CHAPTER 6 - ADEQUACY OF WILDLIFE
REGULATIONS
Term of Reference (b) - the adequacy of existing Federal Government regulations and controls to
ensure biodiversity of any native species commercially utilised
Introduction
6.1 Two seemingly opposing views were presented to the Committee on the adequacy of government
regulations on the commercial utilisation of wildlife. First, as argued mainly by animal rights and some
conservation groups, the current regulations restricting the use of native wildlife were not strong enough
and should be strengthened. Second, as argued by wildlife industry groups, emerging and existing wildlife
industries were hampered by complicated and restrictive bureaucratic requirements which delayed
procedures and placed a financial constraint on business growth.
6.2 These two points of view, however, are not necessarily mutually exclusive. In fact, aspects of both
arguments may be correct and changes in both areas may be needed. That is, in areas where
commercialisation is not appropriate, regulations may need to be strengthened; and in areas where
commercialisation is allowed, restrictive and duplicated bureaucratic arrangements may need to be
rationalised. [1]
6.3 There is also a third point of view, linked to the first, which was strongly argued in some submissions
that some regulations are in fact counter-productive to the conservation of wildlife and maintenance of
biodiversity. A fourth, and important issue is that of the adequacy of the regulatory environment in
relation to animal welfare.
6.4 The issue of exporting live native wildlife, currently prohibited under the Wildlife Protection
(Regulation of Exports and Imports) Act 1982, was also discussed at length in evidence. This issue is
considered in the following chapter (Chapter 7).
Regulations Have Failed to Protect Wildlife from Commercialisation
6.5 A number of conservation and animal welfare organisations argued that the Wildlife Protection
(Regulation of Exports and Imports) Act 1982 was fundamentally flawed because it allowed for the
exportation of wildlife products and thus failed to adequately protect native animals. [2] The Australian
Wildlife Protection Council argued that the Act failed to link animal welfare, cruelty and wildlife
protection issues. [3] Nascaring Wildlife Carers concurred with this view, claiming in its submission that:
'There never has been and never will be adequate regulations and controls. It has been proven time and
time again that regulations and controls are useless without the manpower to police each and every
exploiter on a full time basis'. [4]
6.6 The Native Bird Liberation Alliance argued that if commercial utilisation of native wildlife was to
expand, there would be a corresponding need to expand licensing in all areas (harvesting, trapping,
transportation, sale, housing, health and hygiene), but because enforcement resources of government
agencies were already inadequate, they would not be able to keep up with an expansion of wildlife
trade. [5] The Arid Lands Environment Council argued that there was a need to strengthen the
regulatory framework for the commercial utilisation of wildlife, as was evidenced by the fact that many
commercial and non-commercial activities were already occurring without legislative control. [6]
6.7 The Sunshine Coast Environment Council Inc argued in its submission that the Wildlife Protection
(Regulation of Exports and Imports) Act 1982 offered 'weak criteria in determining which programs
should be used'. The Council suggested that another criteria be included 'which would question the
benefit of trade to the species and Australian community; the economic viability of programs in the
absence of government funding support, and ascertain whether animal welfare and cruelty concerns are
properly addressed'. [7]
6.8 Under the Act, the Minister can approve the export of products from 'controlled specimens'; that is,
species which do not require management plans and TRAFFIC Oceania saw this as a problem
particularly as many more approvals had so far been made for Controlled Specimens, than under
Management Plans. [8] TRAFFIC also noted that the existing legislative structure and enforcement
arrangements were inadequate to protect wildlife from illegal activities and that wildlife crime was well
organised and prolific (see Paragraph 7.7, for example). [9]
Regulations are Counter-Productive to Industry Development
6.9 Industry groups provided strong evidence that because commercial utilisation of wildlife had evolved
in an ad hoc way, many of the statutory requirements were unnecessarily restrictive to their business.
Three types of problems were encountered:
- inflexibility in statutory arrangements in the Wildlife Protection (Regulation of Exports and
Imports) Act 1982;
- an overall excess of administrative procedures, compliance with which was costly and
time-consuming; and
- inconsistencies between state arrangements, and between state and Federal arrangements, leading
to a call for a national approach to commercial utilisation of wildlife. [10]
-
Federal Regulations
6.10 The Wildlife Protection (Regulation of Exports and Imports) Act 1982 implements decisions
made by CITES. However, while CITES aims to regulate trade only of rare and endangered species, a
number of submissions pointed out that the current Australian restrictions on commercial exports from
Australia were not imposed by CITES but were rather a case of Australia adopting stricter domestic
measures than were required under CITES. [11] In short, CITES is invoked too often for species which
are not endangered. [12] The major criticism by both industry and some state governments of provisions
in the Wildlife Protection (Regulation of Exports and Imports) Act 1982 was that commercial use of
wildlife was too restricted and did not sufficiently take into account differences between wildlife species
in terms of their distribution and abundance. [13]
6.11 In discussing the Act, the Western Australian Government noted that, in theory, provisions in the
Act allowed for the use of wildlife but that in practice it was used 'to restrict or prevent use even when
there was no conservation issue at stake'. The Act maintains a blanket ban on the commercial export of
all native wildlife, regardless of whether animals were bred in captivity or taken from the wild, and
regardless of whether the species were rare or common. The Western Australian Government argued
that the Act should be revised to remove the blanket ban on live exports of fauna because it did not
serve a conservation purpose, and to allow each case to be considered on its merits.
6.12 The Western Australian Government also noted that the Commonwealth may seize wildlife
products at the point of export if authorities considered that there was insufficient documentation. This
was equivalent to 'shutting the door after the horse has bolted' and had little conservation merit. In the
opinion of the Western Australian Government, it would be better use of resources to ensure that the
take from the wild was legitimate. [14]
6.13 The Tasmanian Government argued that while the Federal Government had a valuable role in
regulating wildlife trade, changes were needed to the Wildlife Protection (Regulation of Exports and
Imports) Act 1982 to allow for more varied approaches to management of harvested species. The
Government's concern stemmed from an insistence by the Commonwealth on uniform management
strategies for all macropod species despite there being differences in habitat and ecology of the various
species. The Government argued that these differences should be taken into account when management
requirements were determined. [15]
6.14 The Tasmanian Farmers and Graziers Association also argued that the Commonwealth had been
too inflexible in its approach to marsupial management in Tasmania which has hindered an integrated
program of wildlife control. The Association recommended that Environment Australia invest
considerably more effort to assist Tasmania in presenting a 'tailor made' wildlife management strategy
and then support it in a world forum.
