CHAPTER 20
INDIGENOUS USE OF WILDLIFE
Significance of Wildlife to Indigenous People
20.1 The international regulatory community has on a number of occasions recognised the importance of
the inter-relationship between indigenous people and their natural environments. The various international
instruments which have embodied this concept include:
- the UN Draft Declaration on the Rights of Indigenous Peoples (s2);
- the Rio Declaration (Principle 22);
- Agenda 21 of the UN Program of Action from Rio (Chapter 26); and
- Article 8(j) of the Convention on Biological Diversity.
20.2 Aboriginal peoples and Torres Strait Islanders [1] have occupied and used large areas of land in
Australia continuously for many thousands of years. To them all aspects of life are strongly associated
with their natural environment; the physical landscape and the plants and animals that live within it. Their
culture is based on a very different association between animals and people than exists among the many
other people who are now part of Australia's multicultural heritage.
20.3 Traditionally, hunting and harvesting of wildlife provided food and shelter for Aboriginal people,
fulfilment of spiritual and cultural needs and occupied a large amount of time. Although many Aboriginal
people now do not depend on native wildlife for survival, the contribution of wildlife to the diet of
Aboriginal people in some areas, and particularly those people living on outstations, is often
considerable. More significantly, use of wildlife for spiritual and cultural purposes is still of great
importance to many Aboriginal people. [2]
20.4 In addition, a significant proportion of Australia's land area (some 17 per cent) is now under the
ownership and control of indigenous populations. [3] With this has come the opportunity and need for
those people to manage the natural resources in an ecologically sustainable manner, within the constraints
imposed by Federal and state legislation.
20.5 In this regard, Section 1.8.5 of the National Strategy on Ecologically Sustainable Development
recognises the importance of harvesting of indigenous plant and animal species both on land and in
water, to the wellbeing, identity, cultural heritage and economy of Aboriginal and Torres Strait Islander
peoples and recommends that assistance be provided for the establishment of management programs for
ecologically sustainable harvesting of wildlife by individual communities. [4]
Subsistence Use of Wildlife
20.6 Property rights for all flora and fauna is vested in the crown in Australia and legislation prohibits any
taking of native wildlife except through permits. However, in recognition of the importance of wildlife to
indigenous people, various state laws have made provision for Aboriginal people to harvest wildlife for
'subsistence' use. The taking of wildlife on this basis occurs widely throughout some areas of Australia
and in the sense that it replaces food that would otherwise be purchased, it has a commercial value.
20.7 In the Northern Territory, for example, under the Territory Parks and Wildlife Conservation Act
1993, Section 122 provides for the traditional harvest of crocodiles and their eggs for hunting, food
gathering (other than for purposes of sale), ceremonial and religious purposes by Aboriginal people. [5]
In this legislation, the word 'traditional' is very important. It means that Aboriginal people must be
associated historically, socially and culturally with a particular piece of land to be able to hunt on it or to
gather from it. As clarified by Dr William Freeland of the Parks and Wildlife Commission of the
Northern Territory:
In other words, if I am an Aboriginal from Melbourne, I cannot come to the Tanami Desert and catch
myself a bilby. You have to actually be associated with that piece of land upon which you hunt and
gather. [6]
20.8 The Northern Territory Government considers that the only effective way of ensuring the good
management of wildlife used by Aboriginal people for sustenance or other traditional purposes is for the
people themselves to have control over the management of that wildlife and the Government is currently
investigating ways in which traditional owners can be given greater capacity to manage wildlife on their
lands. [7]
20.9 In South Australia, Division II of the National Parks and Wildlife Act provides for hunting and
gathering of wildlife by Aboriginal people and section 68(d) allows an Aboriginal person to take
protected animals, the eggs of a protected animal and native plants from land that is not a reserve, only if
it is to be used for food or for cultural purposes. Aboriginal people can take wildlife from a national park
or reserve if it has been gazetted (five parks and reserves have been gazetted so far). Conservation
groups in South Australia recognise traditional indigenous rights as appropriate exemptions from the
normal prohibitions that apply to wildlife. [8]
20.10 However, despite attempts to accommodate the needs of Aboriginal people, laws enacted to
protect wildlife may have 'had considerable [adverse] impacts on the use of wildlife by indigenous
peoples'. [9] In fact, some Aboriginal people reject the view that the crown owns all wildlife and that
there needs to be special provisions made for Aboriginal people to take wildlife. They believe in prior
ownership and seek recognition of that. [10] According to Dr Jocelyn Davies, a researcher involved in a
global study which is examining community based wildlife management initiatives (known as 'Evaluating
Eden'), some indigenous people do not accept regulatory regimes which conflict with their 'rights' to use
wildlife under traditional Aboriginal law. [11] In this regard the Northern Land Council described in its
submission to the Committee how 'indigenous people within the Land Council's area do not distinguish
different systems of classification, use, philosophy, and territorial and resource ownership for land and
sea'. [12]
20.11 In addition, different provisions under the various state laws have created some difficulties for
Aboriginal people in the use of wildlife on a subsistence basis. As an example, the Northern Land
Council cites a hypothetical case of a Northern Territory Aborigine who legally harvests four geese but
who cannot legally send them to his daughter studying in Melbourne. [13] On this matter wildlife
biologist, Dr Grahame Webb, noted that:
Like all cultures represented in Australia, Aboriginal people should be able to buy traditional foods,
which are important to the maintenance of culture, regardless of where they are living in Australia. At the
present time a penalty for pursuing economic development, education, business or any other activity that
takes Aboriginal people away from traditional lands, is an inability to maintain cultural and traditional
links through food. [14]
20.12 The consequence of uncertain and conflicting legal interpretations, according to Dr Davies, has
been a diminution in the ability of government to manage indigenous wildlife use by regulation. Dr Davies
suggested that the ability of government to manage wildlife resources would be greatly enhanced if the
rights of indigenous people to use wildlife were more widely recognised and Aborigines were included
more frequently in cooperative management programs. [15]
20.13 In this regard, the Native Title Act 1993 recognises that indigenous Australians may have
property rights in species even if they do not have property rights in the land where the species occur,
such as national parks and pastoral leases. This means that they have rights to fish, hunt and gather
wildlife. Professor John Altman, Director of the Centre for Aboriginal Economic Policy Research
(CAEPR), suggested that the issue of 'whether there is a need (or statutory requirement) to recognise
existing and potential indigenous property rights in species' should be further explored. [16] Dr Jocelyn
Davies went so far as to say that the Act 'now provides that statute law restricting wildlife use does not
