Dateline: 31 August 2021
WE ARE WRITING to express our strong opposition to the proposed commissioning of a kangaroo meat processing facility by the Campaspe Meat Company at the Tarnagulla Road abattoirs. We ask that you please take whatever action is open to you to ensure this proposal does not proceed.
In 2018 the Victorian government claimed there were 1,425,000 kangaroos in Victoria and that at 2020–21 this grew to 1,900,000 kangaroos. Since 2018 the Government has issued permits to kill 443,494 kangaroos and in addition to this it is conservatively estimated that 200,000 kangaroos perished in the 2019–20 fires. That is a loss of around 650,000 kangaroos since the beginning of 2018 off a base number of just over 1.4 million.
So almost half the Government’s own population estimate has gone in the period in which the government is today claiming a boom in population numbers. Given kangaroos reproduce at only 10% a year (in the most favourable climatic conditions) it is a biological impossibility for a 40 percent increase in numbers as the Government is claiming.
Contrary to claims that kangaroos are “over abundant”, we believe kangaroo populations are in serious decline as a result of the commercial killing of these native animals. We believe this is no more so the case than in Central Victoria. The proponents of this processing facility have stated they aim to process 2,000 kangaroos a week. On our estimates of kangaroo numbers in the Loddon region [around Castlemain] at that rate every single kangaroo in that region would be killed in 9 weeks.
Aside from decimating the region’s kangaroo populations and the associated cruelty and animal welfare issues surrounding the killing of these animals, this is clearly not a sustainable model. All that will result is the inhumane killing of one of the region’s key native species for the short term financial gain of a handful of people.
We would like to convene a virtual meeting with you to discuss our concerns in more detail.
We look forward to hearing from you.
— Peter Hylands, President Australian Wildlife Protection Council
— Ian Slattery, Member Australian Wildlife Protection Council
Dateline: 31 August 2021
THIS SUBMISSION has been prepared by the Animal Protectors Alliance and the Australian Wildlife Protection Council, on behalf of our members. Signatory organisations are committed to the protection of the wellbeing of all animals as individual sentient beings, and therefore to the health and the sustainability of the ecological systems on which all living things depend. Additionally, many actions which damage the environment also damage animals directly (eg commercial and non-commercial killing of native animals).
The complete failure of the EPBC Act, as the only Commonwealth environmental legislation protect Australia’s environment and to conserve its biodiversity, has resulted in the deaths of billions of wild animals, and thousands of ecosystems. If Australia’s ongoing war against its natural environment is not checked by some form of strong national regulation, the devastation will ultimately extend from wild animals to both humans and all the other animals that are (theoretically) in human care.
The EPBC Act has failed to protect biodiversity from:
These failures reveal an urgent need for a far-reaching and very thorough amendment of the EPBC Act, to address these issues. The first part of this submission is an articulation of nine key issues, and our recommendations for each of them. These issues and recommendations do not appear in any order of priority. All are needed to properly protect biodiversity and ecological processes.
The second part of this submission addresses the questions the Reviewers asked submissions to address. Naturally some of the points made in our key issues will be repeated in these answers.
Date: 7 June 2020
Australian Wildlife Protection Council Inc (AWPC)
The AWPC is a not-for-profit wildlife education organisation and registered charity, founded by Arthur Queripel in 1969. The AWPC celebrates its 50th year of working on behalf of Australia’s precious wildlife.
As the Mallee was cleared, Arthur witnessed mutilated Kangaroos on trucks as the commercial skin and meat trade got underway and saw too much casual cruelty. He sought help from the police, conservation departments and animal welfare organisations to no purpose, each organisation passing responsibility to the other. Arthur founded the AWPC with the aim of protecting Australian native animals from cruelty and exploitation. In the years following Arthur Queripel leadership, Maryland Wilson was the longest-serving president of the organisation. Maryland and many other notable wildlife defenders, here and overseas, worked tirelessly to help the most persecuted wildlife: Australia’s national emblem, the Kangaroo.
The AWPC holds a significant historical archive covering half a century of the mistreatment of Australia’s precious wildlife.
Peter Hylands, conservationist and film producer, is the current President of the Australian Wildlife Protection Council speaking on behalf of the national (and Victorian) AWPC committee and membership. Former Presidents include: Maryland Wilson, Peter Preuss, Arthur Queripel. Patron: Professor Peter Singer.
What appears to happen is that Australian native animals are continually pushed towards the brink, with all sorts of hideous claims about why they should be exterminated. Claims by the Victoria Government, even for animals like Koalas, were that they were over abundant. Prior to the 2020 fires the Victorian Government was suggesting that young Koalas should not be rescued from fire grounds.
