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17 December 2018

Mr Graeme Ford CEO - Game Management Authority GPO Box 4509 Melbourne VIC 3001

By Email: graeme.ford@gma.vic.gov.au Dear Graeme,

Environmental Conditions Relevant to Duck Shooting in Victoria – 2019

Animals Australia appreciates the opportunity to comment on the GMA document ‘Considerations for the 2019 duck season’ (hereafter, “Considerations 2019”). In particular, we were pleased that stakeholder submissions and presentations were this year also considered by representatives from the Department of Environment, Land, Water and Planning (DELWP) and the Department of Economic Development, Jobs, Transport and Resources (DEDJTR), as well as GMA staff.

1. Introduction and recommendation

As you will be aware, Animals Australia opposes recreational duck shooting on animal welfare and ethical grounds; there is no necessity for, nor utility to, this practice, native waterbirds are wounded at high rates due to the nature of shotgun pellet spray patterns and the inaccuracy of shooters. Native waterbirds (including ‘game birds’) are at perilously low numbers due to long-term drier conditions and (documented) climate change and thus depleted habitat along the east coast of Australia. The very last thing waterbird populations need is further ‘predation’ in the form of recreational duck shooting. We have examined the GMA briefing (“Considerations 2019”) document compiled from data supplied by Professor Kingsford’s Eastern Australian Aerial Waterbird Survey (EAAWS), the Bureau of Meteorology (BOM) and GMA-commissioned surveys and information. That information indicates the environmental conditions are dire with drought conditions widespread along the East coast of Australia. It is important to note that BOM estimates a 70% chance of El Nino developing next year (i.e. drier, more heat and fires); there is no indication of any reprieve. See section 4 for further. Waterbird numbers (observed in the long-running survey) are perilously low, and no breeding of ‘game bird’ species was seen in October across all transects. This follows several years of minimal game bird breeding being detected by the annual survey – in 2016 (after good rains), the EAAWS surveyors only observed 22 nests/broods, being 0.1% of detected waterbird breeding, and in October 2017 a single nest/brood was seen (0.4% of all detected breeding). See section 3 for further. In EAAWS 2018, Kingsford et al have introduced trend analysis, rather than relying on comparison with long-term average measures. All four of the major indices - total waterbird

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abundance, breeding index, number of species breeding, and wetland area index - show statistically significant declines over time for the period 1983-2018. The long term survival of Australia’s native waterbirds (including those declared ‘game’ species) is threatened. Our own analysis shows that the waterbird abundance detected in the annual surveys shows a 42% decrease between the averages in the first 18 years (1983-2000) and the second 18 years (2001-2018). In addition to the depleted environmental conditions and low bird numbers, it is of serious concern that the recommendations of the (damning) Pegasus Economics report (2017) titled ‘Assessment of GMA’s compliance and enforcement function’ (the Pegasus Report) are yet to be enacted. As summarized below (section 2), compliance with the most basic duck season regulations is woefully deficient and this will be continued in 2019 if a duck season is permitted to proceed, i.e. the continuance of widespread unlawful behaviour causing suffering and the shooting of protected species. GMA’s objectives (s5 of the Act) are “to promote sustainability and responsibility in game hunting in Victoria” and to perform functions set out in the Act. As indicated in the findings of Pegasus Report, and as evidenced by the GMA’s recommendations in the past several years for seasons to proceed despite dire environmental conditions and low bird numbers, these objectives are not and cannot be achieved. See section 5 further. In these circumstances no recreational duck season can be permitted to proceed; we urge GMA to provide advice to the Ministers that the 2019 duck shooting season be cancelled. The relevant issues are further expanded upon in this submission.

2. Pegasus Economics report – 2017 (compliance and enforcement)

As you are aware, the independent review in 2017 by Pegasus Economics was commissioned in response to appalling and illegal behaviour by hunters during the opening of the 2017 duck season. It is relevant to note that this behaviour was detected and reported by waterbird rescuers (not enforcement officers). Amongst other things, the comprehensive Pegasus Report concluded:

Non-compliant behaviours and unsanctioned breaches of hunting laws are ‘commonplace and widespread’.

The regulation of duck shooting in Victoria is ineffective.

Hunting laws in Victoria are seen as likely ‘impossible to effectively enforce in the field’.

The Game Management Authority is conflicted in its role as both a promoter and regulator of hunting and has a ‘too comfortable’ relationship with hunting organisations.

GMA has ‘not been able to effectively deliver its compliance and enforcement responsibilities’.

GMA’s reporting and complaint handling procedures do not meet the standards expected of a contemporary regulator.

The current licensing regime is ineffective in ensuring a minimum acceptable level of awareness and competence amongst hunters (particularly recommending stringent mandatory testing for knowledge of laws and shotgunning skills training)

We are aware that the GMA Board has advised it has accepted all of the Pegasus Report recommendations, save 2.2 (which relates to a separation of the GMA regulatory functions from its other roles). However, it is totally unacceptable that key recommendations have not yet been enacted1 and yet again we approach the prospect of another (the second)

1 Meeting with GMA’s CEO and Game Director – 23 August 2018

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recreational duck shooting season since the Pegasus Report was delivered to GMA and the Ministers. Several key failings are detailed below. 2.1 GMA’s failure to adequately deliver compliance and enforcement of hunting regulations (as concluded by the Pegasus Report): This aspect is of particular concern to Animals Australia; recreational duck shooting should not be permitted when compliance with even the very basic regulations cannot be enforced. Animals Australia personnel joined other rescuers on the wetlands during the 2018 duck shooting season. We and others again saw numerous examples of illegal and unethical behaviour by shooters, again confirming what the Pegasus Report described as ‘commonplace and widespread’ non-compliant behaviours. Despite the difficult environment of the wetlands’ mayhem (particularly during the opening weekend), we were again able to document breaches of regulations and cruelty directly, and also subsequently received evidence from others. In April 2018 Animals Australia’s (in-house) Legal Counsel, Shatha Hamade lodged formal complaints with GMA regarding breaches of the: Victorian Code of Practice for the Welfare of Animals in Hunting; Wildlife Act 1975 (Vic) and associated regulations; and Prevention of Cruelty to Animals Act 1986 (Vic), as committed by various shooters across Victorian wetlands over several weekends at the commencement of the 2018 duck shooting season. Photographic and video evidence was provided relevant to 18 separate incidents of alleged offences at five different wetlands at various dates through March 2018. The offences documented in the complaint included:

• Shooting non-game species (i.e. ‘protected’ species); • Failure to kill injured ducks immediately (despite the new regulation and education); • Failure to examine retrieved ducks; • Allowing a gun dog to continuously retrieve and maul an injured duck (a serious case of the ‘baiting and luring’ offence under POCTA (13(1B)); • Shooting at low levels across the water; • Shooting from a moving boat; • Killing an injured duck by drowning the duck; and • Continuing to shoot before retrieving last shot/injured duck.

