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REDEFINING THE APPROACH TO GAME MANAGEMENT THROUGH PROMOTION OF THE VALUE OF HABITAT IN AUSTRALIA AND THE CONTRIBUTION FROM HUNTING TO VICTORIA.

Submission from:

Field & Game Australia Inc.

DECEMBER 2015

AUTHORS: David McNabb and Daryl Snowdon.

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BACKGROUND The Wildlife (Game) Regulations 2012 provide for an annual duck season and a ten bird bag limit using prescribed methods only.

The Game Management Authority (GMA) has a statutory function to make recommendations to relevant Ministers in relation to open and closed seasons, bag limits and declaring public and private land open or closed for hunting. The Wildlife Act 1975 enables the responsible Minister to vary these arrangements, including in response to extreme environmental circumstances.

As a stakeholder, Field & Game Australia Inc. (FGA) has been invited by GMA to participate with information to assist GMA with providing complete advice to the relevant Ministers. FGA thanks GMA for this opportunity.

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EXECUTIVE SUMMARY This submission by FGA reinforces the importance of managing habitat with wildlife populations for effective game management. It also recognises the benefits Victorians derive from hunting in environmental, social, and economic terms. Regional Victoria benefits from significant hunting tourism and expenditure, with the Department of Environment and Primary Industries’ Estimating the economic impact of hunting in Victoria in 2013 report providing evidence that hunting was worth $439 million to the Victorian economy in 2013. The majority of this expenditure goes to regional Victoria, while the majority of hunters live in metropolitan areas, which is in contrast to the increasing urbanisation of the population.

FGA has worked collaboratively with government agencies since 1958, and continues to strive for the development and implementation of a robust, effective management model for the harvest of wild game.

An effective management model must provide facts and data to deliver a sound and logical approach to the regulation of duck hunting. This recognises the disciplines established throughout most of the data supplied each year and used by government to assess any modifications to the hunting season.

However, the notable exception where there is little consistency, is the seasonal modifications to vary bag limits and/or season duration in response to other factors. This prevents the accurate collection of data and facts specific to the regulation of hunting: without set variables to assist in the collection of accurate data, decisions risk being made based on instinct and intuition and will make no contribution to the effectiveness of regulated hunting.

This approach is feasible as weather conditions are entering average conditions, and are nowhere near as dire as the height of the most recent drought.

Waterfowl populations have demonstrated resilience to long-term hunting, and demonstrate their incredible ability to respond to weather through enormous breeding events in response to rainfall. The fundamental requirement for healthy populations of waterfowl is habitat, which requires actively managed, adequate water.

Following careful consideration, the recommendations developed by FGA are based on securing greater commitment to improving wetland habitat for waterbirds, and an adaptive management model, through greater focus on monitoring abundance and unmodified seasons to simplify the management of our waterfowl populations. This permits the collection of more accurate data for the long-term regulation of hunting.

Recommendations: FGA advocates the implementation of the legislated hunting season, as defined in legislation, without modification for 2016. FGA recommends the transition to a simplified and, ideally, standardised approach to regulating waterfowl hunting (commencing with the 2016 hunting season) with no modifications implemented for a defined period, recommended as five years. FGA seeks greater commitment to improving wetland habitat for waterfowl, and monitoring waterfowl abundance.

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PREAMBLE BENEFITS TO VICTORIA The social and economic benefits contributed to our communities through hunting are significant and must be recognised.

The economic benefit of hunting has been confirmed by an independent study commissioned in 2013 by the then Department Environment and Primary Industries, as $439 million a year. The benefits to regional Victoria is recognised by elected members, local authorities and commerce in visitation and expenditure, and are actively supporting the economic benefits of hunting.

Hunting also has broader environmental and community benefits. In its many forms, hunting is an intrinsic part of bushcraft. It is important to recognise that the dollar value of hunting is not what motivates hunters in their love of the bush, and the wildlife which populates it. The role of hunting in the community is a traditional, cultural, familial, heritage activity.

CONSERVATION We live in a highly modified landscape, and our waterfowl travels through it to seek out habitat in response to climatic changes. Management of this landscape requires active conservation programs. Conservation occurs when both the habitat and the wildlife populations are valued. The volunteer effort applied to conservation cannot be ignored, and the greatest value applied to habitat and wildlife is by those who seek to selectively use our natural resources.

In the 1950s, concerned conservationists could see that wetlands were disappearing and that, without a disciplined effort to create and conserve wetlands, birds would continue to lose habitat, impacting their ability to breed and sustain their population.