The killing of native Australian wildlife is now so entrenched, and the sense of entitlement of governments promoting this behaviour and the individuals carrying it out, mean poor standards are applied. Just one example of many is that in Victoria and following an extensive trial (from 2014) to turn Victoria’s Kangaroos into pet food, the Government is not able to explain which species are being killed and consequently in what numbers.
So when Australian species have made that journey to the brink, many have gone over the edge, they become endangered, and then perhaps, if they are lucky, some attention and belated compassion is directed towards them. By then it is really too late.
So the trick is to stop endangering the native species that still remain and actually look after their habitat instead of ripping it down when every little bit of common sense provides a thousand reasons why the destruction should stop.
Learning about, and living with Australian wildlife, is an extraordinary privilege that must also be the right of future generations of Australians to enjoy.
Climate change — Recommendation: Accelerate GHG emissions policies and review hazard reduction policies in Victoria based on scientific research. Apply pressure on Commonwealth Government to improve its performance. Key features here include questioning and moving beyond the idea that gas is a transitional energy source and improving governance and compliance (an active testing regime is required) in relation to building standards and energy codes in Victoria.
Economic structure — Recommendation: Within Victoria, urgently review those industries and activities that pose a significant threat to biodiversity in Victoria, the worst of all can either be replaced (coal), creating more jobs in renewables sector, are subsidised by the tax payer (many forestry practices) or are activities with no future that should cease with immediate effect, such as commercial harvesting of wildlife (Kangaroos) or hunting (Duck shooting) which contribute little to economic activity in the state and are significant actors in blocking out more beneficial knowledge based economic activity. Given that Victoria is currently very good at destroying its natural assets, a new way forward to help change current practices will be to develop a significant ecotourism industry. If we can do it for Penguins we can do it more broadly before it is too late.
The environmental impact v productivity of current farming methods in Victoria needs review, the Victorian Government should actively encourage farmers to learn to live with wildlife and more generally the natural world, the opposite is currently occurring.
Government — Recommendation: A long and deteriorating history of government conduct in relation to wildlife conservation clearly indicates that action is now required. In Victoria, that action is a restructuring of DELWP with the precise goal of extracting any responsibility for the care of biodiversity from this department and placing this vital task into the hands of a new department with the sole purpose of protecting Victoria’s environment and the plants and animals that live in it.
Human rights — Recommendation: Free from fear and threat — a new deal for wildlife carers and rescuers and proper protection for the lands surrounding wildlife shelters. The protection of people, their human rights and their property rights — for individuals and families investing in knowledge economy and conservation based activities and businesses in regional Victoria.
Protecting the web of life — Recommendation: Initiate proper and structured conservation activities and a state wide assessment of the current circumstances for Victoria’s species, in doing so to build the understanding of how to avoid further endangerment of all species in Victoria. This should include state wide and cross state border plans and long term objectives for species with the resources to properly monitor the wellbeing of species against plans. We can no longer afford a situation where there is a conflict of interest between the organisations driving key threatening processes, organisations that are also the enforcer and legislator. This practice has been all too common in Victoria and has resulted in the poor outcomes we see today.
Date: 7 June 2020
The Honourable Sussan Ley MP
Minister for Environment, Australia
Address: Parliament House CANBERRA ACT 2600
cc: The Honourable David Littleproud MP, Minister for Agriculture, Australia
cc: The Honourable Lily D’Ambrosio MP, Minister for Energy, Environment and Climate Change, Victoria (firstname.lastname@example.org)
cc: The Honourable Jaclyn Symes, Minister for Agriculture, Victoria
cc: The Honourable Matthew Kean MP, Minister for Energy and Environment, New
South Wales (email@example.com)
cc: The Honourable Adam Marshall MP, Minister for Agriculture, New South Wales
cc: Dr Sally Box, Threatened Species Commissioner
The undersigned wish to express our expert opinion on the status of dingoes across Australia in light of the current bushfire emergency. At the time of writing, more than 10 million hectares has been burnt across Australia, including 1.2 million hectares in Victoria and 4.9 million hectares in New South Wales. Across southeastern Australia this represents burning of major dingo habitat zones in National Parks and State Forests. We commend the Federal, NSW and VIC State Governments for their focus on assisting fauna and flora recovery after the catastrophic 2019/2020 bushfire season, however, the proposed ‘feral predator’ aerial baiting plans are counterproductive to that aim. In particular, we wish to express concern about plans to undertake widespread 1080 “wild dog” aerial baiting across burnt habitat in NSW and VIC.
