Presentation to Department of Jobs Precincts and Regions April 19, 2021

Presentation to Department of Jobs Precincts
                and Regions
                April 19, 2021

Introduction & Background

  • All regulations in Victoria sunset and must be remade after a period of ten years. The Wildlife
    (Game) Regulations 2012 are due to be reviewed and remade before they expire on 11 September
    2022.

  • FGA has completed a significant review of all relevant information while producing its submission
    to the Department of Jobs Precincts and Regions.

  • New regulations must not replicate existing provisions in other legislation and regulations;
    however, they can address regulatory limitations and gaps in other regulatory frameworks in
    terms of recreational game hunting

  • The department may receive comments and written submissions requesting that hunting be
    banned for reasons of public safety, amenity and/or biodiversity. It may also receive comments
    and written submissions on the impact of prohibited deer hunting areas across Victoria. These
    issues are within the scope of the regulatory remake process.

Scope of the review in
    detail

• The Department of Jobs Precincts and
  Regions Draft issues paper V12 considers
  that requests that hunting be banned for
  public safety, amenity and/or biodiversity
  are issues that are allowed to be raised and
  considered in scope.

• Despite this, table 2 included in the issues
  paper states banning of recreational game
  hunting is out of scope.

Proposed objectives

• There are considerable differences between the
  current objectives and the proposed objectives, as
  outlined in the DJPR issues paper provided to
  stakeholders; Sunset review of the Wildlife (Game)
  Regulations 2012 DRAFT V12. Field & Game
  Australia consider these to be over prescriptive
• The proposed objectives are given the following
  four sections:
    • Sustainable, Humane, Responsible and Safe,
      Administrative and enabling.

Key Stakeholders

• All regulations in Victoria sunset and must be remade after
  a period of ten years. The Wildlife (Game) Regulations 2012
  are due to be reviewed and remade before they expire on
  11 September 2022
• The Wildlife (Game) Regulations is the key piece of
  legislation governing game hunting in Victoria and Field &
  Game Australia’s members make up a significant portion of
  those impacted
• Field & Game Australia recognise and respect that other
  stakeholder groups have an invested interest in the
  Wildlife (Game) Regulations, licenced game hunters are the
  ones regulated and we therefore consider them the major
  stakeholders

Issues and opportunities
What should the length and timing of the open and close season be? What
is appropriate for bag limits? Should any species be prohibited from
recreational game hunting? What is considered as sustainable methods of
hunting? What should be the times of day for hunting? What requirements
enable harvest to be monitored?
• Field & Game Australia continue to support AHM model implementation
  for duck hunting season arrangements. Set seasons and bag limits do
  allow greater confidence for hunters and relevant industry stakeholders
  and should remain in place except for validated exceptional
  circumstances. Consider modifications to the time of hog deer season
  due to impacts of duck hunting on it
• No scheduled game species should be prohibited from hunting without
  defendable scientific evidence
• Game populations should be actively managed through habitat
  improvement to ensure sustainability, rather than the current focus on
  hunter management
• Thirty minutes before sunrise until thirty minutes after sunset should
  remain as hunting times and further discussion around a return to
  Saturday opening, set date should return. Harvest returns as a hunter
  requirement at season end should be considered, rather than relying on
  random phone surveys

What should be the requirement for a licence? What testing of licence holders is required to
Issues and      ensure the ability to discriminate among different species for certain licence types and
                times for hunting?
opportunities   • Current arrangements are suitable. WIT testing needs to be readily available year-round
                  rather than being a barrier to participation as it is currently perceived
- continued     • Isolated instances of non-game species inadvertently being taken as a by-catch of
                  waterfowl hunting has negligible impact. Regulations prohibit them being taken and
                  offenders face appropriate sanction if they do so
                • Appropriately regulated hunting poses no real threat to the sustainability of any species

Issues and opportunities - continued

What are appropriate hunting methods? Should the use of toxic ammunition be prohibited?