6.15 The Wildlife Protection (Regulation of Exports and Imports) Act 1982 was also criticised on
the grounds that it did not provide for biodiversity conservation through sustainable use of wildlife. [16]
When asked by Senator Ferris whether the current regulatory system was so restrictive and outdated
that it was preventing conservation being achieved and was contributing actively to the loss of
biodiversity, Dr George Wilson stated:
… on leasehold land, governments intervene in wildlife matters in a way that really is often
counterproductive. … In terms of making decisions about harvest rates and so on, I feel that there is a
lot of scope for entrepreneurs to be able to use the resources of their land in the way that they see fit and
not be constrained by much of the legislation at the moment. [17]
6.16 The Committee notes, however, that the Federal Government has proposed extensive changes to
the suite of environmental legislation which will take into account the concept of biodiversity conservation
through sustainable use of wildlife (see Paragraph 3.13).
6.17 Finally, the submission from the Zoological Parks Board of New South Wales pointed out that the
legislative requirement that animals which were exported by approved institutions for inter-zoological
gardens transfers come from captive-bred populations, excluded the possibility of transferring individuals
of species which were hard to breed in captivity but which were nevertheless common in the wild and
which were frequently given to zoos as orphaned juveniles which could not be released back to the wild.
The Board recommended that the Act be amended to take this situation into account and that
appropriate management plans be drawn up. [18]
Compliance Costs
6.18 A major problem for industry is the cost of compliance with wildlife regulations, both in terms of the
cost of fees and the cost to business in delays in obtaining approval for exports. Costs are incurred both
through direct compliance with the Federal Wildlife Protection (Regulation of Exports and Imports)
Act 1982 and because there is often duplication of administrative requirements between state and
Federal regulations.
6.19 The Western Australian Government submission, while acknowledging the need for regulatory
provisions that protected threatened or endangered species, claimed that the current level of control over
wildlife was so strict that it put industries based on native species at a considerable disadvantage
compared to those based on non-native resources. This was compounded by the fact that emerging
wildlife industries generally did not have access to commercial, technical and marketing resources, and
had little ability to contribute to R&D. The Western Australian Government suggested that 'any initiative
to streamline the regulatory controls associated with these industries is strongly supported'. [19]
6.20 Many industry groups and individuals commented that the combined impact of Federal and state
regulations and the excessive amount of paperwork generated by them which was at times so great that
it threatened the viability of their businesses. Detailed discussion of these problems is included in the
relevant chapters in Part II of this report: kangaroos (Paragraph 9.95), emus (Paragraph 10.44),
crocodiles (Paragraph 11.42), venom supplies (Paragraph 14.35), coral (Paragraph 15.19) and shells
(Paragraph 15.27).
6.21 Often there is duplication of administrative arrangements between state and Federal government
agencies because for export of wildlife products, the Commonwealth requires permits to be issued
regardless of whether a state permit has been issued. In some instances, the Commonwealth requires the
state to provide written verification that the source of the product is legitimate before the Commonwealth
permit is issued. This could be simplified by arrangement with the Commonwealth to authorise the state
to issue the full permit. [20]
6.22 Mr David Millar commented specifically on problems with duplication of effort, both between
departments within the same tier of government and between state and Federal agencies. He also noted
inordinately long delays, inefficiencies caused by frequency of personnel changes, inaction and hastily
made policy decisions. About these inefficiencies he concluded: 'This [poor] standard of performance
costs businesses money and it costs the country money'. [21]
6.23 The need for such complicated administrative arrangements was questioned by Professor Eugene
Moll who stated in evidence:
I am always worried about too much bureaucracy. It is important that, if there is a lot of bureaucracy, it
does not get in the way of what one does. Governments and bureaucracies around the world tend to
protect themselves to a large extent from change. I am not sure how one can do it. … You have to have
some sort of regulation. At the same time, if it becomes too draconian and too difficult to manage, it gets
bypassed and people do it anyway, on the sly. It is a matter of getting that balance. [22]
Inconsistencies Between States in Wildlife Legislation
6.24 There is considerable lack of uniformity in regulations between states and this causes problems
within industries, particularly with the transport of animals or products between states. Some examples
of this are as follows: [23]
- In the crocodile industry, the Northern Territory and Western Australia allow ranching of eggs
whereas the Queensland Government does not. This causes problems for the industry in that
businesses cannot compete equally. [24]
- It is legal in South Australia to keep and breed a number of native mammals. These species are
not endangered, there are well established captive breeding programs for them, and a relatively
large amount is known about their living requirements. Yet such are the restrictions on the transfer
of those animals interstate, that people who have hopping mice or bettongs as pets in Adelaide
cannot take them out of South Australia. [25]
- In Tasmania, legislation only protects species indigenous to that state. If another state requests
assistance in a matter, the Tasmanian authorities are powerless to operate. [26]
- South Australia and Victoria have very open licensing systems for keeping wildlife but captive
breeding cannot supply demand and thus many animals are sourced from the wild. [27]
- NSW allows a person to keep less than 20 birds without a permit, regardless of whether the
species is rare or endangered; Western Australia has a tiered system for keeping birds but
records are not required to be kept so that it is almost impossible to trace parentage unless the
owner has voluntarily kept records. [28]
- Birds and reptiles can be kept in Queensland but not mammals (as is the case in Victoria and
South Australia). There is thus a flow of wild-caught Queensland mammals to southern states.
[29]
-
Need for a National Approach
6.25 Considerable evidence was presented to the Committee which suggested that both wildlife
industries and biodiversity conservation would benefit greatly from a consistent, national approach. [30]
This need arises partly because, while regulations remain within state boundaries, animals may range
widely across state borders. In addition, according to the Australian Veterinary Association: 'There is
arguably quite significant confusion about where responsibility for policy may lie, and how well this is
being enforced'. [31]
6.26 Specific areas where national uniformity is needed included the following suggestions.
- Assessment of proposals for commercial utilisation of wildlife according to an agreed set of
principles and guidelines. [32]
- Agreed set of principles and guidelines for export industries (standards, codes of practice, etc).
[33]
- Where the commercial utilisation of wildlife does not have an export component, a national
scrutiny of all proposals and a national overview of levels of use. [34]
- A national framework for animal welfare and national codes of practice for wildlife industries.