apply to indigenous peoples acting in the exercise or enjoyment of their native title rights'. [17]
20.14 To this end, the Northern Land Council has claimed that the entitlements of indigenous people to
wildlife should extend to sea territory in the first instance to protect Aboriginal subsistence fisheries and
then to provide sustainable commercial opportunities in fishing industries for Aboriginal people. [18]
20.15 The Department of Environment noted that the Commonwealth Native Title Act 1993
recognised indigenous rights with regard to wildlife and recommended that: 'There is a distinct need to
assess current practice in the harvesting and dealing of native flora and fauna as it relates to principles in
the Native Title Act [s.223(1) and (2)] and the Commonwealth Law Reform Commissions' Recognition
of Aboriginal Customary Laws 1986. This further needs to be clarified in relation to the National
Parks and Wildlife Conservation Act 1975, the Racial Discrimination Act 1975, The Land Rights
NT Act 1976, Local Government (Aboriginal Lands) Act 1978 section 29(1), and the Wildlife
Protection (Regulation of Exports and Imports) Act 1982'. [19]
Environmental Impact and Sustainability of Subsistence Use
However, while there may be a broad acceptance that Aboriginal people have a right bestowed by
heritage to continue to use native wildlife as they see fit for sustenance and cultural purposes, [20] there
are a number of management issues which need to be addressed, particularly the question of whether
such use can be ecologically sustained. According to a comprehensive report published by the Bureau of
Resource Sciences in 1996, Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait
Islanders, (edited by Mary Bomford and Judy Caughley):
The fundamental question concerning contemporary use of traditional lands and waters is whether the
cultural and economic needs of Aboriginal peoples and Torres Strait Islanders can be met. To maintain
the spiritual and cultural values associated with wildlife and other natural resources, it is essential that
their use be sustainable under contemporary lifestyles. … Pre-European limits on the size and spatial
distribution of communities no longer apply. As a consequence, the density and distribution of Aboriginal
hunting pressure may now be different from traditional patterns, and the use of local resources may
exceed sustainable levels. [21]
20.16 A major problem is that for many Australian wildlife species, and particularly those in remote and
arid regions, there is insufficient demographic and scientific data on which to base estimates of
sustainable use. Aboriginal people use a wide variety of wildlife species for subsistence and while this
use represents one of the largest scale consumptive uses of wildlife in Australia, there is almost no
information on the impact that this level of use is having on biodiversity. [22] Significantly, the few
species for which there is detailed demographic information are those which are commercially utilised
(kangaroos, crocodiles, emus and muttonbirds). [23]
20.17 Dr Davies suggested to the Committee that one of the reasons there was a lack of data about
subsistence use, which in some areas had led to a rarity of wildlife around Aboriginal communities, [24]
was the prohibitionist regulatory approach of government:
The regulatory approach leads to tremendous stand-offs between governments and local people. Here in
Australia, in my experience, in a lot of places with national park rangers and Aboriginal subsistence
users, if the rangers have this wildlife police image, \DB\PGN\633Aboriginal people are most reluctant
and uncooperative to tell the management authorities about their wildlife use, which is one of the reasons
we do not have a lot of data and one of the reasons why it is difficult to do research in that area. [25]
20.18 The submission from CAEPR suggested that Aboriginal people should be more involved in
wildlife management and that their knowledge of the land could be used to supplement formal ecological
research projects. Species which were regularly used for subsistence or species subject to
commercialisation proposals should be targeted first. As explained by CAEPR:
A precedent for this type of arrangement has been set by other countries. For example, in Quebec,
Canada, the Cree are paid a fixed income under the Income Securities Program for hunting and for
conservation practices such as monitoring the population numbers of hunted game. … If a similar
innovation were introduced in Australia it would ensure biodiversity as well as financially assisting
Aboriginal people who wish to reside in remote situations such as outstations and undertake productive
activities utilising native wildlife. [26]
20.19 As described by CAEPR, examples of this type of cooperation in Australia already exist, but the
philosophy of joint environmental management between indigenous and non-indigenous people needs to
be more formally embraced by government and the practice extended to many other areas and projects.
20.20 Aboriginal people are becoming increasingly concerned about the quality of the environments in
which they live and have sought to become more involved in land management issues in an effort to
marry their needs with the need to maintain biodiversity. [27] According to the Northern Land Council,
there has been a fairly rapid increase in the emergence of localised Aboriginal land management agencies
in the Top End in recent years. [28]
Use of Technology
20.21 An important factor in the level of resource use and whether wildlife populations can sustain
non-commercial harvesting, is the impact of changes in hunting techniques from traditional methods
(spears, throwing sticks, etc) to modern technology (guns and four-wheel drive vehicles). Compared to
traditional methods, modern hunting technology allows a much greater harvest of wildlife over a much
shorter period of time. While over-harvesting of species rarely if ever occurred as a consequence of
hunting using traditional methods, modern hunting techniques have the capacity to create regional
extinctions, especially near roads. About this, the 1996 BRS report commented:
The major constraint to subsistence hunting today is overexploitation arising from loss of traditional
regulatory mechanisms caused by societal changes and the interface with cash-based economies. To
regain effective regulation of harvest, the traditional system of regulation needs to be reshaped to take
into account the changes wrought by the adoption of new technology. In Australia this reshaping is still in
its infancy. [29]
20.22 The potential for new technology to result in over-harvesting of wild life has led to the suggestion
that Aboriginal people should be allowed to hunt only if traditional methods are used. [30] However, this
suggestion is rejected by many, if not all Aboriginal people. In defence of the rights of Aboriginal people
to hunt using any method, the Northern Land Council stated in its submission: 'It has been well
established in the process of land claims and through other substantial precedents that tradition is not
defined by reference to technology, which may change without affecting the traditionality of an act'. [31]
In the words of Mr Chris Roberts, who spoke on behalf of the Balkanu Cape York Development
Corporation:
The Aboriginal view is that technology has very little to do with the activity of hunting. The activity itself is
the part that is important. … Basically, many people who are concerned about technology in Aboriginal
hunting are asking Aboriginal people to do the equivalent of asking a farmer to revert back to a horse
and plough scenario for cultivating land. What the Aboriginal people would like to remind managers of is
that technology might be a way of more efficient harvesting, but it is that efficiency that requires
management rather than the harvesting itself. Improved technology means a better handle on
management rather than removing the ability of people to maintain their rights to their wildlife resources.
