INTRODUCTION
I am a wildlife carer and the operator of a wildlife shelter which is registered with Department of
Sustainability and Environment (DSE)
As a wildlife carer I have completed many certificates of training in various areas of wildlife care and rehabilitation and I am a qualified Team Leader for wildlife rescue during disasters.
During the formation of the Victoria Wildlife Rehabilitation Council I served as a member of the steering committee and later as an elected regional representative for Gippsland.
My interest in our unique wildlife goes back many years and at present I am the
Treasure/Secretary/Newsletter Editor for East Gippsland Wildlife Shelter Groups Inc.
I am a member of Australian Society for Kangaroos (ASK) and have for some years been actively involved in writing letters and lobbying Victorian Government Ministers and DSE regarding the issuing of unsubstantiated ATCWs.
I have undertaken much research and investigation into this subject and speak from the experience I have gained.
I have read through the submission tendered by the Victorian Farmers Federation (VFF)
(sub17.p.5 Authority To Control Wildlife) to VCEC 27 September 2010 and I wish to make the
Commission aware that the points made by VFF are not substantiated are biased toward the views of farmers and do not take into account the wishes of the people of Victoria or those who are concerned about our wildlife.

“Lethal control methods are heavily restricted”
DSE states that an ATCW for lethal control measure is issued as a last resort where other non-lethal options are impractical.
I would refute this claim, DSE are, by their own admission seriously undermanned in their wildlife department and this has led to lack of validation, investigation and monitoring of ATCW permits which has led to permits being issued without any investigation and in many cases permits are issued by area offices of DSE using what their term of ‘first hand knowledge’ meaning the Officer issuing the permits purports to know the situation of the applicant. Permits are often ‘renewed’ using this terminology and inspection of the current situation is not undertaken.
I would suggest the ‘heavy restrictions’ are only perceived by landholders.
“VFF suggest that ATCWs are source of excessive burden to its members”
This statement is extremely misleading,

A permit can be obtained on-line via the DSE web site

The application contains only three pages which the applicant must complete. Two of these pages contain eleven questions which are very relevant, self explanatory and
 very simple.
One of the three pages is a ‘self-assessment’ asking what non-lethal methods have been used and how these were implemented. If indeed non-lethal methods have been employed the process of filling in this form would be easy.
The ‘excessive burden’ referred to by VFF is very misleading.
I would suggest an inquiry into ATCWs which have been issued seeking validation that the applicant has demonstrated the used of non-lethal methods which have failed.
“Prohibition on commercial use of Kangaroo carcasses”
There is a prohibition on the commercial use of Kangaroo carcasses for a very good reason, being the Victorian Government is opposed to the establishment of a Kangaroo industry and fear a backlash from community opposition.
DSE admits that Victoria has very low kangaroo numbers by comparison to other states and territories and the fires of 2009 would have taken a huge toll on their population.
It is not only Victoria which is opposed to this industry but also Tasmania, ACT and Northern
Territory.
The suggested number of 30,000 Kangaroo carcasses being available under the permits for commercial purposes is impractical.

The bodies of these Kangaroos would be spread all over Victoria and they would not all be killed at the same time. To pick-up these carcasses and take them to a processing plant would be extremely expensive.


The meat of these Kangaroos would not meet the strict health and hygiene conditions within Victoria for human consumption which would mean they could only be used for pet food.
Not all Kangaroos are killed instantly by a ‘head shot’ as recommended and shots to the body not only result in hours of suffering for the animal but if and when it is found, decomposition would be evident making the carcasses unfit for pet food or leather.


There is provision by DSE for permit holders to use the Kangaroo carcasses; the permit holder may use the carcasses on the property as a food source for humans or dogs. ATCW holders and their agents may also remove deer and kangaroo carcasses from the property for personal use, subject to a number of strict conditions.
“Identifying Health and Safety Issues”
This claim is made by VFF but is not substantiated and they refer to the circumstances of a sheep which has died and its removal is ‘best practice’. VFF are ignoring the fact that DSE do allow removal of Kangaroo carcasses for personal use and there appears to be a deliberate intention to mislead the Council in an effort to justify lifting the ban on commercial processing of these carcasses.
“Rational for extensive assessment of applications”
VFF claim the DSE rational for extensive assessment of applications which is to ensure that
Kangaroos are only destroyed as a last resort.
The delay in permits being granted is more than likely due to the lack of DSE manpower in the wildlife department.
“Cost of Individual Permits”
The information given by both VCAC and VFF tends to suggest that the applicant bears the cost of issuing an ATCW. Neither party has made it crystal clear that the burden of cost for these permits falls to DSE/Victorian Government and ultimately the Victorian tax payer.
There is absolutely no cost involved to the applicant when applying for an ATCW which in fact means the Victorian electorate is paying to have its own wildlife killed without any knowledge or consultation of this fact.
I would suggest that a permit application cost of $500 be applied, this would then ensure that:
* Adequate numbers of field officers would be available for scientifically based assessments and ongoing monitoring.
*
*
That the applicant is sincere when complaining about a problem.
Would discourage applicants from applying who do not use their property as their sole
* means of income.
Would relieve the burden of cost to the Victorian tax payers.
“Kangaroos be declared unprotected on private land.”
This is totally unacceptable; all wildlife within Victoria is protected with the exception of
Wombats in many of the parishes. To attempt to change the legislation for this is an attempt by
VFF to bring into Victoria a Kangaroo Industry using questionable self serving motives.

IN CONCLUSION
I feel that the proposals made by VFF are unwarranted as they are self serving and not in the interest of all Victorians. In making these proposals VFF is taking advantage of a DSE
Department which is undermanned and unable to cope with its load.
A total overhaul of ATCW permits needs to be urgently undertaken and a full investigation of the way in which they are processed, validated, monitored and issued by DSE.
I have found time and time again that asking questions of DSE about these permits is met with a brick wall and a standard reply of “We are happy with the way the system for these permits work”.
Writing to who ever the current Minister for the Environment is, is even worse as all letters regarding ATCWs are handed on to DSE with any acknowledgement from the Minister.
DSE is a Victorian Government Department and as such should be open and transparent especially where the sensitive issue of our wildlife is concerned.
At the centre of the ATCW problem is the actual number of Kangaroos in Victoria and for this there is no scientific data as a count has never been undertaken so those who say Kangaroo numbers are increasing say so without any validity and with a bias which will aid their particular cause.
Kangaroos are blamed for many things, damage to fences, damage to crops, competing for pasture with domestic stock and so on and there are many ways in which some of these problems can be addressed.
Educating landowners and farmers about the truths and facts of our wildlife, particularly
Kangaroos is of paramount importance as myths and misconceptions are abundant.
Very few farmers understand the concept of ‘carrying capacity’ for their land and even fewer have any knowledge of the ‘Dry Sheep Equivalent’ (DSE) which was researched and compiled by
CSIRO.
Damage to fencing is often cited as a reason to apply for an ATCW and there is a lot of information available through DSE and web sites on the internet but unfortunately it seems to go unheeded.
Education in this area should be given to farmers and landholders by both DSE when an application is received and as a matter of course by VFF.