Photographic evidence of the hunters’ identities (clear facial shots, and car registrations for some) were provided. Despite this substantive collation and brief of evidence relating to these 18 separate ‘offences’, no legal action has resulted. Consequently no deterrent message has been provided to the shooters involved nor the shooting fraternity. Such failures in 2018, similar to previous years, will enable the persistent and unacceptable culture amongst many – i.e. a culture of ambivalence or open hostility to regulatory measures - will continue. Of particular concern from an animal welfare perspective is the failure to kill any bird that is still alive upon recovery. Whilst this aspect was an existing game law, the introduction of the new regulations (in 2018) that hunters must immediately recover downed game birds, brought this issue into sharp focus. Fourteen of the 18 offences in complaints provided to GMA by Animals Australia in April related to the shooter failing to immediately (or even promptly) kill retrieved ducks. Hunters had been advised (by GMA and shooter associations) pre-season that birds must be killed promptly and humanely after retrieval, yet waterbird rescuers continued to witness the incompetent and cruel treatment of retrieved birds during the 2018 season.

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2.1 GMA’s failure to (as yet) put in place further stringent mandatory requirements for testing of knowledge of wildlife laws and shooting skills training (as recommended in the Pegasus Report). As Animals Australia has indicated on many occasions over past years, whilst ever duck shooting continues to be permitted, minimum reforms are needed including requiring all shooters to pass an accuracy test and requiring all shooters to pass the Waterfowl Identification Test (WIT) annually. The Pegasus Report similarly found that mandatory training is required. There is a high incidence of wounding due to the nature of shot gun shooting of flying birds. Wounding of waterbirds is further increased by inexperience, incompetence, impatience, poor visibility (particularly in foggy conditions, or before dawn or after dusk) and/or alcohol consumption. It is therefore incumbent on those who allow or regulate this sport to do all possible to reduce wounding. Mandatory training is required. As GMA officers would be aware, during the initial 'train the trainer' program in 2008 – conducted prior to the Victorian Government-funded development of the Shotgunning Education Program - hunting leader participants (experienced hunters) recorded an average of 29.4% wounding rate before the training. After a week of intensive training (conducted at a range in Tasmania using clay targets) this rate had been substantially reduced but still stood at 5.1% (an 82% reduction). These shooters were most experienced and in a controlled situation with expert tuition, thus indicating the likely much higher wounding rates for others. Given the demonstrable improvement in shooting accuracy and competence likely if training was delivered, it is totally unacceptable that any shooter should be licensed unless they have attended and completed as a minimum the one-day Shotgunning Education Program. It is clear that the voluntary program is not being taken up by the vast majority of shooters, being an estimated 80 shooters in total over several years. Birds will continue to be wounded at an alarming rate and wounded birds will continue to be collected by rescuers. Further the Pegasus Report recommended hunters should be tested for their knowledge of game hunting laws. The Waterfowl Identification Test (WIT) is key to the hunters’ understanding and recongition of which birds are legally ‘protected’ and which are ‘game’. It is totally inadequate that the WIT remains a once-in-a-lifetime requirement for shooters. Rescuers report and provide evidence that threatened and ‘protected’ waterbirds continue to be shot every year. Only the introduction of an annual sitting of the WIT (as a licence requirement) is likely to reduce the illegal killing of protected species, at least by those who are ignorant or mistaken in their choice of target.

3. Sustainability

3.1 GMA’s mandate

After almost five years of the GMA’s operation, it seems appropriate to review its performance against its governing legislation, the Game Management Authority Act 2014 (“the Act”). GMA’s objectives (s5 of the Act) are “to promote sustainability and responsibility in game hunting in Victoria” and to perform functions set out in the Act. We contend that GMA has promoted sustainability of game hunting (the practice), rather than promoting sustainability of the waterbird populations subjected to game hunting and their habitat. There is an important difference. On p3 of ‘Considerations 2019’ the GMA’s focus is clear: ‘to ensure duck hunting remains sustainable’. This goal will be met so long as

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there are still some birds, somewhere, to be shot at. GMA appears to have overlooked the sustainability of the waterbird/duck populations. Given that there is no legal definition of ‘sustainability’, the common understanding of the term should be applied. The community expectation is that sufficient numbers of each species must be preserved to maintain abundance despite the impact of extreme weather events, climate change, disease, animal predators, and any legalised hunting (a further predatory impact). Despite dire environmental conditions, GMA has not once (to our knowledge) recommended the cancellation of the duck shooting season. In 2016 game bird abundance hit a record low after a prolonged dry period, then rain finally arrived and waterbirds began to breed for the first time in years. But GMA’s ‘core message’ advice to the Minister in December 2016 was that “there are no environmental reasons why a duck season of normal length and normal bag limit (as prescribed) should not proceed”.2 Some birds bred twice and the late offspring were particularly vulnerable, having no sense of danger. Juveniles, the hope for regeneration, were killed in high numbers on opening weekend. When parent birds were shot, dependent juveniles were abandoned. Perhaps buoyed by the abundance of waterbirds, duck shooters’ behaviour was particularly abhorrent, shooting illegally and irresponsibly in full view of officials at a major wetland near Kerang. The arrival of good rains in 2016 provided a precious window for recovery. However, GMA’s actions meant the waterbird population was not given any respite. Instead shooters were given a full season with no bag restrictions. In fact, we now know that many shooters exceeded their legal limits but were not held to account. Volunteer duck rescuers found pits where hundreds of dead birds were buried after the opening weekend in 2017. The graph (Fig 1) below shows that the breeding in 2016 had no lasting impact on the population (as indicated in the next survey). This illustrates the problem with sustainability during the tenure of the GMA. The long-term decline over four decades is shown in Fig 2 below.

2 Information obtained through an FOI request to the GMA.

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Fig 1 Game bird abundance: sustainability?

Average game bird abundance, first 18 years of EAAWS

Game bird abundance, GMA period

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As game bird abundance has declined markedly over the 36-year period of the EAAWS, so the long-term average measures (mean or median) have also declined. Fig 1 shows that the average abundance in the first half of the 36-year survey period is more than double the typical abundances recorded in the last 5 years. The average figures for these EAAWS abundance indices are 268,240 (first 18 years, from 1983-2000), falling by a massive 42% to 155,716 (last 18 years, from 2001-2018). In 2014 Kingsford noted that:

“the spectacular colonies and high concentrations of waterbirds on many of the Murray-Darling wetlands were the catalyst for their nomination as wetlands of international importance under the Ramsar Convention. However, from the 1980s… until … 2010, many of these important wetlands underwent a significant decline as a result of over-extraction of water and altered flood regimes. Waterbird populations suffered a massive collapse in numbers, with total waterbird abundance falling by 80 per cent between 1983 and 2006.”