[32]
Involvement of Indigenous People in Commercial Activities
20.23 The recognition of traditional links between indigenous people and the natural components of their
land and that they have a special interest in the utilisation of wildlife is vital to consideration of any
commercial use of native species. In evidence to the Committee Aboriginal people in general supported
the concept of commercial utilisation of native wildlife and their involvement in it. [33] They felt that they
were in a good position to be involved in commercialising wildlife because they have been closely
affiliated with wildlife for thousands of years. [34] Commercial use of wildlife was seen by many as an
appropriate activity if there were economic, cultural and social benefits. [35] As described by Mr Rydal
Wilson, Manager of Murwangi Community Aboriginal Corporation:
Something I should point out from the beginning is that our aim in utilising wildlife is that, as you are
probably well aware, it comes naturally to Aboriginal people, it is something that they can be very much
involved in without any training and it can be on an irregular basis, so it works quite well for us. They
have innate skills already, especially the older people, and it is an opportunity. [36]
20.24 The submission from CAEPR noted that: 'based on prior occupation of the Australian continent
… many indigenous people see native wildlife as their preserve and responsibility'. [37] In fact, some
Aboriginal groups believe that their natural heritage bestows on them a prior right to commercial
opportunities with native wildlife and they claim that if there are going to be any further opportunities in
farming native species, Aboriginal people should be given the first opportunity and given support in order
to develop the industry. [38] A witness for the Yarrabah Community in north Queensland, Mr Ian Kuch,
described this belief as follows:
Firstly, with the expansion of commercialisation of wildlife species, the Aboriginal people believe … in
intellectual and cultural property rights, which also includes ownership of animals. They have totemic
relationships with those animals. They have broad knowledge of animal habits and life cycles and so on.
They possess a wealth of scientific information concerning those animals. If further species were looked
at, in terms of commercialising native species, Aboriginal people in Yarrabah believe that they should
have the first opportunity to be involved in that commercialisation. [39]
20.25 The Northern Land Council noted in its submission that Aboriginal people have traditionally had a
strong involvement in commercial utilisation of native wildlife, mainly through trade along the northern
coastline, and the Council supports strongly the right of landowning groups to continue to be involved in
commercial use of wildlife. [40]
20.26 In addition, there is now an increasing interest among Aboriginal people in becoming less
financially dependent on government support and in considering local development proposals [41] and
thus a great number of Aboriginal people view positively the commercial utilisation of native Australian
wildlife. [42] Some people believe that the involvement of Aboriginal people in commercial utilisation of
native wildlife should be as strong as possible because other economic opportunities were so limited.
[43] Many indigenous communities have title to land which is unsuited to agriculture based on introduced
species and which is remote from markets. The Far North Queensland Network believes that any
industry involved in utilising native wildlife should have at least a 50 per cent involvement of indigenous
people and that this could come about through partnerships between traditional owners and pastoralists
in the peninsula and gulf areas. [44]
20.27 A 1992 BRS report on indigenous use of wildlife noted that wild animal industries could provide
employment for Aborigines both on their own land and on neighbouring lands because animal
populations were often large there and current harvesting practices led to substantial wastage. The report
also concluded that commercial development of wild animal resources would protect native species and
aid in management of their populations. [45]
20.28 According to the 1996 BRS report: 'There is a strong demand from Aboriginal peoples and
Torres Strait Islander traditional owners for government support for projects using wildlife' but that there
is also 'a need to ensure that the aspirations of indigenous people are integrated with the wider
community goals of all Australians'. [46] This report identified the strong need for both co-management
agreements, which incorporate aspects of both the state and indigenous systems in environmental
management, and community-based planning in establishing wildlife projects.
20.29 Dr Jocelyn Davies noted in her submission to the committee that: 'Indigenous people have a
strong interest in developing industries based on commercial use of wildlife' and that 'these can help
provide economic development opportunities in some of the areas where they are now limited'. [47] In
particular, employment opportunities in remote areas of Australia are severely limited and commercial
wildlife enterprises are an important source of jobs. In addition, working with wildlife has a particular
appeal for indigenous people as it draws on their traditional knowledge and skills and keeps them in an
environment for which they hold special attachments.
20.30 However, while some government assistance may be necessary in industry development
programs, Professor Altman warned that it would be wrong to see commercial utilisation of wildlife by
Aboriginal people as a panacea for employment and economic needs:
The comment I would make there is that I think it is important for government to recognise that there is a
lot happening anyway. It is just a question of nudging things along a little bit. I would be concerned if we
looked for a commercial utilisation of a wildlife-led recovery of the Aboriginal sector. Sometimes
governments get good ideas and push them a little bit too hard. I think that all we really need are some
signals to say that this is an acceptable and legitimate economic activity, and there are certainly ways that
it can be facilitated and supported; for instance, with access to vehicles, with access to equipment to
develop, for instance, hunting roads,just small developments, small capital grants for crocodile incubators
in remote communities. [48]
20.31 Finally, a minority view was presented in evidence to the Committee that Aboriginal people, while
having subsistence rights, did not have any intrinsic right to commercialise Australian wildlife. As argued
by the Kangaroo Protection Co-operative Ltd, if Aboriginal people were to be involved in commercial
utilisation of wildlife, then they should be involved in eco-tourism, to explain their culture, and in the
planting and harvesting of plant-based bushfoods. [49] The Australian Conservation Foundation believes
that: 'Commercial use of wildlife [by Aboriginal Australians] is not acceptable until the issue of sovereign
rights to traditional food and genetic resources has been adequately addressed by the Australian
community'. [50]
20.32 However, as noted by Dr Grahame Webb, these views may present a discriminatory approach to
Aboriginal people:
There would appear to be a conflict of interest with organisations such as The Wilderness Society and
ACF purporting to support Aboriginal claims for land, but at the same time opposing any Australians
(Aboriginal people included) being able to use wildlife consumptively for commercial purposes – even
for commercial trade within and between communities! Given general opposition to agricultural
development by some conservation groups, one can only ponder what opportunities are going to be
acceptable for Aboriginal people on traditional lands to pursue economic development. [51]
Harvesting
20.33 Aboriginal people are becoming increasingly involved in the bushfoods industry, both through
harvesting from wild plants and to a much lesser extent growing plants for cropping. Harvesting has the
advantage of providing some financial return without significant financial investment (see Box: Aboriginal
Rural Resource Initiatives Projects).