This realisation led to Victoria’s first public–private partnership. The Bolte Government imposed a licence fee on hunters dedicated to the creation and conservation of wetlands. This created the system of State Game Reserves, which today stretches to 60,000 hectares.

State Game Reserves serve a particular purpose that is not possible in National Parks: the deliberate management of habitat for the increased production of wildlife – not just protection from hunting. It is essential to produce more wildlife in specially-managed habitat, in order to offset the destruction of breeding places on other lands used for intensive agriculture, forestry, and, increasingly, through the spread of residential development.

What is needed is a system that ensures wetlands receive a fair share of water. This ensures long term, sustainable environmental outcomes are achieved, the same environmental outcomes sought in 1958 by concerned conservationists, who happened to also be hunters.

SUSTAINABILITY The long term sustainability of hunting is demonstrated through time, with waterfowl populations sustained despite intensive market hunting for almost two centuries, and despite environmental conditions that can fluctuate widely over the long term between extremes of flood to drought.

Extremes in weather are consistently raised as one of the reasons for a modified hunting season, yet in practice these modifications only serve to complicate the collection of data and evidence necessary for good game management practices.

Decisions applied to game management must be based on evidence and sound data, and not on instinct, intuition, ideology, or prejudice.

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Each year, stakeholders find themselves contributing to a process designed to review a number of factors in the absence of a sound and logical management model for duck hunting. A simplified approach to regulating duck hunting is needed, as is a greater commitment to monitoring abundance and the impacts of hunting.

Examples of scientific disciplines are evident in the EAAWS and meteorological data collated by GMA for considerations by stakeholders. Yet these same disciplines are not applied to the application of the legislated hunting season – bag limits, duration, and species. We see examples of this lack of consistency in 2011 with ‘normal’ conditions applied to the hunting season after extraordinary weather and breeding events, yet in 2015 modifications were applied resulting in a reduced bag limit as a response to drying, but not catastrophic conditions.

This continued application of modifications to the 2015 hunting season has again prevented conclusions being drawn on the impact of hunting on sustainable waterfowl populations. This leaves conjecture as to whether environment, habitat or hunter participation contributed to the reduced harvest in 2015.

SIMPLIFICATION A simplification of the approach taken to regulating duck hunting is available to be implemented now, through application of the legislated hunting season without modifications. This removes the continual variability applied regularly to the hunting season (bag limits or duration) and allows for an objective assessment of the impact of hunting on waterfowl populations.

Some will see this as risky, deferring any decision to data such as the weather and rainfall projections. The real risk is in fact the application of a precautionary approach yet again, and the continued inability to gather facts on the waterfowl harvest for another year.

Across the vast Australian landscape extremes of weather are exceptions. Between these extremes are average conditions, and the scenario developing for 2016 are for average conditions throughout Victoria. Projections are for largely average rainfall and temperatures, with indicators now present of the breakdown of El Niño.

Habitat and refuge is available, and includes the Murray River which cannot be hunted on in Victoria and New South Wales. In Victoria there are 450,000 dams scattered throughout the regional landscape, 13,000 natural wetlands, 6,300km of constructed channels, 85,000 km of natural watercourses, and 120 estuaries1. Collectively, these water sources and other wetlands and rivers provide an abundance of habitat and refuge for waterfowl.

This is an ideal scenario to make progress towards an adaptive model for the hunting of waterfowl. Combined with the available habitat and retained refuge, the assessment for 2016 leads FGA to the recommendations listed in the Executive Summary on page 3.

1 As per Department of Environment, Land, Water & Planning.

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CONSIDERATIONS REQUESTED BY GMA

CONSIDERATION 1: Do you have any additional information on game duck distribution? FGA would like to highlight that there are extensive waterfowl surveys performed every year, yet selective exclusion of some data sets occurs during the seasonal assessment. Monitoring waterfowl abundance and distribution is vital for proper, informed management, and commitment to this monitoring is identified as a key priority for adaptive management2.

Summer Waterfowl Counts (SWC) through the Arthur Rylah Institute for Environmental Research (ARI) have been reported annually; however, these have not been included in the material provided by GMA for consideration.

At the time of writing, the 2015 SWC has just been received following the request for this information. FGA would like to enquire why the SWC is not included for consideration for waterfowl hunting seasons.