The prevailing wisdom is that introduced predators such as foxes and feral cats pose the most significant risk to native fauna (marsupials, birds, reptiles etc). These risks need to be proactively and swiftly managed to protect (already struggling) threatened species that have been endangered by recent bushfires. We agree that proactive measures to limit introduced predators may need to be taken but these should be targeted and not endanger native predators such as quolls, dingoes and varanids. Currently proposed aerial baiting programs will not target cats, leaving threatened species under increased pressure from these predators. It is also important to iterate that “wild dog” baiting will kill dingoes, leading to widespread mesopredator release, removing suppressive pressure on cat and fox populations exerted by dingoes.
Aerial baiting in bushfire affected southeastern Australia is an unacceptable risk to native carnivores Aerial baiting with 1080 poison poses an unacceptable risk to native predators such as quolls, dingoes and varanids because it is unknown if food scarcity in burnt landscape may increase bait consumption leading to poisoning of quolls or varanids. Furthermore, dingoes are highly susceptible to 1080 baiting and are included as a direct target of “wild dog” baiting efforts. Importantly, best-practice guidelines to limit 1080 baiting impacts on quolls suggests that all baits should be buried to a depth of more than 10 cm and “aerial or broadcast surface baiting should only be used in areas where it can
be demonstrated that there is a low risk to spot-tailed quoll populations” (EPBC Act Policy Statement 3.4 — Significant impact guidelines for the endangered spot-tailed quoll Dasyurus maculatus maculatus (southeastern mainland population) and the use of 1080). Currently it is unknown how quolls and other non-target species will be impacted by aerial baiting in burnt habitat. Arguably, the recently proposed NSW “wildlife and conservation bushfire recovery” plan should be referred to the Federal Environment Minister under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 for assessment.
We strongly emphasise the ecological importance of terrestrial apex predators in biodiversity resilience and ecosystem functioning. Dingoes are the sole non-human land-based top predator on the Australian mainland. Their importance to the ecological health and resilience of Australian ecosystems cannot be overstated, from regulating wild herbivore abundance (e.g. various kangaroo species), to reducing the impacts of feral mesopredators (cats, foxes) on native marsupials (Johnson & VanDerWal 2009; Wallach et al. 2010; Letnic et al. 2012; Letnic et al. 2013; Newsome et al. 2015; Morris & Letnic 2017). It would be hypothesised that continued dramatic reduction of dingo populations, by aerial baiting, will enable introduced mesopredators such as foxes and cats to exploit burnt areas unchecked, posing a high risk to threatened native species. The impacts of feral cats and red foxes are likely to be amplified in disturbed ecosystems, such as those burnt by bushfires. Indiscriminate and non-target specific lethal management should not be implemented if there is a risk to the persistence of threatened native fauna or ecosystem resilience.
We would urge the Federal, NSW and VIC State Governments to focus bushfire recovery efforts on proactive evidence-based measures including:
9 December 2019
“The National Code of Practice for the Humane Shooting of Kangaroos and Wallabies for Commercial Purposes outlines an achievable minimum standard of humane conduct with regard to the shooting of kangaroos and wallabies. The code was endorsed by the Natural Resource Management Ministerial Council (NRMMC) on 7 November 2008. The NRMMC consists of the Australian state, territory and New Zealand government ministers responsible for primary industries, natural resources, environment and water policy.
The National Code of Practice for the Humane Shooting of Kangaroos and Wallabies for Commercial Purposes is currently being reviewed through a project led by AgriFutures Australia. The review is being informed through a reference group of representatives from the Australian Veterinary Association, the RSPCA, industry and relevant government agencies”.
The Australian Wildlife Protection Council (AWPC), established in 1969 by Arthur Queripel, is a voice for Australia’s wildlife and for all Australian species.
The AWPC states that:
The AWPC believes that the National Code of Practice for the Shooting of Kangaroos and Wallabies for Commercial Purposes is a government endorsed document designed to conceal from international and domestic observers the fact of immense harm being caused to Australian wildlife by a cruel and unsustainable industry. There is no practical way the code can be supervised or enforced. A key issue remains the use of the word humane to describe the intensely cruel killing, with all its ‘tricks of the trade’.
AgriFutures Australia will need to begin using a new term to describe how animals are treated during ‘harvest’. ‘Humane’ it is not, unless the industry and regulators are of the opinion that death by distance shooting is humane, and (against the international tide of opinion which was firm when it considered the clubbing of seal pups) that beating small animals to death, is humane. Nor is it humane to not consider what happens to at-foot joeys when their mother is killed.
The RSPCA state that:
“The RSPCA would like to see the way in which Kangaroos are managed in Australia significantly improved — but for the purpose of this public consultation process, we are particularly concerned about the cruelty associated with non-commercial and recreational
Kangaroo shooting. Currently non-commercial shooters don’t have to pass a competency test, and don’t have to undertake mandatory training. There is also no oversight and little incentive to comply with animal welfare standards. We see this as the greatest immediate risk to the humane treatment of Kangaroos”.