20.34 The company Robins Bush Foods obtains bush tomatoes and wattle seeds from the Aboriginal
community Utopia and Kakadu plum is harvested by a number of Aboriginal communities in the
Northern Territory. The Aboriginal community at Elliot, in central Northern Territory, plans to establish a
bush food farm. [52] In the Wreck Bay area of New South Wales, the Umbarra Aboriginal community
conducts 'bush tucker' tours. [53]
20.35 In the Cape York region, according to Mr Chris Roberts who spoke on behalf of the Balkanu
Cape York Development Corporation, much of the flora has already been taken by commercial interests
for development in nurseries. This removes the commercial edge for Aboriginal people who would
perhaps like to become involved in the commercial production of local species. [54] However, seed
collection projects are under way in some areas of far north Queensland. [55]
20.36 In Central Australia, a number of Aboriginal people are involved with collecting seeds and fruit
but unfortunately the returns are quite small because the harvest is usually sold through a third party who
takes some profit and the Northern Territory government charges a levy for collection permits. [56]
Aboriginal people in the Top End are interested in increasing the population of agile wallabies in order to
harvest meat for the tourist trade [57] and in the export of trepang (beche-de-mer). [58]
20.37 In particular, the NSW Aboriginal Land Council noted in its submission that while the bush foods
industry was keen to promote its products as 'green, clean, lean and unique', there had been no attempt
to provide financial compensation to the Aboriginal communities which developed them as
recommended by the National Strategy for the Conservation of Australia's Biological Diversity. In
addition, there had been no attempt to disclose the cultural and spiritual relationships that many
Aboriginal and Torres Strait Islander Peoples had with particular species of flora and fauna, or consider
the cultural sensitivity when considering the commercial use of a species. [59]
20.38 The Australian Rainforest Bushfood Industry Association, however, has noted that:
Many people in the bushfood industry, have reservations about the concept of paying Aboriginal
royalties on bushfood produce. It could discourage potential Australian growers, and provide a
competitive advantage to possible overseas producers of our bushfoods by raising this countries [sic]
production costs. Also, a royalty system may be complex: yet again, another layer of administration,
costs and paper-work. [60]
20.39 Harvesting of animals for commercial use occurs on a small scale. There is a small industry based
on the harvest of muttonbird chicks from the islands of Bass Strait (see Paragraph 15.5). While this has
for many years combined a traditional activity with a source of supplementary food and income for local
indigenous people, the industry is in decline though lack of product marketing. Harvesting of crocodile
eggs (ranching) also occurs in the Northern Territory (see Paragraph 11.39). Payments to Aboriginal
people for the harvesting of wildlife on their land is also an increasing trend in northern Australia.
Examples include: crocodile egg ranching, barramundi fishing, bird-watching enterprises, and buffalo
shooting.
20.40 Finally, it should be noted that the Northern Land Council makes a distinction between 'resource
raiders' who take a large commercial harvest with little return to the species or its habitat, and the
'stayers', Aboriginal communities who have a long-term commitment to the land which they work. While
the 'raiders' deplete the resource they harvest (for example pearlers and crocodile hunters of the past),
the 'stayers' harvest is sustainable. [61] Although progress has been slow, Aboriginal communities in the
Northern Territory are now moving towards commercial use of species within their traditional practices
of harvesting in a sustainable manner.
Farming Native Animals
20.41 Although Aboriginal people have been involved in western-style pastoralism for many years, they
do not have a strong farming tradition and quite a number of commercial farming ventures have failed
through lack of ownership, either financially or psychologically, by the Aboriginal communities involved.
[62] There may be, however, more prospect of industries based on native species being successful
because of the less intensive nature of enterprises and the greater inherent interest in endemic species.
20.42 Aboriginal people are already involved in the farming of emus (Paragraphs 10.3 and 10.21) and
crocodiles (Paragraph 11.39) for commercial gain. Other species suggested as being appropriate for
commercial use through harvesting, ranching or farming included tropical birds, [63] reptiles, [64] marine
turtles, [65] cassowaries, [66] scrub turkey, [67] echidnas, [68] red-claw crayfish, [69] dugong [70]
and trepang (beche-de-mer, or sea slug). [71]
Safari Hunting
20.43 A number of Aboriginal communities in the Northern Territory have already commenced safari
hunting operations for non-native species, such as buffalo and biltong, and have expressed interest in
extending this concept to native species such as crocodiles (see Paragraph 19.15). Communities in far
north Queensland have also expressed an interest in safari hunting. [72] A proposal put by the Murwangi
Community Aboriginal Corporation to the Committee outlined the way in which such an operation would
be managed:
… the chosen animals would be old male Crocodylus porosus greater than 14 ft; the number taken
would be limited by the Northern Territory NPWS, but no more than four per year; the expected fee
would be $13,500 per animal; access by airboat and canoe, with Aboriginal guides; hunters could be
expected to be members of recognised recreational hunting associations, such as Safari Club
International. [73]
20.44 However, while a number of groups including the Northern Territory Government and the Far
North Queensland Network are supportive of the concept of safari hunting because it is seen as a way
of allowing Aboriginal people to put a value on their land and thus a secure commercial rationale for
retaining it as natural habitat, the Federal Government is not. [74]
Tourism
20.45 The ownership by Aboriginal people of areas of land which contain major tourist destinations
(such as Uluru, Nitmiluk and Kakadu National Parks) has resulted in an increasing involvement of those
people in tourist related activities and income from them. Such activities have now moved from the initial
stage of simply providing accommodation to a higher level of value-adding with guided tours and
interpretation facilities, although the overall level of involvement may be still quite small. [75] Cultural
tours, for example, brought in royalties for the Northern Land Council of $80,527 in 1994-95, $68,974
in 1995-96 and $88,663 in 1996-97. [76]
20.46 Some Aboriginal groups are keen to be involved in tourism and see possibilities in taking tourists
into their lands on nature-based tours. In Central Australia, Aboriginal people are involved with various
types of tourist enterprises, including trips to find bush tucker and to see the arid lands. [77] In Cape
York, for example, there are a number of endemic species of birds which would be of considerable
interest to ornithologists. [78]
20.47 In some areas, however, too great an influx of tourists has the potential to cause problems, both in
terms of criticisms which outsiders may have of Aboriginal wildlife harvesting practices, and the
psychological impact of too many people visiting Aboriginal lands. As described by Professor Altman of
CAEPR:
I guess the classic situation where you can have that sort of interaction might be in a place like Kakadu
National Park, where you have Aboriginal communities dotted through the park, out-station
communities, and where people on those communities do utilise wildlife for their livelihoods. But they
have to do it in a fairly low key sort of way because they have certainly had some fairly negative
feedback from tourists who come to see the wildlife. There have certainly been incidents where they get
a little bit upset where they see Aboriginal people harvesting.
… with an increase in tourist visitation you are getting something in the region of 250,000 visitors per
annum. There is a sense that the Aboriginal communities are a little bit dissatisfied that if a particular
place becomes popular with tourists, it tends to then restrict their access to that place, to that hunting
ground or fishing place for their subsistence purposes. So there is a potential problem there. [79]
20.48 Following on from this comment, Ms Lynette Liddle of CAEPR commented: 'From my
experience, it would be a good idea for a lot of the government agencies to be proactive in providing
information to Aboriginal clients either through land councils or through other organisations for
disseminating information about animal welfare issues and harvesting'. [80]
Feral Animals
20.49 In some Aboriginal areas, small industries are based on the commercial use of feral animals. In
Central Australia, for example, camels are caught and sold for stud purposes or for meat and the Central
Land Council owns a truck which is used to assist people to transport camels into town or to an
abattoir. [81] In Arnhem Land, Aboriginal communities have for many years been involved in harvesting
of feral animals, mainly cattle, buffalo and pigs. [82]
20.50 In fact this has occurred to such an extent that some Aboriginal people now view some feral
animals (such as pigs) as a legitimate part of their diet. According to Mr Chris Roberts, who spoke on
behalf of the Balkanu Cape York Development Corporation:
With regard to feral animals, many people consider these just to be a nuisance. Aboriginal people have
got some very interesting views on feral animals. Apparently, pigs substitute around about $300,000
worth of meat protein for Aboriginal people. To some extent it takes the heat off turtle eggs and turtles
themselves, which are species recognised in the conservation arena.