The SWC was initiated in 1987 for the management of duck hunting in Victoria3 with the following aims:

locate concentrations of Freckled Duck (listed as Rare and Threatened);

provide details of the distribution of protected and game species of waterfowl;

locate concentrations of breeding waterfowl to avoid possible disturbance (note, breeding is not a regular occurrence in Victoria at the time the SWC is conducted); and

provide a tool for monitoring waterfowl over time.4

SWC data shows record low numbers of game birds during the Millennium Drought in 2008 (58,628 birds) that quickly recovered in 2012 to above average (212,865 game birds).

In 2014, a total of 267,055 ducks belonging to the eight game species were counted, a 44% increase on the 2013 total. The mean number of game birds per wetland across 166 wetlands was 1,609, which is 2.2 times the average of 738 game birds per wetland over 29 years of SWC surveys.

SWC data for 2015 shows 159,666 game birds from a sample of 40 fewer wetlands counted – 60% of the 2014 sample.

The mean number of game birds per wetland across 126 wetlands in 2015 was 1,267 – 1.7 times the average of 738 game birds per wetland over 29 years of SWC surveys.

All indicators show that the 2015 season should never have been a modified season and it was an overreaction to drying after record floods in 2011-2012.

This again raises the impact of overreaching when applying modified bag limits as a precautionary measure to address a variety of conditions.

While the hunting season conditions are already set when the SWC is conducted, the SWC highlights the potential benefits from consistency with data used over the long term. This can avoid the precautionary

2 Adaptive management of duck hunting in Victoria: An assessment of issues, G.J.W. Webb and P. Whitehead, 2004. Report prepared for Field and Game Australia by Wildlife Management International Pty. Sanderson, NT. 3 The management of duck hunting in Victoria – a review, ARI Technical Report Series No. 70, Loyn, R.H., 1989 and Assessing and managing the impact of duck hunting in Victoria – a new approach, Wildfowl 42: pp 155–61, R.H. Loyn, 1991. 4 The 2012 Summer Waterbird Count in Victoria, ARI Technical Report Series No. 242, R.H. Loyn and D. Purdey, 2012.

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approach resulting in modified game seasons/bag limits, which again prevents developing a picture of the impact from regulating hunting.

The 2008 National Waterbird Survey (NWS) surveyed vast areas of Australia at the height of the Millenium Drought. The resulting data demonstrates the ability of waterfowl to secure habitat in the direst of conditions, as illustrated by the distribution maps for game birds surveyed during the 2008 NWS.

The 2008 NWS included 64 Ramsar-listed wetland sites across Australia, within each of 12 drainage divisions, if those Ramsar-listed wetlands held water in 2008. There were 4,858 wetlands surveyed, covering an area of 2,724,351 ha.

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The 2008 NWS records the 20 most abundant waterbird species, for a total count of 4,287,283. Included in the top 20 most abundant are six game species which can be hunted in Victoria, representing 17.5% of the total abundance recorded, plus magpie geese (representing 21% of the abundance, and a game species in the Northern Territory).

Summary: FGA volunteer surveys of 128 wetlands - November 2015

Surveys show the expected return to normal populations following the breeding triggered by significant rainfall events. The breeding demonstrates the incredible resilience of our native waterfowl, in spite of the conditions endured through the Millenium Drought.

Mobility of waterfowl and their adaptability to weather events are demonstrated in two cases.

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In 2012, the lead-up to the opening of the hunting season held prospects of good numbers of game species and good habitat; however, a rain event in central Australia and calm weather resulted in a massive migration of waterfowl from Victoria.

Western Treatment Plant data from 2000 to 20125 shows the regularity of movement in and out of the wetland. The chart shows the migration of waterfowl coinciding with the massive rain events across Australia in late 2010, and again in 2011, before returning in huge numbers (100,000+) in early 2012.

In addition, the opening weekend harvest for 2012 was 5.26 ducks per hunter, down from 9.19 in 2011. However, the season harvest rebounded, with an average number of ducks of 4.6 for each day hunted in 2012 (5.7 in 2011).

5 Waterbird Monitoring at the Western Treatment Plant, 2000–12: The effects of climate and sewage treatment processes on waterbird populations, R.H. Loyn, D.I. Rogers, R.J. Swindley, K. Stamation, P. Macak and P. Menkhorst, 2014.

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History shows the changes to our landscape suits our game and waterfowl species. Within living memory, Wood Ducks were extremely scarce – now they are prolific. Their preferred habitat is improved pasture, lawns, and parkland, which may explain their relative low numbers assessed in the Eastern Australian Aerial Waterbird Survey (EAAWS). In Western Australia, Wood Duck are subject to agricultural damage mitigation by shooting on private property, as are Mountain Duck. This indicates these birds are present in numbers beyond those surveyed by the EAAWS.