- Uniform national licensing conditions for kangaroo shooters. [35]
- A uniform and liberalised approach to fauna licensing laws (using South Australian or Victorian
models as a starting point). [36]
- Uniform laws relating to display of animals to be administered by one instrumentality. [37]
- National coordination on the range of native species that may be kept as pets and a nationally
agreed regulatory framework to cover existing native species in private ownership to protect the
welfare of all such animals. [38]
- Coordinated intelligence between state and Federal agencies and consistency in provision of staff
and resources for investigation of wildlife crime. [39]
-
Rationalisation of Agency Responsibilities
6.27 The separation of responsibilities between government conservation agencies and those involved in
primary industries is usually clear. However, with wildlife utilisation the boundaries become blurred and
the keeping of native wildlife as agricultural stock (emus, for example) has raised the question of which
agency should have responsibility for regulating farming activities and for industry promotion. While some
state governments have been willing to transfer responsibility from conservation to primary industries,
usually at the point when stock are actively farmed in closed-cycle operations, a number of
non-government conservation groups fear that this will undermine the protection provided by
conservation legislation.
6.28 Conservation groups consider that primary production agencies are more interested in promoting
the needs of industry than the ecological needs of native species. To conservation groups, the record in
fisheries and timbers, which are managed by primary industries portfolios, supports the view that the
interests of commerce heavily outweigh the interests of biodiversity conservation. While there are
mechanisms within the conservation domain to allow public participation in management decisions, they
are not common in primary industries.
6.29 Environment Australia noted that the emergence of new and sometimes novel industries, such as
butterfly farming or jellyfish harvesting, often exposed gaps in jurisdictional coverage. Awareness of the
problem had led the Biodiversity Group of the Department to initiate discussions with the Department of
Primary Industries, particularly with regard to that Department's Farm Forestry Program, and the
potential for funding through the National Vegetation Initiative to investigate production from native trees
and shrubs. [40] Further to this, the Department of Environment recommended that:
There is scope for greater harmonisation and streamlining of legislative and administrative approaches of
government agencies with responsibilities for primary industry and those with responsibilities for
conservation, both within and between the Commonwealth and State/Territory levels. [41]
Regulations are Counter-Productive to Maintaining Biodiversity
Prohibitionist Approach Has Not Protected Habitat
6.30 There is a prevailing view among both professional and amateur biological scientists that the existing
regulatory regime has in the long-term failed to protect Australia's biodiversity. Despite the original
intention of the Wildlife Protection (Regulation of Exports and Imports) Act 1982 to protect wildlife,
evidence was presented to the Committee that the prohibitionist approach taken by the legislation has
been counter-productive because it has failed to provide widespread incentives to protect habitat (see
also Paragraphs 4.66 – 4.69).
6.31 More than a decade ago, in a review of policies relating to Australia's endangered herpetofauna,
attention was drawn to the fact that preoccupation by governments with individual species, and
presumed rarity, had resulted in 'serious inconsistencies' and had 'distracted legislators from the more
pressing need to conserve populations and habitats'. The review concluded that the prohibitionist
approach of government agencies was 'counterproductive and contrary to the long-term conservation
prospects of the very fauna for which such organisations have statutory responsibility'. [42]
6.32 While blanket prohibition has placed a strong emphasis on preventing Australian people from
removing wildlife from natural habitats, and much financial resources have been dedicated to surveillance
and enforcement, the legislation has failed to protect the habitat itself, resulting in considerable loss of
wildlife. In support of this argument, wildlife biologist Mr Lyall Naylor quoted noted scientist, Dr Tim
Flannery:
We spend an estimated $120 million a year, or $1.2 billion over the last 10 years funding our wildlife
authorities and the results are still on the negative side of the ledger. Despite some gains, the overall story
is one of loss. The monies allocated to preserving our wildlife is distributed between the 9 wildlife
authorities who, in each State with the Federal body in Canberra, administer these functions. There has
been a growth industry in legislation but little in terms of reversing the negative impacts on our wildlife
and the losses that are occurring. [43]
6.33 Associate Professor Michael Tyler believes that the Act is 'flawed and lacking any social or
scientific justification'. To him it was absurd that a farmer could legally kill hundreds of pest birds or bats,
yet it was illegal to export just one of those animals for commercial gain. [44] Similarly, wildlife
entrepreneur Dr John Wamsley of Earth Sanctuaries claimed that '… to date very little has been
achieved by this legislation or by public funded bodies to reverse the decline in the wild of native species,
with numbers of many continuing to drop'.
6.34 To many scientists, it is ironic that the failure to control feral animals and in particular feral cats has
resulted in a far greater threat to and loss of small wildlife than ever presented by illegal activities. The
reality of this impact was clearly described by Mr Peter Mirtschin of Venom Supplies:
To try to illustrate the futility of one of the preoccupations of the current regulative system in Australia, I
offer the following example: Recently 9 Australian wildlife authorities and [the] customs authority, with
their considerable taxpayer-funded resources, admitted that in 70 prosecutions in a 9 year period
between 1984 and 1993, they saved 956 animals and eggs from wildlife traffickers. Sounds impressive?
Or not? One feral cat is estimated to kill 800 native animals in one year. So for the price of one bullet,
almost the same savings in wildlife can be made in an instant. Two bullets and your [sic] in front. [45]
Constraints on Scientific Research
6.35 There is a widespread view among biologists in Australia that legislation based on almost total
prohibition has been counter-productive to scientific research and thus to effective conservation and
management of Australia's biota. For both professional research scientists and amateur biologists
interested in constructive involvement in the conservation of wildlife, the existing regulatory structure
presents an extremely restrictive framework. In fact, many aspects of the regulatory regime were
described as being counter-productive to the interests of both professional and amateur research
activities.