Some Aboriginal communities take offence at people hunting their pigs because this is their tucker that
runs around in the bush. They have been associated with pigs ever since pigs arrived a couple of
centuries ago. Therefore, it is not hard to see that they see feral animals as part of their environment and
a resource that they can use. [83]
Barriers to Increased Commercialisation
20.51 However, despite strong interest in commercial use of wildlife, the involvement of Aboriginal
people in commercial ventures in remote parts of Australia has not been, overall, greatly successful. A
number of factors have contributed to this which mainly relate to locational, financial and cultural
constraints. [84] Experience, however, is slowly leading to ventures which may have more positive
outcomes. Examples of this are the Bawinanga Aboriginal Community Corporation involvement with
crocodile ranching and incubation in Arnhem Land and the Cherbourg Community Emu Farm near
Murgon in southern Queensland.
20.52 Because many Aboriginal communities are located in remote regions of Australia, one of the
major obstacles to increased development of wildlife resources is distance from markets. [85] In
instances where horticultural ventures have been started in remote Aboriginal communities, they have
failed largely because of lack of easy access to markets. [86] In addition, consumer resistance to
products sourced from native wildlife also needs to be overcome [87] and this may not occur without
public education about sustainable management of Australian wildlife. [88]
20.53 A major inhibition to increased commercialisation is the lack of experience and expertise in
commercial ventures. As explained by Ms Lynette Liddle of CAEPR:
I think that government agencies have to look beyond the conservation element and look at ways in
which Aboriginal people can have scientific and economic support to be involved in the industry but be
supported by scientists and government agencies. There are a lot of Aboriginal people out there wanting
to be involved in commercial utilisation, but they do not have the avenues within the Commonwealth
government or state government agencies to access information and data and issues about legislation and
breeding information of wildlife that is necessary for them to manage those wildlife resources. [89]
20.54 The establishment of joint ventures between indigenous partners having knowledge and expertise
in wildlife and non-indigenous partners who can provide venture capital, with equal involvement in
management decisions, may be one way of overcoming the financial, bureaucratic and market barriers
that indigenous people face with any proposal to commercialise wildlife. [90] The value of this type of
approach was described by Ms Linda Roach, also from CAEPR:
There is one area that probably shows potential for involving Aboriginal people, and that is in the
co-management of wildlife, especially commercial operations which involve co-management, because
then the Aboriginal people can contribute their skills. Very often Aboriginal people do not have a level of
management skill that would enable them to successfully run an operation but they do have other skills
and knowledge that the enterprise could use and which would be valuable to the enterprise or, in fact,
necessary for it. In that way the enterprise is profitable and Aboriginal people are included at an
important level. [91]
20.55 Another major barrier is that legislation allows Aboriginal people 'subsistence' use of wildlife but
does not allow them to sell any wildlife harvested from their own lands, although some 'trade' no doubt
occurs on an informal basis. [92] There is strong evidence to suggest that both indigenous and
non-indigenous people are interested in purchasing native wildlife as food, or for other purposes.
Species include goanna, echidnas, bush turkeys, snakes, magpie geese, dugong, turtles and fish. [93]
20.56 Another legal barrier is that which allows pest-destruction permits to be issued for superabundant
species, but which does not allow any commercial use of the animal after it has been killed. A good
example of this is the emu in Western Australia. State legislation provides for the issue of pest
destruction permits and many thousands of birds are disposed of when they become an agricultural
nuisance in the Merredin and Mullewa areas near the Barrier fence, but the carcases cannot be used in
any way.
20.57 Dr Jocelyn Davies noted in her submission that the demise, in 1996, of the Aboriginal Rural
Resources Initiative, which had been managed by the Bureau of Resource Sciences, was 'regrettable'
given that program had been a catalyst for much support for Aboriginal groups interested in commercial
wildlife use. [94]
20.58 For many years, Aboriginal people have produced artefacts for ceremonial and limited market
exchange and over the last few decades some of these objects have been manufactured for sale as
tourist items (boomerangs, didgeridoos, spears, bark paintings, etc). Some have incorporated in them
by-products of subsistence harvests (echidna quills, feathers, turtle shell, etc) and the inclusion of these
animal parts technically contravenes state laws which allow harvesting for subsistence use but not for
commercial use. [95] In addition, should any of these items be purchased by overseas tourists and taken
out of the country, there is also the risk of contravening the Wildlife Protection (Regulation of Exports
and Imports) Act 1982.
20.59 The Northern Land Council points out that 'Aboriginal people again find non-Aboriginal
behaviour in this respect illogical, as the rights of Aboriginal people in the Northern Territory to kill and
eat the relevant avian species is recognised by the state, but the state prescribes that they may not gather
up the surplus feathers and utilise them for commercial purposes'. [96]
Concerns About Commercial Utilisation of Wildlife
General Concerns
20.60 The submission provided by the Central Land Council outlined a number of key issues of concern
about commercial utilisation of wildlife held by the Aboriginal people it represented. These are
summarised as follows.
- There is a general lack of information about the biology and management of native wildlife in the
arid regions of Australia. (The ecology of the arid zone is noted for enormous population fluxes in
response to severe climatic events making difficult any determination of ecological sustainability.)
- Current hunting levels by Aboriginal people are not known for many arid zone species currently
being used (including red kangaroos, euros, echidna, bustards, emu, and various other birds and
reptiles), and whether those levels of use are sustainable in the long term.
- There has already been some commercial utilisation of wildlife in the Central Region and there is a
strong belief that any further commercial utilisation of native wildlife should not have a detrimental
impact on Aboriginal traditions, customs or contemporary land uses.
- Aboriginal people desire and need to retain the right to control and manage their lands and
resources, regardless of any commercial use of those resources.
- Any commercial utilisation of native wildlife should not impact on subsistence use of that wildlife
(for example, collection of bush tucker); and subsistence use should continue to have a higher
priority than any commercial use.
- There is a concern that commercial utilisation of native wildlife may interfere with traditional
cultural and social systems which direct land and resource use. (Some aspects of commercial
utilisation of native wildlife may directly contravene customs and codes respected by senior desert
Aboriginal people.)