As has been noted in the GMA data, Wood Ducks are harvested by hunters more than any other game duck (29% of the 2015 harvest), yet are recognised as the most difficult to estimate abundance of by fly overs, due to their preferred habitat of rivers, farm dams, and so on.

In the years of 2009 and 2010, when overall duck numbers were very low and bag limits reduced (to two and five, respectively), three extra Wood Duck were allowed each day. This resulted in Wood Duck consisting 59% of the 2009 harvest and 45% in 2010. In the following years when normal bag limits applied, the Wood Duck harvest reduced to around 27%.

In summary:

aerial surveys are insufficient to monitor waterbird distribution and abundance, especially with the less aquatic species such as Wood Duck;

additional surveys should be utilised in seasonal assessments to provide a more complete picture to assist with population monitoring; and

waterfowl are not captive or limited in their migratory habits, regularly travelling in response to climatic changes to find the best suited habitat.

CONSIDERATION 2: Do you have any additional information on habitat availability, distribution and extent? The GMA considerations (reference page 26) illustrate how difficult it is to accurately represent habitat and distribution data, without good process of cross-reference with other data to validate. When used in isolation this creates the risk of providing an incomplete picture. For example, the EAAWS Band 1 indicates minimal concentrations of waterbirds as only the wetlands of Jack Smith Lake (predominately dry) and

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Curdies Inlet are surveyed. The survey ignores the Gippsland Lakes and the Geelong area, both of which are Ramsar-listed and within 40 km of EAAWS Band 1. FGA ground counts indicate these two locations are holding large numbers of game duck species.

Predictions about water and wetlands can be cross-referenced with actual ground conditions, using modern satellite and/or Unmanned Aerial Vehicles (UAV, commonly referred to as ‘drones.’) This use of technology available today provides another reference to other indicators included in the considerations.

Similarly, the process of suitable volunteers on the ground, working to an agreed framework, can assess specific or nominated wetlands. This can provide valuable input to both wetlands and population abundance, and assist to cross-reference with other sets of data.

The largest abundance of waterbirds recorded in the EAAWS was located in NSW and QLD, two areas of the country where waterfowl are not harvested by recreational hunting. We agree with the comment on page 30 of the GMA document that:

‘This year, concentrations of birds are mostly on the NSW/Victorian border, northern NSW and northern QLD. Given there is no recreational hunting in NSW and QLD and little pest control in northern NSW and QLD, those populations are largely not subjected to hunting losses. Besides these concentrations, game ducks are scattered throughout eastern Australia where suitable habitat can be found.’

This comment supports our proposition that NSW and QLD act as refuges during a Victorian hunting season. This is further supported by comments of the Expert Scientific Panel examining the development of a sustainable harvest model for Victorian waterfowl.

‘The survival of many waterbird species in Victoria, despite ongoing reductions in wetland area and quality, and various forms of population harvest and control over the last 100+ years, reflects their high mobility, the fundamental importance of immigration and emigration (to and from wetlands outside of Victoria), and high breeding potential when optimal conditions prevail (inside and/or outside Victoria). From this perspective, most waterfowl species in Victoria are resilient.’6

HABITAT AVAILABILITY In the driest inhabited continent on earth, where there is water, life abounds. Wetlands feed and shelter some of Australia’s rarest and most vulnerable plants, animals and ecosystems.7

SALINE WETLANDS In Victoria it is estimated that approximately one-third of natural wetlands have been lost through drainage since 18358. This loss of natural wetlands is significant for the many species of ducks that use permanent coastal wetlands as refuges during summer, when inland wetlands dry out9 (Firth 1982).

In Victoria we are lucky that we have coastal areas that support huge numbers of ducks on saline wetlands, ranging from the east: Mallacoota, Bemm River, Orbost/Marlo, Lake Tyers, the Gippsland Lakes system

6 Developing a sustainable harvest model for Victorian Waterfowl, D.S.L. Ramsay, D.M. Forsyth, M.J. Conroy. G. Hall, R.T. Kingsford, G. Mitchell, D.A. Roshier, C.J. Vellman, G. Webb, and B. Wintle, 2009. 7 Wetlands Australia National wetlands update issue 27, Australian Government Department of the Environment, August 2015. 8 Wetlands of Victoria I. Wetlands and waterbirds of the Snowy River and Gippsland Lakes catchments, Proceedings of the Royal Society of Victoria, A.H. Corrick and F.I. Norman, 1980. 9 Waterfowl in Australia, 2nd edn, H.J. Frith, Angus and Robertson, Sydney, 1982.