Of course the most obvious method of rebuilding duck populations is to cancel the killing, but to date GMA has seemingly not considered this to be part of its mandate of “promoting sustainability in game hunting”. Nor has GMA indicated an understanding or consideration of the dramatic and negative impact of Murray-Darling water extraction on game bird abundance. We note that the shooter lobby has attempted to amend the Act so that GMA has a broader mandate. This move was unsuccessful in the parliament3. Hence GMA’s primary mandate remains the promotion of sustainability and responsibility in game hunting in Victoria.

3.2 Game duck populations are trending down, threatening long-term survival.

Regression analysis of the game bird abundance data from 1983 to 20184 confirms a long-term downward trend (refer Fig 2). Regression is a standard method of statistical analysis and these results undermine GMA’s oft-repeated claim that ‘Victoria’s game ducks are highly resilient to harvesting and have strong powers of recovery in response to harvesting and favourable environmental conditions’5. While that may have been true thirty or forty years ago, populations are now significantly lower and environmental circumstances have changed.

3 The Shooters Fishers and Farmers Party proposed an amendment to the Primary Industries Legislation Amendment Bill 2017 which was passed in the Upper House with the support of the cross-bench. The amendment sought to significantly expand the role and functions of the GMA. However, Labor opposed this amendment. The state election intervened before the matter could go through the Lower House. 4 p26 of the GMA document ‘Considerations for the 2019 duck season’. This time series data is obtained from the Eastern

Australia Aerial Waterbird Survey (EEAWS) each year. 5 GMA’s ‘Considerations for the 2018 duck season’, p3

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We note that BirdLife Australia has repeatedly requested GMA perform more sophisticated analysis (such as regression) of available data, rather than relying on use of averages which disguise the downward trend6.

As explained above, the long-term average measures (mean or median) of a declining time series will gradually drift downwards, so that this ‘average’ benchmark used for comparisons gets lower and lower, disguising the problem by making dismal results look “close to average”.

GMA’s recent introduction of a long-term median7 does nothing to remove the problem of downward-drifting benchmarks. In fact, by introducing the median, GMA has effectively removed the “boom” part of the boom-and-bust cycle of waterbird populations.

6 BirdLife’s submissions to GMA (Dec 2015 and Dec 2016) regarding the forthcoming duck shooting season – published on GMA website. 7 Considerations 2019, p26

y = -7836.4x + 2E+07

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Fig 2: Game duck abundance index 1983-2018

abundance index

Linear (abundance index)

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An alternative technique for removing the significantly higher populations of native waterbirds in the data from the 1980s has been employed by another (conflicted) stakeholder, Field and Game Australia (FGA).

In the FGA December 2017 submission to the GMA, they simply omitted the first 4 years (1983-1986) of the time series and then compared the data with a suitably lower “long-term” (excluding the very long-term) mean:8

Fig 3: FGA’s abbreviated view (last 32 years) of the 36-year time series. Note that the peak abundances from 1983-1986 have been excluded, resulting in a lower long-term average. Hence the long-term decline appears less dramatic, and recent values are not so far below “average”.

In EAAWS 2018, Kingsford et al have introduced trend analysis, rather than relying on comparison with long-term average measures. All four of the major indices - total waterbird abundance, breeding index, number of species breeding, and wetland area index - show statistically significant declines over time for the period 1983-2018. Ducks as a group also showed a statistically significant decline over this period. It is noteworthy that EAAWS 2018 finds a statistically significant decline (1983-2018) for 6 of the 8 game bird species – Pacific Black Duck, Australasian (Blue-winged) Shoveler, Chestnut Teal, Grey Teal, Mountain Duck and Australian Wood Duck - that are legally hunted in Victoria.

While Considerations 2019 continues to use long-term means, which disguise long-term declines, EAAWS 2018 has introduced plots of ‘decadal changes’ which illustrate how distinctly the data has changed (generally declined) from one ten-year period to the next:

8 FGA submission to GMA, December 2017, p6

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Fig 4: Decadal changes in indices including total abundance, wetland area, number of breeding species and breeding in the EAAWS (1983-2018)

EAAWS 2018 commented: “Most game species abundances were well below long-term averages, in some cases by an order of magnitude”. The phrase “order of magnitude” is used by scientists to describe a change by a factor of ten – for example, a shift from tens of thousands down to thousands. Surprisingly, GMA’s Considerations 2018 omits the key graphs from EAAWS that show these significant declines for game duck species (reproduced below as Figs 5a, b, c, and d).

These graphs use the long-term average as the benchmark, which (as discussed above) is a steadily decreasing benchmark that tends to disguise the problem. Grey teal and Pink-eared duck have declined by an order of magnitude compared with the long-term mean; as the long-term mean is itself diminishing over time, this is an extremely serious situation. As an alternative comparative measure in Fig 5, we have compared the current abundance with the maximum abundance on record.

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FIG 5a: Order of magnitude declines in game duck species (Note: the “b” appears on

each graph in the EAAWS draft for no obvious reason).

Pacific Black Duck: Total count 8,579 (compared with 90,000 in 1984)

Australasian (Blue-winged) shoveler: Total count 1038 (compared with 22,000 in 1984)

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FIG 5b: Order of magnitude declines in game duck species

(Note: the “b” appears on each graph in the EAAWS draft for no obvious reason)

Chestnut teal: Total count 728 (compared with 22,000 in 1991)

Grey teal: Total count 57,448 (compared with 510,000 in 1984)

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FIG 5c: Order of magnitude declines in game duck species

(Note: the “b” appears on each graph in the EAAWS draft for no obvious reason)

Mountain duck: Total count 3,514 (compared with 109,000 in 1984)

Pink-eared duck: Total count 5,850 (compared with 130,000 in 2011)

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FIG 5d: Order of magnitude declines in game duck species

(Note: the “b” appears on each graph in the EAAWS draft for no obvious reason)

Australian Wood duck: Total count 6,777 (compared with 68,000 in 1984)

Kingsford, the leading scientist in this field, is unequivocal about the drivers of this widespread, ongoing decline in waterbird stocks – climate change and Murray-Darling interventions. He also notes that as waterbird populations shrink, their ability to ‘bounce back’ after rain also declines. When ducks were ‘down in the trough’ back in 2015, he advocated tough restrictions or cancellation of recreational duck shooting, to give the populations a chance to recover.9 GMA failed to heed that advice and recommended a full-length 2016 season with a modified bag limit that reduced the “harvest” to 70% of the average, but failed to halt the decline. Game duck abundance subsequently hit a record low in October 2016.

