358 Emu 80 882

Pacific Heron 1 2 Eurasian Coot 1 15

Pied Currawong 25 680 Fallow Deer 66 1173

Purple Swamphen 2 25 Galah 22 1996

Rainbow Lorikeet 20 910 Great Cormorant 1 2

Red Deer 86 1506 Grey Butcherbird 2 30

Red Kangaroo 3 20 Grey Teal 1 30

Red Wattlebird 12 305 Grey-headed Flying-fox 2 9000

Red-necked Wallaby 19 403 Highland Copperhead 1 5

Sambar 198 4044 Hog Deer 2 4

Satin Bowerbird 5 85 Laughing Kookaburra 3 21

Silver Gull 23 10140 Little Black Cormorant 3 57

Silvereye 15 390 Little Corella 36 2870

Sulphur-crested Cockatoo 30 1108 Little Crow 1 15

Tiger Snake 1 10 Little Pied Cormorant 1 2

Welcome Swallow 2 11 Little Raven 10 196

Western Grey Kangaroo 56 1162 Long-billed Corella 29 3085

Yellow-tailed Black-Cockatoo 1 30 Lowland Copperhead 1 5

TOTAL 2240 80368 Maned Duck 94 3064

Masked Lapwing 5 121

Table 10: ATCW data for 2010 Musk Lorikeet 14 705

Species No. ATCWs No. animals Noisy Friarbird 11 270

Australian Magpie 12 286 Pacific Black Duck 4 100

Australian Magpie Lark 5 28 Pied Currawong 32 892

Australian Raven 88 2702 Rainbow Lorikeet 12 460

Australian Shelduck 14 260 Red Deer 49 756

Australian White Ibis 2 70 Red Kangaroo 3 15

Black Swan 1 15 Red Wattlebird 11 215

33 of 35 LC EPC Inquiry into Ecosystem Decline in Victoria Submission 605

Red-bellied Black Snake 1 5 Emu 72 804

Red-necked Wallaby 16 235 Eurasian Coot 2 115

Richard's Pipit 1 10 Fallow Deer 49 928

Sambar 151 3201 Galah 33 4640

Satin Bowerbird 5 85 Great Cormorant 3 27

Silver Gull 14 17031 Grey Butcherbird 3 60

Silvereye 12 350 Grey Teal 1 10

Straw-necked Ibis 1 20 Grey-headed Flying-fox 3 200

Sulphur-crested Cockatoo 32 1481 Hog Deer 1 2

Tiger Snake 1 5 Laughing Kookaburra 3 30

Welcome Swallow 3 440 Little Black Cormorant 3 27

Western Grey Kangaroo 74 1828 Little Corella 29 2905

White-faced Heron 1 10 Little Pied Cormorant 2 22

Yellow-tailed Black-Cockatoo 1 30 Little Raven 8 250

Yellow-throated Miner 1 20 Long-billed Corella 38 6745

TOTAL 2268 95144 Mallee Ringneck 3 15 Maned Duck 120 4266 Table 11: ATCW data for 2009 Masked Lapwing 8 220

Species No. ATCWs No. animals Murray Turtle 1 100

Australian Fur Seal 1 100 Musk Lorikeet 46 2965

Australian Magpie 14 340 Noisy Friarbird 9 270

Australian Magpie Lark 4 40 Pacific Black Duck 6 115

Australian Raven 75 2112 Pied Currawong 34 984

Australian Shelduck 8 172 Purple Swamphen 1 20

Black Kite 1 25 Rainbow Lorikeet 21 1350

Black Swan 3 219 Red Deer 34 262

Black Wallaby 129 1643 Red Kangaroo 5 2085

Black-faced Cuckoo-shrike 2 15 Red Wattlebird 9 265

Black-tailed Native-hen 1 10 Red-necked Wallaby 28 287

Broad-shelled River Turtle 1 100 Sambar Deer 124 2585

Common Brushtail Possum 7 140 Satin Bowerbird 7 120

Common Long-necked Tortoise 2 120 Silver Gull 17 5770

Common Ringtail Possum 1 5 Silvereye 12 370

Common Wombat 156 1955 Straw-necked Ibis 3 40

Crimson Rosella 25 633 Sulphur-crested Cockatoo 38 2690

Eastern Brown Snake 2 40 Tiger Snake 1 20

Eastern Grey Kangaroo 1432 57940 Wedge-tailed Eagle 2 5

Eastern Rosella 11 218 Welcome Swallow 3 560

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LC EPC Inquiry into Ecosystem Decline in Victoria Submission 605

Western Grey Kangaroo 62 4127

White-faced Heron 1 10

Yellow Rosella 1 10

Yellow-tailed Black Cockatoo 2 140 TOTAL 2723 112243

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