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(including Lakes Entrance), Lake King, Jones Bay, Lake Victoria, Lake Wellington, Lake Coleman and Lake Reeve; through to Port Phillip Bay and surrounding wetlands including the Eastern Treatment Plant, the Ramsar-listed Western Treatment Plant and Lake Borrie, Limeburner’s Lagoon, Swan Bay, Lake Connewarre and the Lower Barwon River, Reedy Lake, and Hospital Swamp. In the west: Aire River, Curdies Inlet, Hopkins River, Lake Yambuk, and the many associated wetlands and estuary systems. In total Victoria has 120 estuary systems, 83 of which exceed 1 km in length.

Permanent saline wetlands support a greater abundance of total ducks than all other wetland types except waste stabilisation ponds (WSPs). The density is significantly greater on WSPs than all other wetland types10.

WASTE WATER TREATMENT PLANTS The significance of waste water treatment plants and their WSPs to ducks has been well documented11, including in Victoria1213. The importance of artificial wetlands to ducks has increased as a result of the loss of natural wetlands. WSPs have been found to support significantly greater species richness, abundance and density of many waterfowl species, as well as a different waterfowl community to other wetlands (deep marsh, open water, permanently saline and semi-permanent saline wetlands)14.

Victoria has 198 waste water treatment plants15, representing 4,875 ha of permanent wetlands habitat dispersed evenly throughout Victoria, where no hunting is allowed. These provide thousands of waterfowl important refuge.

10 What can a database compiled over 22 years tell us about the use of different types of wetlands by waterfowl in south-eastern Australian summers?, C.G. Murray et al, 2012. 11 See Perspectives on wastewater treatment wetlands and waterbird conservation, Journal of Applied Ecology, C.G. Murray and A.J. Hamilton, 2010. 12 Distribution of foraging waterbirds throughout the Lake Borrie ponds at the Western Treatment Plant, Victoria (Australia), The Victorian Naturalist, A.J. Hamilton and I.R. Taylor, 2005. 13 Balancing wastewater treatment objectives and waterbird conservation objectives and waterbird conservation at a major sewage treatment plant, W.K. Steele, A.J. Hamilton, I.R. Taylor and R.H. Loyn, 5th World Water Congress, 10–14 September 2006. IWA Publishing, London, Beijing. 14 Ibid 10. 15 Department of Environment, Land, Water & Planning website, accessed December 8, 2015.

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Waste water treatment plants have the capacity to hold large numbers of waterfowl. This has been documented in the ARI report Waterbird monitoring at the Western Treatment Plant 2000-12, 2014, which contains a 12-year data set, with a mean average of 33,500 game species. This year’s November 2015 count was approximately 45,000 game species on the Lake Borrie section (406 ha) of the Western Treatment Plant. The Western Treatment Plant has regularly constituted more than half the birds counted during SWC, particularly in some recent years when fewer wetlands were surveyed state-wide. More than 68% of the state-wide total for Hardhead were counted at the Western Treatment Plant in both 2014 and 2015. The plant also accounted for over a third of the state-wide total of Australian Shelduck, Australasian Shoveler, Chestnut Teal and Pink-eared Duck16.

FGA has counted 21 sewage treatment sites in Victoria during November that found 68,625 game birds. This is an indication of the amount and value of this habitat.

DAMS AND WATER STORAGES Victoria has about 450,000 dams. The sizes of our dams range from major storages such as Dartmouth dam (about 4,000,000 Ml), Lake Eildon (about 3,300,000 Ml) and the Thomson dam (about 1,070,000 Ml) to small swimming pool-sized dams on farms or lifestyle properties. These smaller, privately-owned dams are the most common type of dam in Victoria. There seems to be a direct relationship between the number of farm dams and the number and broods of Wood Ducks17. The vast number of farm dams in Australia

16 Victorian Summer Waterbird Counts: 2014 and 2015, D. Purdey and P Menkhorst, Arthur Rylah Institute for Environmental Research, 2015. Unpublished client report for Ecological Policy Branch, Department of Environment, Land, Water & Planning. 17 Farm dams, B.V. Timms, 1980, in An Ecological Basis for Water Resource Management, ed. W.D. Williams, Australian National University Press, Canberra.

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represents a considerable increase in habitat for Wood Ducks since European colonisation and resulting agricultural expansion. Since farm dams continue to be established, populations of Wood Ducks should continue to increase18.