3.3 Breeding In Animals Australia’s December 2017 submission, we noted that GMA quotes EAAWS breeding in general, without distinguishing between game species and non-game species. We sourced detailed data on breeding, directly from Dr Porter of the EAAWS team. For example, in December 2016, GMA noted (Considerations 2017) that the ‘breeding index’ was the second highest on record, but then failed to indicate the relevant and critical fact that only 0.1% of that 2016 breeding involved game birds. Yet the 2016 breeding event was used to justify a full duck shooting season in 2017. The EAAWS observations provide an index, not a total. As the EAAWS is an aerial survey, with the same areas covered each year using the same manner of observation and recording, the comparative data over time is significant. The breeding index is calculated as the sum of nests and broods observed. EAAWS data gives an important barometer of the

9http://www.theage.com.au/victoria/falling-number-of-waterbirds-in-australias-east-sounds-alarm-20151221-glt0b4.html accessed on 8.12.18

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breeding behaviour of each species in any given year, and it is clear that the waterbirds – especially the game ducks - are in trouble. The observations point to a cumulative and sustained crash in reproduction:

Breeding was well below average over the four-year period 2012-2015:

o In 2012, most (96%) of those breeding were non-game waterbirds o In 2013, only 4 species were breeding, and almost all (98%) of these

waterbirds were three non-game species. o In 2014, only one species was breeding; no game birds were breeding. o In 2015, breeding was at a record low and no game birds were breeding.

Then, two years ago, (October 2016), following good rain, EAAWS observed 23,777 nests/broods among 21 species after good rains fell; however of these there were only 22 nest/broods for game ducks (5 species only), representing 0.1% of observed breeding activity.

Last year (October 2017) the figure plummeted to just 230 nests/broods among 6 species. Only one of these nests/broods was a game duck species. Game ducks accounted for 0.4% of the observed breeding activity.

This year, (October 2018) there were only 200 nests/broods observed, among only 2 species. Neither of these was a game duck species (White Ibis and Black Swan). Game ducks accounted for 0% of the observed breeding activity.

Surprisingly, GMA’s Considerations 2019 contains no comment about breeding in its ‘General Summary’ on p38, despite including the salient graphs from EAAWS 2018:

Fig6: EAAWS 2018 data on Waterbird breeding – (p28 of Considerations 2019)

Incredibly, Considerations 2019 fails to highlight that no breeding of any game ducks was observed in EAAWS 2018. When good rains fell in late 2016 after a severe dry period, shooters rejoiced as birds started to nest; one MP announced there would be a “ripper of a season” in 2017. However, rain is simply water; it is not birds. It takes time for birds to nest, breed, nurture and raise their young. The young need time to reach maturity so they can in turn breed, over several generations, if the population is to recover.

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An analogy is with drought relief for farmers. Government drought relief programs do not cease the moment rain arrives. Programs allow time for crops to be sown and flocks replenished – in other words, time for farmers to recover – before phasing out the support. However in 2016, once the rain came, GMA recommended a full 2017 duck shooting season with a full bag. The official “hunter bag survey” on opening weekend revealed that juveniles comprised a third of all bags, and more than half (54%) of pink-eared ducks killed. Clearly sustainability of game bird populations was not adequately considered by GMA in its recommendation to Ministers. The result is that these waterbird populations have never recovered from the Millennium Drought. The one chance to recover after the good rain in 2016 was squandered; the 2017 “bounce” was short-lived (refer Fig 1).

4. Grim Environmental indicators for the 2019 Season

4.1 The grim reality in 2018-19 In its submission each December, Animals Australia has repeatedly asked that the decision on the forthcoming duck shooting season be delayed until the impact of summer heat and fires is known. GMA’s annual timetable to advise the Ministers as close to Christmas as possible, is inconsistent with its sustainability mandate. It appears this haste relates only to enabling hunters to make travel plans for the March opening weekend. The searing drought that deepened as 2018 unfolded was a sober warning that in these times of climate change, a season, and especially a year, is far too long to “set and forget” with regard to natural assets like native waterbirds. No duck shooting season should be allowed to progress without regular environmental assessments that include temperature, wind, evaporation, fires, rain and habitat. This is an essential part of the GMA’s mandate to “promote sustainability in game hunting in Victoria”. In recommending a full duck shooting season for 2018, GMA appears to have been influenced by one heavy rain event in early December 2017, and the prospect of a La Nina (wetter) summer. However, in its Nov 2017- Feb 2018 Climate Outlook statement, BOM noted that the La Nina was weak and likely to be short lived, and would have less impact on summer rain. It would also tend to prolong the spells of hot weather. The year was characterised by temperatures well above average and rainfall well below average. An unusually windy winter, together with elevated temperatures, increased the evaporation of any rain that did fall. Soil moisture was much lower than normal and so rainfall soaked in, rather than running off. EAAWS 2018 summarises the “exceptionally dry” weather in terms of BOM historical records as follows:

Year-to-date rainfall in Murray-Darling Basin: 3rd-lowest on record

Year-to-date rainfall in NSW: 4th-lowest on record

Year-to-date rainfall in Victoria: 8th-lowest on record

Australian maximum temperatures for year-to-date: 2nd warmest on record

NSW year-to-date: warmest on record

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Victoria year-to-date: equal warmest on record (tied with 2014)

EAAWS 2018 noted that 79% of NSW is drought-affected or in drought, with a further 20% experiencing intense drought; more than half of Queensland is suffering from drought. Considerations 2019 includes the “Annual rainfall decile” map for Australia in 2018 (p7) and the “Long-term rainfall decile” for Australia over the last 6.5 years (p8). The huge red patches show starkly why the wetland habitat, and the waterbirds that depend on it, have been in distress. The BOM has also produced Victorian drought maps (Figs 7 & 8 below). Comparing Figs 8 and 9, it is hard to escape the conclusion that those ducks which found habitat in this dry state of Victoria were effectively subjected to “canned hunting” last year. With few wetland refuges available, they would be relatively easy prey for the shooters. GMA’s official “harvest” figure for 2018 is slightly above the ten-year average. It would be expected that the decadal “average harvest” figure would trend downward (given that duck stocks are in long-term decline) but we do not have access to earlier data. We do note that there was an unexplained “correction” to the 2015 season toll (in a very dry year), increasing it by a massive 40% before GMA’s recommendation for a 2016 season went to the Minister. According to regional media, the GMA said there were 2,100 shooters on Victorian wetlands during the 2018 opening weekend.10 Volunteer duck rescuers confirmed that shooter turnout was low, both on opening weekend and during the season. However, the GMA’s recently released report on the season suggests that 36 per cent (8,958) of all licensed duck shooters took part in the opening weekend.11 This was low compared with previous years (61% in 2014; 56% in 2015; 47% in 2016; 43% in 201712). According to GMA’s fortnightly telephone surveys, only 55% of licensed duck shooters took part in the 2018 season, which was also a low percentage compared to previous years (around 63% 13).