- Any commercial use of wildlife must be considered as part of a broader suite of economic and
non-economic land uses and interests. [97]
20.61 Despite these concerns, the Central Land Council believes that the introduction of commercial
utilisation of native wildlife may present 'an opportunity to establish a regulated commercial environment
in which Aboriginal landowners might successfully participate'. [98] The Council also noted that should
any farming proposals be made, Aboriginal people should be involved in the capture of live animals to
establish breeding stock, under the guidance of wildlife officers. [99]
20.62 The New South Wales Aboriginal Land Council stated in its submission that it did not 'have a
blanket objection to the utilisation by people of our native fauna and flora', but the Council emphasised
the importance of public consultation in determining the manner and extent of any such utilisation. [100]
The Council also emphasised the importance of taking into account Aboriginal perspectives on the
interconnectedness of indigenous people, the various components of the environment in which they lived
and their cultural heritage, including totemic species and sacred sites. [101]
Impact on Subsistence Use of Wildlife
20.63 Because many Aboriginal communities consume wildlife on a subsistence basis, commercialisation
may result in a reduced availability of those resources for subsistence needs. There is evidence of this
occurring in Torres Strait where prawn trawling is apparently affecting the availability of subsistence fish
and off the coast of Arnhem Land where prawn trawlers are having an impact on dugong and turtles.
[102] Aboriginal people on the whole believe that maintenance of subsistence rights should have
precedence over commercial uses, whether by indigenous people or by others. [103]
20.64 The Northern Land Council suggested that before the commencement of a commercial venture
which was based on the harvest of an important subsistence species, a cost-benefit analysis should be
carried out which included both monetary and non-monetary factors, and an analysis of alternative
commercial ventures. As an example, the Council suggested that ecotourism and safari hunting may be
more profitable than extractive harvests for meat and skins, although there may be other negative social
or environmental impacts. [104]
Respect for Totemic Species
20.65 A significant element of traditional Aboriginal culture is the ancestral link between people and a
particular animal or plant species. As described by the Northern Land Council: '… there may be some
tension between ownership of animals based on their presence in particular estates and their association
with totemic collectives, but in daily life, the right to harvest plants and animals rests with the patrifiliated
and matrifiliated members of land-owing lineages in respect of their estates'. [105]
20.66 More importantly, from the point of view of commercial harvesting, individual totemic animals may
hold strong spiritual qualities and it is an affront to an Aborigine for his or her totemic 'kin' to be killed by
another person and left to rot (that is, for the animal to 'die for nothing'). Because non-Aboriginal people
do not have the cultural awareness or insight to be able to discriminate between ordinary animals and a
spiritually potent member of that species, commercial hunters and fishers often kill these spiritually
significant creatures, either directly as a target species or indirectly as by-catch. Examples include the
death of crocodiles and dugong in barramundi nets, and death of turtles in drift nets. The Northern Land
Council stated that this was an issue of great concern to Aboriginal people in the Northern Territory.
20.67 Related to this concern is the issue of fisheries by-catch wastage. Aboriginal philosophy
encompasses a belief that no food animal or plant should be wasted and Aboriginal people consider it
'barbaric' that commercial fisheries are legally allowed to dump by-catch. According to the Northern
Land Council: 'It is not uncommon for large quantities of non-target species eg. grouper, catfish, sharks,
crocodiles, dugong and turtle to be found washed up and rotting along the tideline on Aboriginal land. It
is understood that further considerable by-product waste occurs off-shore in the prawn fishery but may
not reach the shore when dumped overboard by trawlers a long way out'. [106]
Respect for Traditional Knowledge
20.68 A number of Aboriginal groups expressed particular concern about the loss of 'intellectual
property' of indigenous people through increasing commercialisation of aspects of their culture, such as
bush foods and knowledge of plant medicines. The NSW Aboriginal Land Council assured the
Committee that their concerns did not indicate an unwillingness to share, provided that the prior and
informed consent of indigenous people was obtained. [107] Concern about loss of 'intellectual' property
rights was also expressed by Mr Chris Roberts who gave evidence on behalf of the Balkan Cape York
Development Corporation. [108]
20.69 In the opinion of CAEPR: 'if commercial utilisation of wildlife in Australia is to expand, it is
imperative that not only do indigenous people have equal opportunities to participate in such growth, but
also that expansion of non-indigenous interests do not limit the subsistence and commercial options
available to indigenous people'. [109] CAEPR also questioned whether there was a need, or in fact a
statutory requirement, to recognise indigenous property rights in native plant and animal species.
20.70 The bushfoods industry has already indicated a sensitivity to this matter. In its first newsletter, the
Australian Rainforest Bushfood Industry Association noted:
… there are ethical considerations around the cultural property rights of Aboriginal people and the use of
their bushfood lore for financial gain … Where Aboriginal knowledge is used, prior permission, and
acknowledgment of the specific source of information should be standard procedure by the person(s)
introducing the product into the industry. [110]
20.71 Finally, Mr Peter Core, Managing Director of RIRDC noted in evidence to the Committee the
importance of respect for prior Aboriginal knowledge, but claimed that the various rights and obligations
of the parties involved in commercial utilisation of wildlife were currently unclear:
On the linkages between commercialisation of native wildlife and native title issues, the corporation
recognises that indigenous groups in Australia have for a number of years been advocating the
recognition of indigenous rights to intellectual property including biological resources. That issue is, as we
are advised, currently with the federal government. At our level as a research funding organisation, we
will continue to work closely with indigenous people in the development of our program goals in areas
such as bush foods, but we have no substantive comment to make to the committee beyond the obvious
one that the current position is unclear as to what extent, if any, rights to biological resources are
associated with native title. [111]
Opposition to Positive Discrimination
20.72 In some areas of Australia, Aboriginal people have been given special rights to hunt and to harvest
wildlife. For example, the New South Wales Government has banned the hunting of duck and quail for
all non-Aboriginal people, but Aboriginal people are allowed to hunt these birds. There was some
discussion in the evidence as to whether this constituted positive discrimination. The Safari Club
International, for example, did not agree that Aboriginal people should be given special rights, a position
based on the premise that all people, regardless of race or origin have a tradition of hunting which can be
traced back thousands of years. [112]
20.73 As another example of objection to positive discrimination, Mr A M Golding of Little Meadows
Emu Farm in Western Australia argued that favoured treatment by government of two Aboriginal
communities in establishing emu farms had caused difficulties for private businesses which were in
competition with them. In Mr Golding's submission he wrote:
One of the biggest problems that has affected the viability of the emu industry are the vast sums of
taxpayers money poured into two Aboriginal communities in Western Australia and Queensland to assist
them to establish emu farms and market their products in detriment to others in the industry, because
they do not have to borrow from the normal lending institutions to build abattoirs, tanneries and service
wage bills.