Together, Victoria's dams have a total storage capacity of about 13,400,000 Ml.

Although Victoria’s water storage levels are currently at 53.5%, they are still well above levels seen during the Millennium Drought 1996–2010. Melbourne Water storage levels are at 71%, well up from their 2009 low of 26%.

The GMA considerations document states on page 14:

‘Many deep man-made storages do not provide good waterbird habitat but they can provide an indication of the availability of waterbird habitat in surrounding areas and waterflow in feeder systems’

As the dams become shallower, they also become functionally more like natural wetlands19. The shallower water providing excellent habitat for waterbirds.

WATERWAYS Victoria has 3,820 named waterways that total over 85,000 km. The top ten river systems by average flow are the Murray, Goulburn, Snowy, Ovens, Thompson, Yarra, Latrobe, Mitchell, Glenelg and Kiewa systems. These rivers provide ideal habitat for waterbirds, with many of them feeding extensive wetland networks.

Goulburn-Murray Water has 6,300 kms of channels, while not ideal habitat for all waterbirds when full, they become ideal habitat when the water level drops. All Victorian game species have been observed using the channel network, although they are a favorite of Pacific Black Duck and Australian Wood Duck.

NATURAL WETLANDS Over 13,000 natural wetlands exist across Victoria. Wetlands are still-water environments, usually occurring where water collects in depressions in the landscape from either surface water or groundwater, and can include swamps and lakes. Some wetlands are dependent on groundwater for their existence; others rely on surface water run-off or large floods from adjacent rivers.

The 2013 inventory of Victorian wetlands recorded 23,739 natural wetlands covering 604,322 ha, and 11,060 artificial wetlands covering 170,613 ha.

Some wetlands naturally have water in them all the time, while others naturally dry out for short or long periods of time.20

Victoria’s Ramsar Wetlands:

Barmah Forest – 28,515 ha.

Corner Inlet – 67,192 ha.

Edithvale-Seaford Wetlands – 261 ha.

Gippsland Lakes – 60,015 ha.

Gunbower Forest – 19,931 ha.

Hattah-Kulkyne Lakes – 955 ha.

18 Maned Ducks and Farm Dams: a Success Story, R.T. Kingsford, 1992, Emu 92, 163–169. 19 Prioritizing Wetlands for Waterbirds in a Boom and Bust System: Waterbird Refugia and Breeding in the Murray-Darling Basin, G. Bino, R.T. Kingsford, and J. Porter, 2015. 20 Department of Environment, Land, Water & Planning.

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Kerang Wetlands – 9,419 ha.

Lake Albacutya – 5,731 ha.

Port Phillip Bay (Western Shoreline) and Bellarine Peninsula – 22,645 ha.

Western District Lakes – 32,898 ha.

Western Port – 59,297 ha.

Total 306,859 ha.

In summary, there are vast areas of wetland and suitable habitat within Victoria and across the country. Given the nomadic nature of Australian waterbirds, and the abundant habitat and refuge found within areas such as WSPs, the evidence suggests that habitat availability, distribution and extent is far greater than estimated.

CONSIDERATION 3: Do you have any additional information on hunting pressure? The term ‘hunting pressure’ has not been defined and is, therefore, difficult to appropriately address.

Waterfowl hunting is relatively evenly spread between public land and private land. Hunting on private land facilitates less hunters, as access is restricted and by invitation only.

The GMA’s hunter survey response sample is very low: in 2014, responses represented <1% of total game licences issued. Therefore, the sample cannot be considered statistically valid, and again reinforces the need for consistent, standardised collection of data.

The material provided by GMA for consideration illustrates in its own assessment that it is uncertain what contributed to the 2015 harvest, if harvest data is used as a proxy of ‘hunter pressure.’ To quote:

‘It is not possible to separate out if the reduced bag limit or the poor environmental conditions lead to the decline in harvest and hunter participation.’

It is precisely for this reason that FGA recommend that no bag limit reductions occur in 2016.

As an alternative, reducing the season length is not a sensible option. A reduced season length encourages hunters to increase their hunting intensity, resulting in a similar total harvest of ducks to a regular-length season for those hunters. This is supported by anecdotal evidence. However, it is acknowledged that this increased hunting activity is not consistent across the entire population of hunters, which again diminishes the insights available from the summary harvest data provided.

Reducing bag limits, which is often implemented as a response to a wide range of factors, merely serves to create further variability, preventing the standardisation of data to then effectively manage wildlife, habitat or regulate hunting. Based on anecdotal evidence from FGA members, a reduced bag limit delivers a double impact: reduced hunter activity due to smaller bag limits, and significantly diminished contribution of the $439 million economic benefit to Victoria, the majority of this in regional Victoria.