10https://www.weeklytimesnow.com.au/news/national/duck-hunting-seasons-quiet-opening/news-story/551b27bffbd43c6e592c81330db6b819 11 GMA, Estimates of harvest for duck and Stubble Quail in Victoria, 2018 12 Sources: the GMA ‘Considerations’ document for each following season 13 Department of Environment and Primary Industries, Victoria, Estimating the economic impact of hunting in Victoria in 2013, p19

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Fig 7: Victorian drought in the 12 months since GMA sought submissions about a 2018 season

Fig 8: Victorian drought since the start of the 2018 duck shooting season (9 month period).

Fig9: Where ducks were shot in 2018 (Red circles indicate town nearest to location of shooting; size of dot proportional to number of ducks shot) Source: GMA, Estimates of harvest for duck and Stubble Quail in Victoria, 2018, p12

Looking ahead to 2019, there is little hope of improvement in environmental conditions. The BOM has an El Nino (hotter, drier weather) alert, with a 70% chance of an El Nino event. The summer temperature prediction map (p12 of Considerations 2019) promises a summer that is “very likely to be warmer than average” for almost the whole of Australia.

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4.2 Climate change We are again concerned that the GMA-provided information (Considerations 2019) has omitted any mention of climate change. By contrast DELWP has acknowledged the reality of climate change in its Consultation Paper, “Review of the Flora and Fauna Guarantee Act 1988”. DELWP wrote that in the last thirty years:

“Victoria’s biodiversity continues to decline. Key drivers of decline are ongoing loss and fragmentation of habitat and the operation of threats across the landscape such as weeds, pests and diseases. Climate change will add to the current difficulties faced by native species.”14

DELWP proposed a shift in focus, “from reactive emergency interventions to a more strategic focus on halting decline before species become endangered…”15 The BOM website provides ample evidence of how climate change is biting, especially in the areas relevant to consideration of a potential 2019 duck shooting season. Anomaly graphs show (by means of coloured bars) whether the data for a particular year is above or below the mean (refer graphs on next page). Compared to a 30-year mean (1961-1990), Victoria has been warming up, and drying out, since the 1990s. The rainfall deficit has been the most prolonged and serious in more than a century of data, despite temporary respite when the millennium drought broke, and again (briefly) in 2016. Game bird populations have never recovered from this devastating period. Figs 10a&b: Annual temperature and rainfall anomalies for Victoria – 100+ years

14Review of the Flora and Fauna Guarantee Act 1988, DELWP, January 2017, p8. 15 Ibid, p7

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Rainfall has been trending downward over eastern Australia, as shown by the following graphs:

Fig 11: Rainfall trend over the last 5 decades - Australia.

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Fig 12: Rainfall trend over the last 5 decades - Victoria. As the colour key shows there has been a decrease in various regions of Victoria ranging between 10mm and 60mm of rain per decade, the cumulative decrease since 1970 is in the vicinity of 50-300mm of annual rainfall. This has major implications for farming, forests, and of course wetlands and native waterbirds.

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4.3 Water GMA’s Considerations 2019 includes a range of water storage graphics with blue bars and lines, suggestive of moisture or possible relief for waterbirds. However, despite GMA showing these under the title of “Habitat availability”, Kingsford has noted that deep water storages do not provide suitable habitat for game ducks. Considerations 2019 notes that the Murray-Darling Basin (MDB) is a “critical area for waterfowl production and Australia’s most developed river basin (240 dams…)”. However, Kingsford has noted for years now that the dams and water extraction of the MDB have interrupted the natural flood-and-dry cycles of the MDB system, severely diminishing the habitat on which ducks rely, hence contributing to the crash in duck populations. The following graphic is a clearer example of the stark reality of our drying environment:

Fig 13: Forecast flow into Hume Dam, Nov 2018-Jan 2019

Inflow to the Hume dam is a good measure of runoff and streamflow (this is part of the Murray-Darling system, on the Murray and upstream of irrigation extractions). The forecast situation is grim compared with the historical data.

Water storages for Australia, Victoria and the MDB are all lower than this time last year (from 14 to 21% lower)16 reflecting the hotter, drier climate of 2017-18. Pasture growth is “extremely low” across eastern Australia and predicted stream-flows are low at most locations.17

16 Considerations 2019, pp 14-16 17 Ibid, pp18-19

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4.4 Wetland habitat EAAWS 2018 finds that across eastern Australia, overall waterbird abundance, breeding index and breeding species richness (number of species breeding) are positively correlated to available habitat (wetland area index). “Conversely, declines in wetland area are likely to result in declines in waterbird abundance, breeding and breeding species richness.” None of this is surprising: waterbirds need water, which means they need wetlands to survive/thrive. Shooter groups agree that wetland habitat is a key driver of game duck abundance. However, sustainability considerations then suggest that duck shooting should cease when wetland habitat is low. This was the practice under previous regulatory regimes. The following graphic shows in red the years (during the period 1983-2016) when seasons were cancelled:

Fig 14: Time series (1983-2016) of wetland area index and game bird abundance index, showing the years in which shooting seasons were cancelled (red) or modified (yellow). Source: GMA’s Considerations 2017, p27

In interpreting Fig 14, it is important to remember that the abundances and wetland area indices are measured by EAAWS in October each year. Duck shooting normally happens in autumn (mid- March to early June). In the past, a low wetland area index figure for October in the previous (drought) year led to cancellation of duck shooting in the following year.

The autumn 1983 season was cancelled after a dry period that produced the Ash Wednesday bushfires in Victoria. (EAAWS did not exist in 1982.)

Exception: A full season was held in 1986 and 1988 even though the wetland area index dipped in October 1985 and October 1987. Note that the populations were then unable to rebound strongly after good habitat returned (1988-91)

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The autumn 1995 season was cancelled after EAAWS 1994 revealed a sharp dip in the wetland area index (to approx 180,000). Abundance then improved by October 1995.

The autumn 2003 season was cancelled after EAAWS 2002 revealed a wetland area index had dropped even lower (to approx 160,000). Abundance then improved by October 2003.

The autumn 2007 and 2008 seasons were cancelled after EAAWS 2006 and EAAWS 2007 revealed the lowest ever wetland indices (approx. 130,000 and 100,000 respectively). By October 2007, the game duck abundance had started to improve.

But with GMA as the regulator, the situation has been different:

In 2015 when the wetland area index plunged to the lowest on record (approx. 90,000), GMA failed to cancel the autumn 2016 season (merely modifying the ‘bag’). Not surprisingly, game bird abundance hit an all-time low in October 2016.