When the Industry has put in for funding Government Departments have cited the millions of dollars
spent on the industry. When the question is asked where the money has gone the answer is mostly to
Aboriginal communities, which is not to the benefit of the industry as a whole.
It makes the non-Aboriginal commercial emu farmer almost wholly unable to compete on the open
market as such communities can sell in the market place almost without cost. [113]
20.74 Finally, Mr Golding noted in evidence before the Committee that the Wiluna enterprise in Western
Australia had now 'all but closed down', despite considerable funding and he argued that that money
would have been better spent assisting the entire industry. [114]
Summary and Conclusions
20.75 To Aboriginal peoples and Torres Strait Islanders all aspects of life are strongly associated with
their natural environment: the physical landscape and the plants and animals that live within it. In
recognition of the importance of wildlife to indigenous people, various state laws have made provision
for Aboriginal people to harvest wildlife for 'subsistence' use. However, different provisions under the
various state laws have created some difficulties for Aboriginal people in the use of wildlife on a
subsistence basis.
20.76 Because a significant proportion of Australia's land area is under the ownership and control of
indigenous people there is a need to manage the natural resources in an ecologically sustainable manner,
within the constraints imposed by Federal and state legislation. However, Federal and state legislative
arrangement are not completely clear resulting in some uncertainty as to the rights of indigenous people in
their subsistence use of wildlife. The consequence of this has been a diminution in the ability of
government to manage indigenous wildlife use by regulation. Although subsistence use may constitute a
significant commercial use of wildlife (in the sense that it replaces food which might otherwise have been
purchased), little effort has been made to quantify the level of use or its impact on biodiversity
conservation.
20.77 The Committee is concerned that there is insufficient monitoring of the level of
subsistence use by Aboriginal people and its impact on wildlife populations and hence on
biodiversity. The Committee notes that the lack of clarity as to what constitutes 'rights to wildlife' and
the prohibitionist approach generally taken by government wildlife authorities are major factors which
may inhibit Aboriginal people in assessing the full extent and impact of subsistence use. The Committee
believes that joint environmental management between indigenous and non-indigenous people is crucial
to the welfare of Australia's environment and urges both government and Aboriginal peoples to work
together towards sustainable use objectives. More specifically, the Committee recommends a
remote Aboriginal community be invited to carry out a trial survey of the levels of subsistence
wildlife use and its impact on biodiversity, supported by a grant through the National Heritage
Trust.
20.78 In evidence to the Committee, Aboriginal people in general supported the concept of commercial
utilisation of native wildlife and their involvement in it. It was seen by many as an appropriate activity with
economic, cultural and social benefits. There is already a variety of projects involving Aboriginal people
in the commercial utilisation of wildlife. Payments to Aboriginal people for use of wildlife on their land is
also an increasing trend in northern Australia. Examples of this include crocodile egg ranching,
barramundi fishing and buffalo shooting. Aboriginal people are also involved in the farming of crocodiles
and emus. Tourism enterprises are of increasing importance to Aboriginal people, and interest has also
been expressed in safari hunting of native animals (currently prohibited). The Aboriginal Rural Resource
Initiatives includes a number of projects which involve harvesting or horticulture of bush foods.
20.79 Despite strong interest, however, the involvement of Aboriginal people in commercial ventures
based on wildlife in remote parts of Australia has not been, overall, greatly successful largely for reasons
relating to locational, financial and cultural constraints. The two major obstacles to increased
development of wildlife resources are distance from markets and lack of experience and expertise in
commercial ventures. A number of key issues of concern about commercial utilisation of wildlife were
expressed by Aboriginal people and in particular those people represented by the Central Land Council.
In essence these concerns related to the lack of scientific information on species distributions and
abundances, the potential for detrimental impact on Aboriginal traditions, customs and contemporary
land uses, respect for traditional knowledge and the potential for interference with subsistence use.
Nevertheless, the Committee concludes that commercial utilisation of wildlife by Aboriginal
people has an important role to play in the economic development of some Aboriginal
communities. The Committee recommends that Aboriginal people should be consulted where
commercial opportunities are identified on lands where there are communities which have
strong traditional links to those lands.
20.80 The Committee notes that the various rights and obligations of parties involved in commercial
utilisation of wildlife with respect to prior Aboriginal knowledge are currently unclear. The Committee
believes that the importance of intellectual property rights of Aboriginal people in relation to
the use of wildlife has not received sufficient recognition and the Committee recommends that
the Federal Government give greater attention to this issue.
20.81 Finally, the Committee supports the suggestion made by CAEPR that government agencies
provide information to Aboriginal peoples, either through land councils or other organisations, about
animal welfare issues.
Senator J Woodley
Chairman
Aboriginal Rural Resource Initiatives Projects
The Aboriginal Rural Resource Initiatives is a national program of some 73 land management projects
aimed to enhance opportunities for employment and income generation among Aboriginal and Torres
Strait Islander People, with funding provided by the Royal Commission into Aboriginal Deaths in
Custody. Of the total number of projects, some 17 directly involve the commercial utilisation of native
wildlife. The following is a description of five projects, to exemplify the range of opportunities being
explored.
Billy Goat Plum – Oenpelli (Arnhem Land, NT).
Some ten women are involved in this project, with the assistance of two men on specialised tasks when
needed, which has seen the planting of a grove of 300 Billy goat plum trees. Contacts are being
developed in Darwin for marketing.
Djigay Bush Foods – Kempsey (NSW)
The Djigay Bush Foods project has two aspects – the development of a traditional food tree park and a
bush tucker production enterprise. The official opening of the Park took place in August 1997 and two
of the six planned stages are complete. The two projects employ some 15 people and a joint venture has
been entered into with two non-indigenous businesses for marketing purposes.
Mankuni wilykaja bush tucker and seed collection – Western Desert (Central WA)
The aim of the Mankuni Wilykaja project was to develop a bush tucker and seed harvesting enterprise
to meet the subsistence needs of the community, with the possibility of expansion into plant and seed
sales in the future. The seed collection component of the project is still operating and 30 women are
licensed to collect seeds. Sufficient income has been generated to keep the project going for another
year.
Tea Tree Plantation - Cape York (Far North Queensland)
A five-hectare tea-tree plantation is now at production stage and preliminary extraction of oil was initially
carried out with borrowed machinery. The enterprise has now installed its own machinery but has had
some problems with the distillery and pumps. The project employs eight men, two days a week.
Although a profit has not yet been made, the project has the potential to be very successful.
Ceduna Emu Farm – Ceduna (South Australia)
The project at Ceduna aimed to develop a sustainable emu farm and went through a two year planning
period before stock were obtained. Although now operational and employing five people, marketing
problems in the emu industry have led to a need to look at diversifying the project to include other
income streams such as tourism.