6.36 In arguing the flawed nature of this policy approach, Professor Michael Tyler commented in 1979:
'the advent of conservation regulations in some states has created a very serious impediment to the most
fundamental research … blanket regulation involving the total protection of all species in a class …
conjures the analogy of putting every single Australian person in prison, on the legitimate argument that
police are unable to distinguish innocent citizens from the few criminals in their midst'. [46]
6.37 While current legislation generally prevents the acquisition of wildlife for personal collections in
Australia, a number of amateur biologists pointed out to the Committee that these laws impeded them
from pursuing private research and denied genuine enthusiasts access to wildlife and thus opportunities to
acquire knowledge and expertise. [47] The prohibitionist policy tended to discourage amateur biologists
who would otherwise be long-term supporters of conservation measures. [48]
6.38 Many amateur biologists have experienced considerable administrative difficulty in obtaining a
licence to catch and retain native animals. [49] There are considerable differences between states in
administrative efficiency and difficulties in moving animals between states. [50] The cost of obtaining
licences for collecting and transferring animals in some cases is also prohibitive. [51] There are also
frustrating anomalies within some states; for example it is possible to get permits to obtain wildlife for the
purpose of determining taxonomic relationships (which requires the killing of the animal) but it is almost
impossible to obtain permits to capture animals to keep for the study of behaviour of that species. [52]
When Ms Deborah Pergolotti, frogs Coordinator of the Cape York Herpetological Society, was asked
whether she had a licence to keep frogs, she explained:
The way the state legislation is, for the amount of frog material that I have I do not need a licence. It is a
strange sort of set-up in Queensland. In some ways it is ridiculous, because as an unlicensed person I
can go out to any creek or pond I want and collect an absolutely unlimited number of tadpoles. As soon
as I get a licence to keep them, I am not allowed to collect anything. So why does anybody want to get
a licence? There are a lot of anomalies in the legislation that we are certainly concerned about. [53]
6.39 If the laws were changed to allow a quota to be taken from the wild for breeding this would satisfy
amateur collectors and may result in a number of benefits to conservation. Herpetologist Mr Darren
Green argued that in fact benefits could arise from allowing amateur biologists to take a 'quota' of wildlife
from private properties:
… issuing permits or allowing a number (quota) of wildlife to be taken from the wild each year (harvest),
for the purpose of personal collections or public display should be allowed. The wildlife then has a dollar
value placed upon it and as a consequence the dollar value gives the landholder an incentive to protect
the habitat. This is particularly important with reptiles such as snakes as they are the first to be beheaded
with a shovel by the average landholder. [54]
6.40 On this matter the Western Australian Government argued that: 'The Commonwealth should
recognise that commercial collection and/or breeding of native fauna (birds, reptiles, butterflies, etc for
personal collections) can be readily managed to have nil impacts on conservation or to be advantageous
to conservation'. [55]
Lack of Support for Research by Amateur Biologists
6.41 While amateur biologists make a considerable contribution to science and to conservation
knowledge in Australia [56] very often their work goes unrecognised and unassisted. As outlined in the
submission from the Queensland Insect Breeders' Association the contribution made by amateur
entomologists to science is substantial, but not often appreciated:
It is not widely enough appreciated that much of the field work done on our native insect fauna has been
and still is being conducted by non-professional entomologists. This is demonstrated by the fact that
95% of the Australian butterfly specimens held in the Australian National Insect Collection are from
private sources … An examination of the authors of entomological papers published in Australia will
reveal the significance of private research. … As the focus of private entomological research is not
agriculturally oriented, it brings balance to the discipline of Entomology. … Much of the information
published in popular books on natural history has its sources in private entomological research. [57]
6.42 The value of the work carried out by amateur biologists was emphasised in the submission made by
the Cape York Herpetological Society. The Society believes that it is a fallacy that private keepers of
native fauna did not do anything to assist in conservation, but merely reduced wild populations out of
greed. In fact, the contrary was true in some instances where the dedication of amateur biologists had
meant that captive bred stock were available after the species had become extinct in the wild. An
example of this is the case of the Lake Eacham Rainbow Fish (Melanotaenia eachamensis), which was
classified 'extinct' in the wild but, owing to the perseverance of several individuals who were intent on
keeping the species in aquaria regardless of the regulations, was 'rediscovered' in captivity. [58]
6.43 The Society argued that zoos and universities, which were often charged with overseeing the
recovery of declining species, had little motivation to save a species unless there was a financial reason
to do so, or a PhD project attached to it. In contrast, amateurs who were willing to spend their own time
and money on rearing animals, and who generously shared information about that species among other
amateurs and professionals, were prevented from becoming involved.
6.44 In terms of frogs, the Society cited an example of a FNQ species (Taudactylus acutirostris) that
is now presumed extinct which might have been saved had amateur herpetologists been given access to
the species. Several more FNQ frog species are in severe decline. The submission concluded: 'While
interested amateurs are kept away from these frogs, there is little hope of their recovery'. [59]
6.45 In a review of the status of amateur herpetology in Australia, Mr Harald Ehmann, argued that
amateur herpetologists have made a substantial contribution to the study of herpetology over the last
30-40 years. They have played a strong role in public education, environmental awareness and
conservation, as well as providing a training ground and source of recruitment into professional areas.
Despite these contributions, however, the overall status of amateur herpetology is not held in high regard
by those in authority, particularly wildlife authorities. [60] In addition, many amateur biologists suffer
much frustration in their attempts to obtain assistance from government bodies. Mr Bradley Oliver, for
example, is keen to conduct research on the Woma python, a species about which little is known, but his
attempts to obtain assistance from the South Australian Department of Natural Resources and the
Adelaide Zoo have been discouraging:
There is just so little information on these animals. I have started off from scratch. … I have been given
very limited help from Adelaide Zoo. I have asked for information on parasites. … I got basically no
response. I was down there the other week and I wanted to see their animals. I was not even allowed to
have a look at them. So I have had no help from them. … All I wanted to do originally was to breed
them, from which I would obtain my scientific data to publish any papers. … I find the whole
circumstances very frustrating and discouraging. I am only a young person. I have been keeping reptiles
for six years now and all my experiences with National Parks have been discouraging. [61]
Voluntary Conservation Efforts
6.46 It was argued in evidence to the Committee on a number of occasions that Australian wildlife
protection laws were so prescriptive that they acted against voluntary conservation efforts. The many
ways in which voluntary conservation efforts are hampered by excessive and inappropriate Federal and
state regulations is best described by relating several examples.