Fig 15 shows that the wetland area index was critically low also in October 2017; the GMA recommended a full season for autumn 2018. Not surprisingly, game bird abundance decreased again by October 2018.

This year, the EAAWS 2018 wetland area index is even lower than in 2017. The wetland area indices for 2017 and 2018 are similar to those of 2007 and 2008 (approx 100,000 as estimated from Fig 15; we do not have access to the exact numbers) when seasons were cancelled. Sustainability demands that the 2019 season be cancelled, or the game bird abundance will fall even lower next year.

Fig 15: Time series (1983-2018) for game duck abundance and wetland area (Considerations 2019, p31) Shooter groups claim that wetland habitat is all that game ducks need. However, the flaw in this argument is immediately apparent if we consider the role of predators. For example, plentiful habitat will not save ducks (and their young) from foxes. Nor is habitat a protection against duck shooters. We contend that the role of duck shooters is precisely the role of a predator, albeit a predator equipped with many advantages (high-tech firearms, boats, decoys, duck whistles, dogs etc). Promotion of sustainability requires removal of key predators when the game ducks are in such a dire predicament as shown by historical indices.

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4.5 Misleading graphs and disputed data Unlike previous years, the EAAWS 2018 report does not map the key wetlands that are regularly traversed in this survey, rating them as “full”, “drying” or “dry”. Rather, a qualitative account is given, with many important wetlands mentioned as dry or containing few waterbirds. Waterbirds were concentrated in “the south-east wetlands of South Australia” – more commonly known as the Coorong. The EAAWS maps are somewhat misleading this year, as the transects are dotted with spots, one spot corresponding to a wide counting range. For waterbird counts (game and non-game combined) one dark blue spot represents a range from 1 to 250 birds (EAAWS Fig 5). The spot could represent 2 birds or 200 birds, and there is no indication whether any of them are game ducks. For wetland area, one black spot represents the extensive range from 0.001 to 1,000 hectares (EAAWS Fig 7). An area of 0.001 hectares is only 10 square metres, considerably less than the area of one standard car parking space18. So a black dot can be effectively a mere puddle, from the point of view of birds seeking “wetland”. Such a puddle is unlikely to survive the summer heat. The prevalence of these blue or black dots on a map can easily give the misleading impression of plentiful birds and plentiful habitat. GMA appears rather selective in its use of graphs from EAAWS 2018. It omits all the time series graphs we have included (Figs 4 and 5 above) and seized upon the bar graphs (Fig 2 in EAAWS) which carry no historical benchmark to give meaning to the vertical scale. GMA creates new labels for these - “where the ducks are” and “where the habitat is”:

Fig 16: Graphs from p31 of Considerations 2019: Band 2 (in Victoria) is looking good, but there is no benchmark provided; the vertical scale has been exaggerated.

In particular, it is also misleading to suggest the above graph is about “the ducks” – the implication being that these are the game ducks that shooters wish to target. In fact, this data relates to all waterbirds surveyed – up to 50 species. These include the 8 species of game ducks, together with another 42 protected species such as swans, ibis, coots etc19. As if to emphasise the (unfounded) optimism, these graphs and the associated messages have been included multiple times in Considerations 2019, across pages 22 to 25. Considerations 2019 also includes two pages of graphs about “waterbird breeding” (pp28-28) even though none of that breeding is for game species. This tends to mute the impact of the dire climate situation (pp8-12 of Considerations 2019). The alarming time series graphs from EAAWS 2018 that we have reproduced in Fig 5 above are completely absent from Considerations 2019. But on p27, GMA has compressed that data into a graph of ‘relative abundance of game duck species’ (refer our Fig 17 below). 18http://planningschemes.dpcd.vic.gov.au/schemes/vpps/52_06.pdf, p10, accessed on 9.12.18 19Considerations 2019 (pp24-25)

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In that graphic, the eye is drawn to the higher bars with the dominant colours – eg in 2011 there were a lot of Grey teal (shown in red). The eye cannot easily pick out the trends over time for the colours that are barely shown, because their small numbers are getting even smaller. It seems this is a graph to promote game hunting; it is not a graph to promote sustainability (refer s5 of the Act and our comments above). 20

Fig 17: Graph (p27) from Considerations 2019

This year, Kingsford was so concerned with the dearth of water and waterbirds that he took the unusual step of speaking with regional media:21

“ ‘I don’t know where the birds are [said Kingsford]… I think during these long dry periods a lot of them die.’ Drought has already dried up most of the 2000 wetlands the team surveyed in October, leading to a huge drop in waterbird numbers. Each day during their survey the team wrote blogs full of despairing comments on how few waterbirds they observed, from Queensland’s Styx River floodplain to Victoria’s Gippsland wetlands… Over 100 hours, the team sampled 2.9 million square kilometres using ten 30km transects running from the east coast to the Northern Territory border and from Prosperpine to Melbourne, repeatedly stating how few wetlands contained water and waterbirds.”

Despite the EAAWS team’s painstaking search for waterbirds along well-established transects that span one-third of the country, some have tried to dismiss the resulting data as not sufficiently relevant to the decision about a potential duck shooting season in Victoria.

21 Weekly Times, “Aerial survey shows drought drains wetlands of water and game birds”, 7.11.18

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The public arguments have included the following. - In 2016, when rain finally came after a long dry period, waterbird abundance was found

to be at an all-time low. Critics explained away this disturbing result by claiming the birds had spread out, enjoying the improved habitat, and/or furtively guarding their nests, so Kingsford couldn’t find them.

- In 2018, with crippling drought seared into the public consciousness, critics claim the waterbirds have migrated to farm dams, local parks and streams, and that’s why the EAAWS can’t find them.

It seems that irrespective of wet or dry conditions, shooters don’t want to accept the disturbing scientific data produced by EAAWS. Yet no other survey has the length (36 years) and reproducibility (same transects and methods) of the EAAWS. This survey has persisted through all phases of the wet/dry, boom/bust cycles for almost four decades. It has never claimed to count every waterbird in the country. There will always be other birds in other places. But the EAAWS provides an index, tracking changes - it’s counts rise and fall over long periods of time as conditions change. Its data is invaluable as a measure of the health of wetlands and waterbird stocks; it should not be dismissed or disparaged.