• Toxic shot over wetlands has already been dealt with. Unless there is any sound scientific evidence to suggest that
  negligible amounts of lead shot, dispersed over vast areas of dry land from quail hunting, there should be no
  immediate necessity for change
• A proactive approach would be to develop appropriate scientific studies and work with industry over the next
  decade to investigate benefits from non-toxic shot for these applications and investigate bio-degradable wads
• Field & Game Australia does support and encourage the voluntary phasing out of plastic wads for shotgun hunting
  over time as appropriate alternatives, in the required volumes become readily available at a reasonable cost

Issues and opportunities -
       continued
What should be the requirements for a licence? Is the testing and training
adequate?
Any feedback on hunting methods, possession and use of game, regulation of
hounds and other dog breeds used in hunting and retrieval regulations is
welcome.

• Current testing is adequate, aside from difficulty to access year-round. Field
  & Game Australia encourage more voluntary education as long as it is
  affordable and doesn’t become another discouragement which restricts
  recruitment and discourages participation.
• Educational material must be practical, applicable and most importantly
  accessible.
• Electronic quail callers require review as there is much controversy about
  the appropriateness of them and their misuse. Are they applicable and is
  there a need to govern there use more closely if allowed continued use.
• Minimum gauge, is a .410 Gauge firearm using non-toxic shot such as steel
  an appropriate firearm to hunt waterfowl, or should they be removed?
• Is a tri-barrel or three shot capacity in lever action or straight pull shotgun
  appropriate?

Any feedback on bag limits, season timing and length, Hog deer balloting, and tags is
                  welcome.

                  • There is opportunity to alter season timing to benefit all users from various hunting
                    interest groups and other parts of the community. Happy to discuss further as a
Issues and          group including all interested parties, should the season start and finish later in the
                    year and remain at the previous length?
opportunities -   • Field & Game Australia support a Junior/New hunter only beginning to the season.
continued           This would allow new hunters under direct supervision to hunt accompanied by an
                    experienced WIT holder to hunt birds not yet exposed to hunting pressure. The
                    impact of which would result in more hunting opportunities for beginners within
                    close ethical distances and a by product of dispersing birds before the actual hunting
                    season begins. An extension to the traditional season, perhaps Wednesday through
                    Friday (three days or 10 prior to season opening?)

Are the requirements for a licence, testing and training adequate? What is considered to be
                  reasonable hunting methods? Any feedback on recognised deer habitat, not shooting at
                  night using spotlights, specified and prohibited hunting areas and opening times for the
                  duck and deer game hunting seasons is welcome.
                  • Separation between activists and hunters is required urgently before there is an
                    unfortunate incident. Field & Game Australia recognise and respect the right to protest,
                    however activists under the guise of “wildlife rescuers” need to be kept out of wetlands
Issues and          when hunting is occurring as a responsible and safe measure.
                  • While hunting is a statistically very safe activity, people breaching basic safety protocols -
opportunities -     such as deliberately getting in front of hunters when shooting, puts themselves and others
                    at unnecessary risk. The current requirement of staying 10 meters from a hunter is a huge
continued           risk and needs to be altered urgently as previously documented to a minimum of 100
                    meters. Protesting should be removed from the hunting field to remove the inherent risk,
                    protesting at the entrance gate of a wetland would be acceptable and reduce risk. We
                    have already witnessed that the carpark or boat ramp doesn’t work as intimidation and
                    vehicle damage has occurred in the past and creates enforcement constraints.

What are appropriate testing requirements for certain licence types?

                • Education and training of hunters and people who have legal access to shared spaces
                  during hunting periods is imperative to all stakeholders and users of public land
                • The current educational material supplied by GMA is comprehensive and considered
Issues and        adequate. Where it could be improved is the voluntary engagement and consumption of
                  this knowledge by all users of these public spaces. Often misconceptions and lack of
opportunities -   understanding of hunting laws leads to confrontation between hunters, landholders and
                  activists
continued       •   Unless evidence that supports any testing introduced has reduced non-compliance is
                    forthcoming, Field & Game Australia would be reluctant to support any additional
                    compulsory testing. Unnecessary cost burden for participating in game hunting in the way
                    of additional testing should not be introduced simply because anti-hunting elements are
                    demanding it as a result of inadequate or amateur polls

Issues and opportunities -
continued
 Are fees and levies reasonable? Do you recommend
 any changes?