Herpetology
6.47 The Victorian Herpetological Society commented in its submission: ' … most government
regulations and controls seem to be designed to protect bureaucracies. There are few, if any,
conservation success stories where government management is involved'. [62] According to the Society,
because little government-sponsored work is carried out on reptiles and frogs and because the ability of
amateur biologists is hampered by regulations, the unnecessarily slow rate at which information on the
biology and life history of individual species is being gathered has resulted in a major problem for
conservation. [63]
6.48 In discussing the status of amateur herpetology in Australia, Mr Harald Ehmann, argued that the
contribution made to biological science by non-professionals in Australia was significant, yet the attitude
held by professionals and people in authority towards amateurs was negative and unsupportive. Further,
the paper argued, 'a feeling and self-sense of criminality in many amateur herpetologists (and a good
number of professionals …) is engendered by the existing complicated, often irrelevant legislation. …
The restrictions of the past 20 years on amateur herpetological activities and the development of
herpetological skills pose a serious long-term risk to herpetology. … conservation would benefit
significantly from a rationalisation of the present restrictive policies and interpretations of legislation'. [64]
6.49 Similarly, Mr Bradley Oliver, an amateur herpetologist, commented in his submission to the
Committee: 'Under blanket legislation we are seeing the decline of native wildlife at an alarming rate. The
current system regulates people who wish to keep and learn about out native wildlife by confronting
them with frustrating, confusing and poorly managed laws and is doing nothing to conserve and increase
wild populations'. [65] This view was also put by the Victorian Herpetological Society which stated in its
submission to the Committee: 'The least threat to wildlife populations is collecting and keeping, however
this is one of the main areas that state governments have directed a lot of their resources'. [66]
6.50 Ms Pergolotti gave the following example of the way in which wildlife laws were
counter-productive to amateur conservation efforts:
When I lived in Sydney, I was called upon to document the road kills at Homebush Bay (the future
Olympic site) of the endangered Green and Golden Bell Frog (Litoria aurea). … These endangered
frogs were using a particular stretch of one road to cross from the famous 'brickpit area' to an ephemeral
wetland on the other side of the road. In crossing, they were being run over by cars. In two rainy nights
in January 1995, an estimated 6-13% of the entire population of 100-200 known adults was killed, one
of those being a gravid female.
I offered to organise a group of volunteers to patrol the road looking for approaching frogs, pick them
up and carry them to the other side and release them unharmed. I was warned that if any of us picked up
an endangered frog (referred to at the time as a "schedule 12 animal"), we would be prosecuted for
"interfering with an endangered species". However, no charges would be laid against anyone running
over the same frog, even if the event was witnessed and their registration number taken.
… NP&WS refused to back any of the suggestions [made by Ms Pergolotti to save the frogs] on the
grounds that if the general public found out endangered frogs were at that location, everyone would
show up and illegally collect every frog in the area. … [However] the same department later issued a
"take and kill" licence to the Olympic Coordination Authority to kill Green and Golden Bell Frogs … so
much for the conservation and protection of endangered species. [67]
Aviculture
6.51 According to the Queensland Council of Birds Societies, the regulation of the movement of birds
within Australia through a permit system administered by Environment Australia is thorough and functions
well (and may be necessary), but does nothing for the conservation of birds in their natural habitat. [68]
As an example, Mr Cameron McTavish, Past president of the Pet Industry Joint Advisory Council of
Australia argued that recent changes to regulations in Queensland had been counter-productive to the
status of the threatened Gouldian Finch:
The Gouldian finch, which you are probably familiar with, a very pretty little finch, is expected to be
extinct in the wild within 10 years. There is a very limited population of them. There is a huge population
in aviaries,hundreds of thousands of them. They breed like mice if they are protected and fed and looked
after. But the laws in Queensland have just been changed so that for someone to own a pair of Gouldian
finches they have to pay a $35 annual fee. For the retailer to sell them and trade in them, he has to pay a
$350 annual fee.
The result is that these birds are selling for only about $20 a pair … the market has totally collapsed;
people have stopped breeding this bird. Why not buy a canary where you do not have to pay a $35
annual fee? The market has totally collapsed. People who are breeding this endangered species are
going out of it just because there is no economic return in it any more. The same is true for a number of
other species … [69]
Insects
6.52 Entomologists similarly have problems with wildlife laws, particularly with the collection of common
species. [70] As explained by Mr Clive Shaun, a member of the Queensland Insect Breeders'
Association who gave evidence to the Committee in Cairns:
As state and federal laws stand at the present time, with a few exceptions, no amateur or commercial
persons are able to export any of our native insect species unless the specimens themselves have been
captive bred by fully licensed captive breeding establishments. At present, a collector has to be at least
affiliated with a government body to obtain a collecting permit. It is well known that these permits are
just not normally available to the general entomologist.
Our current legislation also has some negative effects. For example, amateur entomologists cannot
expand their own private collection by exchanging material with their counterparts overseas without the
risk of state or federal prosecution. Nor can we easily undertake any type of field work to expand our
knowledge in either state forests or national parks. It is easy to see that current legislation is only stifling
private research. At present, Australia is the only country in the world with such strict measures in place.
[71]
6.53 Mr Shaun went on to argue that with the exclusion of some rare species, there was no reason why
the government should not allow either a self managed or a licensed system to operate. This would allow
amateur and commercial collectors to exchange a small amount of insect material with overseas contacts
without the risk of state or Federal prosecution.
Need to Foster Kinship
6.54 It is well recognised that people have a greater degree of care for wildlife if they have had some
personal involvement or direct contact with it, yet according to Dr Tim Flannery, author of the popular
science book, The Future Eaters, 'there is a great legal fence that divides ordinary Australians from
their fauna'. [72] Thus a number of submissions spoke of the need to foster kinship with our wildlife,
particularly among children. [73] This can take the form of pets, nature-based tourism, encouraging
wildlife into urban areas and increased use of native plants for food and ornament. By fostering a greater
understanding of our natural heritage the needs of wildlife become more widely known and are more
likely to be catered for by landholders, the public and the government.
6.55 In his submission to the Committee, Mr David Millar commented that allowing people access to
wildlife, in a controlled fashion, would do much to foster education and understanding. In discussing the
importance of keeping reptiles and amphibians as pets, Mr Millar stated;
Not only is the herpetofauna market close to cost neutral to wild populations but it provides one very
important if unquantifiable benefit, one which is ignored by the animal 'rights' movement. I can do no
better than to quote Cogger (1997) who, describing the consequences of reduced availability of
specimens for the enthusiast says, 'I believe equally passionately that the more we proscribe physical
contact between people and animals, the more we increase society's indifference to the intrinsic worth of
animals and to their welfare and fate.' The ultimate fate of our wildlife is linked to an empathy for animals
which does not develop in many people who live a barren, animal free existence'. [74]
6.56 Similarly, Mr peter Mirtschin writes: 'One of the biggest problems, I feel, is that most Australians
have lost touch with their native wildlife, which has been effectively shielded from the public by
unnecessarily draconian legislation and regulation'. [75]
Animal Welfare
Legislation
6.57 Each state and territory in Australia has legislation relating to the prevention of cruelty to animals
and to animal welfare covering both domestic pets and agricultural animals. [76] However, this
legislation varies very much between states in terms of current relevance to animal welfare issues. Some
states have enacted new or revised legislation relatively recently (ACT, Tasmania and Victoria, for
example), some are currently drafting totally new legislation (New South Wales, Northern Territory and
Queensland); while the legislation in some states has remained relatively unchanged for many decades
(Western Australia). Because there is no Commonwealth 'Prevention of Cruelty' legislation,
Commonwealth employees (such as scientific researchers) are bound by the various state laws in which
they are working.