5. The regulation and control of duck hunting to ensure it is ‘sustainable and humane’ is inherently flawed and failing.

The claim is made on p3 of Considerations 2019 that ‘(D)uck hunting is regulated to ensure it remains safe, sustainable, humane and equitable’. The following arguments are advanced to contest the truth of these claims. 5.1 – Arguments relevant to ‘sustainability’ of duck hunting: Flawed environmental assessment: The GMA’s failure to recommend cancellation of duck shooting seasons despite dire environmental conditions (as discussed above) contradicts its claim of regulating for sustainability. The desperate plight of the Australasian (Blue-winged) Shoveler: Despite a request from BirdLife Australia22, GMA has not moved to change the status of the Australasian (Blue-winged) Shoveler from ‘game’ to ‘non-game’ or protected. South Australia has prohibited the hunting of this species for more than a decade due to its extremely low numbers. However, GMA waited until 2016 to recommend it be removed from the list of game birds (for that season) that could legally be shot. The fate of this species is still decided season by season. It is disturbing, but relevant, to note that hunting groups support removal of all season restrictions, including any protection for the Shoveler.

In Victoria, during the period 2010-2015, a total of 19,145 Shovelers were legally killed/bagged. Fig 5a above shows that the Shoveler’s ‘abundance index’ graph has virtually flat-lined at zero. There were only 1,038 EAAWS 2018 sightings of this waterbird, seen at the Coorong in SA, and at several sites in Queensland. But if those nineteen thousand Shovelers had lived and bred, rather than being shot for recreation, their conservation status would almost certainly have been different today. There is no sign of a ‘recovery’ for the Shoveler in Victoria, yet shooter groups are keen that it be available for shooting again.

22 BirdLife submission (Dec 2016) to GMA.

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The GMA telephone survey of duck shooters revealed that one respondent had shot two Shovelers during the 2018 season23. It seems GMA took no action against him, even though this is a clear (jail-able) offence. Ineffective and unenforceable bag limit: It seems that bag limits for duck shooting only include the number of birds that a shooter retrieves, and exclude any other birds shot and injured or killed, but not collected. The new regulation requiring “reasonable efforts” for recovery of “downed birds” only applies to birds that are on the ground or water. Those that are too hard to get, and those that keep flapping away, are exempt. As most wetlands are not monitored by officials, there is no way of knowing whether shooters exceed the bag limit and hide the evidence (as happened near Kerang in 2017). So the death toll will be considerably higher than the reported “harvest”. This has a negative impact on sustainability.

Ineffective regulation in dry seasons: Since the formation of GMA duck shooting seasons have been modified when conditions are dry, but this has had little effect. For example, in 2015 a full bag was permitted on opening day (the peak shooting time), and then a bag of 5 per day for the rest of the season. But the average bag is only 4.1, so little would have been achieved by this restriction. It is relevant to note that Field and Game Australia (FGA) states that changes in bag limits “have negligible impact on harvest”.24

Impact on threatened species: Every year, protected and threatened species are shot, such as the Freckled Duck. This is simply unavoidable once a season is sanctioned. GMA’s practice of lowering the bag limit in dry periods does not improve shooter accuracy. Threatened species are in chronically low numbers and severe drought impacts them further. It is particularly irresponsible to allow threatened species to be shot when their numbers are even lower than “usual”.

There are no tests for shooter accuracy, and the WIT (with its historically low pass mark25) is a distant memory for many shooters. Junior shooters with a provisional licence do not have to pass the WIT at all. Although they must be “supervised” by a licensed shooter, there is not much the supervisor can do when the young shooter has already hit a threatened species. Only 7 Freckled duck were observed in the whole of the EAAWS 2018 survey.

Conflict of interest – Impossibility of regulating duck shooting: The illegal and irresponsible behaviour by shooters near Kerang (in full view of officials and police) in 2017 led the Minister to insist that GMA commission an independent review of its compliance and enforcement capability. As indicated above, the Pegasus Review report was scathing. It found the GMA had failed to adequately enforce the law, was too close to shooters, and at risk of being “captive” to the industry it was charged with regulating. In our view, GMA’s inadequate analysis of environmental conditions, and its reluctance to countenance the cancellation of a duck shooting season, are further evidence of this conflicted interest.

5.2. Arguments relevant to regulating to achieve a ‘humane’ duck hunting practice.

Inhumane hunting: GMA has produced a Fact Sheet26 about the new regulations that require a shooter to make “reasonable efforts” to retrieve a wounded duck (and promptly kill it) before taking aim at another. One recommended method of “despatching” the bird is to use a “swatter load”, but this would probably render the bird inedible as it would be riddled with small shot.

23 Ibid (GMA’s 2018 harvest report), p4 24Op Cit, p 16. 25 The pass mark was raised this year for new applicants seeking a duck shooting licence. 26 GMA Fact Sheet: New regulations for the recovery of game birds and game bird meat, 2018

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Duck rescuers often see shooters using one hand to twirl live birds by the neck, as a method of killing them. Sometimes the shooter will simply stuff a live bird into his bag. These common behaviours are not humane and have gone unpunished both prior to the regulatory change and since (see Section 2.1 above).

Failure to act on cruelty breaches: GMA officers are authorised to prosecute for breaches of POCTAA, and under an MOU with RSPCA are the lead agency relevant to duck shooting complaints. As detailed in 2.1 above, Animals Australia has provided GMA with video and photographic evidence, and the offer of witnesses to the alleged cruelty offences but to date no regulatory action has been taken.

Failure to act on common-sense recommendations that would reduce the incidence of wounding and the suffering this inflicts on native waterbirds: GMA is still considering recommendations from the review conducted by Pegasus Economics in 2017. As indicated above, and as Animals Australia has indicated on many occasions over past years, it is our strong view that whilst ever duck shooting continues to be permitted, minimum reforms are needed to reduce wounding (see above discussion in part 2 of this submission), including requiring all shooters to undergoing training and pass a skills/marksmanship test.

In addition, and in recognition that the duck shooting community is ageing, it would be important to also require shooters to pass an eyesight test. This could be encompassed in the existing WIT – i.e. shooters would be tested for their ability to recognise the species of birds in motion and fire accurately at a small moving target. During the same testing time they would be required to demonstrate they could identify the species over the 30 to 50 metres distance over which they would shoot a waterbird. Such testing (for eyesight and accurate identification and firing) should be annual (as indicated above).

Alcohol: Given the expense amount shooters claim to spend on alcohol (refer next section) and the observation of behaviour at major wetlands during the open season, random breath tests for those using a gun on native wildlife should be introduced. This should deter those whose identification and accuracy skills have been impaired by drinking.