The harvest data supplied by the GMA usually gives an indication of sustainability and population, yet the variations in the reported harvest in recent years have been influenced by continued modification. The constant throughout the harvest data remains the number of birds per day hunted. This sits at approximately 3 to 5 birds per hunter per day, regardless of seasonal modification.

At the local level, hunting in south-eastern Australia has no effect on the overall population, as evidenced by the seasonal population increase and decrease correlating with wet and dry cycles (including years where there was no season or a reduced season), the nomadic nature of waterfowl travelling in response to

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weather events, their ability to take advantage of good breeding conditions during these events, and the vast areas of refuge found across Victoria, and in NSW and QLD where there is no waterfowl hunting.

As discussed in Consideration 2, availability of habitat and water is the overriding factor in duck abundance, not hunting pressure.

CONSIDERATION 4: Do you have any additional information on game duck productivity? EAAWS Index Bands 1, 2 and 3 are most relative to game ducks in Victoria. Data from these bands for the game bird species show the abundance index for most game duck species have either increased (54% of game species across Index Bands 1, 2 and 3) or remained static (20%) over the past 12 months. Fewer species recorded a decrease in the 2015 abundance index (25%). This is a favourable trend indicating a possible improvement in productivity. As long as this data is assessed in isolation, the possible causes for this trend will remain unknown.

Information provided in the GMA considerations document (page 38) includes the statement ‘Waterbird breeding is suppressed’. There is no reliable data or evidence to validate this comment; particularly when considering the comment on page 19 that the EAAWS provides ‘limited information on waterbird breeding’ and the comment on page 27 that ‘detectability of breeding is limited using aerial survey methods’. The EAAWS breeding index data also relates to all species of waterbirds – there is no index specific to game birds.

Further, there is another statement (page 27) that ‘The Victorian Summer Waterfowl Count conducted in February 2015 found little incidence of breeding.’ This is not considered a valid comment as February is not within the regular breeding period of ducks in Victoria: most duck species in Victoria breed in late winter and spring21.

Australian waterfowl demonstrate the ability to respond to favourable breeding environments after weather events. FGA’s Waterfowl Research over the past 7 years shows a material increase in size across all species sampled following the break of the Millenium Drought, indicating greater feeding and better overall health in response to improved habitat22.

CONSIDERATION 5: Do you have any additional climate data? Average conditions are favourable indicators to sustaining habitat and water, removing extremes of adverse weather or rainfall.

NSW and north-eastern South Australia received above-average rainfall in 2015. Rainfall is predicted to be above average for most of eastern Australia over summer.

Cooler or average summer temperatures are predicted across most of eastern Australia: this will ease the potential for habitat loss through evaporation and wetland drying.

A large area of eastern QLD and north‐eastern NSW is predicted to receive greater than median rainfall over summer.

The following maps illustrates the average conditions forecast to February 2016 – by rainfall and by temperature – and the moderating effect on conditions from December 2014.

21 Ibid 9. 22 Report on the collection of biological samples from harvested waterfowl during the 2015 Victorian waterfowl season, G. Hall, 2015. Unpublished report prepared for Field & Game Australia.

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Attention is also drawn to the Southern Oscillation Index ranges +7 to -7 which are considered neutral, as referenced in the GMA considerations, page 11.

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For clarity, the Bureau of Meteorology’s outlook has stated that El Niño conditions will ease in early 2016, not deteriorate as mentioned in the GMA consideration document (pages 11 and 37). The use of the word ‘deteriorate’ is misleading.

Post-El Niño outcomes result in:

a return to average conditions (50%),

development into La Nina events (38%), or

redevelop into El Niño (12%) (this is not forecast to occur).

There is additional weather and climate information due on 17 December which, due to timing for the submission, will not be assessed.

CONSIDERATION 6: Do you have any other relevant additional information that could contribute to the recommendation process? Most wetlands now rely on either environmental water allocations or the runoff after irrigation allocations have been taken. With our modified landscape, the result is the requirement to actively manage habitat and water, and remains at the core of the focus established by FGA with government since 1958.