6.58 Legislative provisions are supported in each state and territory by 'Codes of Conduct', or 'Codes
of Practice', which relate to specific types of animals (dogs, cats, birds, sheep, horses, etc). These
documents are often based on 'model' codes developed by the Commonwealth and adapted by each
state government, in consultation with animal welfare groups, to suit particular circumstances. However,
the legal status of these codes varies between states. They may also vary within states according to
legislative arrangements.
6.59 In Queensland, for example, the concept of codes of practice is relatively new to wildlife
management, having been introduced with the commencement of the Nature Conservation Act in
December 1994. As described by Mr David Baker, Wildlife Manager for NPWS, various codes have
difference levels of accountability:
… whether or not a code of practice is enforceable is entirely dependent on how it is presented in the
regulation. For instance, the code of practice of the Queensland Wildlife Parks Association, which is the
association that represents zoo keepers,wildlife parks,in the state, is enforceable under the regulation.
…The code of practice for the humane shooting of kangaroos is enforceable under the legislation. There
is provision in the legislation for an entirely voluntary approach if the minister deems that appropriate. It
is the Minister for Environment who approves a code of practice. Depending on what the legislation
says, we end up with a code which is either enforceable or not. [77]
6.60 In Tasmania, for example, there is only one code of practice which has legal status and that relates
to animal research. There is a code of practice relating to the possum industry, but the only mechanism
to enforce the code is that it is a licence condition that the licensee comply with the code. [78]
6.61 Enforcement of matters relating to animal welfare is usually vested in designated officers of state
government departments, full-time officers of the Royal Society for the Prevention of Cruelty to Animals
(RSPCA), and members of the police force, but in practice, the bulk of prosecutions are made by
RSPCA officers.
6.62 In most states, [79] advice to government on matters relating to animal welfare is provided by an
independent Animal Welfare Advisory Committee (AWAC) which reports to the Minister responsible
for matters relating to animal welfare. The Commonwealth Government is advised by a National
Consultative Committee on Animal Welfare which coordinates animal welfare activity in Australia, and
makes recommendations on matters of national importance to the Minister for Primary Industries.
Codes of Practice
6.63 As described above, the commercial use of domestic animals is regulated through 'Codes of
Practice' and, in some wildlife industries, codes have already been developed (emus, possums,
crocodiles, for example). While codes are usually voluntary, they may have punitive aspects if operators
are found to be in contravention of them (such as the loss of a commercial licence if animals are not
killed in the specified manner). However, a number of submissions expressed concern that the 'Code of
Practice' system was inadequate.
6.64 ANZFAS argued in its submission and in oral evidence to the Committee that codes of practice did
not contain sufficient legislative strength and that there was insufficient industry self-regulation to protect
the welfare of individual animals subject to commercial use. [80] ANZFAS noted the following specific
problems with the system:
- some industries entirely lacked codes of practice and often they were written well after the
industry had commenced;
- some codes actually allowed cruel practices to go on;
- some codes lacked in important details;
- many codes were not legally enforceable and, even if they were shown to be breached, it was
often impossible to get a prosecution; and
- surveillance of industry practice was rarely undertaken, particularly in remote areas. [81]
6.65 ANZFAS was particularly concerned that in several states (Victoria, Tasmania and South
Australia) there were clauses in the Prevention of Cruelty to Animals statutes that allow as a defence the
fact that a practice was described in a code of practice. [82] In evidence to the Committee the Director
of ANZFAS, Ms Glenys Oogjes, concluded: 'I think that codes are a PR exercise … I do not feel any
comfort in the fact that we have these codes'. [83]
6.66 The lack of a comprehensive system of legal accountability for matters relating to animal welfare in
Australia was also of considerable concern to the RSPCA. While all states have Acts relating to aspects
of animals welfare, some of these are out of date and some are ineffective. Not one state has legislation
which covers all circumstances and all species. As explained by the National Director, Dr Hugh Wirth:
… one of the difficulties we are faced with in making any decisions about utilisation of both domestic and
native animals in this country is legal accountability for action. The issue is that you cannot propose
utilisation of animals, for whatever good or bad reasons, if you have no legal accountability for the
consequences. That is why the RSPCA policies are clearly in opposition to so many things, because we
know that the fate of those animals is unprotected. [84] …
I am not just simply talking about native animals, I am talking across the board; activities involving
animals. There is no national system or state-by-state system of legal accountability. There is in some
areas where it is easy to achieve. There is legal accountability, for instance, in how Australians look after
their dog and cat in most jurisdictions. [85]
6.67 When asked about the role of animal welfare legislation and codes of conduct, Dr Wirth claimed
that there was an almost complete lack of an inspectoral force. This allowed commercial enterprises to
sidestep compliance with animal welfare codes:
We have the same example where AQIS is supposed to be responsible,or was formerly responsible,for
animal welfare in domestic abattoirs killing domestic stock. There was never a prosecution and yet, in
my capacity as President of the RSPCA involved with the national consultative committee on animal
welfare, when we went through abattoirs as a working group,this is only several years ago,to have a
look at humaneness, we saw inhumanity everywhere. I have absolutely no confidence in that convoluted
system. There is no public legal accountability unless it is regulatory. …
The reason it [repeated cases of inhumane treatment of animals] does not show up is because there is no
inspectorial force. … there are blatant breaches of the so-called codes approved by AQIS, and you
have got AQIS people on the plant who never report anything,who never do anything. That is the
problem with commercial utilisation: all of the checks and balances are sidestepped to achieve an end
result. [86]
6.68 The RSPCA also noted that many Codes of Practices were merely cosmetic in effect. Frequently,
species management plans contained 'well intentioned objectives in terms of treating animals humanely',
but there was often a lack of explanation as to how the methods were to be carried out and, more
importantly, no mechanism to ensure compliance because the code was only advisory, not regulatory.