Footnotes
[1] Hereafter referred to as indigenous or Aboriginal people.
[2] Evidence, p. RRA&T 296.
[3] The Central Land Council, for example, covers an area of 775,000 sq km, which is 55% of the land
area of the Northern Territory (Evidence, p. RRA&T p. 299).
[4] Submission No. 198, p. 9.
[5] A Management Program for Crocodylus porosus & Crocodylus johnstoni in the Northern
Territory of Australia. November 1996 Parks and Wildlife Commission of the Northern Territory, p.
3.
[6] Evidence, p. RRA&T 331.
[7] Evidence, p. RRA&T 332.
[8] Submission No. 318, p. 17.
[9] Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait Islanders edited by Mary
Bomford & Judy Caughley, Bureau of Resource Sciences, AGPS A62208, 1996, p. 1.
[10] Evidence, p. RRA&T 288.
[11] Submission No. 340, p. 3.
[12] Submission No. 300, p. 1.
[13] Submission No. 300, p. 9.
[14] Submission No. 157, p. 25.
[15] Submission No. 340, p. 3.
[16] Submission No. 327, p. 11; also Evidence, p. RRA&T 1113.
[17] Submission No. 340, p. 3.
[18] Submission No. 300, p.7.
[19] Submission No. 198, p. 41.
[20] There is also a minority view that indigenous people have a right to use native wildlife only if
traditional methods of hunting and gathering are used (Evidence, p. RRA&T 108).
[21] Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait Islanders, op cit, p. 9.
[22] Evidence RRA&T 626, Submission No. 340, p. 2, Submission No. 327, p. 6.
[23] Submission No. 327, p. 4.
[24] Evidence, p. RRA&T 626.
[25] Evidence, p. RRA&T 632.
[26] Submission No. 327, p. 10; see also Evidence, p. RRA&T 1109.
[27] Evidence, p. RRA&T 226.
[28] Submission No. 300, p. 3.
[29] Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait Islanders, op cit, p. 1.
[30] See for example Evidence, p. RRA&T 108 & Submission No. 297, p. 4.
[31] Evidence, p. RRA&T 365; Submission No. 300, p. 5.
[32] Evidence, p. RRA&T 220.
[33] Evidence, p. RRA&T 179, 218, 284, 358 &, 392; Submission No.s 174, 300 & 310, but see
298.
[34] Evidence, p. RRA&T 219.
[35] Evidence, p. RRA&T 287.
[36] Evidence, p. RRA&T 393.
[37] Submission No. 327, p. 2.
[38] Evidence, p. RRA&T 288.
[39] Evidence, p. RRA&T 285.
[40] Submission No. 300, p. 5.
[41] Submission No. 327, p. 3.
[42] Vardon 1997 cited in Submission No. 327, p. 4.
[43] Evidence, p. RRA&T 223.
[44] Evidence, p. RRA&T 202.
[45] Wilson, G., McNee, A. & Platts, P. 1992 Wild Animal Resources: their Use by Aboriginal
Communities, AGPS Canberra, ISBN 0644248629, Summary.
[46] Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait Islanders, op cit, p. 1.
[47] Submission No. 340, p. 2.
[48] Evidence, p. RRA&T 1111.
[49] Supplementary Submission No. 129, p. 1.
[50] ACF Policy Statement No. 61, Tabled by the Nature Conservation Council of NSW, 8 September
1997, p. 3.
[51] Submission No. 157, p. 25.
[52] Evidence, p. RRA&T 1009.
[53] Evidence, p. RRA&T 1010.
[54] Evidence, p. RRA&T 221.
[55] Evidence, p. RRA&T 201.
[56] Evidence, p. RRA&T 303.
[57] Evidence, p. RRA&T 88.
[58] Evidence, p. RRA&T 376.
[59] Submission No. 174, p. 8.
[60] Australian Rainforest Bushfood Industry Association, Newsletter No. 1, Autumn 1996, PO Box
6407, Lismore NSW 2480, p. 3 President's Report.
[61] Submission No. 300, p. 12.
[62] Evidence, p. RRA&T 300.
[63] Evidence, p. RRA&T 203; Submission No. 83.
[64] Evidence, p. RRA&T 829.
[65] Submission No. 340, p. 4.
[66] Evidence, p. RRA&T 286.
[67] Evidence, p. RRA&T 289.
[68] Evidence, p. RRA&T 220.
[69] Evidence, p. RRA&T 221.
[70] Submission No. 340, p. 4.
[71] Evidence, p. RRA&T 365, 376.
[72] Evidence, p. RRA&T 200.
[73] Submission No. 310.
[74] Evidence, p. RRA&T 332.
[75] Evidence, p. RRA&T 1108-9, Submission No. 327, p. 3.
[76] Submission No. 300, Appendix, p. 1.
[77] Evidence, p. RRA&T 304.
[78] Evidence, p. RRA&T 222.
[79] Evidence, p. RRA&T 1115.
[80] Evidence, p. RRA&T 1115.
[81] Evidence, p. RRA&T 302.
[82] Submission No. 300, p. 4.
[83] Evidence, p. RRA&T 221.
[84] Evidence, p. RRA&T 1103, Submission No. 327, p. 6-7.
[85] Submission No. 327, p. 3.
[86] Evidence, p. RRA&T 1112.
[87] Evidence, pp. RRA&T 630, 1106-7.
[88] Submission No. 340, p. 3.
[89] Evidence, p. RRA&T 1113.
[90] Submission No. 327, p. 8.
[91] Evidence, p. RRA&T 1110.
[92] Submission No. 300, p. 8.
[93] Submission No. 327, p. 8.
[94] Submission No. 340, p. 2.
[95] Submission No. 300, p. 8; Submission No. 340, p. 4.
[96] Submission No. 300, p. 8.
[97] Submission No. 298, p. 4; Evidence, p. RRA&T 294-5.
[98] Evidence, p. RRA&T 294.
[99] Evidence, p. RRA&T 294.
[100] Submission No. 174, p. 1.
[101] Submission No. 174, p. 2.
[102] Submission No. 327, p. 4.
[103] Submission No. 340, p. 3.
[104] Submission No. 300, p. 12.
[105] Submission No. 300, p. 6.
[106] Submission No. 300, p. 7.
[107] Submission No. 174, p. 3- 8.
[108] Evidence, p. RRA&T 219.
[109] Submission No. 327, p. 11.
[110] Australian Rainforest Bushfood Industry Association, Newsletter No. 1, Autumn 1996, PO Box
6407, Lismore NSW 2480, p. 3 President's Report.
[111] Evidence, p. RRA&T 1119.
[112] Supplementary Submission No. 118, p. 3.
[113] Submission No. 171, p. 3.
[114] Evidence, p. RRA&T 465.
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