6. Economics and the value or ‘benefits’ of recreational duck shooting

We have above examined environmental factors that should be of concern to all (but particularly to DELWP); now we turn to economic matters which should be of concern also to DEDJTR. GMA has often claimed that game hunters contribute $439m to the Victorian economy. This figure is based on a deeply flawed survey of hunters in 2013. Its weaknesses are numerous and include:

No attempt to provide margins of error for this “estimate” of economic benefit – presumably because the consultants who did the work knew it was flawed;

No independent verification of the figures provided by hunters (from memory) about expenditure that occurred up to 12 months earlier;

No recognition that most of this discretionary expenditure would have occurred in Victoria even if there was no hunting allowed (the hunters also enjoyed other outdoor activities);

Most of the claimed expenditure was for pest hunting, not game hunting;

Expenditure on duck hunting was artificially inflated by allocating all “off-trip” expenses to game hunting rather apportioning them with pest hunting;

Major items like boats and cars would likely have been bought even if hunting was unavailable, because they were used for other purposes too;

Expenditure on food and alcohol would likely have occurred whether hunting or not;

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The figures are clearly exaggerated: in 2013 the claimed expenditure of $99m on duck hunting equated to $235 per duck bagged. In 2018, with a reduced harvest, the alleged expenditure per duck would be almost $250. This claimed expenditure seems particularly unlikely, given the high proportion (almost one in four) of game hunters who qualify for free or concessional licence fees.

The survey suggested that about half of the expenditure was in Melbourne rather than regional Victoria. It also made the observation that duck hunting was affected by climate “variability”, with seasons modified or cancelled in dry conditions. Increasingly, nature-based tourism is becoming a more viable alternative to duck shooting as an economic lifeline for regional Victoria. For example, Lake Tyrrell (near Sea Lake) now has up to 240 visitors a day, and the Winton Wetlands (near Benalla) has 36,000 visitors a year. Those who conduct non-hunting businesses in regional Victoria are starting to speak out against the myth of duck shooting as an economic rescue.27 The Andrews Labor government has increasingly shown support for nature-based tourism.28 There is a strong precedent in the development (by a former Labor government) of the highly successful Phillip Island penguin tourism precinct from what was once a struggling, damaged colony and habitat. The recent announcement of a direct QantasLink air service between Bendigo and Sydney will be a huge boost for year-round tourism in regional Victoria. Non-hunting tourists and non-hunting residents do not want to be disturbed by the sound of gunshot for three months of the year. Those who come here to discover our wildlife would be appalled that our unique native waterbirds are being blasted by a vocal few men who think their “sport” should be given precedence above all other interests. Given the drier, hotter trend that climate change is continuing to bring (discussed in part 4 of this submission), it makes sense for regional Victoria to diversify away from duck shooting. Nature-based tourism will appeal to overseas tourists, whether in drought or flood, as the intrigue is the wide open spaces, the clean air, the powerful cycles of nature and the wildlife that live here. DELWP has written that:

“… by 2028, healthier natural capital could provide between $15 billion and $36 billion in economic benefits for Victoria. However, continuing on the current trajectory of decline in Victoria’s natural capital could cost the state between $16 billion and $78 billion.”29

It is relevant to note other important trends that have occurred since GMA was established on 1 July 2014 (refer Figs 18 and 19 below)

During the tenure of the GMA, there has been a 10 per cent decrease in the proportion of Victorians who shoot ducks (declining from 0.445% in 2014 to 0.401% in 2018). Duck shooters represent a tiny proportion of Victorians, and that proportion is shrinking (Fig 19).

Even those who are licensed to shoot ducks seem more reluctant to participate in the opening weekend, with a steady decrease in participation rates each year, from 2014 through to 2018 (Fig 18).

27https://www.stawelltimes.com.au/story/5393912/tv-advertisements-call-to-ban-duck-hunting/ accessed 10.12.18 28https://www.premier.vic.gov.au/nature-based-tourism-hub-connects-gannawarra-towns/ accessed 10.12.18 29 Op cit, p10

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These graphs are based on figures from GMA’s ‘Considerations’ documents across the years, and ABS June quarter population figures. Population data for June 2018 is not yet available, so March 2018 was substituted; as the population is growing rapidly, the true percentage of Victorians who are licensed duck shooters in 2018 will be lower than shown in Fig 19. These two graphs support our view that duck shooting is waning in popularity. The future of the regional economy lies elsewhere, most likely in activities that appeal to a broader cross-section of the community (99% of duck shooters are male).

0

10

20

30

40

50

60

70

2013 2014 2015 2016 2017 2018 2019

Fig 18: Percentage of licensed duck shooters who participate on opening weekend

% taking part onopening weekend

0.39

0.4

0.41

0.42

0.43

0.44

0.45

2013 2014 2015 2016 2017 2018 2019

Fig 19: Licensed duck shooters as a percentage of the Victorian population

% of Victorianpopulation

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7. Summary and Conclusions

Animals Australia is gravely concerned for the welfare of waterbirds subjected to recreational duck shooting, and more broadly concerned for the survival of native waterbirds in the face of a drying continent. The community – already aware of climate change factors - will be similarly concerned to learn of the long-term decline in game bird stocks (42% drop in average abundance between first 18 years and last 18 years of the EAAWS data).

GMA’s view of sustainability (as per the Sustainable Hunting Action Plan) appears hunter-centric, designed to (optimistically) maximise the long-term harvest. This is a fundamentally different view from that of conserving the historic ‘abundance’ of game birds and of the need to protect biodiversity.

As you are aware, Animals Australia opposes duck shooting on animal welfare grounds – this practice is unnecessary and causes egregious cruelty. Governments in Western Australia, New South Wales and Queensland have banned recreational duck shooting because of community concern and expert views related to the suffering of wounded waterbirds and orphaned young; duck shooting has never been permitted in the ACT.

Untold numbers of native waterbirds are distressed, wounded and some half a million birds are (reportedly) killed during three months of each year for fun in Victoria. That is five times the number of game waterbirds counted by EAAWS 2018 in its painstaking survey across one-third of the continent. Whilst this alone should bring an end to this archaic tradition, the failure of regulators and hunting associations to ensure compliance with existing minimum standards, and the dire environmental conditions threatening waterbird survival each combine to further demonstrate that recreational duck shooting must be banned in Victoria. Further, the failure to act on clear evidence of 18 alleged offences, provided by Animals Australia in April this year, indicates that GMA is unable to regulate a duck shooting season, whatever the environmental circumstances. Sustainability and “humane hunting” have not as yet been addressed nor will they again be able to be achieved if a duck season proceeds in 2019. No other activity in Victoria would be allowed to proceed on this demonstrably flawed regulatory basis. As discussed in this submission, there is strong evidence from previous years that when a shooting season is cancelled due to dry conditions, the game duck abundance does temporarily improve as a result. There is virtual no reprieve for ducks if the bag limit is merely reduced. Animals Australia urges GMA to provide advice to the Ministers that the 2019 duck shooting season be cancelled on sustainability grounds. Please contact us if further clarification is required. Yours sincerely, Glenys Oogjes Chief Executive Officer (03) 9329 6333 googjes@AnimalsAustralia.org