 • Additional fees and levies create a barrier to
   recruitment and participation. Field & Game Australia
   would support first year licence for hunters should be
   free as an incentive to recruit numbers
 • Additionally, first year hunters accompanied and
   directly supervised by a hunter who has completed a
   WIT should not require their own WIT. Reduced fees
   or levies could be offered for hunters prepared to
   commit to 5-year game licences
 • Relevant research and education funding from game
   licence revenue is supported if substantiated as a
   potential benefit to sustainability of the resource. 1-2
   fee units ($14.81) could be added in order to conduct
   research

Issues and opportunities
       - continued
Do you recommend any changes to penalty
provisions and levels?

• Current penalties for non-compliance are
  considered adequate. It’s the enforcement
  efforts and application of the penalties that
  requires attention.
• Improved opportunities for effective compliance
  would be something that could encourage
  hunters, privileged access opportunities,
  guaranteed separation from activist attendance
  or access to temporarily closed areas or those
  areas not open to the general public are some
  examples. Such a reward would encourage
  voluntary additional training, testing or
  knowledge acquisition.

Further consultation
• Field & Game Australia would like to acknowledge their
  members for volunteering their time to undertake extensive
  reading and participation in regular feedback to advise FGA in
  the development of this submission

• The Board of Field & Game Australia acknowledges the
  continued contribution of our branches and its membership.
  From our foundations to the present day the members have
  been unwavering in working towards achieving our mission
  and objectives for the betterment of the whole community

• Field & Game Australia would like to have regular and ongoing
  consultation and offer further feedback during 2021 through
  this process and look forward to regular dialog prior to
  proposed regulations being released in a Regulatory Impact
  Statement (RIS)

Conclusion
• Biological diversity requires habitat diversity, a diversity of habitats is unlikely to be
  maintained if land use is constrained to a narrow range of purposes. Recreational
  hunting is one important land use, that requires upon conserving wildlife habitat.
  Accordingly, hunters and Field & Game Australia members have a long history of
  conserving and restoring wildlife habitat. Through their efforts, funds, and lobbying
  power worldwide conservation bodies have come to recognise the importance of
  wise and sustainable use of wildlife as a powerful motivating force within society in
  favour of conservation solutions to Victoria's massive problems of environmental
  degradation based on narrow use principles. Field & Game Australia and the
  Government require a range of strategies which must operate into the future to
  harness the resources of individuals, local and regional communities, as well as big
  government

• A policy of protecting species by law is only one possible solution, and in many
  situations it can be counterproductive. Protectionism as an approach, may
  discourage private landowners from conserving wildlife habitat, because the native
  animals are given no economic value

• Field & Game Australia have examined numerous commercial and economic uses of
  native wildlife. More specifically, Field & Game Australia recognises that recreational
  hunting plays a significant role in a direction where policy needs to meet practical
  outcomes. Over restrictive and draconian policies, serve to be counter-productive to
  the community, please only a small minority and are often not reflective of policies of
  game management

Conclusion
• In the context to an answer or solution, Field & Game Australia would like to see the
  Government have a coordinated policy on recreational hunting that should contain the
  following elements
• It is explicitly recognised that properly managed game hunting is an appropriate use of
  Australian native and introduced game animals and birds
• Regulation should acknowledge that hunting provides a motivating force for practical
  conservation, and therefore is interconnected part of a national approach to biodiversity
  conservation whilst the community can consume game meats
• As part of our international responsibility for contributing to wildlife conservation in other
  countries, Australia and Victoria should allow hunters to import trophies and other products
  from their overseas hunting trips in accordance with the Convention on International Trade in
  Endangered Species of Wild Fauna and Flora (CITES) resolutions in reciprocation. It should allow
  overseas hunters to visit Australia and Victoria to partake in guided hunting activities

Conclusion
• Regulation should encourage recreational hunters to participate in management of certain
  public lands and water bodies, in conjunction with opportunities for managed hunting. It
  should strongly support private landowners, including traditional landowners who want to
  conserve wildlife habitat on their properties and benefit by entering into our agreements with
  recreational hunters
• Regulation should strongly support hunters and syndicates of hunters who want to acquire land
  and manage it as wildlife habitat, so they can enjoy recreational hunting. It should facilitate a
  role for recreational hunters to contribute to managing pest species and should allow
  traditional owners to re-establish their hunting practices

• Hunters license fees need to be directed back into conservation and preservation of wetlands
  before any other steps are taken
• Field & Game Australia look forward to assisting in allowing this to occur