[87]
6.69 Animal Liberation (Victoria) also expressed concern that codes of practice were not legally
enforceable, [88] and on this matter Animal Liberation (South Australia) commented:
… animal welfare groups are aware of the inadequacy of existing laws, and the totally ineffectual "Codes
of Practice", to prevent animal suffering. This is true in existing industries, such as the intensive farming
industries of egg and chicken production, and is of particular concern in some new industries, such as
emu farming. [89]
6.70 Emu Industry representative, Mr Greg Barowski, agreed that enforceability was a problem with
voluntary codes of practice:
Unless codes of practice can be enforced by any self-regulating industry body or somebody else, that
leaves you open to the fair enough criticism that, if you cannot do anything about a code of practice,
what is the point of having a code of practice. [90]
6.71 Another problem for industry is the potential for different codes to overlap and conflict. In
Queensland, for example, Hartley's Creek Crocodile Farm has to consider three codes of practice in its
management of crocodiles: one which relates to workplace health and safety, one which relates to
farming animals, and one which relates to animals kept in wildlife parks. [91]
6.72 One advantage of the system is that codes can be revised relatively easily, much more easily than
regulations or legislation. Dr Mike Manuel, Secretary to the Tasmanian Animal Welfare Advisory
Committee, explained to the Committee that animal welfare codes needed to evolve to take into account
new research results and changing public opinion and he cited the example that while the third version of
the possum code of practice had just been released, it was already being subject to further review. [92]
Mr Manuel also stated:
The community makes a judgment as to what sort of welfare it is prepared to accept and the standards it
is prepared to accept, and that is one of the reasons why in the animal welfare act we have got two
words for cruelty,that is, 'unreasonable' and 'unjustifiable' pain and suffering to animals. So if the
community wants to shift the welfare to a different plane, the community will have to probably look at the
cost to it. [93]
Impact of Government Policy
6.73 According to a recent draft report by the Industry Commission, despite efforts by government to
develop and implement policies on ecologically sustainable development in Australia, the process has
been 'ad hoc, incomplete and tentative'. At fault were Australian governments which:
… have yet to put in place a comprehensive, integrated and far-sighted way of promoting the
ecologically sustainable management of natural resources in agriculture. On top of this, there are flaws in
the design and execution of what has been done. [94]
6.74 In arguing the case for change, the Industry Commission noted a number of problems with the
current system. The first was a tendency to over-regulate the resource owners or managers. While the
regulatory burden continued to grow in an uncontrolled manner, rules more often prescribed 'means to
be used rather than objectives to be achieved'. The second was the fact that the markets for natural
resources (surface and ground water, forestry, native flora and fauna) were either non-existent or
functioned poorly. The major problem identified by the Industry Commission was the 'lack of
well-defined, tradeable rights'. The third was the failure of most jurisdictions to provide incentives to
promote biodiversity conservation on private land, combined with a lack of coordination of private
efforts with other government programs for natural resource management. Finally, the Commission noted
that the objectives and achievements of many environmental programs were poorly defined or obscure,
and that while environmental commitments were made, there was often lack of adequate implementation
of policy.
6.75 The proposal made by the Industry Commission had three components:
- to recast the regulatory regime to ensure resource owners and managers take into account the
environmental impacts of their decisions (a single unifying statute in each jurisdiction and a greater
emphasis on voluntary codes of practice);
- to create or improve markets for key natural resources (including the removal of impediments and
pricing reforms to eliminate subsidised use); and
- to encourage conservation on private land (an increased duty of care and the widespread use of
conservation agreements with landholders). [95]
Summary and Conclusions
6.76 A number of different views on the adequacy of government regulations on the commercial
utilisation of wildlife were presented in evidence. First, animal rights groups argued that the current
legislation was fundamentally flawed because it allowed for the exportation of wildlife products and thus
failed to adequately protect all native animals.
6.77 Second, industry groups provided strong evidence that because commercial utilisation of wildlife
had evolved in an ad hoc way, many statutory requirements were unnecessarily restrictive to their
businesses. Three types of problems were encountered: inflexibility in statutory arrangements in the
Federal Wildlife Protection (Regulation of Exports and Imports) Act 1982 which prevented export
of live animals and caused difficulties in the export of products; an overall excess of administrative
procedures, compliance with which was costly and time-consuming; and inconsistencies between state
arrangements, and between state and Federal arrangements leading to a call for a national approach to
commercial utilisation of wildlife. The Committee is concerned that duplicated and onerous administrative
procedures are unnecessarily hindering legitimate industries in Australia. The Committee recommends
that State and Federal Governments together review all administrative procedures relating to
commercial utilisation of wildlife in Australia with a view to increasing their efficiency so as to
ensure that there are no unnecessary hindrances to industry.
6.78 Third, many conservation groups, scientists and amateur biologists argued that some regulations
were counter-productive to the conservation of wildlife and maintenance of biodiversity. While amateur
research and voluntary conservation efforts in Australia had made a significant contribution to scientific
knowledge in the past, the ability of non-professionals to contribute to the knowledge base was ever
decreasing. In addition, the current prohibitionist approach failed to recognise the importance of fostering
kinship between people and their wildlife. The Committee is particularly concerned that Federal and, in
particular, state government regulations in some instances act to hinder biodiversity conservation. The
Committee believes that governments should make greater efforts to recognise the
contributions made by amateur biologists. The Committee recommends to Federal and state
Governments that they review wildlife regulations with a view to facilitating the work of
professional and amateur scientists so that they can actively contribute to biodiversity
conservation.
6.79 Fourth, animal rights groups and, in particular, the RSPCA, argued that the current system of
voluntary codes of practice did not contain sufficient legislative strength and that there was insufficient
industry self-regulation to protect the welfare of individual animals subject to commercial use. The
Committee is particularly concerned about animal welfare. While considering that the code of practice
system is an appropriate mechanism for regulation, the Committee believes that some aspects of the
system need strengthening. In particular, the Committee recommends that codes of practice
relating to wildlife industries should: (1) be in place prior to approval being given for an
industry to commence operations; (2) have a clear connection between licensing conditions and
compliance with a code of practice such that failure to comply results in a withdrawal of the
licence; (3) be consistent between states; and (4) where several codes apply to the same
industry, be consistent between codes.
Footnotes
[1] However, some organisations submitted that existing legislative arrangements were adequate and that
there was no need for change. See for example, Submission No.s 8, 9, 50 (p. 7).
[2] For example, Submission No. 66, p. 9. 128, Submission No. 54, p. 2.
[3] Evidence, p. RRA&T 982.
[4] Submission No. 297, p. 2.
[5] Evidence, p. RRA&T 715.
[6] Evidence, p. RRA&T 318.