The process for the annual deliberation on duck season was examined in 2009, producing the report Developing a sustainable harvest model for Victorian Waterfowl. The panel of scientists (D.S.L. Ramsay, D.M. Forsyth, M.J. Conroy. G. Hall, R.T. Kingsford, G. Mitchell, D.A. Roshier, C.J. Vellman, G. Webb, and B. Wintle) acknowledged that:

‘The impacts of controlled hunting of wild populations, by comparison, (i) cannot be quantified on the basis of available data,

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(ii) are likely to be species‐specific, and (iii) are unlikely to be quantified unless an adaptive harvest model is implemented.’

Process of assessing a variety of data, some included for the first time, needs review and change. This is especially in the case when Victoria has a legislated approach to waterfowl hunting.

Timing for the Victorian Minister’s announcement has been highlighted as being long dated as a result of the timing for the processes. This has an impact on small businesses and retailers across the state, as to monetise the impacts of this timing, retail outlets need to order stock by, at latest, the beginning of December. Upstream importers may require up to 90 days for shipping, plus time to place orders.

The variance across states is marked – Tasmania has already signed off the 2016 season and updated websites, without fanfare.

South Australia assesses conditions each year before making recommendations to the relevant Minister. That process has already taken place.

The review of conditions for the 2016 Victorian hunting season has removed direct engagement and; therefore, consultation between hunting organisations and game managers. It is recommended that engagement with hunting organisations be encouraged, not discouraged, as only through ongoing engagement can opportunities be created for greater collaborative effort with a large network of passionate, knowledgeable volunteers.

CONSIDERATION 7: Considering all the information available, should there be a modification to the 2016 duck season in order to ensure sustainability and why? The process of reviewing data and submissions for the 2016 waterfowl hunting season is a reminder of the temptation to base decisions and policy related to hunting on instinct, intuition, prejudice, and ideology rather than facts and data.

If a modified season is the scenario delivered to Victorians, it can only be to achieve some outcome other than to apply sound management consistent with international best practice and establishing the management of waterfowl hunting on a sound scientific base.

It is important that this process resists that temptation. For example, a link between waterfowl hunting and reduction in duck populations must be proven, and not asserted.

Succumbing to this temptation has been an occurrence since market hunting as a means of providing a valuable source of protein to Melbourne households. The fact that market hunting intensively harvested large numbers of waterfowl for the best part of two centuries (without the rigour of bag limits and seasons) exemplifies the long-term sustainability of hunting waterfowl. When environmental conditions worsen, our native waterfowl demonstrates their innate survival instinct and ability to seek out better habitat. They also trigger significant breeding events when conditions improve, such as the break of drought conditions in 2011.

The oft-stated ‘wisdom’ has it that hunting and dry conditions cause a reduction in waterfowl numbers.

Studies are quoted selectively to reinforce this impression. Continuing to adjust the parameters applied to game seasons and hunting prevents the collection of evidence and data to properly inform long-term

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decision making. This has been recognised twice in the past 15 years, resulting in work by the ARI in 2003 and 201023, attempting to address adaptive management models.

This issue is important since the basis of controls and restrictions on the management of wildlife populations is to impose a precautionary response and reduce the collection of facts to assess the regulation of hunting.

For these reasons, FGA submits there is no evidence to act other than to implement the waterfowl hunting season in its entirety as legislated in Victoria, that is both duration and bag limit.

Any modifications applied to the 2016 hunting season will only serve to implement, yet again, a precautionary approach; avoiding the opportunity to demonstrate a commitment to monitoring abundance and the impacts of hunting through a disciplined basis of gathering data and facts.

Recommendations: FGA advocates the implementation of the legislated hunting season, as defined in legislation, without modification for 2016. FGA recommends the transition to a simplified and, ideally, standardised approach to regulating waterfowl hunting (commencing with the 2016 hunting season) with no modifications implemented for a defined period, recommended as five years. FGA seeks greater commitment to improving wetland habitat for waterfowl, and monitoring waterfowl abundance.

Acknowledgements John Byers, Max Downes, Mark Daley, John Hirt, Gary Howard, Bill Paterson, Rob Treble, Peter Warner, Simon Webster.

Bairnsdale Field & Game, Benalla Field & Game, Donald Field & Game, Geelong Field & Game, Portland/Heywood Field & Game, Sale Field & Game, Traralgon Field & Game, Wodonga-Albury Field & Game, and all Field & Game Australia members that participated in the 2015 November Waterfowl Count and Habitat Survey.

23 Developing a sustainable harvest model for Victorian Waterfowl, D.S.L. Ramsay, D.M. Forsyth, M.J. Conroy. G. Hall, R.T. Kingsford, G. Mitchell, D.A. Roshier, C.J. Vellman, G. Webb, and B. Wintle, 2009.