[7] Submission No. 54, p. 2; see also Submission No. 65, p. 3.
[8] Submission No. 299, p. 5 (For a discussion of the difference between Controlled Specimens and
Management Plans, see Paragraph 3.9ff).
[9] Submission No. 299, p. 8.
[10] Submission No. 12, p. 17.
[11] Submission No. 12, p. 9.
[12] Submission No. 77 (p.6), 157 (p. 24), 177, 195 (p. 6); see also the NT A Trial Management
Program for the Red-Tailed Black Cockatoo (Calyptorhychus banksii) in the Northern Territory of
Australia, Parks and Wildlife Commission of the Northern Territory, Feb 1997, p. 2.
[13] Submission No. 7, for example.
[14] Submission No. 329, p. 5.
[15] Submission No. 338.
[16] Evidence, pp. RRA&T 514-5.
[17] Evidence, p. RRA&T 1126.
[18] Submission No. 313.
[19] Submission No. 126, p. 1.
[20] Submission No. 329, pp 4-5.
[21] Submission No. 175, pp. 3-4.
[22] Evidence, p. RRA&T 63.
[23] Submission No. 70.
[24] Evidence, pp. RRA&T 175, 186.
[25] Evidence, p. RRA&T 606; see also Submission No. 116, p. 1.
[26] Submission No. 70.
[27] Ibid.
[28] Ibid.
[29] Ibid.
[30] Evidence, pp. RRA&T 186, 273, Submission No.s 149, 190, 194.
[31] Submission No. 187, p. 10.
[32] Submission No. 314, p. 6.
[33] Evidence, p. RRA&T 36.
[34] Submission No. 314, p. 7.
[35] Evidence, p. RRA&T 36.
[36] Submission No. 175, p. 19.
[37] Submission No. 175, p. 19.
[38] Draft Minutes, NCCAW19, 19 May 1997.
[39] Submission No. 70, Evidence, p. RRA&T 1051ff.
[40] Submission No. 198, p. 50.
[41] Submission No. 198, p. 50 (Recommendation 24).
[42] Grigg G, Shine R and Ehmann H (eds) 1985 The Biology of Australasian Frogs and Reptiles,
Royal Zoological Society NSW, Surrey Beatty and Sons, Chipping Norton, NSW, p. 435.
[43] Evidence, p. RRA&T 270.
[44] Submission No. 104.
[45] Submission No. 69, p. 8.
[46] Tyler, M (1979) The impact of European man on Australian amphibians. In 'The Status of
endangered Australasian wildlife', ed M J Tyler, Roy. Soc. SA.
[47] Submission No. 337, p. 3.
[48] 1992 Herpetofauna 22 (1): 1-2 'Editorial - A case for significant deregulation of the keeping and
taking or reptiles and frogs', p. 1.
[49] See for example, Submission No. 119 and Evidence, p. RRA&T 554.
[50] PIJAC considers Queensland most the difficult in this regard (Submission No. 332).
[51] See for example, Submission No. 41 p. 17.
[52] Submission No. 1, p. 2.
[53] Evidence, p. RRA&T 257.
[54] Submission No. 40, p. 1.
[55] Submission No. 329, p. 4.
[56] For example, Rowlands estimates that some 40% of contributions to museum collections and to the
literature of herpetology in Australia has been made by amateurs (Rowlands R P V 1982 The role of
the amateur herpetologist. In "New Zealand Herpetology" Ed Don G Newman, Occasional
Publication No.2 New Zealand Wildlife Service, Department of Internal Affairs).
[57] Submission No. 41, p. 13.
[58] Submission No. 308, p. 6.
[59] Submission No. 308, p. 6.
[60] Ehmann, H (1994) Amateur Herpetology in Australasia: its history, roles, status, problems
and future. Herpetofauna 24(1): 6 - 12.
[61] Evidence, p. RRA&T 593, 595.
[62] Submission No. 190, p. 4.
[63] 1992 Herpetofauna 22 (1): 1-2 'Editorial - A case for significant deregulation of the keeping and
taking or reptiles and frogs'. See also Paragraph 14.7ff.
[64] Ehmann, H 1994 Amateur Herpetology in Australasia: its history, roles, status, problems and
future. Herpetofauna 24(1): 10.
[65] Submission No. 119, p. 4.
[66] Submission No. 190, p. 3.
[67] Submission No. 308, p. 3. Note: for every frog or reptile collected by amateurs, there is estimated
to be an additional 880 killed on roads or lost through land clearing; in addition, Australia loses 24
million reptiles by domestic and feral cat predation each year (1992 Herpetofauna 22 (1): 1-2 'Editorial
- A case for significant deregulation of the keeping and taking or reptiles and frogs', p. 2). See also
Submission No. 1, Attachment Australia's Reptiles Victims of the Road.
[68] Evidence, p. RRA&T 116.
[69] Evidence, p. RRA&T 691.
[70] Submission No. 41, p. 16.
[71] Evidence, p. RRA&T p. 181.
[72] Flannery, T F (1994) The Future Eaters, Reed Books, Sydney.
[73] Submission No.s 91 & 190, Evidence, p. RRA&T 384-5.
[74] Supplementary Submission No. 175, p. 11.
[75] Submission No. 1, Attachment - Flaws in the Laws of Nature.
[76] Information for the following section has been adapted from information provided by the RSPCA
Internet site at http://www.ezycolour.Committee.au/RSPCA/australia.html.
[77] Evidence, p. RRA&T 65.
[78] Evidence, p. RRA&T 914.
[79] The exceptions are Northern Territory, Queensland and Western Australia.
[80] Evidence, p. RRA&T 234.
[81] Evidence, p. RRA&T 950.
[82] Evidence, p. RRA&T 951.
[83] Evidence, p. RRA&T 951.
[84] Evidence, p. RRA&T 944.
[85] Evidence, p. RRA&T 938.
[86] Evidence, p. RRA&T 945.
[87] Evidence, p. RRA&T 939.
[88] Evidence, p. RRA&T 971.
[89] Submission No. 35, p. 1.
[90] Evidence, p. RRA&T 1036.
[91] Evidence, p. RRA&T 138.
[92] Evidence, p. RRA&T 900.
[93] Evidence, p. RRA&T 894.
[94] Industry Commission A Full Repairing Lease – Inquiry into Ecologically Sustainable Land
Management, Draft Report, September 1997, Executive Summary, p. xxi.
[95] Industry Commission, op cit, pp. xxii-xxiv.
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